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How to Format PDFs for EDGAR Filing

The Electronic Data Gathering, Analysis, and Retrieval (EDGAR) system, operated by the U.S. Securities and Exchange Commission (SEC), requires filers to adhere to specific formatting standards when submitting documents. This guide outlines the necessary steps to properly format PDF files for EDGAR filing, ensuring compliance with regulatory requirements.

Objective

The objective of this guide is to assist 17(H) filers in formatting PDF files to meet EDGAR's acceptable standards, thereby facilitating smooth submission processes.

Key Principles

Before formatting PDF files for EDGAR, it's crucial to understand two key principles:

Prohibited Content: PDF files submitted to EDGAR must not contain active content such as embedded JavaScript, active external references, document passwords, or security controls. Additionally, no embedded files (text, graphic, or audio) are permitted.

Machine Readability: PDF files must be machine-readable to ensure the text is recognizable by the system.

Basic Guidance

In most cases, electronically "printing" documents to a PDF from the source application is sufficient for EDGAR submission. Follow these steps to electronically print your document to a PDF:

1. Select the "File" menu, then choose "Print" (not "Save to PDF").
2. Select "Adobe PDF" as the printer.

This method removes active content that may cause issues with EDGAR. Avoid using the "Save as PDF" option, as it may embed additional content.

Software Requirement

Adobe Acrobat software (or equivalent) is required for the formatting process. If Adobe Acrobat is unavailable, Google Chrome browser may be used to resolve specific error messages.

Formatting Steps for Different Document Categories

Documents may fall into one of three categories based on how they were created and formatted. Follow the respective steps for each category:

Document Category 1: Created from Another Application

These documents are electronically printed or saved as electronic PDF files.

1. From the application, select File -> Print (not "Save to PDF").
2. Choose "Adobe PDF" as the printer.
3. Review the file size to ensure it falls within the expected range.

Document Category 2: Physically Printed and Scanned

These documents lack machine readability and need special attention.

1. Consider re-printing the document electronically to a PDF.
2. Open the PDF in Adobe Acrobat and ensure no embedded items exist.
3. Perform text recognition to enhance machine readability.

Document Category 3: Mixed Documents

These documents contain a mix of electronically printed and scanned pages.

1. Consider separating different page types for easier processing.
2. Follow similar steps as Document Category 2 to enhance machine readability.

Readable vs Unreadable PDF Files

Distinguishing between readable and unreadable PDF files is essential. Readable files allow text selection and searchability, while unreadable files may contain scanned images without selectable text.

Error Messages and Resolutions

Common error messages such as invalid file names, Java.lang.NullPointerException, external references, and PDF form data issues are addressed with specific resolutions tailored to each scenario.

Filing Guidelines and Considerations

Unnecessary documents and security considerations are outlined to streamline the filing process and ensure compliance with EDGAR requirements.