The US Securities and Exchange Commission (“SEC”) recently announced1 that it will not take final action before April 24, 2020, regarding the following five proposed actions, which have comment periods expiring in March, to allow commenters additional time to submit comments. The SEC is concerned that “challenges associated with COVID-19 may delay the completion and submission of some comment letters.” That said, the SEC encouraged market participants to submit comments within “the most reasonable possible timeframe.”

  • Use of Derivatives by Registered Investment Companies and Business Development Companies; Required Due Diligence by Broker-Dealers and Registered Investment Advisers Regarding Retail Customers’ Transactions in Certain Leveraged/Inverse Investment Vehicles, File No. File No: S7-24-15, Release Nos.: 34-87607, IA-5413, IC-33704;
  • Amendments to Rule 2-01, Qualifications of Accountants, File No: S7-26-19, Release Nos.: 33-10738, 34-87864, FR-86, IA-5422, IC-33737;
  • Amending the “Accredited Investor” Definition, File No: S7-25-19, Release Nos.: 33-10734, 34-87784;
  • Disclosure of Payments by Resource Extraction Issuers, File No: S7-24-19, Release No. 34-87783; and
  • Notice of Proposed Order Directing the Exchanges and the Financial Industry Regulatory Authority to Submit a New National Market System Plan Regarding Consolidated Equity Market Data, File No. 4-757, Release No. 34-88340.

The SEC and its staff generally will consider comments submitted after a comment period closes but before adoption of a final rule or order, based on informal procedures.

The SEC could make adjustments to the list above as needed.

If you have any questions about this SEC announcement, or about the SEC’s or its staff’s responses to COVID-19 more generally, please contact Leslie Cruz or Stephanie Monaco. We will continue to keep our clients updated on any future significant SEC or staff announcements regarding COVID-19.

This SEC announcement is part of an evolving COVID-19 response that is moving across regulatory agencies. Please visit our website to learn more.


1 See the “Comment Periods for Certain Pending Actions” section on the SEC’s COVID-19 webpage at