As part of its response to the effects and economic disruption
that the novel coronavirus disease 2019 ("COVID-19") is
causing to the worldwide economy, on March 25, 2020, the Division
of Corporation Finance of the U.S. Securities and Exchange
Commission ("SEC") issued additional guidance regarding
public company disclosure requirements with respect to
COVID-19.1
This client alert supplements and updates our client alert
issued on March 16, 2020, which discusses disclosure and capital
markets considerations for U.S. listed public
companies.2
COVID-19 Disclosure Considerations
The guidance reminds companies that, while it is difficult to
predict with precision the effects of COVID-19 on a company,
management's views on COVID-19's effects and future impact
on the company can be material to investment and voting
decisions.