Client Advisories and Bulletins

SEC Adopts Final Rules Mandating Electronic Filing And Web Site Posting For Forms 3, 4 And 5

May 2003

The SEC released its final rules mandating electronic filing and, for issuers with corporate Web sites, Web site posting of beneficial ownership reports filed by officers, directors and principal security holders under Section 16(a) of the Securities Exchange Act of 1934. The new rules, released on May 7, 2003, and issued pursuant to Section 403 of the Sarbanes-Oxley Act of 2002, generally become effective June 30, 2003. The rules:

• Require that all Forms 3, 4 and 5 be electronically filed with the SEC via the EDGAR system;
• Extend the filing hours for Forms 3, 4 and 5 that are submitted by direct electronic transmission to 10:00 p.m. Eastern time;
• Make the temporary hardship exemption unavailable to these forms; and
• Require an issuer that maintains a corporate Web site to post on its Web site all Forms 3, 4 and 5 filed with respect to its equity securities by the end of the business day after filing.