SEC Proposes Rules to Update Statistical Disclosure Requirements for Banking Registrants: Proposed Rules Would Continue the SEC’s Efforts to Eliminate Disclosure Requirements that Overlap With Other SEC Rules and Accounting Standards by Replacing Industry Guide 3 With Updated Disclosure Rules in a New Subpart of Regulation S-K

Sullivan & Cromwell LLP - September 24, 2019

On September 17, 2019, the Securities and Exchange Commission proposed rules to update the statistical disclosures that bank holding companies, banks, savings and loan holding companies, and savings and loan associations provide to investors in accordance with Industry Guide 3, Statistical Disclosures by Bank Holding Companies. Under the proposal, Guide 3 would be rescinded and replaced with a new Subpart 1400 of Regulation S-K. The proposed rules would codify certain Guide 3 disclosures and eliminate disclosures that overlap with SEC rules, U.S. GAAP or International Financial Reporting Standards.