7 Staff have informally indicated that a revised redacted exhibit must be submitted with an amendment to the original registration declaration or report. In 2013, Citigroup admitted that it failed to protect sensitive data such as Social Security numbers and dates of birth of 146,000 customers who filed for bankruptcy between 2007 and 2011 because its software edited customer data in bankruptcy filings for secured loans. Initial requests for confidentiality may be withdrawn. Staff will continue to process requests for confidentiality under Rules 406 and 24b-2.12 An entity that has filed a request for confidentiality under one or both of the Rules, but instead wishes to follow the more efficient procedure permitted by the amended Rules, as described in the section « Redactions on New Attachments Filed with the SEC, » can do so: by complying with the amended rules and withdrawing their request for confidentiality. The Corporation must submit a revised version of the amended Schedule that complies with the amended rules by amending the registration report or statement with which the redacted part was originally submitted.13 To withdraw the pending request for confidentiality, the Corporation must coordinate with the Office of the Deputy Director, which is responsible for reviewing its bids. Once staff have processed the revocation, the request and related documents (including the unresponsive copy of the agreement) will be returned to the Company upon request or otherwise destroyed. As a result, confidential documents will no longer remain in the possession of staff and will be subject to disclosure under the FOIA. In recent years, there have been some notable editorial errors. In June 2016, House Democrats released a series of digital documents related to the 2012 investigation into attacks on two U.S. facilities in Benghazi, Libya. The Los Angeles Times found that parts of a transcript edited with Hillary Clinton`s adviser, Sidney Blumenthal, could actually be viewed if that section was copied from the PDF version and pasted into another document. Technical Proposals: If you request a copy of an unsuccessful technical tender or a successful technical proposal that has not been included in a final procurement document, please understand that we cannot provide it to you.
Federal law prohibits all agencies, including the NIH, from publishing technical proposals that have not been included in a final contract. This law is found under 41 U.S.C. §253b(m). Staff feedback process. After reviewing an exhibit provided by an additional company, staff may send a comment letter requesting justification for the extent of redaction. In this case, staff comments are likely to focus on whether the redacted information is material and/or whether disclosure of the information would cause competitive harm to the entity. Contract Requests: If you request a copy of an awarded order in which no offer has been included, we will blacken any pricing information or any other information that causes commercial harm to the contractor upon release. Before publishing a contract in which a proposal has been included, we will ask the proposer for advice on any business information that may be included in the proposal. We will heed this advice and, if we agree, we will blacken this information before sending you the documents. If possible, submit a redacted copy of the submitted court record so that it can be made available to the public.
Completion of the staff review. At the end of a compliance review, only the first staff request for an unredacted part and the letter completing the review will be made public on the Company`s EDGAR filing page. Unlike correspondence related to staff review of registration reports and statements, the Company`s comments or responses resulting from a compliance review of redacted exhibits will not be made public on EDGAR. In addition, in accordance with historical practice in reviewing registration declarations, companies are required to resolve any staff comments regarding redacted documents before requesting that the effectiveness of a registration declaration be accelerated. Given the alternative procedure available under the amended rules described above, it is unlikely that companies will rely on Rules 406 and 24b-2 in the future to darken investment conditions. However, because the SEC is not permitted to return or destroy unredacted copies of agreements that already supported confidentiality orders issued under Rule 406 and/or Rule 24b-2, companies that wish to continue to protect such unredacted copies from disclosure under the FOIA must continue to rely on these rules to seek a renewal of a confidentiality order. before it expires. If an order expires before the SEC receives a renewal request, the redacted information could be disclosed in response to a third party`s request for disclosure under the FOIA. 1. The document will be scanned and converted to digital format using OCR 2.
PII in searchable digital files are identified for writing 3. Confidential information is deleted and the redacted file is stored Confidential information that could be used to commit fraud or reveal private information must be blacked out. The following list is a general guide: In addition, the amended rules allow companies to omit similar schedules and attachments to all issuance filings (including essential contracts) as long as those attachments do not contain material information and that information is not otherwise disclosed in the schedule or disclosure document, thereby expanding the accommodation previously limited to takeover plans. Restructuring, order, liquidation or succession under Regulation S-K, Article 601(b)(2). See e.B. Regulation S-K, item 601(a)(5) and Regulation M-A, Instructions 1 to 1016. In 2011, the same copy-and-paste tactic was used to access altered information about Apple`s business relationships, which was mistakenly included in a U.S. District Court notice. 13 For example, if the redacted part was submitted on Form 10-Q, a revised version of the redacted part should be submitted with an amendment to this Exhibit 10-Q. Applicants who apply for contracts in which a proposal has been included generally only want to receive documents that help to understand the process that led to the award or to improve their own methods of preparing proposals. Applicants generally do not want material that the authors believe would harm them if published.
Blackening a paper document can be done by cutting literally all the text to be edited or by using opaque tape to cover the blackened sections. However, writing electronic applications is more complicated. The following methods appear to blacken a document, but in reality they are neither effective nor foolproof: as in the past, companies should closely align their blackens with the omission of only the conditions they deemed appropriate under the rules.3 Furthermore, while this is not mandatory, companies should consider documenting the legal and factual basis for such redactions. .
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