# PREPARING AND TRANSMITTING ONLINE SUBMISSIONS > Briefs, arguments, decisions, and more. URL: https://www.frixlaw.com/law-library/documents/agency%3Asec%3Af3eaf9e2c86a4fc1 ## Record - **Collection:** Agency decision - **Document type:** Agency decision ## Text 8. PREPARING AND TRANSMITTING ONLINE SUBMISSIONS This chapter discusses the process of preparing and transmitting online submissions to the EDGAR system. This is done using two separate EDGAR websites: 1. EDGAR OnlineForms Management website: This website is used for preparing and submitting: x Ownership Reports (Forms 3, 3/A, 4, 4/A, 5, and 5/A) x Forms 144 and 144/A x Forms D and D/A x Schedule 13D x Schedule 13G 2. EDGAR Filing Website: This website is used for preparing and submitting the following forms and submissions: ƒ EDGARLink Online Forms ƒ Regulation A Forms ƒ Regulation Crowdfunding Forms [Effective March 2, 2027, the following bullet will be added to the EDGAR Filer Manual, pursuant to Extension of Compliance Dates for Electronic Submission of Certain Materials Under the Securities Exchange Act of 1934; Amendments Regarding the FOCUS Report, Securities Act Release No. 33-11386 (Dec. 8, 2025).] ƒ Form 1 (1, 1AA, 1AC, 1/A, 1/A-A, 1/A-T, 1/S-M, 1/S-R, and 1W) Form 13H variants (13H, 13H-A, 13H-Q, 13H-I, 13H-T, and 13H-R) Form 13F variants (13F-HR, 13F-HR/A, 13F-NT, 13F-NT/A, 13F-CTR, and 13F-CTR/A) ƒ Form ATS-N (ATS-N, ATS-N/MA, ATS-N/UA, ATS-N/CA, ATS-N/OFA, ATS-N-C, and ATS-N-W) ƒ Form SDR variants (SDR, SDR/A, SDR-A, and SDR-W) ƒ SBS Entity Forms (SBSE, SBSE/A, SBSE-A, SBSE-A/A, SBSE-BD, SBSE-BD/A, SBSE-C, SBSE-W, SBSE-CCO-RPT, and SBSE-CCO-RPT/A) ƒ Form X-17A-5 Part III variants (X-17A-5 and X-17A-5/A) ƒ Form 17-H variants (17HACON, 17HACON/A, 17HQCON, and 17HQCON/A) ƒ Municipal Advisor Forms (MA, MA-A, MA/A, MA-I, MA-I/A, and MA-W) ƒ Transfer Agent Forms (TA-1, TA-1/A, TA-2, TA-2/A, and TA-W) ƒ Form N-CEN (N-CEN and N-CEN/A) ƒ Form N-CR (N-CR, N-CR/A) September 14, 2026 8-1 EDGAR Filer Manual (Volume II) ƒ Form 24F-2 (24F-2NT and 24F-2NT/A) ƒ Form N-PX (N-PX, N-PX/A, N-PX CTR, and N-PX CTR/A) ƒ Form SBSEF variants (SBSEF, SBSEF/A, SBSEF-W, SBSEF-V) ƒ Forms SBSEF-CCO-RPT, SBSEF-FIN-QTR, and SBSEF-FIN-REQ variants (SBSEF-CCO-RPT, SBSEF-CCO-RPT/A, SBSEF-FIN-QTR, SBSEF-FIN-QTR/A, SBSEF-FIN-REQ, and SBSEF-FIN-REQ/A) ƒ ANE Exception Notice variants (ANE EXCEP NOTICE and ANE EXCEP NOTICE-W) The following sections provide detailed information on the use of these websites for filing online submissions. 8.1 EDGAR OnlineForms Management Website – Online Filing Preparation It is easy to create and submit your filings through the EDGAR OnlineForms Management website. Submission form types 3, 3/A, 4, 4/A, 5, 5/A, 144, 144/A, D, D/A, Schedule 13D, and Schedule 13G are available for online preparation. The EDGAR OnlineForms Management website software uses filer-provided information to prepare an XML tagged primary document that can be verified and printed by the filer and then transmitted to EDGAR for processing. Once EDGAR has accepted the submission it will disseminate the header in tagged SGML and the primary document in tagged XML. Note: Ownership Forms Only: You may create and submit only one form submission at a time. If you are filing on behalf of a company's officers and directors you must create a separate form for EACH officer and director. 8.1.1 Online Forms Data Gathering Model Online submissions follow a basic model, with some distinctions dependent upon the submission form type being filed. 8.1.1.1 Data Gathering Common to EDGAR OnlineForms Management The EDGAR OnlineForms Management website will: x Allow you to choose the type of submission to prepare, (i.e., File Ownership Forms, Form 144, Form D, Schedule 13D, or Schedule 13G) x Allow you to provide general submission information (i.e., contact name, phone number, e-mail address) x Allow you to provide additional e-mail addresses to receive Filer Notification messages x Allow you to provide all of the necessary information required by the SEC rules on an appropriate data gathering form x Allow you to provide your signature and signature date x Allow you to verify the information on the form September 14, 2026 8-2 EDGAR Filer Manual (Volume II) x Allow you to review and confirm your information in the context of the form you are filing and then print the submission for your records x Allow you to transmit the reviewed submission to EDGAR for processing The following are important notes to consider when preparing a submission using the EDGAR OnlineForms Management website: x There is no capability to save work in progress so it is important for you to have all of the information necessary to complete the form before you begin to assemble your submission online. x You can exit the window at any time to discard your work in progress and start over. x All filings that you prepare and submit online are considered to be live EDGAR submissions; once you transmit an online prepared submission it will be automatically processed by EDGAR and, if accepted by EDGAR, immediately disseminated to the public. x The maximum size of your submission must not exceed 200 MB. x Once you select the [Submit] button, EDGAR will transmit your submission and you will see an indicator of the submission progress. 8.1.1.2 Ownership In support of filing ownership reports, the EDGAR OnlineForms Management website will: x Allow you to select the specific ownership form type that you want to assemble and submit to the SEC, (Forms 3, 3/A, 4, 4/A, 5, and 5/A). x Allow you to edit reporting owner address on the form where necessary. x Allow you to upload attachments (i.e., cover letters, exhibits, or correspondence) 8.1.1.3 Form 144 In support of filing Form 144, the EDGAR OnlineForms Management website will: x Allow you to submit a new Form 144 filing or an amendment to a previous Form 144 filing. 8.1.1.4 Form D In support of filing Form D, the EDGAR OnlineForms Management website will: x Allow you to submit a new Form D filing, a new Form D filing using previous electronically filed Form D data or an amendment to a previous Form D filing. 8.1.2 Navigating EDGAR – Logging into EDGAR OnlineForms Management Website To access any of the EDGAR OnlineForms Management website functions, you will need to log in to EDGAR OnlineForms Management website: 1. Go to the EDGAR OnlineForms Management website Login page. 2. Enter your individual account credentials. September 14, 2026 8-3 EDGAR Filer Manual (Volume II) Note: You must obtain individual account credentials from Login.gov to log in to the EDGAR Filing Website. For more information, please refer to Volume I of the Filer Manual, at Section 3(a). If your individual account credentials are valid, the Welcome page appears. 3. If you are already logged into EDGAR with a concurrent session, a message will appear indicating the number of concurrent session(s). 4. You will be able to choose your login CIK, which is the CIK that will be reflected in the accession number for each of your EDGAR submissions. You may change your login CIK at any time to any other CIK for which you are authorized to make filings. 5. After logging into the EDGAR Online Forms Management website, you may see one of the following messages: “Account Confirmation Due Soon” or “Account Confirmation Missed.” If your account confirmation is due soon or if your missed confirmation deadline was within the last three months, EDGAR allows you to perform an account confirmation in the EDGAR Filer Management dashboard. For more details, please refer to the “How Do I Complete Annual Confirmation for an EDGAR Account” webpage on SEC.gov (https://www.sec.gov/submit-filings/filersupport-resources/how-do-i-guides/complete-annual-confirmation-edgar-account). If it has been more than three months since the missed confirmation deadline, you will need to submit a new Form ID to regain access to the account. If you need assistance, contact our Filer Support Staff at (202) 551-8900 for help. 8.1.3 EDGAR OnlineForms Management Menu Options Once you log in to the Online Forms Website, a menu of options appears on the left-hand side of the browser window. This menu allows you to navigate easily without having to return to a menu page. x Home x Information Exchange x Support Two additional functions will help you use the EDGAR OnlineForms Management website. The [Logoff] button ends your EDGAR session. Clicking ‘Home’ brings you to the EDGAR OnlineForms Management website welcome page. From this menu you can move back and forth between pages, find news, or get additional assistance. 8.1.3.1 Information Exchange In the Information Exchange section, there are four main action options: x Make a Filing x x x x File Ownership Forms File Form 144 Schedule 13D Schedule 13G September 14, 2026 8-4 EDGAR Filer Manual (Volume II) x x x File Form D Transmit XML Submission Retrieve/Edit Data By clicking the ‘File Ownership Forms’ link, you can prepare, assemble, validate, and transmit online ownership submissions to EDGAR for processing. For more details, please refer to Section 8.1.4, “Creating an Online Section 16 Ownership Submission.” By clicking the ‘File Form 144’ link, filers can create, validate and submit Form 144 filings using the Online Forms Website. Once submitted, these Form 144 filings are processed by EDGAR. For more details, please refer to Section 8.1.5, “File Form 144 Submission.” By clicking the ‘Schedule 13D’ link, filers can create, validate and submit Schedule 13D filings using the Online Forms Website. Once submitted, these Schedule 13D filings are processed by EDGAR. For more details, please refer to Section 8.1.10, “File Schedule 13D.” By clicking the ‘Schedule 13G’ link, filers can create, validate and submit Schedule 13G filings using the Online Forms Website. Once submitted, these Schedule 13G filings are processed by EDGAR. For more details, please refer to Section 8.1.12, “File Schedule 13G.” By clicking the ‘File Form D’ link, filers can create, validate and submit Form D filings using the Online Forms Website. Once submitted, these Form D filings are processed by EDGAR. For more details, please refer to Section 8.1.7, “File Form D Submission.” By clicking the ‘Transmit XML Submission’ link, you can transmit any filer-constructed submissions to EDGAR for processing. For more details, please refer to Section 9.1, “Filer-Constructed XML Technical Specifications.” By clicking the ‘Retrieve/Edit Data’ link, you can update company information maintained in EDGAR (e.g., address, contact information, e-mail address), or query company or filing information. For more details, please refer to Section 7.1.1.1, “Information Exchange.” 8.1.3.2 Support In the Support section there are four links: x General Help x Frequently Asked Questions x SEC Rule Making x Company Search 8.1.3.2.1 General Web Help If you need help while using the EDGAR OnlineForms Management website on the Internet, click ‘General Help’ from the menu to bring up the General Support Menu page that displays a list of help topics. When you click a topic, you are shown information or additional links to specify the type of assistance you need. 8.1.3.2.2 Frequently Asked Questions September 14, 2026 8-5 EDGAR Filer Manual (Volume II) Click the ‘Frequently Asked Questions’ link to open the EDGAR OnlineForms Management website Frequently Asked Questions (FAQ) page. The FAQ page includes different questions that have been asked most often. You may find the answers helpful while using the EDGAR OnlineForms Management website. Click the hyperlink topic to display the answer in the lower portion of the window. 8.1.3.2.3 SEC Rule Making Click the ‘SEC Rule Making’ link to go to the SEC’s Public Website that gives you up-to-date rule information. You will get information about rules that have been proposed or adopted, as well as other bulletins and notices. 8.1.3.2.4 Company Search The EDGAR OnlineForms Management website restricts you to retrieving company information only for your CIK. To search for information about other companies, click the ‘Company Search’ link to redirect your browser to the EDGAR Company Database. From this website you can perform company searches through the EDGAR database that is updated daily. 8.1.4 Creating an Online Section 16 Ownership Submission This section describes the general process for preparing a Section 16 ownership submission using the EDGAR OnlineForms Management website and then transmitting the submission to EDGAR for processing. Before beginning, gather the following information: x Determine the proper form type you need to file. x Have your CIK and CCC handy. x Determine the Issuer CIK and the ticker symbol of the transactions you need to report. You can use the EDGAR Company Database for assistance. x Make sure you are authorized in the EDGAR Filer Management dashboard as a user, account administrator, delegated user, or delegated administrator for each reporting owner to be included in the submission. x Make sure you have the proper address for each reporting owner to be included in the submission. x Make sure you have the E-Mail address for each additional addressee to receive filer notification messages. x Make sure you have all necessary transaction and holding details. x Prepare any attachments, such as a Cover Letter or Exhibit, save them in the correct format, and have the file names identified. 8.1.4.1 Select Ownership Submission Form Type The first step for preparing an ownership submission using the EDGAR OnlineForms Management website is to select the proper ownership submission form type by: 1. Logging in to the EDGAR OnlineForms Management website. September 14, 2026 8-6 EDGAR Filer Manual (Volume II) 2. Click ‘File Ownership Forms’ in the menu bar. 3. The Select Ownership Form Type page will appear. 4. Using the drop-down list, select the form type you wish to prepare, and click the [Assemble Ownership Submission] button. 5. A new browser window will open and the data entry page for the selected submission form type should appear. 8.1.4.2 Assemble Ownership Submission - Filing in the Top of the Form The following are some basic EDGAR OnlineForms Management website data entry conventions: x Disabled fields are made read-only and are colored gray. x Required fields are indicated by an asterisk to the right of the label name (for example, CIK* and Date* are some of the required fields) x Certain fields are indicated by a double asterisk to the right of the label name to indicate that a footnote is required if you are unable to provide the required data in the space provided (for example: Date Exercisable** and Conversion or Exercise Price of Derivative Security** are fields that require a footnote if the field is left blank) x Press the [Tab] key to move from field to field x Field level help is available by clicking the label x The [Exit Window] button will close the current data entry session and return to the Select Ownership Form Type Page. Any data entered or attachments uploaded will be discarded. Once the Assemble Ownership Submission data entry screen is displayed, you can begin completing your ownership submission for each of the entry sections: Submission Contact x Provide a point of contact for the submission in the name, phone, and E-Mail address fields. Notification Information x Enter additional E-Mail addresses to receive filer notification messages. x Click the [Add Entry] button to add additional notifications. x To remove a notification, select the radio button to the left of the notification and click the [Delete Entry] button. Issuer Information x Enter the CIK and trading symbol for the Issuer company. Date Information x Enter the date of the event that triggered this submission, such as the earliest transaction date to be reported in a Form 4. x The Date Original Filed is only available for amendments and refers to the date when the original submission that is being amended was filed. September 14, 2026 8-7 EDGAR Filer Manual (Volume II) Reporting Owner Information x Enter the CIK, CCC, and relationship fields for each reporting owner. x Click the [Add Entry] button to add additional reporting owners. x To remove a reporting owner, select the radio button to the left of the reporting owner and click the [Delete Entry] button. 8.1.4.3 Assemble Ownership Submission - Filling in the Middle of the Form The middle part of the Assemble Ownership Submission data entry form indicates where Table I and Table II data are displayed. The following are some additional data entry conventions for the Assemble Ownership Submission data entry form: x Fields in Table I and II appear as read-only. You can enter data by clicking the [Add Entry] button. x Once [Add Entry] has been clicked, the Add Holding data entry screen is displayed for Table I or Table II. You can begin entering your holding information for your ownership submission. See Section 8.1.4.3.1 below. x To modify a row, select the radio button to the left of the entry you wish to modify and click the [Edit Entry] button. x To delete a row, select the radio button to the left of the entry you wish to delete and click the [Delete Entry] button. x Footnote references are represented by a superscript to the right of the field. The referenced footnote appears at the bottom of the page. x Date format is MM/DD/YYYY. The following sections illustrate how to enter the required information for Table I and Table II and provide footnotes where necessary. 8.1.4.3.1 Adding a Holding (Form 3 Non-Derivative Security) The Add Holding page appears when the [Add Entry] button is clicked in Form 3 Table I. You use this data entry form to enter all of your Form 3 non-derivative securities that appear in Table I. You must provide the title of the security, the amount of securities beneficially owned, and indicate if the security is owned directly or indirectly. If the security is owned indirectly, you must indicate the nature of indirect beneficial ownership. The following are some data entry conventions for this page: x Default unit for Amount of Securities Owned is Shares. x Default setting for Ownership Form is Direct. x Footnotes can be added on a per field basis by clicking the corresponding [Footnote] button. Note: The total number of rows in the Non-Derivative Table (Table 1 on the printed form) cannot exceed 30. x [OK] button adds information entered to the Ownership Form September 14, 2026 8-8 EDGAR Filer Manual (Volume II) x [Cancel] button when clicked does not save the entered information and returns you to the “Assemble Ownership Submission” data entry form. x [Help] button opens the General Instructions for the Ownership Submission form in a new browser window. x [Exit Window] button exits the form, discards all entered information and returns you to the EDGAR OnlineForms Management website. 8.1.4.3.2 Edit Holding (Form 3 Non-Derivative Security) The Edit Holding page appears when the [Edit Entry] button is clicked for Form 3 Table I. The Edit Holding page is similar to the Add Holding page in Table I and has the same data entry conventions. 8.1.4.3.3 Add Holding (Form 3 Derivative Security) The Add Holding (Form 3 Derivative Security) page appears when the [Add Entry] button is clicked for Table II. You use this data entry form to enter all of your Form 3 derivative securities that appear in Table II. You must provide the title of the security, date exercisable, expiration date, title of securities underlying derivative security, amount or number of shares of securities underlying the derivative security, conversion or exercise price of the derivative security, and mark whether the security is owned directly or indirectly. If the security is owned indirectly, you must indicate the nature of indirect beneficial ownership. If you are unable to provide any of the following information in the space provided you must provide an explanation footnote for each situation: x A date for the Date Exercisable x A date for the Expiration Date x The Amount or Number of Shares of Underlying Derivative Securities x The Conversion or Exercise Price of Derivative Security Note: The total number of rows in the Derivative Table (Table 2 on the printed form) cannot exceed 30. The following are some data entry conventions for this page: x Default unit for Amount of Securities Owned is Shares x Default setting for Ownership Form is Direct x Footnotes can be added on a per field basis 8.1.4.3.4 Edit Holding (Form 3 Derivative Security) The Edit Holding page appears when the [Edit Entry] button is clicked for Table II. The Edit Holding page is similar to the Add Holding page for Table II and has the same data entry conventions. 8.1.4.3.5 Footnotes The Footnotes page appears when you click the [Footnote] button from Table I or Table II entry September 14, 2026 8-9 EDGAR Filer Manual (Volume II) page. You use this page to add, edit, or delete footnotes associated with your submission. In addition, you use this page to associate selected footnotes with a specific data entry field from Table I and Table II. The following are some data entry conventions for this page: x This page contains the master list of all of the footnotes for this submission. x To apply a footnote to a field, select the “Apply To Field” check box for that footnote. x To add a new footnote, click the [Add Footnote] button. x To modify a footnote, select the radio button to the left of the entry you wish to modify and click the [Edit Footnote] button. x To delete a footnote, select the radio button to the left of the entry you wish to delete and click the [Delete Entry] button. 8.1.4.3.5.1 Add Footnote The Add Footnote page appears when the [Add Footnote] button is clicked. The following are some data entry conventions for this page: x You can enter up to 1000 characters for a footnote. If you need to add more than 1000 characters, split your footnote in multiple pieces and associate the pieces with the appropriate fields using the Footnote page. x EDGAR will automatically create the footnote number. x Click the [OK] button to save the footnote entry. x Click the [Cancel] button to cancel the footnote entry. 8.1.4.3.5.2 Edit Footnote The Edit Footnote page appears when the [Edit Footnote] button is clicked. You can modify the existing text of the footnote. The following are some data entry conventions for this page: x Click the [OK] button to save the footnote changes. x Click the [Cancel] button to cancel the footnote changes. 8.1.4.4 Filling in the Bottom of the Form The bottom part of the Assemble Ownership Submission data entry form illustrates where the Explanation of Responses and Signature data is displayed. The following are some additional data entry conventions for this page: Explanation of Responses x Each form type has some specific responses that are indicated by checking the box. Some of these check boxes are automatically filled in based on your responses in Table I and Table II, while others you must complete if appropriate. For example, on Form 3 there is a response September 14, 2026 8-10 EDGAR Filer Manual (Volume II) “No securities are beneficially owned” along with a check box that is auto-filled. When the page first appears, it will be checked. If you add an entry to Table I or Table II, the checkmark will be removed. x Footnotes are listed here as read-only. You can enter additional footnotes or modify an existing footnote by returning to the Table I or Table II entry portion of the form. x Remarks can be used to supply additional commentary on the submission. This field also should be used to provide a list of exhibits and other attachments, if any. Remarks exceeding the 2000 character limit should be included in an attached document. Signature Data x Enter the name of each reporting person in the signature field along with the date signed. Click the [Add Entry] button to add more signature entry lines. x To delete a signature, select the radio button to the left of the entry you wish to delete and click the [Delete Entry] button. 8.1.4.5 Verify Form and Correct Errors Once you have completed entering all of the information for the submission, you will need to verify the form information. Click the [Verify Form] button. One of two screens will appear, either the Assemble Ownership Error screen or the Insider Confirmation/Correction page. The Insider Confirmation/Correction page appears when there are no errors on the form. If your information passes the validation, refer to Section 8.1.4.6, “Insider Confirmation/Correction,” to continue. The Assemble Ownership Error screen will appear if the system detects errors in the format and syntax of your information. See instructions below to resolve your errors. If there were any errors on the form, the form will be re-displayed with the error fields clearly marked with a red circle in front of the field. This will occur if a required field is missing or if the data that you filled in does not meet the formatting criteria. These checks are built into the system to help you avoid errors. You should follow the instructions on the page to correct the errors. Note: EDGAR will validate ONLY the format and syntax of the information provided, and that the Issuer CIK and Reporting Owner CIK and CCC combination are valid. YOU ARE RESPONSIBLE for confirming the accuracy of all transactional and ownership information submitted in the form. If there are errors in Table I or Table II, select the field entry or field value that needs to be revised and click the [Edit Entry] button. The detailed form will appear with the fields in error marked. 8.1.4.6 Insider Confirmation/Correction If your submission was successfully verified, the Insider Confirmation/Correction page will appear. As part of verification, EDGAR retrieves the company name for the Issuer CIK and the name and address information for each reporting owner you entered. Before continuing, you need to confirm that the name and address information that was retrieved from EDGAR based on the issuer CIK and reporting owner CIK and CCCs are correct and update where necessary. The following are some data entry conventions for this page: September 14, 2026 8-11 EDGAR Filer Manual (Volume II) x If you need to modify a reporting owner's mailing address, select the desired reporting owner row and click the [Edit Mailing Address] button. Note: These address changes apply only to the addresses contained within this form and do not update the CIK's address of record. To update the address of record, you must use the ‘Retrieve/Edit Data’ link in the main EDGAR OnlineForms Management window. 8.1.4.7 Edit Mailing Address The Edit Mailing Address page appears when the [Edit Mailing Address] button is clicked. This screen allows you to modify the mailing address for addresses contained within this form and do not update the CIK's address of record. To update the address of record, you must use the ‘Retrieve/Edit Data’ link in the main EDGAR OnlineForms Management window. The following are some data entry conventions for this page: x Click the [OK] button to change the information for this submission x Click the [Cancel] button to return to the Insider Confirmation/Correction screen without making changes. 8.1.4.8 Upload/Delete Attachment(s) The Upload/Delete Attachment(s) page appears when the [Upload/Delete Attachment(s)] button is clicked. This page allows you to manage the attachments associated with your submission. The following are some data entry conventions for this page: x Click the [Upload Attachment] button to upload an attachment. x If you need to delete an attachment, select the radio button to the left of the attachment you wish to delete and click the [Delete Attachment] button. x Click the [Edit Ownership Form] button to return to the Assemble Ownership Submission data entry form. x Click the [Transmit Submission] button to proceed to transmit your submission. 8.1.4.9 Upload Attachment The Upload Attachment page appears when the [Upload Attachment] button is clicked. Note: Any attachments you plan to include should already have been prepared and saved in the appropriate format prior to assembling your online submission. The following are some data entry conventions for this page: x To upload an attachment, enter the attachment information in the fields, and then click the [Upload] button. x To return to the Upload/Delete Attachment(s) screen without uploading an attachment, click the [Cancel] button. 8.1.4.10 Transmit Submission Confirmation The Transmit Submission Confirmation page appears when the [Transmit Submission] button is September 14, 2026 8-12 EDGAR Filer Manual (Volume II) clicked. The following are some data entry conventions for this page: x Click the [Cancel Transmission] button to return to the Assemble Ownership Submission data entry form. x Click the [View/Print Submission] button to view the submission document in HTML format. x Click the [Transmit Submission] button to proceed to transmit the submission to EDGAR for processing. 8.1.4.10.1 View/Print Submission The View/Print Submission page appears when the [View/Print Submission] button is clicked. Use this to print a copy of your form for your records. The following are some data entry conventions for this page: x To view your submission in HTML format, click the [Continue] button. This will display your submission. From the screen, you can print your document by selecting the [Print Page] button. x To close this window and continue your submission processing, click the [Close] button. 8.1.4.11 Transmit Submission Acknowledgment When the [Transmit Submission] button is clicked the Transmit Submission Confirmation page, the Transmit Submission Acknowledgment page appears. This page provides acknowledgment of the transmission, along with the submission accession number. Record your accession number so you can later identify your submission and retrieve the acceptance messages from the website. 8.1.4.12 Transmit Submission Cancelled The Transmit Submission Cancelled page appears when the [Cancel Transmission] button is clicked. The following are some data entry conventions for this page: x Click the [Edit Ownership Form] button to return to the Assemble Ownership Submission data entry form. x Click the [Upload/Delete Attachment(s)] button to return to the Upload/Delete Attachment(s) page. 8.1.5 File Form 144 Submission This section describes the general process for preparing, transmitting and submitting Form 144 to EDGAR for processing. Before beginning, gather the following information: x Have your CIK and CCC handy. x Determine the CIK of the Issuer. You can use the EDGAR Company Database for assistance. September 14, 2026 8-13 EDGAR Filer Manual (Volume II) x Prepare any attachments, such as a Cover Letter or Exhibit, save them in the correct format, and have the file names identified. Form 144 has the following variants (submission form types): x Notice of Proposed Sale of Securities: Submission Form Type 144 x Amendment of Notice of Proposed Sale of Securities: Submission Form Type 144/A 8.1.6 Completing a Form 144 Submission To aid you in completing a Form 144 or 144/A, the primary screens are described below. File Form 144 The File Form 144 screen allows you to specify the type of Form 144 filing. x If you are filing a Form 144 submission, select “Notice of Proposed Sale of Securities (144)” x If you are filing an amendment, select “Amendment to Notices of Proposed Sale of Securities (144/A)” and enter in the Previous Accession Number. Filer Information The Filer Information screen allows you to enter Form 144 filer information. Note: It is necessary to provide a valid filer CIK and CCC on the Filer Information screen before entering any other data or navigating to other screens. Based on the CIK/CCC entered, certain fields on the Issuer Information screen are pre-populated with information maintained in EDGAR. The following are the data entry conventions for the Filer Information screen: x Filer CIK and CCC: Enter the CIK and CCC of the filer. x Issuer CIK: Enter the CIK of the issuer. x Is this a LIVE or TEST Filing?: Select the radio button to mark the submission as a LIVE or TEST filing. The default selection for this button is LIVE. Select the “TEST” radio button if you want to submit a test filing and EDGAR will treat the submission as a test and it will not be disseminated. x Submission Contact Information: Enter the name, phone number, and e-mail address of the person you would like the SEC to contact for any questions concerning the submission. x Notify via Filing Website only?: Select the “Yes” check box to download the filing status notification from the EDGAR Filing Website. Selecting this option restricts EDGAR from sending e-mail notifications of filing status. x Notification E-mail Address: To notify others about the status of the filing, enter their e-mail addresses. A maximum of three addresses may be added by clicking the [Add] button. After the applicant submits the filing, EDGAR will automatically send notification messages to these e-mail addresses informing them of the filing status, i.e., the filing was accepted or suspended. September 14, 2026 8-14 EDGAR Filer Manual (Volume II) Issuer Information The Issuer Information screen allows you to enter information about the issuer. The Name of Issuer and the Address of Issuer are pulled from EDGAR but the filer can change the information. The SEC File Number is also pulled from EDGAR if available. The following are the data entry conventions for the Issuer Information screen: x Name of Issuer x SEC File Number: This information is pre-populated from EDGAR based upon the Reporting File Number if it has a prefix of "000,” "001,” "002,” "033,” "333,” or "811" or, if a relevant match is not found, the Issuer’s most recent File Number with a prefix of "000,” "001,” "002,” "033,” "333,” or "811." x Address of Issuer x Telephone Number x Name of Person for whose Account the Securities are to be sold: This information is pre-populated from EDGAR based upon the Filer CIK. x Relationship to Issuer x Officer x Director x 10% Owner x Member of immediate family of any of the foregoing x Other (Specify)* Securities Information The Securities Information screen for submission form type 144 allows you to enter information about the securities. The following are the data entry conventions for the Securities Information screen: x Title of the Class of Securities To Be Sold x Name and Address of the Broker x Number of Shares or Other Units To Be Sold: Cannot be a negative number. x Aggregate Market Value: Cannot be a negative number. x Number of Shares or Other Units Outstanding: Cannot be a negative number. x Approximate Date of Sale: Should not be greater than today’s date + 10 business day, should not be less than today’s date – 1 calendar year. x Name of the Securities Exchange September 14, 2026 8-15 EDGAR Filer Manual (Volume II) Securities To Be Sold The Securities To Be Sold screen for submission form type 144 allows you to enter information about the securities to be sold. The following are the data entry conventions for the Securities To Be Sold screen: x Title of the Class x Date you Acquired: Should not be greater than today’s date + 10 business days, should not be less than 1/1/1933. x Nature of Acquisition Transaction x Name of Person from Whom Acquired x Is this a gift? x The Date Donor Acquired (if the “Is this a gift” checkbox is selected): Should not be greater than today’s date, should not be less than 1/1/1933. x Amount of Securities you Acquired: Cannot be a negative number. x Date of Payment: Should not be greater than today’s date + 10 business day, should not be less than 1/1/1933. x Nature of Payment Securities Sold In the Past Three Months The Securities Sold In the Past Three Months screen for submission form type 144 allows you to enter information about the securities sold in the past three months. If no securities have been sold in the past three months, click the “Nothing to Report” checkbox. The following are the data entry conventions for the Securities Sold In the Past Three Months screen: x Name and Address of the Seller x Title of Securities Sold x Date of Sale: Should not be greater than today’s date + 10 business day, should not be less than today’s date – 9 calendar months. x Amount of Securities Sold: Cannot be a negative number. x Gross Proceeds: Cannot be a negative number. Signature & Remarks The Signature screen allows the registrant to provide remarks and the signature of the duly authorized representative of the filer who certifies that the information provided in this submission is true and correct. The following are the data entry conventions for this screen: September 14, 2026 8-16 EDGAR Filer Manual (Volume II) x Date of Notice: Enter the "as of" date. Date formats entered will be converted to the EDGAR preferred format mm-dd-yyyy. Future dates greater than ten business days after the filing date will be flagged as errors. x Date of Plan Adoption: Enter the date of plan adoption or giving of instruction, if relying on rule 10B5-1. Date formats entered will be converted to the EDGAR preferred format mm-dd-yyyy. Future dates greater than one business day after the filing date will be flagged as errors. x Signature: Enter the name of the person for whose account the securities are to be sold. Type the name in full (i.e., first name, middle name, and last name) in the Signature field. Initials are not acceptable, unless they are part of the individual’s legal name. Documents The Attach Documents List screen enables you to upload the attachments necessary for submission form types 144 and 144/A. For details on how to add, delete or validate a document, refer to the analogous instructions for Regulation A documents “Attach Documents List” in Section 8.2.4.6. 8.1.7 File Form D Submission This section describes the general process for preparing, transmitting and submitting Form D to EDGAR for processing. Before starting the Form D submission process, gather the following information: x The primary issuer’s CIK and CCC. x The e-mail address for each additional addressee to receive filer notification messages. x The name and address for each related person (executive officer, director, and promoter). x The name and address for each recipient and that you have the CRD numbers for each recipient of sales compensation and their associated broker-dealer. x All necessary transaction and offering details. x The CIK and CCC for each additional issuer making the submission. 8.1.8 Basic Information for Form D Submission This section discusses the basic information you need to know to file a Form D. Throughout the filing process, you will have the ability to view the filing instructions, view and print the form, save the form to your computer, and exit the process. The ‘FORM D INSTRUCTIONS’ link will display the filing instructions in a new browser window. The ‘Print’ link will allow you to view/print Form D. Selecting the ‘Print’ link will display the following menu items: x Print Blank Form: This option will display a blank Form D in a PDF format. x Print Form D: This option will display a partially or fully completed Form D in a PDF format. September 14, 2026 8-17 EDGAR Filer Manual (Volume II) The ‘Save’ link will enable you to save a partially completed Form D on your computer. (Refer to Section 2.3.3 for details on how to set up the Google Chrome browser's save/download preferences.) When you save the partial Form D, the system will display the following message: x “This file can be used at a later date to resume this session. However, please note that any tampering with this file may result in its corruption and render it unusable.” Once saved, you will have the option of retrieving the Form D on the “File Form D” screen. When you return to the Form D screen, you will be given the option of continuing with a saved Form D (stored on your computer) or creating a new Form D. The ‘Exit’ link will prompt you to confirm and then close the current Form D filing and return to Online Forms Website. Any data entered will be discarded. You must complete all required field(s). “Clarification of Response (if necessary)” is an optional field. Enter a description in this field if you consider the information to be relevant to the question being answered. If you are amending a previously filed electronic Form D or creating a new submission based on a previous Form D, some fields will be pre-populated. Note: In cases where “Securities Act Section 4(5)” and “Rule 506” were selected on Item 6, in a previously filed Form D submission or a saved Form D submission, these values will not be restored as they are no longer operative and available as options on Item 6. 8.1.8.1 Help Functions The following help functions will provide you with more information during your Form D filing process: x Field Help: Help text will be available for selected fields by placing your mouse over the field labels. x Information Icon: The current Form D item help will appear when you click this icon. x FORM D INSTRUCTIONS link: This link will display filing instructions in a new browser window. 8.1.8.2 Navigating Form D Items There are several ways to navigate within Form D. To navigate from item to item, you may perform one of the following (excluding the first item, Issuer’s Information, and the last item, Signature and Submission): x Click [Previous] located at the bottom left of the screen, to return to the previous screen. x Click [Next] located at the bottom right of the screen, to navigate to the next item. x Select the appropriate Form D Item from the navigation menu located on the left side of the screen. 8.1.8.3 Validating Form D Submission There are several ways EDGAR will validate the information that you have entered for Form D. September 14, 2026 8-18 EDGAR Filer Manual (Volume II) EDGAR will validate Form D at an individual screen level and the entire Form D on the last screen, “Signature and Submission,” when you click the [Submit] button. EDGAR will check to ensure that each screen is completed appropriately before you can proceed to the next Form D screen or submit your Form D. At the individual screen level, you will receive error messages if EDGAR detects invalid information for the field. The error messages for this validation will be shown in red in the active Form D screen and display a “red x” icon next to the associated field. You must correct the errors before you can proceed to the next Form D screen. When you have completed the entire Form D and clicked the [Submit] button on the “Signature and Submission” screen, EDGAR will automatically validate your Form D information. If there are errors, EDGAR will take you to the Form D screen that contains the first occurrence of invalid information. The list of error messages for this validation will also be shown in red, and display a “red x” icon next to the screen names in the navigation menu to indicate which screens contain invalid information. You must correct the errors for each Form D screen. For best results, it is recommended that you correct the errors in sequence, starting with the first screen that has invalid information. 8.1.8.4 Preparing to File Form D When you are ready to prepare a Form D filing, click the ‘File Form D’ link, which is provided on the navigation menu of the Online Forms Website. The “File Form D” screen appears. The following are the data entry conventions for the screen: x If you want to file a new Form D submission, select the option “New Form D Submission.” x If you want to file a new Form D submission based on a previous electronically filed Form D submission, select the option “New Form D Submission (using previous electronically filed Form D data).” The Accession Number field will appear and you will be required to supply the accession number for the previous electronically filed Form D submission. x If you want to file an amendment to a previously filed Form D submission, select the option “Amendment to a previous Form D Filing.” The Accession Number field will appear and you will be required to supply the accession number for the previously filed Form D submission. The “Form D Issuer’s Information” screen will appear in a new browser window after you select the Form D type. 8.1.9 Completing an Online Form D Submission After you have made a selection to complete a new Form D submission, a new Form D submission using previous electronically filed Form D data or an amendment to a previous Form D, you will be presented with the “Form D Issuer’s Information” screen. 8.1.9.1 Form D Issuer’s Information The following are the data entry conventions for the “Form D Issuer’s Information” screen: x Primary Filing Issuer’s Information: Enter the CIK (Filer ID Number) and CCC (CIK Confirmation Code). If there is more than one issuer, enter the CIK for the primary issuer. September 14, 2026 8-19 EDGAR Filer Manual (Volume II) x Submission Contact Information: Enter the contact information for the issuer. Note: If there is a problem with the filing, EDGAR will contact the person you have provided here. x Notification Information: Enter the e-mail address of anyone else that you want to be notified of the status of your filing (e.g., submission was accepted or suspended). A maximum of three additional e-mail addresses are allowed. After you submit the filing, EDGAR will automatically send notification messages to the e-mail addresses associated with the Login CIK, Submission Contact and Primary Issuer. The automated submission notification e-mails will include the web address of the Electronic Filing Depository (https://nasaaefd.org) to enable you to fulfill your state filing obligations for Form D. x Adding or Removing Additional E-mail Addresses ƒ You may add additional e-mail addresses by clicking the [Add] button. You may add up to three additional e-mail addresses. ƒ An e-mail address must be in the standard e-mail format and include one “@” and at least one “.” after the “@”. ƒ You may remove one or more additional e-mail addresses by checking the box to the left of the e-mail address and then clicking the [Remove] button. Making Changes to Issuer/Company Information If you wish to make changes to the issuer/company information maintained in EDGAR (e.g., address, contact information, e-mail address), click the hyperlinked word “here” within “Changes to company information may be made here.” You will be directed to the Online Forms Website’s “Retrieve/Edit Data” function where you may modify EDGAR company information. Any changes made to the issuer/company information on your Form D filing will ONLY be saved as part of the filing data. 8.1.9.2 Issuer’s Identity The following are the data entry conventions for the “Issuer’s Identity” screen: x CIK (Filer ID Number), CCC (CIK Confirmation Code), Name of Issuer, Jurisdiction of Incorporation/Organization, and Previous Names will be pre-populated, based on the CIK entered on “Form D Issuer’s Information” screen, and will be disabled. x Year of Incorporation/Organization: Enter a year if you select “Within Last Five Years (specify year)” (enter a four digit year). Adding or Removing Additional Issuers To add additional issuers, select the [Add Issuer] button. Note: You will receive an error message if you enter an invalid CIK/CCC combination. x You must select Year of Incorporation/Organization as required for the primary issuer. Previous Name(s) for additional issuers will be pre-populated and disabled. Note: You may add up to 99 additional issuers. You will need to indicate if the September 14, 2026 8-20 EDGAR Filer Manual (Volume II) number of additional issuers exceeds 99. The following is an action you may perform: x You may remove one or more additional issuers by checking the box to the left of the issuer’s CIK, and then clicking the [Remove Issuer] button. You cannot remove the primary issuer. Adding or Removing Additional Previous Names x You may add up to three “previous names” used by your company that were not previously recorded in EDGAR, by clicking the [Add Name] button. Any previous names recorded in EDGAR will be displayed and disabled. Those names cannot be edited or removed. However, you will be able to edit the most recent three “previous names” added via the online Form D submission process. x You can also remove any additional previous names added via the online Form D submission process by checking the box to the left of the name, and then clicking the [Remove Name] button. Making Changes to Issuer/Company Information If you wish to make changes to the issuer/company information maintained in EDGAR (e.g., address, contact information, e-mail address), click the hyperlinked word “here” within “Changes to company information may be made here.” You will be directed to the Online Forms Website’s “Retrieve/Edit Data” function where you may modify EDGAR company information. Any changes made to the issuer/company information on your Form D filing will ONLY be saved as part of the filing data. 8.1.9.3 Principal Place of Business and Contact Information The following are the data entry conventions for the “Principal Place of Business and Contact Information” screen: x The information in this item will be pre-populated based on the Business Address on file in EDGAR for each CIK entered in the “Issuer’s Identity” screen. x If your address on file in EDGAR contains a P.O. Box, it will not be valid for a Form D filing. You will have to enter a new valid address that will be associated with the current Form D filing only. To change the address on file in EDGAR, you must use “Changes to company information may be made here” option or the Online Forms Website’s “Retrieve/Edit Data” option. Making Changes to Issuer/Company Information If you wish to make changes to the issuer/company information maintained in EDGAR (e.g., address, contact information, e-mail address), click the hyperlinked word “here” within “Changes to company information may be made here.” You will be directed to the Online Forms Website’s “Retrieve/Edit Data” function where you may modify EDGAR company information. Any changes made to the issuer/company information on your Form D filing will ONLY be saved as part of the filing data. September 14, 2026 8-21 EDGAR Filer Manual (Volume II) 8.1.9.4 Related Persons The following are the data entry conventions for the “Related Persons” screen: x Complete the required field(s): Last Name, First Name, Street Address 1, City, State/Province/Country, Zip/Postal Code and Relationship. Middle Name, Street Address 2, and “Clarification of Response” fields are optional. Adding or Removing Additional Related Persons x You may add additional related persons by clicking the [Add Person] button. You may add up to 99 additional related persons. x You may remove additional related persons by checking the box to the left of the related persons, and then clicking the [Remove Person] button. x Last Name allows up to 200 characters. September 14, 2026 8-22 EDGAR Filer Manual (Volume II) 8.1.9.5 Industry Group The following are the data entry conventions for the “Industry Group” screen: x Select the applicable Industry Group option. Some selections require additional choices. x If you selected “Pooled Investment Fund” from the “Banking and Financial Services” industry option, you will be required to further select an “Investment Fund Type,” and will need to answer the question that appears. x Address whether or not the issuer is registered as an investment company under the Investment Company Act of 1940. 8.1.9.6 Issuer Size The following are the data entry conventions for the “Issuer Size – Revenue Range” screen: x The issuer size option on this screen will depend on what you selected in the previous Form D item, Industry Group. x The Revenue Range will be the default list that appears. x The Aggregate Net Asset value range will appear if you selected “Hedge Fund” or “Other Investment Fund” for the “Industry Group” item. 8.1.9.7 Federal Exemption(s) and Exclusion(s) Claimed The following are the data entry conventions for the “Federal Exemption(s) and Exclusion(s) Claimed” screen: x Select as many exemptions and exclusions claimed that apply. Notes: (1) You cannot select both “Rule 506(b)” and “Rule 506(c)” in a single submission. (2) Each rule option is hyperlinked to provide more information about the rule. x If you select “Investment Company Act Section 3(c),” you will need to further select one or more of the Section 3(c) paragraphs from the Section 3(c) list. 8.1.9.8 Type of Filing The following are the data entry conventions for the “Type of Filing” screen: x Entry for this screen will depend on the type of Form D that was selected in preparation for the Form D submission process. Refer to Section 8.1.8.4, “Preparing to File Form D,” for more information. x If you are amending a previous electronic Form D, the “Amendment” option will be pre-populated, and disabled. x If you are creating a new Submission based on a previous Form D, the New Notice field in this item will be pre-populated, and disable the other fields. September 14, 2026 8-23 EDGAR Filer Manual (Volume II) Note: You may either select the “Date of First Sale” or “First Sale Yet to Occur.” 8.1.9.9 Duration of Offering The following are the data entry conventions for the “Duration of Offering” screen: x Does the issuer intend this offering to last more than one year?: Select “Yes” or “No.” 8.1.9.10 Type(s) of Securities Offered The following are data entry conventions for the “Type(s) of Securities Offered” screen: x Select one or more type(s) of securities. x If you select “Other (describe),” you will need to enter a description. x “Pooled Investment Fund Interests” will be pre-populated if you selected “Investment Company Act Section 3(c)” in the “Federal Exemption(s) and Exclusion(s) Claimed” screen. You will be able to unselect “Pooled Investment Fund Interests” without affecting the Investment Company Act Section 3(c) field. 8.1.9.11 Business Combination Transaction The following are data entry conventions for the “Business Combination Transaction” screen: x Is this offering being made in connection with a business combination transaction, such as a merger, acquisition or exchange offer?: Select “Yes” or “No.” x Clarification of Response (if Necessary): This field allows a maximum of 255 characters. 8.1.9.12 Minimum Investment The following is the data entry convention for the “Minimum Investment” screen: x Minimum investment accepted from any outside investor: You may only enter whole US dollars. 8.1.9.13 Sales Compensation The following are the data entry conventions for the “Sales Compensation” screen: x You must enter data for all of the fields, with the exception of “Street Address 2,” which is an optional field. x You may select one or more “State(s) of Solicitation.” x You may either provide the “Recipient CRD Number” or select “None.” x You may either identify the “(Associated) Broker or Dealer” or select “None.” x You may either identify the “(Associated) Broker or Dealer CRD Number” or select “None.” x You may add or remove recipients. x “(Associated) Broker or Dealer” and “Recipient” both allow up to 200 characters. September 14, 2026 8-24 EDGAR Filer Manual (Volume II) Adding or Removing Additional Recipients x To add additional recipients, select the [Add] button. x You may add up to 99 additional recipients. You will need to indicate if the number of additional recipients exceeds 99. You must follow the same instructions that apply to the initial recipient for which you listed, and enter in all the required fields. x You may remove additional recipients by checking the box to the left of the “Recipient,” and then clicking the [Remove] button. 8.1.9.14 Offering and Sales Amount The following are the data entry conventions on the “Offering and Sales Amount” screen: x Enter either the “Total Offering Amount” or check “Indefinite.” Note the following restrictions: x If Rule 504 in Item 6 (Federal Exemption(s) and Exclusion(s) Claimed) is selected and the “Total Offering Amount” entered exceeds $10 million, you will receive the following warning: “Only $10 million of securities is permitted to be offered within a 12-month period under Rule 504.” x “Total Offering Amount” must always be greater than $0. x If necessary, you can provide clarification in the Clarification of Response field. Clarifications should not exceed 255 characters. x If you are creating a new submission based on an existing Form D or amending a previously filed one, offering and sales amounts of the original Form D will be automatically populated on this page. x Enter the “Total Amount Sold.” x The amount must be provided as a whole US dollar. Note: “Total Remaining to be Sold” is a disabled field. 8.1.9.15 Investors The following are the data entry conventions for the “Investors” screen: x Select the check box and enter the number of non-accredited investors, if applicable. x Enter the total number of investors. x If you selected Rule 506(b) in the “Federal Exemption(s) and Exclusion(s) Claimed” item of Form D and enter more than 35 non-accredited investors on this screen, you will receive the following warning: “You have selected Rule 506(b) in Item 6, Federal Exemption(s) and Exclusion(s) Claimed. No more than 35 non-accredited investors are permitted in Rule 506(b) offerings.” Note: ‘accredited investors’ is a link, which will provide more information. September 14, 2026 8-25 EDGAR Filer Manual (Volume II) 8.1.9.16 Sales Commissions and Finder’s Fee Expenses The following are the data entry conventions for the “Sales Commissions and Finders’ Fee Expenses” screen: x Enter a value for the “Sales Commissions” and “Finders’ Fees.” x The default value is $0 for the “Sales Commissions” and “Finders’ Fees.” Check “Estimate” if the amount is uncertain. x You may enter only whole US dollars. September 14, 2026 8-26 EDGAR Filer Manual (Volume II) 8.1.9.17 Use of Proceeds The following are the data entry conventions for the “Use of Proceeds” screen: x The default value is $0 for the amount of gross proceeds. Check “Estimate” if the amount is uncertain. x You may enter only whole US dollars. 8.1.9.18 Signature and Submission Once you have completed all of the Form D items, the “Signature and Submission” screen appears,. For signature, type in the signer’s name or other letters or characters adopted or authorized as the signer’s signature. Carefully read through the Terms of Submission agreement. You may print the Terms of Submission. Note: ‘Rule 504(b)(3)’ and ‘Rule 506(d)’ are links, which provide more information. The following are the data entry conventions for this screen: x Complete the required field(s). The check box for the duly authorized representative is an optional field. x Each issuer will be pre-populated to correspond with the issuer names which were provided in the “Issuer’s Identity” item and disabled. x Select the date by clicking the Calendar icon. x Click [Submit] button when you have completed the form and are ready to submit the filing. The system will take you to the confirmation screen. x If there are two or more issuers, you may sign on behalf of the additional issuers which you have provided in the Issuer’s Identity item. Select the check box that indicates you are an authorized representative. On the printed form, “All Issuers” shall be displayed in the Issuers Identity section of the form. x Each issuer must retain the manually signed document signed on its behalf for five years. 8.1.9.19 Form D Confirmation/Correction After your Form D filing has been submitted and verified, the “Form D Confirmation/Correction” screen appears. The following are actions you may perform: x [Edit Form D] button: Allows you to modify your form. x [View/Print Submission] button: Displays your completed filing in a new browser window in a PDF format. x [Transmit Submission] button: Passes your submission to the “Transmit Submission Confirmation” screen. It does not immediately transmit your submission. September 14, 2026 8-27 EDGAR Filer Manual (Volume II) 8.1.9.20 Transmit Submission Confirmation Once you click ‘Transmit Submission’, the “Transmit Submission Confirmation” screen appears. The following are actions you may perform: x [Cancel Transmission] button: Returns you to the “Form D Confirmation/Correction” screen. x [View/Print Submission] button: Allows you to view your Form D filing in a PDF format. x [Transmit Submission] button: Allows you to submit Form D filing to EDGAR. The “Transmit Submission Acknowledgment” screen will appear and display your accession number for the submission. After you have confirmed your transmission, the “Transmit Submission Acknowledgment” screen will appear and display your accession number for the submission. 8.1.9.21 Transmit Submission Acknowledgement The “Transmit Submission Acknowledgment” screen provides acknowledgment of your Form D submission transmission. Note: You should write down your accession number for your records. 8.1.10 File Schedule 13D This section describes the general process for preparing, transmitting and submitting Schedule 13D. The new structured data (XML) implementation of SCHEDULE 13D/A is not required for a combination filing with SC TO-I, SC TO-I/A, SC TO-T or SC TO-T/A. EDGAR does not currently support combined SC TO-I, SC TO-I/A, SC TO-T, or SC TO-T/A with SC 13D/A in XML format. At this time, if needed, please continue to submit SC 13D/A in a non-structured data format when combined with SC TO-I, SC TO-I/A, SC TO-T, or SC TO-T/A.. The following instructions in this section pertain to submitting Schedule 13D or its corresponding amendments in structured data format using an online web form to EDGAR, per the Final Rule Modernization of Beneficial Ownership Reporting, effective February 5, 2024. Submission of Schedule 13D in structured data format is submitted via the EDGAR OnlineForms Management website interface. Before beginning, gather the following information: x Have your Filer CIK and CCC handy. x Determine the CIK of the Issuer. You can use the EDGAR Company Database for assistance. Prepare any attachments, such as exhibits to the schedules, save them in the correct format, and have the file names identified. x September 14, 2026 8-28 EDGAR Filer Manual (Volume II) The submission types applicable to Schedule 13D are: x A schedule filed to report acquisition of beneficial ownership of more than 5% of certain classes of equity securities: SCHEDULE 13D x Amendment to Schedule 13D: SCHEDULE 13D/A o NOTE: NEW structured data (XML) implementation of SCHEDULE 13D/A is not required for combination filing with SC TO-I, SC TO-I/A, SC TO-T or SC TO-T/A. EDGAR does not currently support submitting a combined SC TO-I, SC TO-I/A, SC TO-T, SC TO-T/A with SC 13D/A in XML format. At this time, if needed, please continue to submit SC 13D/A in a non-structured data format with SC TO-I, SC TO-I/A, SC TO-T, or SC TO-T/A 8.1.11 Completing a Schedule 13D To assist you in completing a Schedule 13D or Schedule 13D/A, descriptions of the primary screens are included in this section. The first step to filing a Schedule 13D is to select the required submission type on the File Schedule 13D screen. To navigate to this screen, select the ‘Schedule 13D’ link on the EDGAR menu of the Online Forms Management Website. The File Schedule 13D screen is displayed and allows you to select the type of form you are filing. Select the type of filing from this screen: x x x If you are filing a Schedule 13D, select “Schedule 13D” If you are filing an amendment, select “Amendment to Schedule 13D” If you want to continue working on a previously saved Schedule 13D filing, select the “Continue with any saved File Schedule 13D (Stored on your computer)” radio button. Once you select a submission type on the File Schedule 13D screen, click [Next]. You will be directed to the Filer Information screen specific to the selected submission type. Below is a list of conventions used throughout the online web form: x Each field has a help message that provides information on how to complete a field. Some of these messages will include information on permitted formats. To view a help message, hover over the field name or question. x Asterisks identify fields that are required. x Unless otherwise specified, dates should be reported in the format MM/DD/YYYY. You may either type the date or choose a date from the calendar widget. Certain fields will be pre-populated based on your responses to the Filer Information screen. These fields cannot be edited (they will be grayed out). x Certain items request a State or Country. If a State is entered, the country defaults to United States. September 14, 2026 8-29 EDGAR Filer Manual (Volume II) x Certain questions permit multiple entries. Below are instructions for adding entries: 1. Complete the first entry. 2. Select the [Save] button to save the entry. 3. Select the [Add] button to add more entries. 4. To delete an entry, click the [Delete] button adjacent to the entry. A dialog box prompts you for confirmation prior to deleting the entry. Click [Yes] to delete the entry. The Confirmation dialog box closes and the deleted entry is removed from the list. To edit an entry, click the [Edit] button adjacent to the entry. Make the required changes and save the entry. x Throughout the filing process, you will have the ability to view the filing instructions, view and print your form, save your form to your computer, or exit the filing process. For more information on menu buttons (Save, Print, Instructions, etc.) available on the submission refer to Section 8.2.2, “General Information on Online Forms.” Filer Information The Filer Information screen allows you to enter Schedule 13D filer information. Note: The Filer CIK belongs to one of the Reporting Persons or Reporting Entity in the Schedule 13D or Schedule 13D Amendment. It is necessary to provide a valid filer CIK and CCC on the Filer Information screen before entering any other data or navigating to other screens. The Filer CIK information will pre-populate the CIK and Name of the first Reporting Person in the section “Cover Page Reporting Person Information.” The following are the data entry conventions for the Filer Information screen: x x x x x Filer CIK and CCC: Enter the CIK and CCC of the filer. Is this a LIVE or TEST Filing?: Select the radio button to mark the submission as a LIVE or TEST filing. The default selection for this button is LIVE. Select the “TEST” radio button if you want to submit a test filing and EDGAR will treat the submission as a test and it will not be disseminated. Submission Contact Information: Enter the name, phone number, and e-mail address of the person you would like the SEC to contact for any questions concerning the submission. Notify via Filing Website only?: Select the “Yes” check box to download the filing status notification from the EDGAR Filing Website only. Selecting this option restricts EDGAR from sending e-mail notifications of filing status. Notification E-mail Address: If you want to notify others about the status of the filing, then enter their e-mail addresses. After you submit the filing, EDGAR will automatically send notification messages to these email addresses informing them of the filing status, i.e., whether the filing was accepted or suspended. September 14, 2026 8-30 EDGAR Filer Manual (Volume II) To add a Notification E-mail Address: 1. Enter the e-mail address. 2. Select the [Save Notification Email] button to save the email address. The record is saved. 3. If you need to add more email addresses, repeat steps 1 to 2. Note: If you need to delete an address, click the [Delete] button adjacent to the email address. A dialog box prompts you for confirmation prior to deleting the email address. Click [Yes] to delete the email address. The Confirmation dialog box closes and the deleted email address is removed from the list box. Cover Page Header The Cover Page Header screen for Schedule 13D requires the Issuer CIK and CUSIP to be entered. The Name of Issuer and Address of Issuer’s Principal Executive Offices are pulled from EDGAR based on the Issuer CIK entered. You may update the Address of Issuer’s Principal Executive Offices or leave it as is. However, if EDGAR does not pre-populate the Issuer Address, the information will have to be entered manually. Information about the person authorized to receive notices and communications will also have to be entered manually. The following are the data entry conventions for the Cover Page Header screen: x Title of Class of Securities: Enter the Title of Class of Securities using alphanumeric text. x Date of Event Which Requires Filing of this Statement: Enter the Date of Event Which Requires Filing of this Statement. Should not be greater than today’s date plus 1 business day. If the filing person has previously filed a statement on Schedule 13G to report the acquisition that is the subject of this Schedule 13D, and is filing this schedule because of §§ 240.13d-1(e), 240.13d-1(f) or 240.13d-1(g), check the following box as applicable. Issuer CIK: Enter the Issuer CIK. This is a required entry. CUSIP Number: Enter up to 20 CUSIP numbers. At least one CUSIP entry is required. Name of Issuer – This information is pre-populated from EDGAR based on the Issuer CIK Address of Issuer’s Principal Executive Offices - This information is pre-populated from EDGAR based on the Issuer CIK Notification Information o Name, Address and Telephone Number of Person Authorized to Receive Notices and Communications: Enter the Name, Address and Telephone Number of Person Authorized to Receive Notices and Communications x x x x x x Cover Page Reporting Person Information The Cover Page: Reporting Person Information screen for Schedule 13D allows you to enter information for the Reporting Person. The following are the data entry conventions for the Cover Page: Reporting Persons Information September 14, 2026 8-31 EDGAR Filer Manual (Volume II) screen: x Reporting Person CIK: The Reporting Person CIK will pre-populate with the Filer CIK for the first reporting person. If there is more than one reporting person, enter the CIK of each additional reporting person, if a CIK is available. . x Reporting Person does not have an EDGAR CIK: If a CIK is not available for the additional Reporting person, check this box. This box will not be applicable for the first reporting person entry OR if the schedule is being filed only for one individual or entity. (Optional) Click link to go to Company Database: Select this link to search the EDGAR Company Database to determine if a CIK exists for a Reporting Person CIK. Name of Reporting Person – This information is pre-populated from EDGAR based on the Reporting Person CIK, if a CIK is provided. For additional reporting persons where a CIK is not provided, Name of Reporting Person must be entered manually. Check the appropriate box if a member of a Group (see instructions): Check one box if applicable. Please see Schedule 13D instructions, as needed, for more information on (a) or (b). If any of the shares beneficially owned by a reporting person are held as a member of the group and the membership is expressly affirmed, please check row 2(a). If the reporting person disclaims membership in a group or describes a relationship with other person but does not affirm the existence of a group, please check row 2(b) (unless it is a joint filing pursuant to Rule 13d–1(k)(1) in which case it may not be necessary to check row 2(b)). SEC Use Only – Not Applicable Source of Funds: Check one or more sources, as applicable. At least one source must be checked.. o Subject Company (Company whose securities are being acquired) (SC) o Bank (BK) o Affiliate (of reporting person) (AF) o Working Capital (of reporting person) (WC) o Personal Funds (of reporting person) (PF) o OO - Other (OO) Check if disclosure of legal proceedings is required pursuant to Items 2(d) or 2(e): Check the box if applicable. Citizenship or Place of Organization: Select one country or state from the dropdown list, as applicable. Sole Voting Power: Enter a numeric value.This cannot be a negative number. Shared Voting Power: Enter a numeric value. This cannot be a negative number. Sole Dispositive Power: Enter a numeric value. This cannot be a negative number. Shared Dispositive Power: Enter a numeric value. This cannot be a negative number. Aggregate Amount Beneficially Owned by Each Reporting Person: Enter a numeric value. This cannot be a negative number. Check box if the aggregate amount in row (11) excludes certain shares (See Instructions): Check the box if applicable. Percent of class represented by amount in row (11): Enter a numeric value.. Round to the nearest tenth. Type of reporting person: Select at least one type of reporting person. o Broker Dealer (BD) x x x x x x x x x x x x x x x September 14, 2026 8-32 EDGAR Filer Manual (Volume II) x o Bank (BK) o Church Plan (CP) o Corporation (CO) o Employee Benefit Plan or Endowment Fund (EP) o Individual (IN) o Insurance Company (IC) o Investment Adviser (IA) o Investment Company (IV) o Parent Holding Company/Control Person (HC) o Partnership (PN) o Savings Association (SA) o Other (OO) Comments (optional): Enter any comments, if applicable. Select “Save Reporting Person” to save the information. If there is more than one Reporting Person, please repeat this process for each Reporting Person. Items 1 through 7 The Items 1 through 7 screens for Schedule 13D allow you to enter detailed information about Items 1 through 7 in Schedule 13D or its amendment. The following are the data entry conventions for the Items 1 through 7 screen: x x Item 1: Security and Issuer – State the title of the class of equity securities to which this statement relates and the name and address of the principal executive offices of the issuer of such securities. o Title of Class of Securities – This information is pre-populated from information provided in the Cover Page: Header page. o Name of Issuer – This information is pre-populated from EDGAR based on the Issuer CIK. o Address – This information is pre-populated from EDGAR based on the Issuer CIK. o Comments (optional): Enter comments, if applicable. Item 2: Identity and Background – Identity and Background: If the person filing this statement or any person enumerated in Instruction C of this statement is a corporation, general partnership, limited partnership, syndicate or other group of persons, state its name, the state or other place of its organization, its principal business, the address of its principal office and the information required by (d) and (e) of this Item. If the person filing this statement or any person enumerated in Instruction C is a natural person, provide the information specified in (a)( A ) through (f) of this Item with respect to such person(s). o Enter the requested information for Item 2, (a) through (f): ƒ Name ƒ Residence or business address ƒ Present principal occupation or employment and the name, principal business and address of any corporation or other organization in which such employment is conducted; ƒ Whether or not, during the last five years, such person has been convicted in a criminal proceeding (excluding traffic violations or similar September 14, 2026 8-33 EDGAR Filer Manual (Volume II) x x x x x misdemeanors) and, if so, give the dates, nature of conviction, name and location of court, any penalty imposed, or other disposition of the case; ƒ Whether or not, during the last five years, such person was a party to a civil proceeding of a judicial or administrative body of competent jurisdiction and as a result of such proceeding was or is subject to a judgment, decree or final order enjoining future violations of, or prohibiting or mandating activities subject to, federal or state securities laws or finding any violation with respect to such laws; and, if so, identify and describe such proceedings and summarize the terms of such judgment, decree or final or ƒ Citizenship Item 3: Source and Amount of Funds or Other Consideration o This is an alphanumeric data entry field that allows entry up to 20,000 characters. Item 4: Purpose of Transaction o This is an alphanumeric data entry field that allows entry up to 20,000 characters. Item 5: Interest in Securities of the Issuer: Enter the requested information for Item 5, (a) through (e): o Aggregate Number and Percentage of the Class of Securities Identified o Number of Shares o Transaction Description o Statement and Listing of Shareholders o State the date on which the reporting person ceased to be the beneficial owner of more than five percent of the class of securities. Item 6: Contracts, Arrangements, Understandings or Relationships With Respect to Securities of the Issuer. o This is an alphanumeric data entry field that allows entry up to 20,000 characters. Material to be Filed as Exhibits – Click the link to be directed to the Documents tab to upload exhibits or enter in exhibit description or static URL to incorporate filings by reference in the comment box. Documents The Attach Documents List screen enables you to upload the attachments necessary for Schedule 13D and Schedule 13D/A. For detailed information on EDGAR acceptable document formats, naming conventions, validations and restrictions on attached documents, please refer to Section 5 CONSTRUCTING ATTACHED DOCUMENTS AND DOCUMENT TYPES. Adding and Deleting a Document: To add a document, follow the steps given below: 1. Click the [Add Document] button on the Attach Documents List screen. The Select File window is displayed. 2. Select the file you want to attach and click the [Open] button. The name of the attached file is displayed in the File Name field. September 14, 2026 8-34 EDGAR Filer Manual (Volume II) Note: The file name must follow the EDGAR file naming standards described in Section 5.1.1, “File Naming Standards.” 3. Select the document type from the values displayed in the Type field. 4. Enter a description for the attached document in the Description field. This field is optional and allows you to include up to 255 characters. 5. If you want to add multiple attachments, repeat steps 1 through 4. To delete a document, follow the steps given below: 1. Select the check box adjacent to the document you want to delete and click the [Delete Document] button. A window prompts you to confirm that you want to delete the document. 2. Click the [Yes] button to confirm deletion. EDGAR removes the document from the submission. 3. Click the [Yes] button to confirm deletion. EDGAR removes the document from the submission. Moving a Document Up and Down To move a document up, follow the steps given below: 1. Select the check box adjacent to the document that you wish to move up on the screen. 2. Click the [Move Doc Up] button to move the selected document up one row. To move a document down, follow the steps given below: 1. Select the check box adjacent to the document that you wish to move down on the screen. 2. Click the [Move Doc Down] button to move the selected document down one row. Before you transmit your submission, we recommend that you validate your document attachments. Validating a Document You can validate the document for errors by using the Doc Validation function. 1. Attach your documents to the EDGAR submission as described above. 2. Select the check box for the document you want to validate. 3. Click the [Validate Document] button. If there are no errors in the document, then the Errors field displays a value of zero. Proceed to step 6. If there are errors in the document, then the Errors field displays a value that corresponds to the number of errors in the document. Proceed to step 4. September 14, 2026 8-35 EDGAR Filer Manual (Volume II) 4. Click the value in the Errors field for the document that contains errors. A Document Validation window opens and lists the errors in the document. 5. Correct any document errors using the tool that you used to create the document. 6. Transmit your submission once your submission has been compiled and validated. Note: Clicking the check box next to the File Name field will automatically select all attachments for this submission. Clicking the check box next to the File Name field again will automatically de-select all selected attachments for this submission. The system validates the form to ensure that you have completed all Items. If there are errors in the form, a ‘red x’ icon is displayed on the tabs that contain incomplete or invalid information. You must complete any missing information and correct any errors before re-submitting your form to EDGAR. If there are no errors in the form, the system displays a Confirmation/Warning screen. This screen prompts you for confirmation prior to transmitting your submission. Signature The Signature section must be completed for each reporting person identified in the Cover Page Reporting Person Information section. The Reporting Person/Group Name of each Reporting Person entered in the Cover Page Reporting Person Information will populate on the Signature page. To add the signatures, perform the following steps: 1. Select ‘View/Modify’ next to the Reporting Person/Group Name entry you wish to add a signature. 2. Select ‘Add Signature’ 3. Enter the information for the following: a. By (Signature) b. By (Name/Title) c. Date 4. Select ‘Save Signature.’ 5. Repeat the steps for each entry. x Select ‘Click here to be directed to the Documents tab’ to upload power of attorney. x If you need to incorporate by reference your power of attorney, specify the information in the comment box. Schedule 13D Submission When you have completed and saved the information and are ready to submit the filing, click the [Submit] button at the top of the screen. The system validates the information provided to ensure that you have appropriately supplied the necessary information. If there are errors in the September 14, 2026 8-36 EDGAR Filer Manual (Volume II) submission, a ‘red x’ icon is displayed on the tabs that contain incomplete or invalid information. You must complete any missing information and correct any errors before re-submitting your filing on EDGAR. If there are no errors in the submission, the system displays a Confirmation/Warning screen. Confirmation Screen The Schedule 13D screen prompts you for confirmation prior to transmitting your submission. Submission Acknowledgment The Acknowledgment screen provides acknowledgment of your Schedule 13D or Schedule 13D/A submission transmission. Note the accession number for your records. The accession number only confirms receipt of the submission, not that it was actually accepted by EDGAR. 8.1.12 Completing a Schedule 13G Submission To assist you in completing a Schedule 13G or Schedule 13G/A, descriptions of the primary screens are included in this section. The first step to filing a Schedule 13G is to select the required submission type on the File Schedule 13G screen. To navigate to this screen, select the ‘Schedule 13G’ link on the EDGAR menu of the Online Forms Management Website. The File Schedule 13G screen is displayed and allows you to select the type of submission you are filing. Select the type of filing from this screen: x x x If you are filing a Schedule 13G, select “Schedule 13G.” If you are filing an amendment, select “Amendment to Schedule 13G.” If you want to continue working on a previously saved Schedule 13G filing, select the “Continue with any saved File Schedule 13G (Stored on your computer)” radio button. Once you select a form type on the File Schedule 13G screen, click [Next]. You will be directed to the Filer Information screen specific to the selected form type. Below is a list of conventions used throughout the online web form: x Each field has a help message that provides information on how to complete a field. Some of these messages will include information on permitted formats. To view a help message, hover over the field name or question. x Asterisks identify fields that are required. x Unless otherwise specified, dates should be reported in the format MM/DD/YYYY. You may either type the date or choose a date from the calendar widget. Certain fields will be pre-populated based on your responses to the Filer Information screen. These fields September 14, 2026 8-37 EDGAR Filer Manual (Volume II) cannot be edited (they will be grayed out). x Certain items request a State or Country. If a State is entered, the country defaults to United States. x Certain questions permit multiple entries. Below are instructions for adding entries: 5. Complete the first entry. 6. Select the [Save] button to save the entry. 7. Select the [Add] button to add more entries. 8. To delete an entry, click the [Delete] button adjacent to the entry. A dialog box prompts you for confirmation prior to deleting the entry. Click [Yes] to delete the entry. The Confirmation dialog box closes and the deleted entry is removed from the list. To edit an entry, click the [Edit] button adjacent to the entry. Make the required changes and save the entry. x Throughout the filing process, you will have the ability to view the filing instructions, view and print your form, save your form to your computer, or exit the filing process. For more information on menu buttons (Save, Print, Instructions, etc.) available on the submission refer to Section 8.2.2, “General Information on Online Forms.” Filer Information The Filer Information screen allows you to enter Schedule 13G filer information. Note: It is necessary to provide a valid filer CIK and CCC on the Filer Information screen before entering any other data or navigating to other screens. Based on the Filer CIK entered, the first Reporting Person CIK and Name are pre-populated with information maintained in EDGAR. The following are the data entry conventions for the Filer Information screen: x x x x x Filer CIK and CCC: Enter the CIK and CCC of the filer. The Filer CIK will be used to pre-populate the first Reporting Person CIK and name. Is this a LIVE or TEST Filing?: Select the radio button to mark the submission as a LIVE or TEST filing. The default selection for this button is LIVE. Select the “TEST” radio button if you want to submit a test filing and EDGAR will treat the submission as a test and it will not be disseminated. Submission Contact Information: Enter the name, phone number, and e-mail address of the person you would like the SEC to contact for any questions concerning the submission. Notify via Filing Website only?: Select the “Yes” check box to download the filing status notification from the EDGAR Filing Website only. Selecting this option restricts EDGAR from sending e-mail notifications of filing status. Notification E-mail Address: To notify others about the status of the filing, enter their e-mail addresses. A maximum of three addresses may be added by clicking the [Add] button. After the applicant submits the filing, EDGAR will automatically send notification messages September 14, 2026 8-38 EDGAR Filer Manual (Volume II) to these e-mail addresses informing them of the filing status, i.e., the filing was accepted or suspended. Cover Page Header The Cover Page Header screen for Schedule 13G allows you to enter information about the issuer. The Issuer Name and Address of Issuer’s Principal Executive Offices are pulled from EDGAR based on the Issuer CIK. The filer may change the Address of Issuer’s Principal Executive Offices. The following are the data entry conventions for the Cover Page Header screen: x Title of Class of Securities: This is an alphanumeric data entry field. x Date of Event Which Requires Filing of this Statement: Enter the Date of Event Which Requires Filing of this Statement. Should not be greater than today’s date plus 1 business day. Issuer CIK: This must be a valid EDGAR CIK. You may use the Company Database lookup link to determine the Issuer CIK. CUSIP: Enter up to 20 CUSIP numbers. At least one CUSIP entry is required. Issuer Name – This information is pre-populated from EDGAR based on the Issuer CIK. Address of Issuer’s Principal Executive Offices - This information is pre-populated from EDGAR based on the Issuer CIK. This information may be edited by the filer when completing the submission. Check the appropriate box to designate the rule pursuant to which this Schedule is filed: One or more rules may be selected, as applicable. o Rule 13d-1(b) o Rule 13d-1(c) o Rule 13d-1(d) x x x x x Cover Page Reporting Person Information The Cover Page Reporting Person Information screen for Schedule 13G allows you to enter information for the Reporting Person. The following are the data entry conventions for the Cover Page: Reporting Persons Information screen: x Reporting Person CIK: The Reporting Person CIK will pre-populate with the Filer CIK for the first reporting person. If there is more than one Reporting Person, enter the CIK of each additional reporting person, if a CIK is available. x Reporting Person does not have an EDGAR CIK If a CIK is not available for the additional Reporting person, check this box This box will not be applicable for the first reporting person entry OR if the schedule is being filed only for one individual or entity. (Optional) Click link to go to Company Database: Select this link to search the EDGAR Company Database to determine if a CIK exists for a Reporting Person. Name of Reporting Person: This information is pre-populated from EDGAR based on the x x September 14, 2026 8-39 EDGAR Filer Manual (Volume II) x x x x x x x x x x x x Reporting Person CIK, if a CIK is provided. For additional reporting persons where a CIK is not provided, Name of Reporting Person must be entered manually. Check the appropriate box if a member of a Group (see instructions): Check one box if applicable. Please see Schedule 13G instructions, as needed, for more information on (a) or (b). If any of the shares beneficially owned by a reporting person are held as a member of a group and that membership is expressly affirmed, please check row 2(a). If the reporting person disclaims membership in a group or describes a relationship with other person but does not affirm the existence of a group, please check row 2(b) [unless it is a joint filing pursuant to Rule 13d-1(k)(1) in which case it may not be necessary to check row 2(b)]. SEC Use Only – Not Applicable. Citizenship or Place of Organization: Select one country or state from the dropdown list, as applicable. Sole Voting Power: Enter a numeric value. This cannotbe a negative number. Shared Voting Power: Enter a numeric value. This cannot be a negative number. Sole Dispositive Power: Enter a numeric value. This cannot be a negative number. Shared Dispositive Power: Enter a numeric value. This cannot be a negative number. Aggregate Amount Beneficially Owned by Each Reporting Person: Enter a numeric value. This cannot be a negative number. Check box if the aggregate amount in row (9) excludes certain shares (See Instructions): Check the box if applicable. Percent of class represented by amount in row (9): Enter a numeric value rounded to the nearest tenth. Type of reporting person: Select at least one type of reporting person. o Broker Dealer (BD) o Bank (BK) o Church Plan (CP) o Corporation (CO) o Employee Benefit Plan or Endowment Fund (EP) o Individual (IN) o Insurance Company (IC) o Investment Adviser (IA) o Investment Company (IV) o Non-U.S. Institution (FI) o Parent Holding Company/Control Person (HC) o Partnership (PN) o Savings Association (SA) o Other (OO) Comments (optional): Enter any comments, if applicable. Items 1 through 9 The Items 1 through 9 screen for Schedule 13G allows you to enter detailed information about Items 1 through 9. The following are the data entry conventions for the Items 1 through 9 screen: September 14, 2026 8-40 EDGAR Filer Manual (Volume II) x x x x x Item 1 o Name of issuer - This information is pre-populated from EDGAR based on the Issuer CIK. o Address of issuer’s principal executive offices - This information is pre-populated from information provided in the Cover Page Header page and is not editable. Item 2 o Name of person filing: Enter name of person filing. o Address of principal business office, or, if none, residence: Enter Address of principal business office, or, if none, residence. o Citizenship: Enter Citizenship. o Title and class of securities: This information is pre-populated from information provided in the Cover Page Header page. o CUSIP No.: This information is pre-populated from information provided in the Cover Page Header page. Item 3 o Not Applicable: Select this if Rule 13d-1(d) was selected in the Cover Page Header tab. Note: This field will be deactivated if Rule 13d-1(d) was not selected in the Cover Page Header tab. o If this statement is filed pursuant to §§ 240.13d-1(b) or 240.13d-2(b) or (c), check whether the person filing is a: Select at least one of the following if ‘Not Applicable” was not selected. ƒ Broker or dealer registered under section 15 of the Act (15 U.S.C. 78o); ƒ Bank as defined in section 3(a)(6) of the Act (15 U.S.C. 78c); ƒ Insurance company as defined in section 3(a)(19) of the Act (15 U.S.C. 78c); ƒ Investment company registered under section 8 of the Investment Company Act of 1940 (15 U.S.C. 80a-8); ƒ An investment adviser in accordance with § 240.13d-1(b)(1)(ii)(E); ƒ An employee benefit plan or endowment fund in accordance with § 240.13d-1(b)(1)(ii)(F); ƒ A parent holding company or control person in accordance with § 240.13d-1(b)(1)(ii)(G); ƒ A savings associations as defined in Section 3(b) of the Federal Deposit Insurance Act (12 U.S.C. 1813); ƒ A church plan that is excluded from the definition of an investment company under section 3(c)(14) of the Investment Company Act of 1940 (15 U.S.C. 80a-3); ƒ A non-U.S. institution in accordance with § 240.13d-1(b)(1)(ii)(J). If filing as a non-U.S. institution in accordance with § 240.13d-1(b)(1)(ii)(J), please specify the type of institution;: If (j) is selected, please specify the type of institution. ƒ Group, in accordance with § 240.13d-1(b)(1)(ii)(K). Note: Items 4 to 6 allow you to enter not just numeric information but also details and narratives, as applicable. Item 4: Ownership: Enter the requested information for Item 4, (a) through (c): o (a) Amount beneficially owned September 14, 2026 8-41 EDGAR Filer Manual (Volume II) x x x x x o (b) Percent of class o (c) Number of shares as to which the person has ƒ (i) Sole power to vote or to direct the vote ƒ (ii) Shared power to vote or to direct the vote ƒ (iii) Sole power to dispose or to direct the disposition of ƒ (iv) Shared power to dispose or to direct the disposition of Item 5. Ownership of 5 Percent or Less of a Class o Not Applicable: Select if Item 5 is not applicable. o Ownership of five percent or less of a class: Select if Ownership of 5 Percent or Less of a Class. o Note: Dissolution of a Group requires response to this item. Item 6. Ownership of More than 5 Percent on Behalf of Another Person. o Not Applicable: Select if Item 6 is not applicable. o If any other person is known to have the right to receive or the power to direct the receipt of dividends from, or the proceeds from the sale of, such securities, a statement to that effect should be included in response to this item and, if such interest relates to more than 5 percent of the class, such person should be identified. A listing of the shareholders of an investment company registered under the Investment Company Act of 1940 or the beneficiaries of employee benefit plan, pension fund or endowment fund is not required.: Enter information if Item 6 is applicable. Item 7. Identification and Classification of the Subsidiary Which Acquired the Security Being Reported on by the Parent Holding Company or Control Person. o Not Applicable: Select if Item 7 is not applicable. o If a parent holding company or control person has filed this schedule pursuant to Rule 13d-1(b)(1)(ii)(G), so indicate under Item 3(g) and attach an exhibit stating the identity and the Item 3 classification of the relevant subsidiary. If a parent holding company or control person has filed this schedule pursuant to Rule 13d-1(c) or Rule 13d-1(d), attach an exhibit stating the identification of the relevant subsidiary.: Enter information if Item 7 is applicable. Item 8. Identification and Classification of Members of the Group o Not Applicable: Select if Item 8 is not applicable. o If a group has filed this schedule pursuant to § 240.13d-1(b)(1)(ii)(J), so indicate under Item 3(j) and attach an exhibit stating the identity and Item 3 classification of each member of the group. If a group has filed this schedule pursuant to Rule 13d-1(c) or Rule 13d-1(d), attach an exhibit stating the identity of each member of the group.: Enter information if Item 8 is applicable. Item 9. Notice of Dissolution of Group. o Not Applicable: Select if Item 9 is not applicable. o Notice of dissolution of a group may be furnished as an exhibit stating the date of the dissolution and that all further filings with respect to transactions in the security reported on will be filed, if required, by members of the group, in their individual capacity. See Item 5.: Enter information if Item 9 is applicable. Item 10 and Exhibit Information The Item 10 and Exhibit Information screen for Schedule 13G allows you to provide applicable September 14, 2026 8-42 EDGAR Filer Manual (Volume II) certification(s) and exhibit information for the Schedule 13G. The following are the data entry conventions for the Certifications and Exhibit Information screen: x Item 10: Certifications: o Not Applicable (if reporting pursuant to Rule 13d-1(d)): Select “Not Applicable (if reporting pursuant to Rule 13d-1(d))” if Rule 13d-1(d) was selected in the Cover Page Header tab. Note: if Rule 13d-1(d) was not selected in the Cover Page Header tab, this field will be deactivated. o (a) The following certification shall be included if the statement is filed pursuant to § 240.13d-1(b): ƒ By signing below I certify that, to the best of my knowledge and belief, the securities referred to above were acquired and are held in the ordinary course of business and were not acquired and are not held for the purpose of or with the effect of changing or influencing the control of the issuer of the securities and were not acquired and are not held in connection with or as a participant in any transaction having that purpose or effect, other than activities solely in connection with a nomination under § 240.14a-11.: x Select if Rule 13d-1(b) was selected in the Cover Page Header tab. The certification statement will then populate in the Applicable Certification(s) section. Note: if Rule 13d-1(b) was not selected in the Cover Page Header tab, this field will be deactivated. o b) The following certification shall be included if the statement is filed pursuant to § 240.13d-1(b)(1)(ii)(J), or if the statement is filed pursuant to § 240.13d-1(b)(1)(ii)(K) and a member of the group is a non-U.S. institution eligible to file pursuant to § 240.13d-1(b)(1)(ii)(J): ƒ By signing below I certify that, to the best of my knowledge and belief, the foreign regulatory scheme applicable to [insert particular category of institutional investor] is substantially comparable to the regulatory scheme applicable to the functionally equivalent U.S. institution(s). I also undertake to furnish to the Commission staff, upon request, information that would otherwise be disclosed in a Schedule 13D. x To select this option, you must first, provide the ‘Particular category of institutional investor’ in the text box provided. The certification statement will then populate in the Applicable Certification(s) section and the data entered for the ‘Particular category of institutional investor’ will populate within the certification. o c) The following certification shall be included if the statement is filed pursuant to § 240.13d-1(c): ƒ By signing below I certify that, to the best of my knowledge and belief, the securities referred to above were not acquired and are not held for the purpose of or with the effect of changing or influencing the control of the issuer of the securities and were not acquired and are not held in connection with or as a participant in any transaction having that September 14, 2026 8-43 EDGAR Filer Manual (Volume II) purpose or effect, other than activities solely in connection with a nomination under § 240.14a-11. x Select if Rule 13d-1(c) was selected in the Cover Page Header tab. The certification statement will then populate in the Applicable Certification(s) section. Note: if Rule 13d-1(c) was not selected in the Cover Page Header tab, this field will be deactivated. x Material to be Filed as Exhibit - Click the link to be directed to the Documents tab to upload exhibits or enter in exhibit description. x Use the text box to type in a description or details about the exhibit(s) or provide a static URL to incorporate filings by reference. Documents The Attach Documents List screen enables you to upload the applicable exhibit attachments for Schedule 13G or Schedule 13G/A. For detailed information on EDGAR acceptable document formats, naming conventions, validations and restrictions on attached documents, please refer to Section 5 CONSTRUCTING ATTACHED DOCUMENTS AND DOCUMENT TYPES. Adding and Deleting a Document: To add a document, follow the steps given below: 1. Click the [Add Document] button on the Attach Documents List screen. The Select File window is displayed. Select the file you want to attach and click the [Open] button. The name of the attached file is displayed in the File Name field. Note: The file name must follow the EDGAR file naming standards described in Section 5.1.1, “File Naming Standards.” 2. Select the document type from the values displayed in the Type field. 3. Enter a description for the attached document in the Description field. This field is optional and allows you to include up to 255 characters. 4. If you want to add multiple attachments, repeat steps 1 through 4. To delete a document, follow the steps given below: 1. Select the check box adjacent to the document you want to delete and click the [Delete Document] button. A window prompts you to confirm that you want to delete the document. 2. Click the [Yes] button to confirm deletion. EDGAR removes the document from the submission. Moving a Document Up and Down To move a document up, follow the steps given below: September 14, 2026 8-44 EDGAR Filer Manual (Volume II) 1. Select the check box adjacent to the document that you wish to move up on the screen. 2. Click the [Move Doc Up] button to move the selected document up one row. To move a document down, follow the steps given below: 1. Select the check box adjacent to the document that you wish to move down on the screen. 2. Click the [Move Doc Down] button to move the selected document down one row. Before you transmit your submission, we recommend that you validate your document attachments. Validating a Document You can validate the document for errors by using the Doc Validation function. 1. Attach your documents to the EDGAR submission as described above. 2. Select the check box for the document you want to validate. 3. Click the [Validate Document] button. If there are no errors in the document, then the Errors field displays a value of zero. Proceed to step 6. If there are errors in the document, then the Errors field displays a value that corresponds to the number of errors in the document. Proceed to step 4. Click the value in the Errors field for the document that contains errors. A Document Validation window opens and lists the errors in the document. Correct any document errors using the tool that you used to create the document. 4. Transmit your submission once your submission has been compiled and validated. Note: Clicking the check box next to the File Name field will automatically select all attachments for this submission. Clicking the check box next to the File Name field again will automatically de-select all selected attachments for this submission. The system validates the form to ensure that you have completed all Items. If there are errors in the form, a ‘red x’ icon is displayed on the tabs that contain incomplete or invalid information. You must complete any missing information and correct any errors before re-submitting your form to EDGAR. If there are no errors in the form, the system displays a Confirmation/Warning screen. This screen prompts you for confirmation prior to transmitting your submission. Signature The Signature section must be completed for each reporting person identified in the Cover Page Reporting Person Information section. September 14, 2026 8-45 EDGAR Filer Manual (Volume II) The Reporting Person/Group Name of each Reporting Person entered in the Cover Page Reporting Person Information will populate on the Signature page. To add the signatures, perform the following steps: 6. Select ‘View/Modify’ next to the Reporting Person/Group Name entry you wish to add a signature. 7. Select ‘Add Signature’ 8. Enter the information for the following: a. By (Signature) b. By (Name/Title) c. Date 9. Select ‘Save Signature.’ 10. Repeat the steps for each entry. x Select ‘Click here to be directed to the Documents tab’ to upload power of attorney. x If you need to incorporate by reference your power of attorney, specify the information in the comment box. Schedule 13G Submission When you have completed and saved the information, and are ready to submit the filing, click the [Submit] button at the top of the screen. The system validates the information to ensure that you have appropriately supplied all necessary information. If there are errors in the submission, a ‘red x’ icon is displayed on the tabs that contain incomplete or invalid information. You must complete any missing information and correct any errors before re-submitting your filing on EDGAR. If there are no errors in the submission, the system displays a Confirmation/Warning screen. Confirmation Screen The Schedule 13G screen prompts you for confirmation prior to transmitting your submission. Submission Acknowledgment The Acknowledgment screen provides acknowledgment of your Schedule 13G or Schedule 13G/A submission transmission. Note the accession number for your records. The accession number only confirms receipt of the submission, not that it was actually accepted by EDGAR. 8.1.13 Common Ownership Problems The EDGAR OnlineForms Management website helps the Ownership filer avoid most common mistakes when constructing their primary document. For filers using this site to submit ownership forms, the most common errors will occur with their attached documents. To prevent these errors, filers can use EDGARLink Online to validate the document content. The error messages listed below reflect issues with attached documents. September 14, 2026 8-46 EDGAR Filer Manual (Volume II) Problem Description Illegal tags in HTML filings For security reasons, EDGAR does not support all valid HTML tags. Be sure to restrict your tags to those listed in this manual. Invalid ASCII characters The ASCII character set is limited and including characters in your documents that are not specified in this manual will cause your filing to be suspended. This is especially true of binary characters. Illegal External References If you include references in HTML documents that are external to your References filing, your filing will be suspended. The only legal reference is to the SEC’s Public Website. September 14, 2026 8-47 EDGAR Filer Manual (Volume II) 8.2 EDGAR Filing Website The EDGAR Filing Website (https://www.edgarfiling.sec.gov) is used for preparing and submitting the following forms and submissions: x EDGARLink Online Forms x Regulation A Forms x Form 1 (1, 1AA, 1AC, 1/A, 1/A-A, 1/A-T, 1/S-M, 1/S-R, and 1W) x Form 13H variants (13H, 13H-A, 13H-Q, 13H-I, 13H-T, and 13H-R) x Form 13F variants (13F-HR, 13F-HR/A, 13F-NT, 13F-NT/A, 13F-CTR, and 13F-CTR/A) x Form ATS-N (ATS-N, ATS-N/MA, ATS-N/UA, ATS-N/CA, ATS-N/OFA, ATS-N-C, and ATS-N-W) x Form SDR variants (SDR, SDR/A, SDR-A, and SDR-W) x SBS Entity Forms (SBSE, SBSE/A, SBSE-A, SBSE-A/A, SBSE-BD, SBSE-BD/A, SBSE-C, SBSE-W, SBSE-CCO-RPT, and SBSE-CCO-RPT/A) x Form SBSEF variants (SBSEF, SBSEF/A, SBSEF-W, SBSEF-V) x Forms SBSEF-CCO-RPT, SBSEF-FIN-QTR, and SBSEF-FIN-REQ variants (SBSEF-CCORPT/A, SBSEF-FIN-QTR/A, SBSEF-FIN-REQ/A) x Municipal Advisor Forms (MA, MA-A, MA/A, MA-I, MA-I/A, and MA-W) x Form X-17A-5 Part III variants (X-17A-5 and X-17A-5/A) x Form 17-H variants (17HACON, 17HACON/A, 17HQCON, and 17HQCON/A) x TA Forms (TA-1, TA-1/A, TA-2, TA-2/A, and TA-W) x Form N-CEN (N-CEN, N-CEN/A) x Form N-CR (N-CR, N-CR/A) x Form 24F-2 (24F-2NT and 24F-2NT/A) x Form N-PX variants (N-PX, N-PX/A, N-PX CTR, and N-PX CTR/A) x ANE Exception Notice variants (ANE EXCEP NOTICE and ANE EXCEP NOTICE-W) To access any of the EDGAR Filing Website functions, you will need to log in to the EDGAR Filing Website. Follow the directions described in Section 7.1.1 for details on how to obtain access and use the EDGAR Filing Website. 8.2.1 EDGAR Filing Website Menu Options Once you log in to EDGAR, an option menu appears on the left-hand side of the browser window. This menu allows you to navigate easily through EDGAR without having to return to a menu page. This menu is broken down into six different sections: Information Exchange, Draft Submissions, September 14, 2026 8-48 EDGAR Filer Manual (Volume II) Regulation A, Regulation Crowdfunding, Online Forms, and Support. To access the Online forms, go to the ‘Online Forms’ section on the EDGAR menu. For more information on the six sections of the EDGAR menu, refer to Section 7.1.1, “Using the EDGAR Filing Website.” 8.2.2 General Information on Online Forms This section discusses the basic information you need to know to file Online Forms. Throughout the filing process, you will have the ability to view the filing instructions, view and print the form, save the form to your computer, and exit the process. The following menu items display on the right hand corner of the Online Forms window: x The ‘Submit’ function will allow you to submit the completed form to EDGAR. Selecting this function will transmit your submission and you will see an indicator of the submission progress. x The ‘Save’ function will enable you to save a partially completed form on your computer. To resume working on the form at a later time, log in again and select the ‘Continue with Saved ’ option available on the Type of Filing selection screen of each form. If you use Google Chrome as your web browser, refer to Section 2.3.3 for details on how to set up the Google Chrome browser's save/download preferences. x The ‘Print’ function allows you to print either a blank form or a current form. x x Print Blank Form: This option will display a blank form in PDF. Print Current Form: This option will display a partially or fully completed form in HTML format. x The ‘Instructions’ function will display the instructions for completing a form. x The ‘Exit’ function will prompt you to confirm and then close the current form filing. Any data entered will be discarded unless you first ‘Save’ the work you have entered. Note: When entering data in a form, a time-out warning message will be displayed if the form’s browser window is left inactive for 55 minutes. Click the [Keep Alive] button to keep the current session active and prevent a time-out at 60 minutes of inactivity. 8.2.2.1 Help Functions The following help functions will provide you with more information during the Online Form filing process: x Field Help: Help text will be available for selected fields by placing your mouse over the field labels. x ‘Instructions’ link: This link will display instructions for completing a form. 8.2.2.2 Navigating Online Forms There are several ways to navigate within Online Forms. To navigate from item to item, you may perform one of the following: x Click [Previous] located at the bottom left of the screen, to return to the previous screen. September 14, 2026 8-49 EDGAR Filer Manual (Volume II) x Click [Next] located at the bottom right of the screen, to navigate to the next screen. x Select the appropriate form Item from the navigation menu located on the left side of the screen. 8.2.2.3 Validating Online Forms EDGAR will validate the information that you have entered for Online Forms at different levels. EDGAR will validate forms at an individual screen level and the entire form when you click the [Submit] button. Additionally, EDGAR also provides the option of validating document attachments. EDGAR will check to ensure that each screen is completed appropriately before you can proceed to the next form screen or submit your form. Required fields are indicated by an asterisk to the right of the label name (for example, Filer CIK* and Filer CCC* are some of the required fields.) If EDGAR detects invalid information for a field at the individual screen level, a red ‘x’ icon is displayed within the field. Clicking the icon displays a message describing the type of information that belongs in the field to help you correct the errors, before final submission of the form. When you complete the entire Online Form and click the [Submit] button, EDGAR will automatically validate your form’s information. If there are errors, they must be corrected for each form screen. For best results, it is recommended that you correct the errors in sequence, starting with the first screen that has invalid information. 8.2.3 File Regulation A Forms This section describes the general process for preparing and submitting Regulation A submissions under the Securities Act of 1933 to EDGAR for processing. Issuers can file the following Regulation A submission form types: Draft Submissions x DOS: Non-public draft offering statement under Regulation A x DOS/A: Non-public draft pre-qualification amendment for offering statement under Regulation A x DOSLTR: Draft Offering Statement Letter Regulation A Offering Statements and Circulars x 1-A: Offering statement under Regulation A x 1-A/A: Pre-qualification amendment for offering statement under Regulation A x 1-A POS: Post-qualification amendment to a 1-A offering statement x 1-A-W: Withdrawal of offering statement under Regulation A x 1-A-W/A: Amendment to a withdrawal of offering statement under Regulation A x 253G1: Reflects information previously omitted from the offering circular in reliance on Rule 253(b) September 14, 2026 8-50 EDGAR Filer Manual (Volume II) x 253G2: Reflects information that constitutes a substantive change from or addition to the information set forth in the last offering circular x 253G3: Reflects information covered in both 253G1 and 253G2 x 253G4: Reflects information covered in 253G1, 253G2 or 253G3 that is not being timely filed Regulation A Ongoing Reports x 1-K: Annual Report Pursuant to Regulation A x 1-K/A: Amendment to Annual Report Pursuant to Regulation A x 1-SA: Semiannual Report Pursuant to Regulation A x 1-SA/A: Amendment to Semiannual Report Pursuant to Regulation A x 1-U: Current Report pursuant to Regulation A x 1-U/A: Amendment to Current Report pursuant to Regulation A x 1-Z: Exit Report under Regulation A x 1-Z/A: Amendment to Exit Report under Regulation A x 1-Z-W: Withdrawal of Exit Report under Regulation A x 1-Z-W/A: Amendment to a withdrawal of Exit Report under Regulation A 8.2.3.1 General Information for Regulation A Forms The following section provides general information that is applicable to Regulation A form types: x You can access Regulation A form types using the: x x ‘Regulation A’ or ‘Draft Offering Statement’ link on the EDGAR menu of the EDGAR Filing Website ‘REG A’ link on the EDGARLink Online Submission Type Selection screen x You can submit filer-constructed XML submissions for all Regulation A submission form types (with the exception of DOS, DOS/A, and DOSLTR) via the ‘Transmit’ link on the EDGAR Menu. For DOS, DOS/A, and DOSLTR no filer-constructed XML submissions will be accepted. Refer to Chapter 9, “Filer-Constructed XML Submissions,” for information on filer-constructed submissions. x You must provide a valid Issuer CIK and CCC on the Filer Information screen for submission form types DOS, DOS/A, 1-A, 1-A/A, 1-K, 1-K/A, 1-Z, and 1-Z/A prior to entering any other data. Based on the CIK and CCC entered, certain fields on the Issuer Information screen are pre-populated with information maintained in EDGAR. x For submission form types DOS/A, 1-A, 1-A/A, 1-A POS, 1-K/A, and 1-Z/A form data will be pre-populated based on the CIK, CCC, and file number entered, eliminating the need to re-enter this information. The details are as follows: x The system will pre-populate submission form type DOS/A with data from the most September 14, 2026 8-51 EDGAR Filer Manual (Volume II) x x x x x x recent previously accepted DOS or DOS/A filing with the ‘367’ prefix file number provided by the issuer, with the exception of the fields that are populated from the company database after the issuer has entered a valid CIK/CCC combination. The system will pre-populate submission form type 1-A with data from the most recent previously accepted DOS or DOS/A submission, with the exception of the fields that are populated from the company database, if the issuer enters the file number from the most recently accepted DOS or DOS/A filing with a ‘367’ file number prefix and a valid CIK/CCC combination. Issuers can edit all fields on submission form type 1-A, except three fields, namely “Exact name of issuer as specified in the issuer’s charter,” “CIK,” and “Total (the sum of the aggregate offering prices in the four preceding paragraphs).” The system will pre-populate submission form types 1-A/A with data from the most recent previously accepted 1-A or 1-A/A submission having the same ‘024’ prefix file number as that provided by the issuer, with the exception of the fields that are populated from the company database after the issuer has entered a valid CIK/CCC combination. The system will pre-populate submission form type 1-A POS with data from the most recent previously accepted 1-A or 1-A/A submission having the same ‘024’ prefix file number as that provided by the issuer, with the exception of the fields that are populated from the company database after the issuer has entered a valid CIK/CCC combination. The system will pre-populate submission form type 1-K/A with data from the most recent previously accepted 1-K or 1-K/A submission having the same ‘24R’ prefix file number as provided by the issuer, with the exception of the fields that are populated from the company database after the issuer has entered a valid CIK/CCC combination. The system will pre-populate submission form [Text truncated at 120,000 characters. The full text is on the page linked above.] --- Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/agency%3Asec%3Af3eaf9e2c86a4fc1. Public record. Not legal advice.