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Vedder Thinking | Articles SEC Adopts Amendments to Electronic Filing Requirements


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On June 23, 2022, the SEC adopted various rule and form amendments that will require the electronic submission of certain documents that may currently be filed in paper format by registered investment advisers, institutional investment managers and other entities. Additionally, the amendments include certain technical amendments intended to modernize Form 13F and applications for orders submitted under the Investment Advisers Act of 1940 and the Investment Company Act of 1940. The SEC adopted the amendments with the goal of promoting more efficient storage, retrieval and analysis of filings and submissions.

The rule and form amendments will require the electronic submission through the EDGAR system of applications for orders under the Advisers Act and confidential treatment requests relative to Form 13F filings. The amendments will also require the electronic submission through the Investment Adviser Registration Depository System of Form ADV-NR filings. In addition, the amendments will add requirements for enhanced identifying information in Form 13F. In an effort to harmonize the requirements for the submission of applications for orders under the Advisers Act and the Investment Company Act, the amendments will eliminate requirements to notarize verifications and statements of fact in, and to include proposed notices as exhibits to, Advisers Act applications. Finally, the amendments will remove references to microfilming from the rules specifying the requirements for applications submitted under the Advisers Act and the Investment Company Act.

The new rules and form amendments will be effective on August 29, 2022. The amendments to Form 13F will be effective on January 3, 2023, and there will be a six-month transition period to submit the required documents electronically.

The SEC’s adopting release is available here, and a related press release is available here.


Christina V. West


John S. Marten


Nathaniel Segal


Jacob C. Tiedt