COVID-19-Related Disclosure Considerations for Upcoming Periodic SEC Reporting

The ongoing COVID-19 pandemic has resulted in unprecedented and rapidly evolving disruptions to public companies’ businesses, financial condition, and results of operations, as well as broad-based economic dislocation and market volatility. Against this backdrop, companies face challenging and complex disclosure considerations.  

The staff of the U.S. Securities and Exchange Commission ("SEC") has provided guidance to help clarify U.S. public companies’ disclosure obligations. By adhering to SEC guidance and disclosure principles and anticipating scrutiny that may arise in the future with the benefit of hindsight, companies can manage their disclosure obligations to public investors. 

In connection with upcoming periodic filings, public companies should evaluate their current business demands, filings deadlines, and disclosure obligations in light of the impact of the COVID-19 pandemic. Companies and those responsible for public reporting obligations should be proactive in addressing filing timelines and appropriate disclosure in response to the COVID-19 pandemic, consistent with the effective implementation of established disclosure controls.

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