A Small Change with Big Impact

On March 24, 2025, the SEC rolled out a meaningful update: broker-dealers are no longer required to notarize the officer’s signature on the PCAOB annual audit report oath. At first glance, this may seem like a minor shift, but for firms racing against deadlines or working across locations, the change brings welcome relief.

This isn’t just about removing a step. It’s about modernizing the way compliance gets done, making the process more practical without compromising on trust or accountability.

What’s New and Why It Matters

Historically, firms had to include a notarized oath signed by an officer as part of their annual audit submission on Form X-17A-5, Part III. That extra layer often created bottlenecks, especially when key signers were remote or travel schedules got in the way.

Now, that requirement has been eliminated. The SEC’s updated rule allows firms to submit signed oaths, either manually or electronically, without a notary. The updated approach ensures electronic signatures are valid by requiring:

• Identity authentication using a credential
• Assurance the signature cannot be denied or repudiated
• A direct link between the signature and the document
• A timestamp to confirm when the document was signed

The process is now easier and still meets regulatory standards for reliability and security.

What This Means for ACI Clients

For our clients, this update offers clear benefits.

Without the need for notarization, audit filings are faster to complete and easier to coordinate, especially for teams with remote or traveling executives. The requirement to have an officer or owner sign the oath remains in place. The SEC clarified that FinOps can only sign if they also serve as an officer or owner of the firm.

This clarity helps avoid confusion during busy filing periods, and our team is here to ensure the right individuals are handling this step.

Looking Ahead: Other Filing Changes on the Horizon

The end of notarization is just one of several updates coming from the SEC and FINRA. Over the next year, firms should be prepared for additional changes in how they submit and manage filings.

EDGAR Filings Move to PDF

Starting June 30, 2025, firms must submit their annual and supplemental reports in PDF format through EDGAR. This applies to reports under Rules 17a-5, 17a-12, and 18a-7. If your firm hasn’t already made this adjustment, now is the time to get ahead of it.

Transition to EDGAR Next

In March 2025, the SEC launched EDGAR Next to improve security and streamline the submission process. Firms must now use individual login credentials and multi-factor authentication through Login.gov. A new Filer Management Dashboard allows compliance teams to manage user access and filing roles more efficiently.

Although enrollment remains open through December 19, 2025, firms were strongly encouraged to complete the transition by September 12. Final compliance becomes mandatory on September 15.

FOCUS and XBRL Updates Coming in 2026

Looking further ahead, changes to FOCUS Part II and IIA, including new XBRL tagging requirements, take effect March 31, 2026. These updates aim to improve the accuracy and usefulness of regulatory data.

The SEC continues to review late-stage feedback about XBRL challenges. Firms may still submit comments by emailing rule-comments@sec.gov with “File No. S7-08-23” in the subject line.

How ACI Is Helping You Stay Ahead

ACI is actively working with clients to prepare for all of these changes. Our team is:

• Updating audit checklists to reflect the removal of the notarization requirement
• Assisting with EDGAR Next enrollment and secure login setup
• Advising on PDF submission protocols
• Building readiness for FOCUS updates and XBRL formatting

Removing the notarization requirement makes the filing process more efficient and better suited to today’s business environment. While the oath still carries weight, the way firms fulfill it can now be more flexible and less burdensome.

Have questions or need help adjusting your audit or filing processes? We’re here to guide you every step of the way. Contact your ACI advisor to ensure your firm is aligned with the latest SEC requirements.

Today, January 9, 2025, the New York Stock Exchange (NYSE) will be closed for a national day of mourning declared by President Joe Biden to honor the life and legacy of President Jimmy Carter.

Due to the loss of the workday, the Q4 regulatory filing deadline has been extended by one day, moving from January 27th to January 28th, 2025.

At ACI, we are committed to providing exceptional support and guidance to our clients as they navigate their regulatory requirements. As a trusted leader in broker-dealer FinOp outsourcing, we are dedicated to ensuring FINRA member firms have the resources they need to meet their obligations on time.

Our offices will remain open during normal business hours tomorrow. If you have any questions or need assistance, please don’t hesitate to reach out.

We’re here to support you every step of the way!