Hot Topic | May 2022

 

Insight

Impact of the Russia-Ukraine war on SEC disclosures

SEC publishes sample comment letter and KPMG discusses certain disclosures that may be impacted by the Russia-Ukraine war.


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.

Applicability

New: Sample letter to companies regarding disclosures pertaining to Russia’s invasion of Ukraine and related supply chain issues.

  • SEC issuers required to present MD&A
  • SEC issuers presenting forward-looking information
  • SEC issuers presenting non-GAAP financial measures

Relevant dates

  • Effective immediately

Key impacts

This Hot Topic addresses:

  • Assessing and disclosing impacts to operations, liquidity and capital resources.
  • Assessing and disclosing the evolving impact of the war, including forward-looking information.
  • Non-GAAP financial measures.

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:

  • General disclosures
  • Risks related to cybersecurity
  • MD&A
  • Non-GAAP financial measures
  • Disclosure controls and procedures
  • Internal control over financial reporting

Related content


External resources

Subscribe to our newsletter

Receive timely updates on accounting and financial reporting topics from KPMG.

Receive timely updates on accounting and financial reporting topics from KPMG.

ARO

Use our Accounting Research Online for financial reporting resources.

Use our Accounting Research Online for financial reporting resources.