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SEC Disclosure Modernization

On September 11, 2020, the Securities and Exchange Commission followed through with the promise of modernization of Regulation S-K disclosure requirements. In its effort to eliminate requirements duplicative with U.S. GAAP or IFRS, this update rescinds Industry Guide 3, Statistical Disclosure by Bank Holding Companies, with new rules codified in a new subpart 1400 of Regulation S-K. 

These long-awaited changes are intended to bring S-K disclosure requirements for financial institutions more current with the significant financial reporting changes that have impacted the industry over the last decade. Having not been substantively updated in the last 30 years, the former Guide 3 requirements were widely thought to be outdated and lacking requirements for information complimentary to other financial statement disclosure requirements and beneficial to both investors and registrants alike.

The rules will be effective 30 days after publication in the Federal Register and will apply to fiscal periods ending on or after December 15, 2021. Early adoption is permitted; however, the final rule requires voluntary early compliance be applied in its entirety from the date of early compliance. Industry Guide 3 will be rescinded effective January 1, 2023.

More information on the specific changes being updated in this modernization effort can be found in the SEC’s press release (including a link to the full “Final Rule”) by Clicking Here.


If you have additional questions, please do not hesitate to reach out to your trusted advisor at YHB.