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Deloitte responds to SEC’s request for comment on possible changes to Industry Guide 3 (“Statistical Disclosure by Bank Holding Companies”)

Published on: Jun 01, 2017

Deloitte & Touche LLP has commented on the SEC's Request for Comment on Possible Changes to Industry Guide 3, which was issued in March 2017.

Deloitte & Touche LLP supports the SEC's revisions to Industry Guide 3, but believes the SEC should consider:

  • Establishing a well-defined objective for its Guide 3 disclosure requirements that incorporates a principles-based approach.
  • Obtaining input from investors and users of the financial statements, as well as the FASB, to determine the current and ongoing importance of Guide 3 disclosures and, if they are deemed useful for investment and voting decisions, retaining and enhancing them on the basis of input received.
  • Eliminating Guide 3 disclosure requirements that duplicate or are redundant with U.S. GAAP requirements.

Full text of the comment letter is available below.


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