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SEC Considers Modernization of Industry Guide 3 for Bank Holding Companies

Earlier this month, the SEC published its Request for Comment on Possible Changes to Industry Guide 3 (Statistical Disclosure by Bank Holding Companies) (the Request). The SEC is seeking public input on the potential modernization of Industry Guide 3, Statistical Disclosure by Bank Holding Companies (Industry Guide 3). Comments must be received by May 8, 2017.


Industry Guide 3, originally published in 1976 and last updated in 1986, contains statistical disclosure requirements that apply to the description of business included in or incorporated by reference into registration statements filed by bank holding companies. The SEC is considering modernizing Industry Guide 3 to reflect developments in the ever-changing financial services industry as well as changes in accounting standards applicable to financial and other reporting requirements. Rather than proposing specific amendments, the Request solicits comments from bank holding companies and other market participants on potential improvements to Industry Guide 3’s disclosure regime, including the scope and applicability of Industry Guide 3; whether new or revised disclosure requirements are needed; whether any existing requirements should be eliminated; and whether any of Industry Guide 3’s disclosure requirements should be codified as SEC rules.

The Request describes each disclosure section in Industry Guide 3, as well as related SEC, United States Generally Accepted Accounting Principles (U.S. GAAP), and banking agency disclosure requirements, and sets forth 112 specific requests for comment. Comments must be received by May 8, 2017, and information about how to submit comments can be found in the Request.

To see our team’s Top 10 Issues Facing Financial Institutions series, click here.

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About this Author

Victoria Pool, Corporate Attorney, Schiff Hardin Law Firm

Victoria Pool handles a wide range of corporate and securities matters including business organization, corporate governance, commercial transactions and securities compliance. She advises both public and private companies and their boards of directors in a variety of industries, including the financial services industry.

Ms. Pool has experience with public and private mergers and acquisitions, securities offerings, and general corporate organization and compliance matters. She is also knowledgeable in securities, futures and derivatives...