In a comment letter to the Securities and Exchange Commission today, ABA recommended broad streamlining of the Industry Guide 3, which prescribes statistical disclosures in annual filings for bank holding companies. Noting that banks disclose financial information for various purposes, such as for GAAP financial statements, call reports, and Pillar 3 regulatory reporting, “reducing and eliminating redundancy of prescriptive disclosure requirements…should be a priority.”
ABA has long advocated for an overhaul of Guide 3, which has been in existence since the late 1970s, noting that the usefulness of many of its required disclosures have been diminished by new accounting standards and timely disclosures within Management’s Discussion and Analysis.
