On September 30, 2019, the Securities and Exchange Commission (the “SEC") went live with EDGAR Release 19.3 (announcement available here) and made related changes to the EDGAR Filer Manual (announcement available here). Two notable changes are summarized below.
Change to EDGAR Password Requirements
Filers, including Section 16 filers, will now be requested to provide twelve character passwords instead of eight character passwords when logging into both the EDGAR Filing Website and the EDGAR Online Forms Management Website. Current filers who do not update their password to twelve characters will be prompted to update it each time they log in. We have confirmed with the staff of EDGAR Filer Support that current filers who do not update their password when prompted will not be prevented from logging in successfully. However, EDGAR passwords expire annually and should be changed before the expiration date. Any filers who have not already updated their password by the time they otherwise expire will be required to create a password that satisfies the new requirements before being permitted to log in to EDGAR.
To change their password, filers will need to be logged into the EDGAR Filing Website or the EDGAR Online Forms Management Website and follow the procedure described in Section 4.1.3 of Volume 1 of the EDGAR Filer Manual. This procedure requires filers to enter their CIK number and Password Modification Authorization Code (“PMAC"). If filers do not know their PMAC, they must generate a new set of EDGAR access codes using the EDGAR Filer Management Website.
This update will not impact the requirements for other EDGAR access codes (e.g., thePMAC, passphrase, CIK Confirmation Code (“CCC")).
Update Allowing for More Characters in Security Titles
Companies subject to cover page tagging requirements must tag certain information relating to their securities that are registered pursuant to Sections 12(b) or 12(g) of the Securities Exchange Act of 1934, including the title of such securities. When making their most recent Form 10-Q filings, many companies discovered that the names of some classes of securities registered pursuant to Section 12(b) (for example, classes of debt or convertible or preferred securities) exceeded the character limitation imposed by the “Security12bTitle" tag. The SEC has now attempted to alleviate this issue by increasing the allowable number of characters with respect to security titles tags from 100 characters to 150 characters.
 An alternative method for updating a filer’s password is to select “Generate Access Codes (New / Replacement)" on the EDGAR Filer Management Website. Once selected, the filer will generate a new password, as well as PMAC and CCC, by entering their CIK number and passphrase. The automatically-generated new password will be twelve characters.
Special appreciation to associates David Korvin and Rob Kelley for their assistance with this post.