Reviewing both WilmerHale's "COVID-19: Updating Risk Factor Disclosure in SEC Filings" and Hogan Lovells' "COVID-19: Considerations for Quarterly Reports on Form 10-Q" will go a long way toward helping companies effect Corp Fin's recently issued Coronavirus (COVID-19) guidance: "CF Disclosure Guidance: Topic No. 9" (COVID-19) in their Risk Factors. WilmerHale's memo illustrates by example (original vs. updated disclosures) how to update previously disclosed risk factors to reflect risks that are no longer hypothetical and changes in management’s expectations, and as well as how to update general COVID-19 risks with specific risks that have manifested due to the passage of time. Hogan Lovells' memo - which addresses the guidance across the 10-Q including the MD&A and Financials - focuses its discussion of Risk Factors on how to transform broad, non-specific risk factors, such as Acts of God and economic conditions into COVID-19-specific risk factors based on particular facts and circumstances.
Access numerous additional resources on our Financial Reporting page under Coronavirus (COVID-19). This post first appeared in the weekly Society Alert!