SEC EDGAR Large Trader Identification (LTID)

[rho4]

I got myself into a Kafkaesque situation and could use your help

Recently I overtraded and generated a trading volume of >20 Mio. in a day (~100 open/close trades for 100k each).

My broker sent me this email, asking me to apply for and provide a large trader identification:

IBKR also has a setting to provide this ID (which I cannot look up currently because the IB portal is not loading right now).

After reading this reddit post, I started the application process on the EDGAR filer management website.

I paid CHF 20 to notarize my signature (Unterschriftsbeglaubigung) on the EDGAR application form, which got promptly rejected by the SEC with the reason: “PDF copy contains personally identifiable information (PII)”.

ChatGPT explained to me that apparently European notaries notoriously “over-identify” a signature and that the notarization MUST NOT contain my birthdate, place of origin or ID/passport number (all of which was added by Einwohnerkontrolle Zug.

So today I made a 3rd trip to the Einwohnerkontrolle Zug (the 1st time I forgot my ID). I tried to explain my situation which caused the clerk to laugh out loud. I was informed that the US has no authority to tell CH-authorities how to notarize, generously sprinkled with anti-US/Trump comments.

I countered with “I totally understand, but was kind of hoping that the canton of Zug - which advertises as very business friendly and even the crypto-valley of Switzerland - would be interested in supporting its citizens in dealing with the SEC”.

This got me another “ha!” but the clerk did pick up the phone and posed my question to a notary inside the same building. Unfortunately that notary confirmed that under no circumstances would they change their notarization seal in any way.

Has anyone else been in this situation? Any ideas how to move forward from here?

[larix.aurea]

@rho4

Has anyone else been in this situation? Any ideas how to move forward from here?

No.

What happens if you do nothing?

Could you just leave this broker?

[rho4]

@larix.aurea

What happens if you do nothing?

I don’t know.

@larix.aurea

Could you just leave this broker?

I don’t think so, because it is an SEC requirement. In my opinion it would be a bad trust-signal if a US-broker did not adhere to these regulatory duties.

[nabalzbhf]

Could you try some online (US) notarization service?

Edit: otherwise maybe try a different notary service, iirc it’s setup differently depending on the Canton.

Notariat, Grundbuchamt und Konkursamt Enge-Zürich | Ihre Notariate im Kanton Zürich in Zürich I think is seeing a lot of requests from foreigners.

[1742]

Allow me to say: You bloody idiot (but congratz on the trading volume )

I suggest you don’t try to escape your SEC reporting obligations. At the very least, your broker will report you (even just to protect themselves), and the SEC will eventually act (they are slow at the moment, for whatever reason). But, the SEC isn’t that terrible, as long as you at least try to follow their rules.

That being said: You are already in violation. You had ten days following the trigger, and your next reporting duty will be the yearly update 45 days after year-end. The good thing is, you can file to deregister (or set your large trader status inactive) prior to Christmas 2026 and that will be it. Apart from that, the reddit post you linked explains everything quite well.

Regarding the required signature for the EDGAR registration:

• If you were at the Einwohnerkontrolle Zug (Stadthaus, Gubelstrasse) then you were at the right place. Not sure why the reacted so strange. Go again, make sure you simply ask for a “Beglaubigung” of your signature, and sign the form in front of them (maybe you asked for a “Beurkundung” of the entire form?). Tell them it’s for the US, they should use their English stamp (but it doesn’t really matter and does not change anything).
• Then go to the Staatskanzlei Zug (Seestrasse) and get an “Apostille”, which is confirming that whoever just notarized your signature was actually allowed to do so. They will ask which country it is for, and here it very much makes a difference.
• Send the form to the SEC. If it doesn’t work, do the roundtrip again (or just resubmit the next day). Yes, even if you do everything correctly, it might take two or three tries for the SEC to accept it. Welcome to the world of international non-standardization.

Best of luck!

By the way: This is all going to be public, Google will be able to find your CIK and your SEC filing history, which includes the mailing address you register.

[rho4]

@nabalzbhf

Could you try some online (US) notarization service?

Maybe. I created an account with notarize.com / proof.com but during the signing process it turned out that they require a US address.

I haven’t found a reasonably priced alternatives (only USD 200+ and confusing old-looking websites).

@nabalzbhf

maybe try a different notary service

Thanks for the tip. I think I will try a Zurich notary next.

[rho4]

@1742

Allow me to say: You bloody idiot

You’re allowed

@1742

I suggest you don’t try to escape your SEC reporting obligations.

I’m not trying to, but it’s hard

@1742

But, the SEC isn’t that terrible

Oh don’t get me wrong, that’s what I love about US brokers: The laws and regulations that protect my investments.

@1742

That being said: You are already in violation. You had ten days following the trigger, and your next reporting duty will be the yearly update 45 days after year-end.

Yep. Again, not for lack of trying to conform

@1742

The good thing is, you can file to deregister (or set your large trader status inactive) prior to Christmas 2026

Yep, I should do that.

@1742

If you were at the Einwohnerkontrolle Zug (Stadthaus, Gubelstrasse) then you were at the right place. Not sure why the reacted so strange. Go again, make sure you simply ask for a “Beglaubigung” of your signature, and sign the form in front of them (maybe you asked for a “Beurkundung” of the entire form?). Tell them it’s for the US, they should use their English stamp (but it doesn’t really matter and does not change anything).

Yes, I was at the Stadthaus at Gubelstr. The first time I did exactly that: I asked für a simple “Unterschriftsbeglaubigung” (not an Apostille). They even offered the English stamp, which I accepted. I signed in their presence (only page 4), and they signed and stamped only on that page as well. That’s the version that got rejected.

@1742

Then go to the Staatskanzlei Zug (Seestrasse) and get an “Apostille”, which is confirming that whoever just notarized your signature was actually allowed to do so.

From everything I’ve read, an Apostille could make things less likely to be accepted (and is also more expensive of course).

@1742

Send the form to the SEC.

I did, it got rejected.

@1742

If it doesn’t work, do the roundtrip again (or just resubmit the next day).

Indeed, that I will also try.

@1742

This is all going to be public

I know sigh.

[rho4]

@1742

If it doesn’t work, do the roundtrip again (or just resubmit the next day).

My girlfriend suggested to cover the personal information with black rectangles, like in a redacted court document. That way it should be apparent that I am not trying to tamper with an official seal, but only explicitly hide the information that the SEC does not want to see.

I invested another CHF 50 for a PDF X-Change Editor Plus license, covered the info with black rectangles and for good measure rasterized all pages (so that the rectangles cannot just be removed with a PDF editor).

I submitted again and it was accepted last night

Also please note that I only had the absolute minimum required for daytrading in the broker account: USD 25k. US-brokers can give you a margin of 4:1, which is why one individual trade can have a value of 100k. And a roundtrip open/close counts as 200k. So a 100 roundtrip trades amount to 20 mio.