SEC Staff Issues C&DIs on Exchange Act Forms

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.