Beginning December 18, Schedules 13D and 13G must be filed using an XML-based language.
Filers will have the option of (1) using a fillable web form that converts inputted disclosures into 13D/13G-specific XML or (2) submit filings directly in 13D/G-specific XML format.
Filers submitting filings directly in 13D/G-specific XML format may need to involve a financial printer, which could increase the time and costs of compliance.
Issuers and filers should be aware that this structured data requirement will make the information easier for the public to analyze. For more information, please see our client alert and the SEC’s final rule.
Some commenters suggested, however, that the Commission should provide for an extended compliance period with respect to the proposed structured data requirement for Schedules 13D and 13G.661 Based on this feedback, we believe that an extended transition period for compliance with the structured data requirement is appropriate. As such, compliance with the structured data requirement for Schedules 13D and 13G will not be required until December 18, 2024.
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