Securities Regulation and Corporate Governance


Securities Regulation and Corporate Governance > Posts > Disclosure Considerations: One Month Into the U.S. Outbreak
Disclosure Considerations: One Month Into the U.S. Outbreak

​The COVID‐19 outbreak is creating a great deal of uncertainty in the global economy and in our daily lives. Companies worldwide are facing unique legal and operational challenges related to the outbreak and the downturn in the economy. In the midst of this constantly evolving landscape, U.S. publicly traded companies must continue to consider how the situation impacts their disclosure.

One month into the outbreak in the United States, Gibson Dunn has been tracking disclosure among public companies as practices develop. We have prepared an alert for our clients and friends that provides observations and guidance for companies preparing disclosure in areas that are influenced by the COVID-19 outbreak. 

This client alert is intended to serve only as a starting point for appropriate analysis, and each company’s disclosure should be tailored to its particular circumstances. Given the rapidly changing landscape, disclosure should be assessed and, if necessary, revised shortly before it is made. We encourage you to reach out to Gibson Dunn’s Securities Regulation and Corporate Governance and Capital Markets teams to discuss specific questions as they arise.

Significant areas of disclosure that public companies should continuously consider during the course of the COVID-19 outbreak include the following:

  • SEC Guidance and Questions to Ask
  • Earnings Guidance
  • Disclosure in Periodic Reports
  • Non-GAAP Supplemental Measures
  • Forward-Looking Statement Disclaimers
  • Regulation FD and Insider Trading Laws
  • Capital Markets Disclosure
  • Form 8-K Triggers

With this framework in mind, we hope you find our obversations and recommendations helpful. Access the client alert at the link below.

 ‭(Hidden)‬ Blog Tools

© Copyright 2019 Gibson, Dunn & Crutcher LLP.
Attorney Advertising. Prior results do not guarantee a similar outcome. All information provided on this site is for informational purposes only, does not constitute legal advice, is not confidential, and does not create an attorney-client relationship. Statements and content posted to this site do not represent the opinion of Gibson Dunn & Crutcher LLP ("Gibson Dunn"). Gibson Dunn makes no representations as to the accuracy, completeness, currentness, suitability, or validity of any information on this site and will not be liable for any errors or omissions therein, nor for any losses, injuries, or damages arising from its display or use.