Section 16 filings limit the amount of data that can be included as a footnote or in the Remarks section of the ownership document. Each footnote can contain a maximum of 1,000 characters. The Remarks area can only contain 2,000 characters. In addition, no formatting (or line breaks) can be added to these fields.
To overcome this limitation, consider using a separate document to express this information. The external document can then be attached to the GoFiler project that contains the Form 3, 4 or 5 as an Exhibit 99. Within the ownership document, add a reference to the Exhibit 99 when applicable. For example, in the Remarks section, you might write: “See Exhibit 99 - Additional Information, for extended remarks.”
To move all your footnotes to an external exhibit, you can use the Copy Table function while the selector is located in the footnotes area. You can then paste the footnotes into a new HTML or ASCII document. Finally, each footnote should then state: “See Exhibit 99 for extended footnotes."
You can format the Exhibit 99 file in HTML or ASCII.
Once the exhibit file is formatted and save, add it to your GoFiler project to submit it as part of your filing.
