Posted on Wednesday, October 2, 2019

On September 17, 2019, the SEC published a rule proposal: Update of Statistical Disclosures for Bank and Savings and Loan Registrants.  Today, that proposal was posted on the Federal Register, with an official publication date of October 3. Comment letters are due 60 days from the date of publication in the Federal Register. A proposal on the same issue was published in 2017 and XBRL US submitted a comment letter. Much of Industry Guide 3 data is monetary in nature, and therefore, we believe that it should be reported using financial data standards.

The current proposal would update the disclosures that investors receive, codify certain Guide 3 disclosures and eliminate other Guide 3 disclosures that overlap with Commission rules, as well as US GAAP and IFRS requirements. The proposal also indicates that the Commission will relocate the codified disclosures to a new subpart of Regulation S-K and will rescind Guide 3. In addition, the Commission is not proposing that Industry Guide 3 disclosures be included in the notes to the financial statements. Therefore, these disclosures would not be required to be audited, nor would they need to be filed in XBRL format. The proposal states that they received limited feedback to their 2017 proposal on this point and believe that additional feedback would be useful.

Read the proposal.