Exploring new filing fee disclosure rules
A helpful new post from Paul Hastings LLP, shared by Toppan Merrill, explores the new filing fee disclosure requirements introduced by the US Securities and Exchange Commission (SEC) last year. As it explains, “The Final Rule includes extensive amendments to filing fee-related disclosures across “most fee-bearing forms, schedules and statements,” which are geared toward improving efficiencies related to the payment and calculation of filing fees throughout the registration and related Commission review processes and to reduce the miscalculation of filing fees by registrants.”
The new Rule makes three key, related changes: it modernises payment methods available to report filers; reorganises and refines the presentation of filing fee-related information; and – likely of most interest to our readers – introduces a requirement that this information be submitted as structured data using Inline XBRL. This, says the SEC, will “result in machine-reachable data that could then be used to more efficiently automate the filing fee preparation, disclosure, assessment, and verification processes.” It is also worth noting that this data will be subject to automatic validation checks by the EDGAR (Electronic Data Gathering, Analysis, and Retrieval) system. After a three-month adjustment period, submissions will not be accepted by the SEC until all filing fee errors are corrected and a clean test filing is completed.
Read more here.