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SEC Proposes Rules to Update Guide 3 Statistical Disclosures for Public Banking Organizations

By Juan M. Arciniegas, Thomas P. Desmond, James M. Kane, Jennifer Durham King, Daniel C. McKay, II, James W. Morrissey & Mark C. Svalina on September 24, 2019
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On September 17, 2019, the Securities and Exchange Commission (the “SEC”) proposed rules that would update the statistical disclosures currently required by Industry Guide 3, Statistical Disclosure by Bank Holding Companies (“Guide 3”) applicable to public bank holding companies, banks, savings and loan holding companies and savings and loan associations. The proposed rules are intended to also codify certain Guide 3 disclosures as well as eliminate other disclosures that overlap with SEC rules, Generally Accepted Accounting Principles and International Financial Reporting Standards.

Guide 3 was first published in 1976 and was most recently revised in 1986. The proposed rules are meant to reflect the numerous changes to the financial reporting and accounting requirements affecting banks since that time.

Specifically, the proposed rules would replace Guide 3 with updated disclosure requirements in a new subpart 1400 of Regulation S-K.  The SEC’s proposed rules would require disclosure about the following:

  • distribution of assets, liabilities and stockholders’ equity, the related interest income and expense, and interest rates and interest differential;
  • weighted average yield of investments in debt securities by maturity;
  • maturity analysis of the loan portfolio including the amounts that have predetermined interest rates and floating or adjustable interest rates;
  • an allocation of the allowance for credit losses and certain credit ratios; and
  • information about bank deposits including amounts that are uninsured.

The proposed rule is subject to a 60-day comment period.  To read the SEC’s proposed rules, click here.

Photo of Juan M. Arciniegas Juan M. Arciniegas

Mr. Arciniegas works primarily as a derivatives lawyer and covers markets for over-the-counter (OTC) derivatives, structured finance products and listed futures. He advises on every stage throughout the life cycle of a derivatives transaction, providing assistance to a wide range of market participants…

Mr. Arciniegas works primarily as a derivatives lawyer and covers markets for over-the-counter (OTC) derivatives, structured finance products and listed futures. He advises on every stage throughout the life cycle of a derivatives transaction, providing assistance to a wide range of market participants engaged in the markets in various capacities. Regulatory matters range from assisting clients on financial reform legislation, registration and membership with the CFTC, NFA, and other financial market utilities, to providing guidance to commercial end-users and sell-side participants on exemptions, cross-border access issues, and matters involving the overlapping jurisdiction of securities and commodities regulation. Transactional matters include the negotiation and implementation of comprehensive documentation for agency-MBS, cleared and OTC derivatives, FX, futures, loan-level hedging arrangements, prime brokerage, repurchase transactions, securities lending, structured finance transactions, and related industry protocols implementing changes in those markets. Mr. Arciniegas has appeared before the CFTC, the Federal Reserve, the SEC, and is a frequent speaker and published author on futures and derivatives topics.

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Photo of Thomas P. Desmond Thomas P. Desmond

Thomas P. Desmond is Co-Chair of the Executive Compensation & Employee Benefits practice group, a member of the firm’s Board of Directors and Chair of the firm’s Compensation Committee.

Mr. Desmond’s practice includes advising corporations and financial institutions with respect to executive compensation…

Thomas P. Desmond is Co-Chair of the Executive Compensation & Employee Benefits practice group, a member of the firm’s Board of Directors and Chair of the firm’s Compensation Committee.

Mr. Desmond’s practice includes advising corporations and financial institutions with respect to executive compensation, mergers and acquisitions, corporate finance and governance matters. His corporate engagements have included acting as advisor to boards of directors and to compensation, audit, governance and other special committees of boards of directors of public and privately held corporations.

Mr. Desmond is known nationally for his representation of corporations, compensation committees and executives with respect to employment, retirement and separation arrangements affecting senior executives, incentive compensation programs and related regulatory and disclosure requirements. His assignments in this area have included employment arrangements, compensation plans, and regulatory and disclosure matters relating to numerous organizations, including Ace Hardware, Beam, Calamos Investments, ConAgra, Delphi, Dimensional Fund Advisors, DIRECTV, Fifth Third, First Midwest, Fiserv, Harris Associates, Hershey, Hyatt, ING, LPGA, MB Financial, PepsiCo, PGA Tour, Protective Life, Stancorp Financial, Swiss Re, Tellabs, Treehouse Foods, Visa, United Way and a number of private equity-sponsored entities.

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Photo of James M. Kane James M. Kane
Read more about James M. KaneEmail
Photo of Jennifer Durham King Jennifer Durham King
Read more about Jennifer Durham KingEmail
Photo of Daniel C. McKay, II Daniel C. McKay, II
Read more about Daniel C. McKay, IIEmail
Photo of James W. Morrissey James W. Morrissey
Read more about James W. MorrisseyEmail
Photo of Mark C. Svalina Mark C. Svalina
Read more about Mark C. SvalinaEmail
  • Posted in:
    Financial
  • Blog:
    The 21st Century Banker
  • Organization:
    Vedder Price PC
  • Article: View Original Source

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