United States

SEC seeks comment on possible changes to Industry Guide 3


Industry Guide 3 (Statistical Disclosure by Bank Holding Companies) was first published in 1976 as a convenient reference to the statistical disclosures sought by the staff of the SEC’s Division of Corporation Finance in registration statement and other disclosure documents filed by bank holding companies. Since the last substantive revisions to Guide 3, the financial services industry has evolved significantly. Also, the SEC has issued disclosure requirements, and the Financial Accounting Standards Board has issued accounting standards that have changed the reporting obligations for all registrants generally. Consequently, the disclosure guidance in Industry Guide 3 may not in all cases reflect recent industry developments or changes in accounting standards related to financial and other reporting requirements.

Therefore, the SEC recently issued a Request for Comment on Possible Changes to Industry Guide 3 (Statistical Disclosure by Bank Holding Companies), which seeks public input on statistical and other disclosures provided by bank holding company registrants and covers the following:

  • Existing disclosure guidance for bank holding companies called for by Guide 3, as well as other sources of disclosure for bank holding companies and other registrants in the financial services industry
  • Potential improvements to the disclosure regime, which could include new disclosures, the elimination of duplicative or overlapping disclosures, or revisions to current disclosures
  • The scope and applicability of Guide 3
  • The effects of regulation on bank holding companies, including with regard to their operations, capital structures, dividend policies and treatment in bankruptcy