“I need to file an SEC Form D for my LLC, and I believe I need ‘SEC access codes’ first. I have prepared, notarized and submitted the application to obtain these codes, but EDGAR is not accepting it and I seem to be at a dead end. Can you help me?”
We hear this a lot! If an entity hasn’t filed with the SEC before, it needs to first obtain access codes before anything else can be filed. Obtaining these codes involves:
- Preparation of a “Form ID” application and an authentication document in the proper format
- Getting the authentication document notarized
- Submitting the application and authentication document to the SEC in the proper file formats
Whereas applicants can do the above on their own, the process is prone to errors which cause rejection of the application, delays and missed deadlines. If you’re a first-time filer, it may be to your benefit to hire an SEC EDGAR Filing Agent (service provider) to take care of all this for you (click here or here for examples). An experienced filing agent will ensure that (1) the application is filled in correctly, (2) the authentication document is in the proper format, (3) you know how to get it properly notarized, and (4) everything is submitted and filed in the proper manner. This not only saves you time and frustration, it also ensures that your subsequent filing can be submitted in a timely manner.
The service provider should provide you with the cost up front. For example, edgar-services.com, an SEC EDGAR Filing Agent, covers all this and obtains SEC access codes for U.S. individuals or entities for a flat $95 fee.
If you or your company was previously registered with the SEC, but the access codes are lost and the individual responsible for the initial registration is no longer accessible, then you have to file for new codes. The CIK will stay the same as before, but the other codes will be replaced and reissued. This also involves creating and getting notarized an authentication document, but it is not the same document as for first-time registration. You also have to provide an explanation of why you need new codes. Again, it may be to your benefit to hire an SEC EDGAR Filing Agent (service provider) (click here for an example), which will save you time and frustration and get your codes reissued in a timely manner.
The Access Codes
The SEC provides four access codes to each filer:
- CIK (Central Index Key) – This is a 10-digit number that uniquely identifies the filer, and is public information. At the SEC website, you can readily look up the CIK of any filer, as well as the filer associated with any CIK (here is the link). A CIK, once assigned, holds for the lifetime of the filer, and a new (different) CIK may not be assigned to the same filer.
- Password – This is a 12-character code which the filer uses (along with the CIK) to log into non-public SEC websites. The password is private, and the filer should not disclose it to outside parties. The password expires after one year. The filer may change it at any time, but certainly must do it before it expires.
- CCC (CIK Confirmation Code) – This is an 8-character code that confirms the validity of a CIK. It must be included in a filing along with the CIK to establish its validity, but the CCC is not publicly disseminated on EDGAR. The filer should treat the CCC as private, and disclose it only to a Filing Agent who is submitting the filing on its behalf. The CCC does not expire, and is not affected by password changes, but the registrant may regenerate it if needed (e.g., in case of a security compromise).
- PMAC (Password Modification Access Code) – This is a private 8-character code that is required to change the password. The filer should not disclose it to outside parties. It does not expire, and is not affected by password changes, but the filer may regenerate it if needed.