So each Section 16 officer has to obtain their own Login.gov ID and EdgarNext and then they delegate administrators?
Directors managing their own EDGAR Next and login.gov accounts would be highly impressive, but also highly uncommon. The SEC has foreseen this situation and has noted that, with a Power of Attorney letter, a reporting owner can turn over the management of their EDGAR Next account to another entity. The POA letter format is not specified and this is not something that is submitted to EDGAR such as Section 16’s Exhibit 24. By outsourcing the management to one or more trusted entities, the director would not need to obtain or maintain a login.gov account.
However, note that every EDGAR account (CIK), including individuals, must enroll in EDGAR Next no later than September 15, 2025. EDGAR Next enrollment does not require a POA authorization, so the director will need to decide on which entity will perform the enrollment on their behalf and act as their initial account administrator. Also note that enrolling in EDGAR Next will automatically reset the individual’s CCC, and therefore careful coordination between law firms and filing agents may be required to both ensure timely enrollment as well as communicating the updated CCC.
A director who sits on multiple boards may turn over this account administration to multiple entities, and it is a good idea for at least one account administrator from each issuer to have administrator access to the director’s EDGAR Next account. For example, if the director sits on the boards of Company A, Company B, and Company C, they will either want a trusted representative managing their EDGAR Next account, including acknowledging the yearly confirmation process, or at least a paralegal or lawyer from A, B, and C having account administrator access to their EDGAR Next account.
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