management's discussion and analysis (including overall performance and discussion of operations, known trends, events and uncertainties, liquidity and capital resources, debt covenants and risk-factor disclosure);

financial statements (including impairment of non-financial assets, going concern, significant judgments and measurement uncertainties, expected credit losses, fair value changes for the real estate industry, financial instrument and risk disclosures, government assistance and COVID-19-related amendments to IFRS 16 Leases for lessees); and

other regulatory requirements (including non-GAAP financial measures, forward- looking information, material change reporting and promotional disclosures).

the current and expected impact of COVID-19 on the issuer's operations and financial condition (including liquidity and capital resources);

the key risks that the COVID-19 pandemic presents to the issuer;

known trends, demands, events or uncertainties related to COVID-19 that management reasonably believes will materially affect the issuer's future revenues, expenses or projects;

the operational and other measures taken by management in response to COVID-19;

how COVID-19 has impacted the issuer's capacity to meet working-capital requirements, debt covenants, planned growth or funding of future development activities and capital expenditures;

how the COVID-19 pandemic has impacted areas of financial reporting subject to significant judgment and measurement uncertainty in the current environment;

how the issuer has assessed impairment of non-financial assets given the extended impact of the COVID-19 pandemic (where applicable, sensitivity analysis and disclosures relating to key assumptions will be especially important and should be both realistic and supportable); and

the accounting policy for (and nature and extent of) government grants in the financial statements.

many issuers provided "lists" of measures employed to manage operational and liquidity risks but did not provide an adequate discussion to address the anticipated impact to the issuer;

most issuers that quantitatively disclosed variances related to COVID-19 (for example, impact to sales) did not explain the methodology used by management in determining that fluctuations were isolated to COVID-19;

several issuers provided limited disclosure of known trends or events related to COVID-19 that are likely to affect future performance;

many issuers with material liquidity risks did not disclose in detail their ability to meet working capital requirements, planned growth initiatives or to fund developmental activities and capital expenditures (lack of disclosure regarding trends or expected fluctuations in liquidity taking into account events or uncertainties related to COVID-19 was commonly observed); and

several issuers provided "lists" of risks without discussion or general disclosures that touched on general economic or societal impacts of COVID-19 and did not describe entity-specific COVID-19-related risks.

some issuers failed to adequately update their disclosures and assumptions impacted by COVID-19 in the context of testing impairments of goodwill and intangible assets, measuring fair value and estimating credit losses;

some issuers failed to include entity-specific disclosure for significant judgments or measurement uncertainties or only included this disclosure in their management's discussion and analysis but not in their financial statements;

a few issuers did not identify reasons for impairments or just noted "negative economic impacts of COVID-19" as an impairment indicator for all cash-generating units but did not elaborate on those impacts;

some issuers breached financial covenants during the reporting period but did not disclose the implications of breaches on the issuer's ability to continue as a going concern (some issuers disclosed "close call" situations but did not disclose the mitigating actions that impacted their determination that there were no material uncertainties that cast significant doubt on the issuer's ability to continue as a going concern (for example, successful negotiation of credit facilities subsequent to period end));

over half of the issuers reviewed recognized (or disclosed in subsequent events) COVID-19-related government assistance in their financial statements since the outbreak of the COVID-19 pandemic (some issuers did not disclose the nature and extent of the government assistance or the accounting policy adopted, including the methods of presentation);

only a few issuers disclosed the use of COVID-19-induced adjustments/overlays to their expected credit losses (ECL) models;

some issuers that experienced material adverse impacts of COVID-19 did not provide an entity-specific update to their risk disclosure in the financial statements; and

certain issuers did not sufficiently disclose whether they applied the practical expedient to either some or all of their rent concessions in connection with COVID-19-related amendments to IFRS 16 Leases for lessees.

most issuers did not present non-GAAP financial measures that adjusted for the impact of COVID-19 (the CSA staff review found isolated instances of potentially misleading non-GAAP financial measures in relation to COVID-19 (for example, adjusting for expenses attributable to COVID-19 without adjusting for government subsidies or "normalizing" revenue or expenses for the year-to-date period based on more positive results for one quarter));

in certain cases CSA staff observed insufficient disclosure of assumptions used to develop forward-looking information and failure to adequately update the management's discussion and analysis for events and risks that could cause actual results for future period to differ materially from previously disclosed forward-looking information;

if COVID-19 has an equal effect throughout an issuer's industry, a material change report may not be required (only a few issuers reviewed filed material change reports in relation to COVID-19; although, in some instances, changes to the issuer's business, operations or capital were more unique or more significant to them than to others in their industry); and

some issuers concentrated in the biotech/pharma industry provided disclosure in relation to COVID-19 that was overly promotional and/or lacked specificity to fully address the issuer's business intentions and expected milestones.