SEC Staff Issues C&DIs on Exchange Act Forms
April 7, 2020
The staff in the SEC’s Division of Corporation Finance has updated its compliance and disclosure interpretations (C&DIs) related
to the SEC’s recent order granting a 45-day
extension to file certain disclosure reports as a result of COVID-19.
Specifically, the SEC has added Questions 104.18 and 112.02 to its C&DIs on Exchange Act forms. The C&DIs
are related to multijurisdictional disclosure system filers and domestic registrants
that have elected to file part III of Form 10-K in proxy statements that would be
filed within 120 days of year-end.