SEC proposes changes to fee payment and disclosure rules

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On October 24, 2019, the SEC proposed amendments (https://www.sec.gov/rules/proposed/2019/33-10720.pdf) that would modernize filing fee disclosure and payment methods for most SEC forms that require fees to be paid. The amended rules, if approved, would require each fee table and accompanying disclosure to include all required information for fee calculation (not just certain aspects, as is the case under the current rules) in a structured format using inline XBRL. This would purportedly allow the SEC to better automate the fee verification on their end and in theory make the fee process more efficient. The proposed amendments would also add the option for fee payment via Automated Clearing House ("ACH") and eliminate the option for fee payment via paper checks and money orders.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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