The coronavirus pandemic (COVID-19) has had a significant impact on many if not all US publicly-traded companies. Whether companies suffered breaks in their supply chains, closures of their sites, or faltering demand as consumers were forced to stay at home, companies endured disruptions that, in some cases, materially impacted their results. Yet, despite this unprecedented dislocation, even when the SEC provided a 45-day grace period for making periodic filings, including 10-Q filings, we found that most S&P 500 companies filed their SEC reports on time.
We outline below some of the notable COVID-19 disclosure trends from the most recent quarterly reports of S&P 500 companies and provide recommendations on what companies should consider when preparing this quarter’s SEC disclosure.
SEC guidance
On March 25, 2020, the Division of Corporation Finance issued guidance on how companies should disclose the evolving business risks affecting several areas of disclosure. On April 8, 2020, the Division urged companies to provide as much information as practicable about their current financial and operating status and future operational and financial planning. It underscored the importance of providing more forward-looking information and reminded companies to carefully craft forward-looking statement safe harbors that would help to protect them from liability.
