Rumor has it that the SEC’s July 28th changes to the Section 16 e-filing system will not fix all the glitches. However, it is likely that the changes will start allowing CEO/CFO certifications to be filed under the new proper items. In other words, the EDGAR system will be reprogrammed to permit filing of 8-K Items 10, 11, 12 and 13. If correct, this will have a big effect on those making earnings announcements and filing second quarter 10-Qs.
For TheCorporateCounsel.net subscribers, we have added two more sample reporting up policies to our “Attorney Responsibility Portal” at http://www.thecorporatecounsel.net/member/FAQ/attnyresponsibility/index.htm.