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Is it possible to Edgarize a pdf in a text searchable format for filing as an exhibit?

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3 comments

  • Mike
    Hi Tarik,

    Great question. Technically, when you EDGARize a PDF in Wdesk, it adds the text to the HTM file behind the scenes. If you were to open the file and perform a CTRL+F in your browser, the text should be found in the correct spot, like so:



    More info on EDGARizing a PDF in Wdesk can be found here: https://success.workiva.com/help/filing/filing-prep/pdf-edgar-generator

    However, this feature is designed to be used for image-heavy slides to be converted to a fileable exhibit, and not for full-text PDF documents. This is because of creating an image of full-text or tabular data would not be EDGAR compliant.

    Does that make sense?

    Let me know if you have any questions on the above, or if you need anything else. Thanks, and have a great day!
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  • Tarik Gause
    Many thanks, Mike.  Very helpful.  It sounds like as a practical matter, the EDGARization of pdf is usually done for exhibits like earnings releases and decks?  And when you say "creating an image of full-text or tabular data would not be EDGAR compliant", you are referring to exhibits like contracts, bylaws or letters.  Is that correct?  And is there a section in the Edgar filing manual that touches on this last point about image filing?
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  • Mike
    No problem, Tarik. Happy to help!

    Yep, you are correct. The EDGARize feature is mostly used for earnings releases and other similar decks you might be included in your filing. And you are correct again, "full-text and tabular data" does refer to exhibits such as bylaws and letters which are commonly submitted but often supplied to users in PDF format.

    Regarding your last question, the particular ruling comes from Rule 304(e) of Regulation S-T and specifies that...
    “filers may not present in a graphic or image file information such as text or tables that users must be able to search and/or download into spreadsheet form (e.g., financial statements); filers must present such material as text in an ASCII document or as text or an HTML table in an HTML document.”
    The above can be found in a Question 118.01 of this Q&A on the SEC: https://www.sec.gov/divisions/corpfin/guidance/regs-tinterp.htm

    In the end, though, it is really up to the filer to determine if they are compliant.  While there is text included in the HTM document during EDGARization in Wdesk, it is unformatted so the information in tables would be a bit disconnected, which may not be compliant with the regulation. In that instance, you may need to also provide a clean HTML version too.

    Hope that helps. Let me know if you have any clarifying questions or need anything else. Thanks, and happy Wednesday!
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