The SEC's Division of Corporation Finance has just issued CF Disclosure Guidance: Topic No. 9. This "guidance provides the Division of Corporation Finance’s current views regarding disclosure and other securities law obligations that companies should consider with respect to the coronavirus disease 2019 (COVID-19) and related business and market disruptions." While related to public companies, the questions are great - and certainly helpful to inform due diligence questions when thinking about asset managers.
We have extracted and condensed the SEC's guidance below.
"The impact of COVID-19 on companies is evolving rapidly and its future effects are uncertain. The Division is monitoring how companies are reporting the effects and risks of COVID-19 on their businesses, financial condition, and results of operations.
The Division encourages timely reporting while recognizing that it may be difficult to assess or predict with precision the broad effects of COVID-19 on industries or individual companies. We also recognize that the actual impact will depend on many factors beyond a company’s control and knowledge. Nevertheless, the effects COVID-19 has had on a company, what management expects its future impact will be, how management is responding to evolving events, and how it is planning for COVID-19-related uncertainties can be material to investment decisions.
(Couldn't agree more! Then - the SEC has the following questions:)
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