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COVID-19 is presenting challenges for many companies. To address these challenges, many regulators/agencies have issued orders, releases and statements which allow, subject to certain conditions, companies to take advantage of any applicable relief. Companies need to ensure they meet all applicable criteria and are in compliance with the requirements outlined below, as in many cases, extensions are not automatic.
The following is a list of regulatory reliefs as of March 29, 2020. Please check back regularly, as regulators are making announcements frequently.
- Conditional Regulatory Relief for Registered Transfer Agents and Certain Other Persons Affected by the Coronavirus Disease 2019 (COVID-19) – extensions through May 30, 2020. Additional Details
- CorpFin has also issued guidance (see link below) providing the staff’s current view regarding disclosure obligations that registrant’s should consider. The guidance encourages timely reporting while recognizing that it may be difficult to assess or predict with precision the broad effects of COVID-19 on industries or individual companies. Additional Details
- Conditional regulatory relief has been added for Regulation A and Regulation Crowdfunding issuers. The rules provide, subject to certain conditions, affected companies with an additional 45 days to file certain disclosure reports that would otherwise have been due between March 26, 2020 and May 31, 2020. Additional Details
- Conditional Regulatory Relief and Assistance for Companies Affected by the Coronavirus Disease 2019 (COVID-19) provides publicly traded companies with an additional 45 days to file certain disclosure reports that would otherwise have been due between March 1 and July 1, 2020. Utilizing the relief requires a registrant to file an 8-K or 6-K with specified information required. Additional Details
- The Federal financial institution regulatory agencies and the state banking regulators issued an interagency statement encouraging financial institutions to work constructively with borrowers affected by COVID-19 and providing additional information regarding loan modifications. The agencies encourage financial institutions to work with borrowers, will not criticize institutions for doing so in a safe and sound manner, and will not direct supervised institutions to automatically categorize loan modifications as troubled debt restructurings (TDRs). Additional Details
SINGLE AUDIT REPORTING
- Delay the completion and submission of the Single Audit reporting package, as required under Subpart F of 2 CFR § 200.501Audit Requirements, to six (6) months beyond the normal due date. No further action by awarding agencies is required to enact this extension. Additional Details
- HUD announced a blanket 30-day extension for the filing of all REAC financial statements. That extension is automatic and does not require any action by the project. However, REAC has clarified that the extension DOES NOT EXTEND THE 60-day RESIDUAL RECEIPTS deposit requirement. Additional Details
Assistance and Guidance from Freed Maxick
The Freed Maxick COVID-19 Resource Center has a wealth of information and guidance on a wide range of topics related to tax relief and benefits, regulatory relief and benefits, and business continuity in the era of COVID-19. Click on the button to explore insights, observations and updates.
If you wish additional guidance, we are available to discuss your issues and concerns. Connect with us here or call Freed Maxick at 716.847.2651.
Please keep in mind that due to the quickly-changing nature of the COVID-19 pandemic, you should always discuss changes with your Freed Maxick advisor or legal counsel.