Yesterday, June 23, 2020, the Division of Corporation Finance of the Securities and Exchange Commission issued CF Disclosure Guidance Topic No. 9A.  This additional Staff guidance provides views regarding the types of disclosures that SEC-reporting companies should consider as a result of disruptions arising as a result of the pandemic.  The Guidance notes that the Staff is monitoring the disclosures made by reporting companies regarding the effect of the pandemic on their businesses, financial condition and results of operations.  The Guidance emphasizes the importance of transparency to investors.  In particular, the Guidance notes that reporting companies should consider addressing changes to their businesses, changes to supply chains, as well as financing activities.  In addition, the Guidance emphasizes the significance of going concern considerations.

A detailed client alert will follow.  See the Guidance here.