December 18, 2002

This morning, the SEC proposed rules that would mandate electronic EDGAR filing for all Section 16 reports. It also would require companies to post their Section 16 reports on their web sites (and links to the reports as filed would satisfy this requirement).

At this point, the SEC is vague about when this proposal would be adopted – but it is shooting for Spring 2003 – which is before the Sarbanes-Oxley deadline of July 30th. The SEC envisions a “filer friendly” Web template system – although it will give the specs to third parties in the hope that they will develop even a friendlier system.

As proposed, the SEC’s Web template system would allow exhibits to be attached – however, the only exhibit likely would be a power of attorney as the SEC will encourage more important information to be included in the “footnote” section.