The Division of Corporation Finance of the Securities and
Exchange Commission (SEC) has issued CF Disclosure Guidance
Topic No. 9 (Guidance), which provides guidance on the
disclosure and other securities law obligations companies need to
consider for COVID-19 and its related business and market
disruptions. Although the Guidance has no legal force or effect, it
provides timely insights into the rapidly evolving impact that
COVID-19 is already having, and likely will continue to have, on
many sectors, and how companies can position themselves to
proactively adjust disclosure so as to address these material
changes.
Disclosure Requirements
Acknowledging that the effects of COVID-19 may be difficult to
accurately assess or predict, the Guidance indicates that the
effects COVID-19 has had on a company, what management expects its
future impact will be, how management is responding, and how it is
planning for COVID-19-related uncertainties can be material to, and
have
