On March 1, 2017, the U.S. Securities and Exchange Commission ("SEC") adopted rule changes requiring public companies to include hyperlinks to specific exhibits in their SEC reports.
Under SEC rules, public companies are entitled to incorporate – by reference into registration statements and periodic reports – exhibits that have previously been filed with the SEC. Consequently, someone wanting to review a specific exhibit must manually search for the specific filing containing the exhibit.
The recent amendments will require issuers to include hyperlinks in the filing's exhibit index to each specific exhibit. There will be exemptions for XBRL exhibits and for paper filings made pursuant to a temporary or continuing hardship exemption. The final rules will take effect on September 1, 2017. Non-accelerated filers and smaller reporting companies that submit filings in ASCII will not have to comply with the final rules until September 1, 2018.
Please contact our Capital Markets & Securities lawyers for further information on the matters discussed herein.