How does Delegation work for Section 16 Filers?
As with other filing types, your company and/or your reporting owners do not need to delegate to Workiva for Section 16 filings.
While delegation is a single level process - an entity who is delegated to can not further delegate to another, multi-party filings such as Section 16, Form 144, Schedule 13, as well as co-registrant filings only require one of the parties/CIKs to be delegated (if desired). Since there is no limit to the number of delegations, the individual may opt to delegate to several different filing agents, law firms, or companies where they are board members - or none of the above.
For example, a CEO at Company A will likely choose to delegate to Company A. When filing in Workiva, Company A has two options - if the Company A EDGAR Next Account/CIK choose not to delegate to Workiva, they will submit Section 16 filings as usual in Workiva, using Company A’s Filer API Token and an authorized User Token in place of their SEC password. If Company A has delegated to Workiva, they have the additional options of providing only their User Token or using the “File With Workiva” feature.
-
If CEO at Company A has designated an account administrator at Company A for the CEO's personal CIK, could that account administrator make Workiva a Delegated Entity for the CEO's CIK, enabling Workiva to use its Filer API Token?
How is Company A's delegation to Workiva as to that entity's CIK relevant to a filing for the CEO's personal CIK using the CEO's personal CCC?0
I have the same question as James. Or rather, let's take a more likely scenario.
CEO at company A has an account administrator at Company A. (Why bother delegating?)
The CEO is on the board of Company B. And Company B becomes a delegate for CEO.
When compliance personnel at Company B want to file a Form 4 for CEO with Workiva, what will they need? I think they need:
1. CEO's CCC, which I understand the cannot obtain simply as a delegate, but must get from the CEO or the CEO's account administrator.
2. The Company B user's user token (or they can "file with Workiva")
3. Do they also need the CEO's filer token? Or can they use Company B's user token? Or can they rely on Workiva being a delegated entity for Company B to make the filing?
0댓글을 남기려면 로그인하세요.
댓글
댓글 2개