On November 17, 2020, the Securities and Exchange Commission
("SEC") voted to adopt amendments to Regulation S-T and
the Electronic Data Gathering, Analysis, and Retrieval system
("EDGAR") Filer Manual to permit the use of electronic
signatures when executing authentication documents in connection
with electronic filings on EDGAR. The SEC adopting release
indicates that these new rules were adopted in recognition of the
current widespread use of electronic signatures, technological
developments in the authentication and security of electronic
signatures, and increased difficulties in obtaining manual
signatures during the ongoing COVID-19 pandemic.
Rule 302(b) of Regulation S-T currently requires that each
signatory to an electronic filing manually sign a signature page or
other document ("authentication document") before or at
the time of the electronic filing to authenticate the signature
that appears in typed form within the electronic filing.
