A quick survey of the Fortune 100 IR webpages reveals that only about a third comply with the upcoming requirement to break out Section 16 filings on corporate websites (filings made on – and after – June 30 have to be posted). Of those that do, most do it as part of their outsourcing agreement with an investor relations’ provider.
Very few provide a link to their Section 16 reports as they reside in the Edgar database on the SEC website (eg. Morgan Stanley at http://www.morganstanley.com/about/ir/sec_filings.html?page=inv).
Last month, the SEC tweaked Edgar so that companies can link directly to their insider’s Section 16 reports to facilitate compliance with the upcoming requirement. This is important because if companies decide to link to their Section 16 reports, it must be a separate link only for the Section 16 filings – not a link to all of the company’s filings. To create such a link, you can use the following URL and insert the company’s CIK code for the string of 10 z’s: http://www.sec.gov/cgi-bin/browse-edgar?action=getcompany&CIK=zzzzzzzzzz&owner=only (don’t forget the link must be clearly captioned to indicate that it is a link to the Section 16 filings).
For TheCorporateCounsel.net subscribers, we have provided links to the various ways that companies have chosen to comply with the new requirement at http://www.thecorporatecounsel.net/member/FAQ/Disclosure/disclosure_websites.htm.