SEC Issues Additional COVID-19 Disclosure Guidance: Division of Corporation Finance Provides Additional Disclosure Guidance for Reporting on the Impact of COVID-19 and the Office of the Chief Accountant Issues Statement on the Importance of High-Quality Financial Reporting in Light of COVID-19

Sullivan & Cromwell LLP - June 25, 2020
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On June 22, the SEC issued additional guidance (“Disclosure Guidance Topic No. 9A”) setting forth further views of the Division of Corporation Finance regarding operations, liquidity and capital resources disclosures that companies should consider with respect to business and market disruptions related to COVID-19.  Disclosure Guidance Topic No. 9A supplements Disclosure Guidance Topic No. 9, which provided the Division of Corporation Finance’s initial views on disclosure and other securities law obligations that companies should consider with respect to COVID-19, and is discussed in our memorandum to clients dated March 30, 2020, available here.  On the same day, the Office of the Chief Accountant of the SEC issued a statement regarding the importance of high-quality financial reporting in light of the significant impacts of COVID-19 and its role in the functioning of markets and efforts to mitigate COVID-19. Disclosure Guidance Topic No. 9A and the Office of the Chief Accountant Statement reflect the SEC’s continued emphasis on robust public disclosure regarding the impacts of COVID-19, which is also discussed in our memorandum to clients dated April 9, 2020, available here.