On 8 April 2020, SEC detailed disclosures key for markets, in Covid.
- Chair Clayton statement on importance of disclosure, fight against pandemic, facilitate engagement to mitigate economic contraction, evolve strategies, address challenges.
Firm Disclosures
- Respond to investor interest firm's currrent operational, financial status.
- Response to Covid, progress to protect health, well-being of workforce, clients, how ops, financial condition may change as fight continues; future conditions, resources.
- High-quality disclosure to benefit investor, firms but also enhance key communication, coordination across economy, between public, private sectors as Covid fight pursued.
- Transparency to foster confidence in all stakeholders, firms encouraged to respond to call for forward-looking disclosure, avail of safe-harbors for such statements.
- Note good faith attempts to provide properly framed forward-info not be 2nd-guessed.
Highlights
- SEC actions focused on market integrity, function, guidance, relief, investor interests.
- Broad support from constituents for mitigating step taken despite huge economic cost.
- Recognition of need for transition to forward-looking, health, welfare strategies.
- In light of highly integrated economy, challenges but combine dramatic health-focused mitigation efforts with monetary, fiscal intervention evolve over long term, corrections.
- Framework for forward-looking health, welfare strategies to address Covid, develop more tools to fight it with increased testing, enhanced monitoring, data analysis, ID.
- Accept effective therapeutics anchored by advice of healthcare specialist, tailor efforts.
- Key to continue target fiscal assistance of CARES Act, efforts on workers, businesses constrained by health, safety directives, adjust operational norms to ensure safety.
- Extensive coordination between public, private sectors essential for success in fight.
- Nimble coordinated health, economic strategy to affect outcome, isolated effort to fail.
Q1 Earnings Reports
- Statements, calls to come will not be routine, since historical projections not as great interest as forward plans, where firm is today, how they adjusted, expect to in future.
- Challenges in producing detailed reports understood, SEC to be practicable, mindful.
- Firms urged to disclose as much info as practicable on current status, plans to address Covid, operating capability, future operating plans, liquidity positions, financial needs.
- Recognize challenge of forward-looking disclosure, believe taking on challenge is right.