Managing COVID-19: New Disclosure Guidance from the SEC

Managing COVID-19: New Disclosure Guidance from the SEC

July 9, 2020, Covington Alert

The second quarter of 2020 is the first period in which most U.S. public companies were fully confronted with challenges presented by the COVID-19 global pandemic. The SEC and its staff (the “Staff”) have recently issued a number of statements regarding disclosure considerations and updates to reporting relief that will affect various aspects of companies’ second quarter reporting. Of greatest relevance to public companies is the additional COVID-19 disclosure guidance in CF Disclosure Guidance: Topic No. 9A (“Topic 9A”), which was issued by the SEC’s Division of Corporation Finance (the “Division”) on June 23, 2020. This alert discusses key highlights of Topic 9A and also summarizes recent SEC statements and regulatory developments that provide accounting and disclosure guidance and regulatory relief.