In this Hot Topic, we discuss how previous disclosure guidance from the staff of the SEC’s Division of Corporation Finance applies to impacts from the Russia-Ukraine war. Additionally, the Division of Corporation Finance published a sample comment letter highlighting areas of focus related to the Russia-Ukraine war. Companies should consider the staff’s questions and scenarios when preparing their quarter and year-end reports.
New: Sample letter to companies regarding disclosures pertaining to Russia’s invasion of Ukraine and related supply chain issues.
This Hot Topic addresses:
Additionally, the Division of Corporation Finance published a sample letter with comments that the Division may issue to companies related to the impact of the Russia-Ukraine war. While not an exhaustive list, we recommend that companies use the questions in the sample letter to assess planned disclosures.
Topics covered in the sample letter include: