SEC enforcement and litigation risks amid the COVID-19 pandemic

Hogan Lovells
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In recent weeks, the Co-Directors of the SEC's Enforcement Division warned of the "importance of maintaining market integrity" in these uncertain times. Specifically, they urged public companies to be mindful of Regulation FD and insider trading laws, as rapidly changing market conditions could heighten the risks of violating such laws. Also, on 8 April 2020, the SEC Chairman and Director of Corporation Finance encouraged companies to make robust forwardlooking disclosures, in part, to provide the investing public access to high-quality financial information, even if some projections might have to be "update[d] and supplement[ed]" at a later date.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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