Hot Topic  | October 2019

SEC proposes to streamline bank disclosures

SEC proposes to include disclosures into Reg S-K, reduce uncertainty about who must comply, and enhance comparability. This is the first substantive update to Guide 3 since 1986.

Applicability

SEC Release Nos. 33-10688; 34-86984; File No. S7-02-17

Public companies that are:

  • banks
  • bank holding companies
  • savings and loan associations and
  • savings and loan holding companies.

Relevant dates

  • Comments are due 60 days after the proposed rule is published in the Federal Register.

Key impacts

The proposed changes would accomplish the following:

  • codify the proposed disclosure requirements into a new subpart 1400 of Reg S-K.
  • limit the scope to banks, bank holding companies, savings and loan associations, and savings and loan holding companies.
  • create a term, ‘reporting period’, to mean each period required by the SEC rules for a registrant’s financial statements.

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