SEC Proposes Requiring Hyperlinks in Filings

Chris Gaetano
Published Date:
Sep 1, 2016

The Securities and Exchange Commission has proposed requiring that reports subject to the exhibit requirements under Item 601 of Regulation S-K, or that file on Forms F-10 or 20-F have a link to each exhibit in the index, and that all such filings be written in HTML.

Currently registrants are required to list exhibits included in the filing in an index. This, said the SEC proposal, means that "someone seeking to retrieve and access an exhibit that has been incorporated by reference must review the exhibit index to determine the filing in which the exhibit is included, and then must search through the registrant’s filings to locate the relevant filing to review for the particular exhibit."

The SEC said that this process can be time consuming and cumbersome. The SEC believes that requiring registrants to include hyperlinks from the exhibit index to the actual exhibits would facilitate easier access for investors and other users. Registrants cannot currently do so because of rules that prohibit linking to sites, locations or documents that go outside the commission's EDGAR system. 

The proposed rule would affect registrants filing Forms S-1, S-3, S-4, S-8, S-11, F-1, F-3, F-4, SF-1, SF-3, 10, 10-K, 10-Q, 8-K, 10-D, F-10 and F-20F. Excluded would be 
Form ABS-EE because the form is used solely to facilitate the filing of tagged data and related information that must be filed as exhibits to the form, according to the SEC. Because the current ASCII system does not allow links, this means that all affected forms would have to be written, instead, in HTML. 

Comments are being taken on the proposal for the next 45 days. 

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