Hot Topic | July 2020
Insight
Applicability
- Public companies, investment companies and other market participants affected by COVID-19
Key impacts
On June 26, 2020, leaders from various divisions of the SEC issued a joint public statement summarizing and updating the COVID-19 temporary relief and assistance provided by the Commission and staff. The SEC has remained fully functioning throughout the pandemic and stated it will continue to assess the need for further regulatory action, including appropriate, targeted relief during times of operational challenges and market volatility as the pandemic continues.
The following table summarizes the SEC’s regulatory actions, targeted relief and assistance, including updates made by the Commission in this cross-divisional statement based on recent developments, current conditions and expectations.
Relevant dates
Division of Corporation Finance
| Currently effective | Effective/Expiration dates |
|---|---|
Facilitating capital formation for small businesses |
August 31, 2020 |
Forms 144 and other paper submissions |
Effective until further notice |
Authentication and retention requirements of Rule 302(b) of Reg S-T |
Effective until further notice |
Conducting shareholder meetings |
Available; limited use expected |
Proxy material delivery accommodation |
Available; limited use expected |
| Expired | |
Additional time to file public company reports |
July 1, 2020 |
Additional time to file Reg A and Reg Crowdfunding reports |
May 31, 2020 |
Division of Investment Management
| Currently effective | Effective/Expiration dates |
|---|---|
Form N-23C-2 (advance notice by registered closed-end funds and business development companies (BDCs) to call or redeem securities) |
August 15, 2020 |
Term asset-backed securities loan facility (TALF 2020) no-action letter |
September 30, 2020 |
Temporary regulatory flexibility to assist BDCs in fulfilling their statutory mandate |
The earlier of December 31, 2020 and the date the BDC ceases to rely on conditional exemptive order |
In-person board meetings |
Effective until further notice, but not earlier than December 31, 2020. |
International mail service suspensions to certain jurisdictions |
When mail delivery service by jurisdiction’s common carrier is resumed |
Short-term funding flexibility for open-end funds and separate accounts |
Effective until further notice |
Affiliated purchases of debt securities in light of market dislocation no-action letters |
Effective until further notice |
Authentication and retention requirements of Rule 302(b) of Reg S-T |
Effective until further notice |
Conducting shareholder meetings |
Available; limited use expected |
| Expired | |
Prospectus delivery |
June 30, 2020 |
Transmittal of annual and semi-annual reports |
June 30, 2020 |
Form N-CEN (annual report for registered investment companies) and Form N-PORT (monthly portfolio investments report) |
June 30, 2020 |
Form ADV and Form ADV Part 1A Reports |
June 30, 2020 |
Form ADV Part 2 Brochures, Brochure Supplements, and Summary of Material Changes |
June 30, 2020 |
Form PF |
June 30, 2020 |
Division of Trading and Markets
| Currently effective | Effective/Expiration dates |
|---|---|
Extension of certain deadlines under Rule 606 of Regulation NMS:
|
July 29, 2020
|
Certain COVID-19 related FINRA guidance and relief |
July 31, 2020 |
TALF 2020 Order |
September 30, 2020 |
Conditional relief to municipal advisors |
December 31, 2020 |
Relief relating to the broker-dealer financial responsibility rules:
|
December 31, 2020
|
Facilitating the continued and orderly operation of national securities exchanges |
When exchanges resume normal floor trading operations |
International mail service suspensions to certain jurisdictions |
When mail delivery service by jurisdiction’s common carrier is resumed |
Registered transfer agent relief |
Effective until further notice |
Relief from fingerprinting requirements |
Effective until further notice |
Paper submissions, manual signatures and notarization requirements |
Effective until further notice |
Authentication and retention requirements of Rule 302(b) of Reg S-T |
Effective until further notice |
Consolidated audit trail (CAT) reporting deadlines |
Phased reporting timeline consistent with the February 19, 2020 exemptive request |
| Expired | |
Extension of certain deadlines under Rule 606 of Regulation NMS: |
|
|
May 29, 2020 |
|
June 1, 2020 |
Relief relating to the broker-dealer financial responsibility rules: |
|
|
June 30, 2020 |
Other
| Currently effective | Effective/Expiration dates |
|---|---|
Pending administrative proceedings |
Effective until further notice |
| Expired | |
Exemption from certain requirements of the Exchange Act for municipal advisors |
June 30, 2020 |
Relief for Form ID filers, and Reg Crowdfunding and Reg A issuers |
July 1, 2020 |
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