United States: SEC Amends Requirements For Statistical Disclosures For Bank And Savings And Loan Registrants, Formerly Guide 3

On September 11, 2020, the 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. The changes also form part of the SEC's Division of Corporation Finance's ("CorpFin") disclosure effectiveness initiative. These changes will affect the annual reports and the registration statements of issuers of structured products in the United States and, therefore, may be of interest to our readers.

Originally published in REVERSEinquiries: Volume 3, Issue 8.
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