United States

Updated disclosures for bank and savings and loan registrants


As part of its Disclosure Effectiveness Initiative, the SEC recently issued Final Rule 33-10835, Update of Statistical Disclosures for Bank and Savings and Loan Registrants. The new rules codify updated disclosure requirements in new Subpart 1400 of Regulation S-K, replacing Industry Guide 3, Statistical Disclosure by Bank Holding Companies. The SEC’s rules reflect new accounting standards that have been issued since the SEC last updated Industry Guide 3 and codify or modify certain Guide 3 disclosures, while eliminating disclosures that overlap with SEC rules, U.S. generally accepted accounting principles or International Financial Reporting Standards.

The new rules apply to banks, bank holding companies, savings and loan associations, and savings and loan holding companies. The rules reduce the required reporting periods to align them with the relevant financial statement periods required by SEC rules. Disclosures are required for each annual period presented, and any interim period subsequent to the most recent fiscal year end if a material change in the information, or trend evidenced thereby, has occurred. The rules require disclosures about the following topics:

  • Distribution of assets, liabilities and stockholders’ equity, the related interest income and expense, interest rates and interest differential
  • Weighted average yield of each maturity category of debt securities not carried at fair value through earnings for which disclosure is required in the financial statements
  • Maturity analysis of the loan portfolio, including the amounts that have predetermined interest rates and floating or adjustable interest rates
  • Certain credit ratios (and the factors that explain material changes in the ratios, or the related components, during the periods presented):
    • Allowance for credit losses to total loans
    • Nonaccrual loans to total loans
    • Allowance for credit losses to nonaccrual loans
    • Net charge-offs to average loans, by loan category disclosed in the financial statements
  • The allowance for credit losses by loan category
  • Bank deposits, including average amounts, rates paid and amounts that are uninsured

The rules apply to fiscal years ending on or after December 15, 2021. However, voluntary early  compliance is permitted, provided that the rules are applied in their entirety.

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