On December 2, BPI and SIFMA submitted a comment letter to the SEC responding to proposed updates and revisions to the SEC’s Industry Guide 3 governing disclosure requirements by bank and savings and loan holding companies. The letter supports proposed updates, including the elimination of duplicative disclosure requirements, reduction in required reporting periods, and codification of disclosures within Regulation S-K. The letter recommends that the SEC eliminate disclosure requirements of uninsured time deposits and requirements to disclose more broadly in XBRL format. In addition to other recommendations, the letter further encourages the SEC to retain its guidance allowing registrants to exclude or aggregate certain loan categories for the loan maturity table, allowance for credit losses, and credit ratio disclosures.
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