Working the forensics of last Thursday’s fraudulent SEC regarding an offer to purchase Avon Products is none of our business here at Vintage. We’ll leave that to the SEC. This NYT article has a good review of the news.
Our responsibility is to prevent faux filings BEFORE any bits of bytes reach EDGAR. Here is a simple summary of how we on-board new clients:
For every new client that comes to Vintage we require a New Member Application completed prior to any work being done. This ensures that the responsible party is agreeing to our terms of service, and that we have the correct company and billing contacts on file. When the New Member Application is filled out it comes into Vintage Client Services and we vet the company.
Some major points of that vetting process are…
- We verbally confirm every application with the applicant.
- We confirm that the person who filled out the application is associated directly with the organization which is signing up and will be receiving the bills (aka: responsible for payment of invoices generated on that account). If not we obtain permission from the billing entity to process work received from the agency sending in the work.
- We ask if the Organization has a valid website with contact information matching what is provided on the application and is their email a domain email address.
- We also crosscheck all information with our Salesforce.com database.
- If validation cannot be made on information submitted in application our last step is asking for a bill (electric or telephone) that connects the person with the Organization’s address and telephone number (aka: some form of proof).
- We also ask if they will be working with a law firm or third party and note this on our checklist.
Additionally there is strict policy we have surrounding releasing of any filing entities EDGAR codes. Whenever an entities’ codes are requested that request is forwarded to Vintage Client Services. If it is a telephone call request, we ask they follow up with the request via email for our records. Vintage Client Services will then require that authorization is given to us from an Officer of that company. We ask the same for Individuals, that authorization is received from the individual.
There are many reason companies should use a filing agent. There are even more reasons a company should us Vintage. (Yes, that was a shameless sales plug)