Waller October 14, 2020 - Tennessee SEC Updates and Modernizes Statistical Disclosures for Financial Institutions by Wes Scott, Kevin Tran The Securities and Exchange Commission (SEC) recently adopted rules to update the statistical disclosures that bank holding companies, banks, savings and loan holding companies, and savings and loan associations (Financial Institutions) provide to the market. The rules will eliminate Guide 3 and will replace it with new Subpart 1400 of Regulation S-K. The rules primarily streamline former Guide 3 disclosures and eliminate disclosures that overlap with SEC rules and U.S. generally accepted accounting principles (GAAP) but, importantly, do not add substantial new disclosure requirements. Financial Institutions will be required to apply the final rules for the first fiscal year ending on or after December 15, 2021. Financial Institutions that file initial registration statements are not required to apply the final rules until making a filing containing financial statements for a period on or after December 15, 2021. Voluntary compliance with the new rules is permitted in advance of the mandatory compliance date as long as the final rules are applied in their entirety. Below are summaries of the major changes: Click here for a full-color, printable PDF of the summary table below. Applicability, Reporting Periods, Locations, Regulation S-X and Daily Averages Applicability
Reporting Periods
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