March 30, 2020

On March 25, 2020, the SEC’s Division of Corporation Finance issued CF Disclosure Guidance Topic No. 9. The guidance reflects the current views of the Division of Corporation Finance, or the Division, in response to the ongoing outbreak of COVID-19. The Division emphasized the rapidly evolving and uncertain nature of the impact of COVID-19 and urged companies to provide timely disclosure that is responsive to the federal securities laws. To that end, the Division highlighted that disclosure of business risks and COVID-19-related effects may be necessary or appropriate in a variety of areas, such as management’s discussion and analysis, the business section, risk factors, legal proceedings, disclosure controls and procedures, internal control over financial reporting, and the financial statements.

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