Notary Crowdfunding and Municipal Advisor Relief

March 27th | 2020

The SEC announced additional temporary regulatory relief to market participants in response to the effects of the Coronavirus Disease 2019 (COVID-19). Today’s relief includes the following:

Temporary Relief from Form ID Notarization Requirement

The SEC is temporarily easing the notarization requirement that would usually be required to gain access to submit filings via the SEC’s EDGAR system. The relief is scheduled to run from March 26 – July 1, 2020, subject to certain conditions. Among those conditions are (1) that the filer indicates on its manually signed Form ID that it could not provide the required notarization due to circumstances relating to COVID-19, and (2) that the filer submits a PDF copy of the notarized manually signed document within 90 days of obtaining an EDGAR account.

Compliance with Regulation A and Regulation Crowdfunding

Subject to certain conditions, affected Regulation A and Regulation Crowdfunding companies will have an additional 45 days to file certain disclosure reports that would otherwise have been due between March 26, 2020 and May 31, 2020. Among other conditions, a company relying on the relief must promptly disclose to its investors such reliance; and when a company does file the required report or form, it must disclose that it is relying on the SEC’s temporary final rules and state the reasons why, in good faith, it could not file such report or form on a timely basis.

Annual Update to Form MA for Municipal Advisors

To address potential compliance issues municipal advisors may have in timely submitting annual update filings (Form MA-A), the SEC will provide, subject to certain conditions, affected municipal advisors with an additional 45 days to file annual updates to Form MA that would have otherwise been due between March 26, 2020 and June 30, 2020. Among other conditions, the municipal advisor must be unable to meet the filing deadline for its annual update to Form MA due to circumstances related to current or potential effects of COVID-19 and must provide a brief description of the reasons why it could not timely file.

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