SEC’s Conditional Reporting Relief and COVID-19 Disclosure Guidance: First Analysis


This First Analysis article discusses some key recent updates by the Securities and Exchange Commission (SEC) regarding the coronavirus outbreak. The SEC, in its ongoing effort to assist reporting companies and other market participants in meeting their reporting and other obligations under the federal securities laws, announced on March 25, 2020 that it was extending the conditional relief granted on March 4, 2020 (the Original Order) in respect of certain SEC filing obligations. The extension is set forth in an order (the Updated Order) that supersedes the Original Order. Concurrently, the Staff of the Division of Corporation Finance (the Staff) issued CF Disclosure Guidance Topic No. 9 (CF-9) setting forth its views regarding disclosure and securities law obligations that reporting companies should consider in respect of COVID-19 and related business and market disruptions.