Get Ready for the SEC's Fee Based Filing Modernization

Summary

This webinar, hosted by Michelle Savage, discusses the SEC's fee-based filing modernization rule, focusing on practical tagging, preparation, and payment processing. Expert speakers from the SEC and industry provide insights, guidance, and answer questions on implementing the new structured format for filing fees, emphasizing the importance of accuracy and validation in the process.

Takeaways

• 📅 The SEC implemented new rules effective January 31st, 2022, to streamline the presentation of filing fee information by moving it to a new exhibit and requiring it to be tagged in inline XBRL.
• 🌐 A beta environment was provided from October 4th, 2023, through December 22nd, 2023, for filers to test the technical and structured data features of the tool and provide feedback to the SEC.
• 📚 The rule impacts 72 submission types, including registration statements and proxy forms, requiring enhanced disclosure of fee information in structured fee tables.
• 🗂️ The SEC's FFD taxonomy for filing fee disclosure was created and published on January 26, 2024, specifically for tagging the filing fee exhibit information.
• 📈 Compliance dates for the new requirements are July 31st, 2024, for large accelerated filers and July 31st, 2025, for all other filers, including certain investment companies.
• 💳 As part of the fee modernization rule, the SEC enhanced payment submission methods, allowing payments via debit and credit cards and discontinuing checks or money orders.
• 🔍 The FFD taxonomy is a closed taxonomy, meaning it cannot be extended, and filers must fit their data into the predefined model.
• 📝 Filers are required to tag all information in the filing fee exhibit, including both tabular and narrative disclosures.
• 🤝 Communication between the person doing the work at the computer and the one authoring the data is crucial for successful implementation of the new filing fee requirements.
• ⚠️ Filers are encouraged to use the Filing Fee Preparation Tool (FPT) for its prompts and assisted technology, but remain responsible for the accuracy of their output.

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