COVID-19 SEC Reporting Considerations

Due to the ongoing COVID-19 outbreak, the SEC has provided public companies an option to apply for a 45-day extension for filings due from March 1, 2020 through April 30, 2020.

While this relief does not apply to most accelerated filer, the SEC has left open the possibility of an extension. Companies should continue to monitor the developments in this area if they believe their Q1 2020 close process may be significantly impacted as a result of COVID-19.

In order to qualify for relief, you must meet the following conditions:

• Registrant is unable to meet filing deadline due to circumstances related to COVID-19

• Registrant is required to file Form 8-K be either March 16 or original filing deadline (whichever is later) which includes the following: 1. Reliance on the relief order; 2. Description of reasons why it could not file timely; and 3. Estimated date by which it expects to file.

• Risk factors, if material, explaining the impact of COVID-19 on its business; and

• If reason is due to a third party, attach a statement signed by such party stating the specific reasons for the delay.

Filing needs to be completed no later than 45 days after the original due date.