SEC Shares Additional COVID-19 Disclosure Considerations

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SEC Shares Additional COVID-19 Disclosure Considerations

Blog Keeping Current: Disclosure and Governance Developments
Yesterday, the Securities and Exchange Commission Division of Corporation Finance released CF Disclosure Guidance: Topic No. 9A and SEC Chief Accountant, Sagar Teotia, issued a Statement on the Continued Importance of High-Quality Financial Reporting for Investors in Light of COVID-19. Both offer guidance and suggested considerations with regard to the impacts of COVID-19. The latest Corporation Finance Disclosure Guidance supplements CF Disclosure Guidance: Topic No. 9, which was issued on March 25, 2020, and Mr. Teotia’s statement supplements his April 3, 2020 statement on the same topic (see our April 10 post). While the latest guidance covers much of the same ground addressed earlier this year, it also adds discussion of additional disclosure considerations, many of which relate to the challenges of reopening and returning to work. To assist companies in evaluating their circumstances and analyzing their disclosure obligations, the latest Corporation Finance Disclosure Guidance sets out a host of questions to consider, including with regard to operations, government assistance, and going concern evaluations. Mr. Teotia’s statement highlights some of the recent accounting, auditing and financial reporting issues addressed by the SEC Office of the Chief Accountant through engagement with financial reporting system stakeholders. This latest guidance is worth keeping in mind as companies and their auditors and audit committees prepare for upcoming quarterly reporting. 

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