Today, the staff of Corp Fin issued Disclosure Guidance Topic No. 9, which offers
the staff's views regarding disclosure considerations, trading
on material inside information and reporting financial results in
the context of COVID-19 and related uncertainties. The guidance
includes a valuable series of questions designed to help companies
assess, and to stimulate effective disclosure regarding, the impact
of the coronavirus. As always these days, the guidance makes clear
that it represents only the views of the staff, is not binding and
has no legal force or effect.
In the guidance, the staff indicates that it is continuing to
monitor how companies are reporting the impact of COVID-19 and
acknowledges that reporting companies view timely and robust
disclosure as "essential to functioning markets and that they
want to file periodic and current reports in a timely manner,
notwithstanding the available relief." Nevertheless, the staff
recognizes that the uncertainties
