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Division of Corporation Finance Statement Regarding Requirements for Certain Paper Documents (other than Forms 144) in Light of COVID-19 Concerns

June 25, 2020

The staff of the Division of Corporation Finance is aware of logistical difficulties submitting certain forms (other than Forms 144)[1] in paper given the spread of coronavirus disease 2019 (COVID-19).  In light of ongoing health and safety concerns related to COVID-19, the staff is providing the following statement to those affected by COVID-19 regarding the forms listed below. This staff statement is temporary and covers those who submit the following forms until the staff provides public notice that it no longer will be in effect; that notice will be published at least two weeks before the announced termination date.[2]

  • Annual reports to security holders furnished by foreign private issuers on Form 6-K pursuant to Rule 101(b)(1) of Regulation S-T;
  • Forms 11-K pursuant to Rule 101(b)(3) of Regulation S-T;
  • Periodic reports and distribution reports filed by certain international development banks pursuant to Rule 101(b)(5) of Regulation S-T;
  • Reports or other documents furnished by foreign private issuers on Form 6–K pursuant to Rule 101(b)(6) of Regulation S-T; and
  • Unabridged foreign language documents and English translations of a foreign government’s or its political subdivision’s latest annual budget pursuant to Rules 306(b) and (c) of Regulation S-T.

Division of Corporation Finance staff will not recommend enforcement action to the Commission if the above documents are submitted via email in lieu of mailing or delivering the paper document to the SEC if the filer attaches a complete document, including any required exhibits, as PDF attachments to an email sent to

If the filer is unable to provide a manual signature on a document submitted by email, the staff will not recommend enforcement action to the Commission if the filer provides a typed form of signature in lieu of the manual signature and:

  • the signatory retains a manually signed signature page or other document authenticating, acknowledging, or otherwise adopting his or her signature that appears in typed form within the email submission and provides such document, as promptly as practicable, upon request by Division or other Commission staff;
  • such document indicates the date and time when the signature was executed; and
  • the filer establishes and maintains policies and procedures governing this process.

Filers may continue to submit these documents to the SEC mailroom.  There may, however, be delays in the processing of such documents.

We remind all signatories of the penalties for false and misleading statements under, among other things, 15 U.S.C. 78ff(a).


[1] See June 25, 2020 Division of Corporation Finance Statement Regarding Requirements for Form 144 Paper Filings in Light of COVID-19 Concerns.

[2] This statement represents the views of the staff of the Division of Corporation Finance.  It is not a rule, regulation, or statement of the Securities and Exchange Commission (“Commission”).  The Commission has neither approved nor disapproved of its content.  This statement, like all staff statements, has no legal force or effect; it does not alter or amend applicable law, and it creates no new or additional obligations for any person.

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