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Key Considerations for the 2021 Reporting Season | Troutman Pepper

9. Proxy Advisory Firm Voting Policy Updates. 10. Diversity Considerations. 12. Hedging Disclosure Requirements Now Applicable to Smaller Reporting Companies and Emerging Growth Companies. A. COVID- 19 1. SEC’s COVID-19 Supplemental Guidance Reinforces Importance of High-Quality Financial Reporting. On June 23, 2020, the SEC’s Division of Corporation Finance (the Division) released CF Disclosure Guidance: Topic No. 9A (the Supplemental Guidance), which supplements CF Disclosure Guidance Topic No. 9 (the Original Guidance). The Supplemental Guidance provided the Division’s additional views regarding operations, liquidity, and capital resources disclosures that companies should consider with respect to business and market disruptions due to COVID-19. In the Supplemental Guidance, the Division reiterated that it will continue to monitor companies’ disclosures of the impacts and risks of the ongoing COVID-19 pandemic on their businesses, financial condition, and results of o

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