On March 25, 2020, the Securities and Exchange Commission (“SEC”) published CF Disclosure Guidance: Topic No. 9 (the “Disclosure Release”) to provide guidance to registrants regarding their disclosure obligations with respect to the impact of coronavirus disease 2019 (“COVID-19”) on their operations.
The Disclosure Release encourages registrants to assess the continued effects of COVID-19 on their operations when considering appropriate public disclosures regarding related risks, including how the company and management are responding to them, in a way that is specific to a company’s situation in order to allow investors to evaluate the current and expected impact of COVID-19 on the company’s operations. Key points from the Disclosure Release, and practical considerations that public companies may consider in light of the Disclosure Release, are summarized below.
