The bar for disclosure is quite low, and is not dependent on quarterly cycles.
> On May 16, 2022, Coinbase Global, Inc. (“Coinbase” or the “Company”) issued a blog post (the “Blog Post”) relating to its hiring plans. In connection with the Blog Post, Coinbase affirmed its expense outlook for the second quarter of 2022 and full year 2022 that the Company provided on May 10, 2022 in a letter to its shareholders announcing its financial results for the quarter ended March 31, 2022. A copy of the Blog Post is furnished as Exhibit 99.1 to this Current Report on Form 8-K.
> Coinbase announces material information to its investors using filings with the Securities and Exchange Commission, the Company’s website at www.coinbase.com and blog.coinbase.com, as well as press releases, public conference calls, public webcasts, its Twitter feed (@coinbase), its Facebook page, its LinkedIn page, its YouTube channel, and Brian Armstrong’s Twitter feed (@brian_armstrong). Therefore, Coinbase encourages investors, the media and others interested in the Company to review the information it makes public in these locations, as such information could be deemed to be material information.
> The information in Item 7.01 of this Current Report on Form 8-K, including Exhibit 99.1, is being furnished and shall not be deemed “filed” for the purposes of Section 18 of the Securities Exchange Act of 1934, as amended (the “Exchange Act”), or otherwise subject to the liability of such section or incorporated by reference in any filing under the Securities Act of 1933, as amended, or the Exchange Act, except as shall be expressly set forth by specific reference in such a filing.
So whether or not they were required to communicate the slowdown, they did at least consider the post to be material information that needed to be communicated with investors.