The Clearing House (TCH) filed a comment letter with the SEC in response to its request for comment on Industry Guide 3. In the letter, TCH urged the SEC to significantly streamline Guide 3 so that it acts as a “gap filler” for U.S. BHCs, whereby items that provide meaningful information and are not otherwise required in SEC filings be retained and items that duplicate or overlap with U.S. GAAP, Regulation S-K or Regulation S-X disclosures, or do not provide meaningful information, be eliminated. Furthermore, TCH recommended that the SEC defer to home country practices and eliminate the applicability of Guide 3 to FBO registrants filing Form 20-F, and in the event that the SEC nevertheless decides that Guide 3 disclosures are necessary for FBOs, TCH urged the SEC to adopt the approach recommended for U.S. BHCs. TCH recommended that the SEC not codify Guide 3 into Regulation S-K or S-X and instead argued for it to remain as guidance.
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