COVID-19 CLIENT MEMO FOR FINANCIAL REPORTING CONSIDERATIONS
You have asked us for assistance in identifying financial reporting considerations related to the risks and uncertainties associated with the Coronavirus (COVID-19) epidemic. COVID-19 has begun to cause significant disruption in the global economy. The ripple effect is far-reaching across multiple industries, including travel and hotel companies, airline companies, manufacturers, and companies in the supply chain. Companies have begun issuing warnings that revenues may be adversely affected by the virus, and early warnings are important to investors; however, the challenges posed by this virus are unprecedented, and the scope and downstream effects are still unknown. Given the uncertainty of the current environment, reporting entities must balance the accuracy of the information available against the need to provide appropriate, adequate disclosure for investors.
Here are some considerations to keep top of mind while preparing financial statements:
Geographic concentration of business operations. An entity will need to evaluate the extent to which it relies on operations in countries outside the US, especially China, South Korea, Italy, or other areas of the world with confirmed spread of COVID-19. An entity that has business operations in these countries will need to evaluate the risk of a material disruption, which may have to be reported in the 10-K under Item 1A. Risk Factors. These effects may also lead an entity to restructure its operations, which could lead to changes in its business segments under Topic 280, Segment Reporting.
Subsequent events. COVID-19 was first identified in December 2019, so the entity will have to determine what disclosures are required under Topic 855, Subsequent Events, based on the entity’s individual facts and circumstances. It may be necessary to provide additional disclosures or even adjusted financial statements.
Volatility. Asset valuations may be adversely impacted by the uncertainty in the financial markets. This could result in unanticipated losses, which may or may not be unrealized. The entity will have to ensure valuations are correct as of the reporting date, which can be challenging in a highly volatile market.
Credit risk. Entities will have to monitor changes in their customers’ credit risk and decide if credit impairments or loan write-offs are necessary.
Liquidity risk. Entities will have assessed their ability to meet short-term obligations. Expanded liquidity disclosures may be necessary.
Pension and other postretirement plans. Entities will have to monitor pensions and other postretirement plans for potential changes to the funded status.
Hedging. The entity may need to reevaluate its hedging strategies and examine its hedges to determine the extent of hedge ineffectiveness, which must be recorded in earnings. If a hedge is no longer highly effective, then hedge accounting under Topic 815, Derivatives and Hedging, can no longer be applied.
SEC guidance and expectations. In a public statement issued January 30, 2020, Chairman of the SEC Jay Clayton said that the SEC will be monitoring disclosures related to COVID-19. Acknowledging that the effects of COVID-19 are beyond the control of issuers, Mr. Clayton said that issuers can still disclose how they are planning for uncertainty and how they will respond to the unfolding epidemic, which could be material to investors.
Entities have already begun to include information related to the Coronavirus in their 10-K filings:
Norwegian Cruise Line Holdings disclosed the following in Item 1A – Risk Factors of its 10-K for the period ended December 31, 2019:
Public perception about the safety of travel and adverse publicity related to passenger or crew illness, such as incidents of viral illnesses, stomach flu or other contagious diseases may impact demand for cruises and result in cruise cancellations and employee absenteeism. For example, the recent outbreak of the COVID-19 coronavirus has resulted in costs and lost revenue related to customer compensation, itinerary modifications, travel restrictions and advisories, the unavailability of ports and/or destinations, cancellations and redeployments and has impacted consumer sentiment regarding cruise travel. The spread of the COVID-19 coronavirus, particularly in North America, could exacerbate its effect on us. Any future wide-ranging health scares would also likely adversely affect our business, financial condition and results of operations.
United Airlines, Inc. disclosed the following regarding the risks from the Coronavirus in item 1A – Risk Factors and in Note 16 – Subsequent Events of its 10-K for the period ending December 31, 2019:
In December 2019, a novel strain of coronavirus (“COVID-19”) was reported in Wuhan, China. The World Health Organization has declared COVID-19 to constitute a “Public Health Emergency of International Concern.” On January 30, 2020, the U.S. Department of State issued a Level 4 “do not travel” advisory for China. The U.S. government has also implemented enhanced screenings, quarantine requirements and travel restrictions in connection with the COVID-19 outbreak. The Company has suspended its flights between the United States and each of Beijing, Chengdu, Shanghai and Hong Kong through April 24, 2020. These routes represented approximately 5% of the Company’s 2020 planned capacity and the Company’s other trans-Pacific routes represented an additional 10% of the Company’s 2020 planned capacity. As of the date of this report, the Company is experiencing an approximately 100% decline in near-term demand to China and an approximately 75% decline in near-term demand on the rest of the Company’s trans-Pacific routes. The extent of the impact of the COVID-19 on the Company’s operational and financial performance will depend on future developments, including the duration and spread of the outbreak and related travel advisories and restrictions and the impact of the COVID-19 on overall demand for air travel, all of which are highly uncertain and cannot be predicted. If traffic on the Company’s trans-Pacific routes were to remain at these levels for an extended period, and/or routes in other parts of the Company’s network begin to see significant declines in demand, our results of operations for full year 2020 may be materially adversely affected.
Of course, you must evaluate the effects of the Coronavirus on your own business based on your unique facts and circumstances and tailor your disclosures accordingly. If you have any questions or concerns – Please email us direct at firstname.lastname@example.org or email@example.com