Skip to main content

ADI 2018-04 - Marked copies of amendments to registration statements

April 3, 2018

The staff reminds funds that the filing of amendments to registration statements under the Securities Act of 1933 must include marked copies indicating the changes effected by the amendment.[1]  These marked copies help focus staff attention on changes that may warrant additional staff scrutiny.  Funds provide a marked copy on the EDGAR system by inserting a tag before and after any changed disclosure.[2]  The staff will not object if, instead of filing marked copies of reviewable filings on the EDGAR system, a fund emails to their staff reviewer more user-friendly marked copies. 

* * * *

ADI are recurring publications that summarize the staff’s views regarding various requirements of the federal securities laws.

The statements in this ADI represent the views of the Division of Investment Management. This update is not a rule, regulation or statement of the Securities and Exchange Commission.  Further, the Commission has neither approved nor disapproved its content.  Future changes in rules, regulations, and/or staff no-action and interpretive positions may supersede some or all of the information in a particular ADI.

We hope that this ADI will assist registrants in preparing their filings.  We also welcome feedback on this ADI and on any disclosure matters.  If you have any questions or feedback, please contact:

Disclosure Review and Accounting Office

Phone: 202.551.6921



[1] See rule 472 under the Securities Act.  These marked copies should “indicate clearly and precisely … the changes effected in the registration statement by the amendment.” 

[2] See rule 310 of Regulation S-T (specifying the tags <R> and </R>, respectively).

Return to Top