| ____________ | | Filing Agent Location: Hover over flags to see “Business Address, Mailing Address or Organized/Incorporated in...”, as filed with the SEC. | | ¹ | In SEC terminology, a “filing agent” (in non-bold all-lowercase herein) is the entity submitting a Filing, i.e., the party who is logged into the SEC’s EDGAR system when it is submitted, and is identified by the CIK³ they used to login to EDGAR. They are either (1) an SEC-registered Filing Agent (in Bold Initial-Caps herein), or (2) a Registrant (in non-bold names above) who has “self-filed” a Filing as the Filer/Issuer or is submitting one for an affiliate, or (3) the SEC itself. A registered Filing Agent is in the business of submitting Filings for other Registrants, so we call them a “true” Filing Agent (Bold Initial-Caps) to distinguish them conceptually from the filing agent (non-bold all-lowercase) who submitted the Filing. Out of 1.3M+ Registrants, there have been 300K+ filing agents and 4K+ “true” Filing Agents, meaning that ≈77% of Registrants have used only Filing Agents for their Filings and ≈23% have filed at least one Filing for themself as a “self-filer” without using a Filing Agent. Determining which filing agents are “true” Filing Agents is difficult.² You cannot tell whether a Filing’s filing agent CIK³ is that of a Filing Agent or a Registrant Filer/Issuer, because Registrants may be (or own) Filing Agents (e.g., Donnelley Financial Solutions) or submit Filings for their directors/officers, and Filing Agents may be Registrants for other business purposes (e.g., some Transfer Agents). Further complicating this, some “parents” submit Filings for their subsidiaries, Funds/ETFs or ABSs, and various Money Managers submit Filings for other related Money Managers. Another complication is that some Filing Agents offer self-filer filing services on websites, whereby the Filer/Issuer can choose on some websites to have the site’s Filing Software§ login to EDGAR with either their own CIK³ or the Filing Agent’s. A Filing is self-filed when the Filer/Issuer is logged into EDGAR with their own CIK³ and is filing their own Filing, whether or not they are using an SEC website or Filing Software§ from a Filing Agent or another vendor. Similarly (but less frequently, due to password-security issues), if a Filer/Issuer allows a Filing Agent to login to EDGAR with the Filer/Issuer’s CIK³, that would be a self-filing situation, because there would be no SEC record of the Filing Agent’s involvement. If a Filer/Issuer is logged into a Filing Agent’s site when submitting a Filing but doesn’t use their own CIK³ for the submission, then the Filing Agent is the filing agent. In this case, regardless of whether or not a Filing Agent’s site allows Registrant clients to “sign off” on Filings or submit them from there, the Filing Agent is still the filing agent and the Filing is not self-filed. Our algorithms reconcile all of this daily and figure out who the “true” Filing Agents are. | | ² | We determine which of the 300K+ historic filing agents are “true” Filing Agents, and of those 4K+, which of them are “pure” (≈90%) or not (≈10%), by comparing the CIK³ of each Filing’s filing agent with that of the Filer/Issuer for whom the Filing was filed. We consider a Registrant to be a “true” Filing Agent when they have either (1) done Filings only for others, or (2) done more than a specific number (which is based upon our extensive research and is proprietary to us) of Filings for others for each Filing they did for themself as the Filer/Issuer. The “Filings Ratio” after each name above indicates either (1) that the filing agent is a “pure” Filing Agent (shown as “All : 0” when all of their submissions have been for other Registrants and none have been for themself), or (2) the ratio of Filings for others versus for themself as a Registrant (e.g., “100+ : 1” or “# : 1”). Not all Filing Agents are identified by name above; some are paying us to remain “anonymous” for competitive reasons, mostly to protect their client lists from poaching by other Filing Agents (see the Services We Offer below). | | ³ | To submit Filings, an entity must first register with the SEC to receive a 10-digit Central Index Key (CIK). When a Filing is submitted, the CIK of the filing agent¹ is used, and it may differ from that of the Filer/Issuer legally required to make the Filing. The submitting filing agent¹ may be a “true” Filing Agent or a Registrant who is self-filing or filing for a related Registrant. The filing agent’s CIK shows up as the first part of each Filing’s identifying SEC Accession Number, which is in ‘CIK-Year-Submission#’ format (e.g., SEC # 0001193125-23-043421). | | § | Most Filing Agents use specialized SEC Filing Software to create and edit the Documents in the Filings that they submit. Shown above is the name of the most frequently used software that each Filing Agent uses, based upon the number of their Filings in which identifiable software was used. We search through all Filings and look for patterns that enable us to accurately identify the software that was used to edit each Document. The software may be a commercially available Filing Software product or customized software that a Filing Agent wrote for their own purposes (for internal use and/or for sale). Surprisingly, many Filing Agents actually use software written and sold/licensed by their direct competitors. The reasons for this are that each software product has varying capabilities, strengths/weaknesses and costs/benefits depending upon the underlying complexities of the Filing/Form Types that are being filed, and Filing Agents are diverse in the degree to which they specialize/generalize in the various Types that they can file. For many of the Filing Agents, you can hover over the most frequently used software’s name to see a list of the multiple software packages that they use (some use over 10!). Registrants who self-file instead of using a Filing Agent use most of this same software for their Filings. (Some of the Types can be filed on the SEC’s EDGAR Filing Websites without special software.) SEC Info is the only service that offers detailed info and data on the SEC Filing Software market! |
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