Based on data from Audit Analytics, the WSJ reported in “SEC Presses Some Companies for Details on Russia-Linked Losses, Risk” that the SEC has sent at least 39 comment letters to 16 companies between March 9 and July 22 concerning their Russia/Ukraine war-related disclosures and requesting additional disclosures in future filings about the implications of the conflict on their business and financial performance. As previously reported, in May, the SEC Division of Corporation Finance issued guidance to companies, inclusive of an illustrative letter with sample comments, regarding their disclosure about the impacts on their business associated with Russia’s invasion of Ukraine and related supply chain issues.
Bass Berry Capital Markets Subgroup head and Society member Jay Knight, who was interviewed for the article, commented: “The letters remind companies to consider how current events might affect their results and financial condition. There’s just more exposure in helping to identify the trends and drivers of results. For companies, sometimes it’s very challenging to quantitatively figure out the financial impact of things like that.”
See NACD BoardTalk’s “Increasing Geopolitical Risks Raise Disclosure Issues”; our prior reports: “Russia/Ukraine Conflict: SEC Filing Disclosure,” “Financial Reporting Implications of Russia/Ukraine Conflict,” “Russia – Ukraine Conflict: Regulatory & Other Risks,” “Financial Reporting Implications of Russia/Ukraine Conflict,” and “Russia – Ukraine: SEC Comment Letters”; and additional resources on our Geopolitical Risk page.
This post first appeared in the weekly Society Alert!