March 26, 2020

Updated SEC Reporting Considerations Related To COVID-19

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SEC Relief Order Extension

In response to the ongoing COVID-19 outbreak, the SEC has extended its order to provide public companies an option to apply for a 45-day extension for any filings due from March 1, 2020 through July 1, 2020.

This extended relief will now be relevant to most accelerated filers and relief may provide their teams the extra time needed to effectively execute Q1 close processes and prepare required SEC filings.

The conditions to qualify for the relief remain unchanged from the SEC’s original order on March 4th and as a reminder have been laid out below:

  • Registrant is unable to meet a filing deadline due to circumstances related to COVID-19;
  • Registrant is required to file Form 8-K by either March 16 or the original filing deadline (whichever is later) and state:
    • That it is relying on the relief order;
    • Brief description of the reasons why it could not file on a timely basis; and
    • Estimated date by which it expects file.
  • Risk factors explaining, if material, the impact of COVID-19 on its business; and
  • If the reason the filing cannot be done in a timely manner is due to the inability of another party to furnish any required opinion, report or certification, then attach a statement signed by such party stating the specific reasons for the delay;
  • Filing needs to be completed no later than 45 days after the original due date.

Updated Disclosures

Additionally, the Division of Corporate Finance issued guidance on March 25th on disclosures and other security law obligations which filers may find helpful as they assess the impact of COVID-19 on their Q1 10-Q and other filings.


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