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SEC Adopts Temporary Final Rule 10(c) to Address Form ID Notarization Challenges

March 26, 2020

The Securities and Exchange Commission and its staff recognizes that the COVID-19 public health crisis has presented challenges for some entities and individuals who require initial access to file in EDGAR; in particular, some applicants for EDGAR access have experienced difficultly obtaining notarization of the authorized signature on the Form ID application, required by Rule 10(b) of Regulation S-T. 

In response, the Commission announced that it is adopting interim temporary final Rule 10(c) to permit applicants for EDGAR access to upload a signed copy of Form ID (completed online) without the notarization, containing a statement that applicants were unable to obtain notarization due to difficulties related to COVID-19.  In addition, within 90 days of obtaining access to EDGAR under the temporary rule, applicants must obtain notarization of the authorized signature on a copy of the completed Form ID and upload it as correspondence to their EDGAR account.  If applicants using the temporary rule do not do so, the SEC may inactivate their EDGAR access codes. 

Similar notarization requirements concerning EDGAR access exist for paper convert to electronic filer access and manual passphrase reset procedures, and those notarization requirements will follow the temporary rule.

The SEC Staff will accept applications for access that comply with the interim temporary final rule filed on or after March 26, 2020 through July 1, 2020.

The temporary rule can be reviewed on the SEC website at 

Questions should be directed to Filer Support 202-551-8900 Option 4.

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