Overview
In our comment letter, we supported the SEC’s objective to eliminate many of the outdated or duplicative disclosure requirements in Guide 3, Statistical Disclosure by Bank Holding Companies (Guide 3) and to codify the remaining requirements into new Subpart 1400 of Regulation S-K. The proposed changes would help registrants effectively communicate to investors material information that is more relevant, organized and focused on a company’s facts and circumstance. We also suggested that the SEC clarify the definition of uninsured deposits to be disclosed as of the end of each reporting period.
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