On November 17 the SEC adopted rules that permit the use of electronic signatures for most SEC filings and the electronic storage of executed signature pages.
As a result, filers will no longer be required to create or collect "wet ink" signature pages for these SEC filings or keep physical files with manual signatures. The SEC expects that many companies will make use of the new rules to simplify their signature collection and storage processes, particularly in light of the administrative burdens imposed by the COVID-19 pandemic.
The amendments will be effective immediately upon publication in the Federal Register, although the SEC staff has issued guidance indicating that it will not object if filers elect to rely on the new rules before the effective date.
The SEC's adopting release describing the amendments (Release No. 33-10889) can be viewed here.
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Authored by Alan Dye, Richard Parrino, David Crandall, and Nicholas Hoover
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