Hot Topic | October 2020



SEC finalizes rule to streamline bank disclosures

KPMG reports on changes made to Guide 3 in a new subpart of 1400 Regulation S-K.

Tim Phelps

Tim Phelps

Partner, Dept. of Professional Practice, KPMG US

+1 212 872 3249

The final rule updates and expands the statistical disclosures under Guide 3 that bank and savings and loan registrants provide to investors and further eliminates certain disclosure requirements that are duplicative of other SEC rules and requirements of US GAAP or IFRS.


  • The final rule will apply to banks and savings and loan registrants.

Relevant dates

  • The rule is effective for fiscal years beginning on or after December 15, 2021
  • Early adoption allowed

Key impacts

Since the last substantive revision to Guide 3 in 1986, the SEC has adopted disclosure requirements, and the FASB and the International Accounting Standards Board have issued accounting standards that have changed the financial reporting obligations for registrants engaged in material lending and deposit activities.

The new rule:

  • Codifies certain elements of Guide 3 into a new subpart 1400 of Regulation S-K.
  • Defines the term ‘reporting period’ to mean each annual period required by the SEC rules for a registrant’s financial statements.
  • Introduces new credit ratio disclosures and disclosure about bank deposits including uninsured amounts.
  • Eliminates certain disclosures over:
    • Issuer concentration
    • Investment portfolio values
    • Loans by type
    • Loan loss exposures
    • Loan portfolio risk elements
    • Interest-bearing assets
    • Return on equity and asset disclosures.

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