COVID-19: SEC Reporting and Filing Matters

On March 31, 2020, Cravath prepared a presentation for clients entitled “COVID‑19: SEC Reporting and Filing Matters,” which examines U.S. Securities and Exchange Commission reporting and filing challenges caused by COVID‑19 disruptions. Noting that the SEC remains fully operational through remote working, the presentation is intended to serve as a resource for companies evaluating their SEC reporting and filing obligations in light of COVID‑19, which it does by analyzing recent SEC orders and guidance, presenting examples of and best practices with respect to COVID‑19‑related risk factors and examining Form 8‑K disclosure requirements relating to events influenced by COVID‑19. In some cases, extensions for filing periodic reports and exemption from certain proxy delivery requirements are applicable for companies affected by COVID‑19. Risk factors that companies have noted in filings include supply chain disruption, reduced workforce availability, facility closures and a reduction in store hours and non‑essential services. Events disclosed in 8‑K filings include amending bylaws to allow for virtual shareholder meetings, suspending dividend payments and changing director and officer compensation.

Please click here to read the full presentation.