The SEC Division of Corporation Finance issued today COVID-19 Disclosure Guidance: Topic No. 9A to supplement its previously issued Disclosure Guidance Topic No. 9, which we reported on here. As is the case with our SEC disclosure scheme generally, and Topic No. 9 specifically, the guidance is principles-based and designed to elicit company-specific disclosure based upon each company's analysis of their unique facts and circumstances. Along those lines, the guidance (like Topic No. 9) enumerates a series of questions companies are encouraged to consider as respects potential impacts of pandemic-prompted operational adjustments, financing activities, government financial assistance, and other actions on their financial condition, results of operations, liquidity, capital resources, and ability to continue as a going concern. Companies are also reminded to consider whether any of the information is appropriately disclosable in the MD&A.
As a precursor to Q2 filings for many companies, Chief Accountant Sagar Teotia concurrently issued this "Statement on the Continued Importance of High-Quality Financial Reporting for Investors in Light of COVID-19," reiterating and elaborating on key takeaways from his April 3rd Statement (reported on here - see SEC Chief Accountant") and emphasizing the importance of robust audit committee financial reporting oversight.
Access additional resources on our Financial Reporting page under Coronavirus (COVID-19).