On September 11, 2020, the U.S. SEC adopted amendments to the requirements for statistical disclosures that bank and savings and loan registrants provide to investors. The rules rescind Industry Guide 3, Statistical Disclosure by Bank Holding Companies (Guide 3); codify certain Guide 3 disclosures into a new Subpart 1400 of Regulation S-K; eliminate other Guide 3 disclosures that overlap with other SEC disclosure requirements, U.S. Generally Accepted Accounting Principles (GAAP) or International Financial Reporting Standards (IFRS); and add certain credit ratio disclosure requirements. According to the SEC, the rules aim to streamline compliance efforts and decrease reporting burdens for registrants and to enhance comparability among issuers.

Listen to the teleconference here, in which partners Anna Pinedo and Jerry Marlatt discuss:

  • Industry Guide 3,
  • The SEC’s 2016 Concept Release and the proposed rules,
  • New Subpart 1400 of Regulation S-K,
  • The applicability of the amendments,
  • The principal changes from Guide 3,
  • The new requirements, and
  • The effective date of the amendments.