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SEC Proposed Rule updates required disclosures

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Wooden Gavel The SEC issued a Proposed Rule, Update of Statistical Disclosures for Bank and Savings and Loan Registrants, which would codify certain disclosures in Industry Guide 3, “Statistical Disclosure by Bank Holding Companies” (Guide 3), in a new subpart of Regulation S-K; eliminate disclosures that overlap with SEC rules, U.S. GAAP, or IFRS Standards; and rescind Guide 3.

The proposal would apply to both foreign and domestic registrants, including banks, bank holding companies, savings and loan associations, and savings and loan holding companies.  The proposed amendments would expand Regulation S-X, Article 9, Bank Holding Companies, to include savings and loan associations and savings and loan holding companies.
The proposal would apply to both foreign and domestic registrants, including banks, bank holding companies, savings and loan associations, and savings and loan holding companies.
Codifying certain disclosures The addition of Subpart 1400, Disclosure by Bank and Savings and Loan Registrants, to Regulation S-K would codify certain disclosures and add incremental requirements, including:

  • Item 1402, Distribution of assets, liabilities and stockholders’ equity; interest rate and interest differential — All current disclosures required by Guide 3, Item I, as well as a requirement to disaggregate the categories of interest-earning assets and interest-bearing liabilities.

  • Item 1403, Investments in debt securities — The weighted-average yield disclosure currently required in Guide 3, Item II.B, with a change to the categories presented, as well as a requirement that this disclosure apply only to debt securities not carried at fair value through earnings.

  • Item 1404, Loan portfolio — The maturity by loan category disclosure currently in Guide 3, Item III.B, as well as a requirement that such categories be the same as those required in the financial statements, including disclosure of the total amount of loans with predetermined interest rates and floating or adjustable interest rates that are due after one year.

  • Item 1405, Allowance for credit losses — Additional credit ratio disclosures on a consolidated basis, including an allowance for credit losses to total loans, nonaccrual loans to total loans, and an allowance for credit losses to nonaccrual loans, as well as disclosure of the net charge-offs to average loans ratio on a disaggregated basis by loan category, as disclosed in the financial statements; a requirement to discuss the factors that drove material changes in such ratios; and the breakdown of the allowance disclosures currently required by Guide 3, Item IV.B, for registrants that apply U.S. GAAP.

  • Item 1406, Deposits — The majority of the disclosures required by Guide 3, Item V, with some revisions, as well as a requirement to separately present certain time deposits, including amounts that are uninsured.

Comment due date The comment period ends 60 days after the Proposed Rule is published in the Federal Register.

Contacts:

Kendra DeckerKendra Decker
Partner-in-charge 
SEC Regulatory Matters 
T +1 202 521 1530 


Graham DyerGraham Dyer
Partner 
Accounting Principles Group
T +1 312 602 8107


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