COVID-19 Disclosure Considerations

As part of its response to COVID-19, and further to initial guidance issued on March 4, 2020, the SEC issued additional guidance on March 25, 2020, regarding public company disclosure requirements relating to COVID-19.

The guidance makes clear that the SEC is conscious of the rapidly evolving nature of the pandemic, and that disclosure will need to be tailored to each company based on a facts and circumstances analysis, but goes on to set out generally applicable guidelines for all companies. For instance, companies should disclose the effects COVID-19 has already had on the company, what management expects the future impact will be, how management is responding to evolving events, and how the company is planning for COVID-19-related uncertainties material to investment and voting decisions. The guidance notes that the existing disclosure framework for each of Management's Discussion and Analysis of Financial Conditions and Results of Operations (MD&A), business and