Client Alert: SEC’s Division of Corporation Finance Issues Guidance on Financial Reporting as a Result of the Ongoing Outbreak of COVID-19

On March 25, 2020, the SEC’s Division of Corporation Finance issued CF Disclosure Guidance Topic No. 9. The guidance reflects the current views of the Division of Corporation Finance, or the Division, in response to the ongoing outbreak of COVID-19. The Division emphasized the rapidly evolving and uncertain nature of the impact of COVID-19 and urged companies to provide timely disclosure that is responsive to the federal securities laws. To that end, the Division highlighted that disclosure of business risks and COVID-19-related effects may be necessary or appropriate in a variety of areas, such as management’s discussion and analysis, the business section, risk factors, legal proceedings, disclosure controls and procedures, internal control over financial reporting, and the financial statements.

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© 2026 Jenner & Block LLP. Attorney Advertising. Jenner & Block LLP is an Illinois Limited Liability Partnership including professional corporations. This publication, presentation, or event is not intended to provide legal advice but to provide information on legal matters and/or firm news of interest to our clients and colleagues. Readers or attendees should seek specific legal advice before taking any action with respect to matters mentioned in this publication or at this event. The attorney responsible for this communication is Brent E. Kidwell, Jenner & Block LLP, 353 N. Clark Street, Chicago, IL 60654-3456. Prior results do not guarantee a similar outcome. Jenner & Block London LLP, an affiliate of Jenner & Block LLP, is a limited liability partnership established under the laws of the State of Delaware, USA and is authorised and regulated by the Solicitors Regulation Authority with SRA number 615729. Information regarding the data we collect and the rights you have over your data can be found in our Privacy Notice. For further inquiries, please contact dataprotection@jenner.com.

Client Alert: SEC’s Division of Corporation Finance Issues Guidance on Financial Reporting as a Result of the Ongoing Outbreak of COVID-19

On March 25, 2020, the SEC’s Division of Corporation Finance issued CF Disclosure Guidance Topic No. 9. The guidance reflects the current views of the Division of Corporation Finance, or the Division, in response to the ongoing outbreak of COVID-19. The Division emphasized the rapidly evolving and uncertain nature of the impact of COVID-19 and urged companies to provide timely disclosure that is responsive to the federal securities laws. To that end, the Division highlighted that disclosure of business risks and COVID-19-related effects may be necessary or appropriate in a variety of areas, such as management’s discussion and analysis, the business section, risk factors, legal proceedings, disclosure controls and procedures, internal control over financial reporting, and the financial statements.

To read the full article, please click here.

Related Capabilities

Related Locations

© 2026 Jenner & Block LLP. Attorney Advertising. Jenner & Block LLP is an Illinois Limited Liability Partnership including professional corporations. This publication, presentation, or event is not intended to provide legal advice but to provide information on legal matters and/or firm news of interest to our clients and colleagues. Readers or attendees should seek specific legal advice before taking any action with respect to matters mentioned in this publication or at this event. The attorney responsible for this communication is Brent E. Kidwell, Jenner & Block LLP, 353 N. Clark Street, Chicago, IL 60654-3456. Prior results do not guarantee a similar outcome. Jenner & Block London LLP, an affiliate of Jenner & Block LLP, is a limited liability partnership established under the laws of the State of Delaware, USA and is authorised and regulated by the Solicitors Regulation Authority with SRA number 615729. Information regarding the data we collect and the rights you have over your data can be found in our Privacy Notice. For further inquiries, please contact dataprotection@jenner.com.

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Associate Steven Arango to Speak at the Veterans' Legal Career Fair

On September 18, Associate Steven Arango will speak on a panel at the Veterans' Legal Career Fair (VLCF), the only legal career fair in the United States dedicated to veterans, active-duty service members, and military spouses.

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In American Banker, Partner Laurel Loomis Rimon Weighs in on OCC's Handling of Fintech Bank Charter Applications

Partner Laurel Loomis Rimon spoke with American Banker about how the Office of the Comptroller of the Currency is approaching bank charter applications from fintechs, amid a growing wave of companies seeking charters from federal regulators.

August 18, 2026

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Partner David Greenwald to Speak at PLI Program on Privilege and AI

On August 17, David Greenwald will speak at "Fitting New “Tech” Into the Attorney-Client Privilege and Work Product Protection," a virtual program hosted by the Practising Law Institute (PLI).

August 17, 2026