There are various options for individuals under EDGAR Next, ordered from least intrusive to most hands on. The EDGAR Business Office provides a document which discusses these options:
- Provide a notarized Power of Attorney letter, similar to what may be filed in a Form 3 or Form ID filing, authorizing an entity to perform all of the EDGAR Next requirements for an individual as an account administrator. Note that a PoA letter is NOT required to enroll the individual in EDGAR Next. It isn’t exactly specified how this letter is provided - it may be similar to a signature authorization document where it is held and (rarely) presented to the SEC upon request, for existing filers.
This eliminates the need for a reporting owner to create a login.gov account, perform the required yearly acknowledgments, and other Filer Management tasks for themselves. The authorized entity would then decide which of the above filing scenarios would work best in the filing situations. One or more unrelated entities could potentially have PoA for the reporting owner’s account, so some coordination may be necessary between the account administrators regarding which users are authorized to file for the RO as well as delegations. One of the entities will also be responsible for enrolling the EDGAR account (CIK) in EDGAR Next as well as performing the required annual confirmation and token management. The only requirement for an “entity” to enroll an account in EDGAR Next is knowledge of the CIK, CCC, Passphrase (power of attorney or a notarized document are not required), so this could be an employee, law firm, or filing agent. All Account Administrators can complete the annual confirmation, while only Technical Administrators may manage the Filer Token, and only individuals can manage their User Token.
- The reporting owner could create their own login.gov account, perform the enrollment with themselves, and, hopefully one or more users such as a personal or corporate attorney or paralegal, as additional account administrators. Then one of the account administrators could choose to delegate to another entity - perhaps a law firm who themselves delegate to a filing agent, or none of the above.
- The reporting owner could create their own login.gov account and act as their own account and technical administrator, creating the Filer Token (unless delegated to a filing agent) and their personal User Token, and perform filings directly without any assistance from other authorized users. They may choose to delegate to one or more entities, such as filing agents or law firms.