September 24, 2020

SEC Amends Requirements for Statistical Disclosures for Bank and Savings and Loan Registrants, Formerly Guide 3



On September 11, 2020, the U.S. Securities and Exchange Commission (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.

During this GFM call, partners Anna Pinedo and Jerry Marlatt will 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. 

Mayer Brown’s Global Financial Markets initiative helps clients deal with the legal and business challenges resulting from the ongoing turbulence in worldwide financial markets. By mobilizing the firm’s global resources from multiple practices and offices, the initiative provides clients with knowledgeable and timely counsel on a broad spectrum of their legal needs.

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