Using Certifications for electronic signatures for 10Q/10K
In 2020, the SEC revised the rules to permit use of electronic signatures for Edgar filings. Is anyone using the Certifications as the tool to obtain the electronic signature for SEC filings.
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Hi Elizabeth!
Great question. This sounds similar to this one from last November. TL;DR - the Workiva Certification module + our audit logs would satisfy the requirements outlined by the SEC. As noted, though, we always encourage customers to consult with their own legal team on their interpretations too. That being said, we'd be terribly curious too on anyone who has been taking this approach.
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The following is from the EDGAR Filing Manual:
If a signatory signs this authentication document using an electronic signature, the signing
process must, at a minimum:
(1) require the signatory to present a physical, logical, or digital credential that authenticates the
signatory’s individual identity;
(2) reasonably provide for non-repudiation of the signature;
(3) provide that the signature be attached, affixed, or otherwise logically associated with the
signature page or document being signed; and
(4) include a timestamp to record the date and time of the signature.It may be best to reach out to Workiva's legal team to see if using the Certifications module meets the process requirements?
Orbit, Adobe Sign and DocuSign are some of the leading electronic signature providers. We use DocuSign and discussed w/our legal counsel if it was acceptable and satisfied Reg S-T.
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