Let’s take a look at the options in GoFiler for importing and filing 24F-2NT data to the U.S. Securities and Exchange Commission.

Importing a Complete Form via CSV

Like most XML forms supported by GoFiler, sections can be imported via CSV or Comma Separated Values. However, for certain forms we have been offering an expanded approach to import data that is generated by other systems.

In this case, the CSV contains information tagged by the same names used in the new XML format. The form can be imported in its entirety, validated, proofed, approved and then filed.

Importing a Form via Legacy Text

We recognize many filers have developed custom software to generate 24F-2NT filing data, specifically what is now known with the new XML format as the “Annual Filing Information”. In the past, this data was included as a “document” in part of the legacy filing. That document would contain one or more complex groups, with each having one or more series.

The legacy format satisfied the SEC EDGAR disclosure requirements for the rule, but that data was free flowing and was rather loosely formatted. This in turn made it difficult to be read and processed by machine.

However, with the extensive text processing of our Legato programming language, these forms can be read relatively easily and translated into a structure format:

Unfortunately, the legacy format does not contain series ID information or the additional EDGAR information for filing. Because the legacy document doesn’t have certain information, it can’t be imported. This process can import the Annual Filing Information as XML, but the SEC now requires the Series IDs and, to the extent necessary, class IDs and names, which must be added manually.

Overall, there is very little new data being requested by the SEC as part of the Annual Filing Information, which makes importing legacy text a good transition conduit while existing fund management systems are updated to provide CSV or XML.

Customized CSV Import for Multiple Registrants

Finally, many fund complexes file multiple forms. We have already completed processing for such systems to allow our clients to quickly create dozens or even hundreds of filings quickly and easily using underlying functionality within GoFiler we call EDAC (or the EDGAR Data Access Class). Once approved, these filings can be bulk filed.

In the above mode, the import script can be customized to batch convert multiple files and automatically create XML filings without the need to open each filing individually.

The first two options are included as part of GoFiler Complete and GoFiler Online. Customized CSV Import can be developed for your organization, if needed. We can support your team as they develop a script to interface with your systems and automate the process or we can provide custom software development. Contact sales for additional information.