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Comment Letter

SEC: Possible Changes to Industry Guide 3 – Statistical Disclosure by Bank Holding Companies

Monday, May 8, 2017

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In this letter, the CAQ provides input on the Securities and Exchange Commission’s (SEC) Request for Comment on Possible Changes to Industry Guide 3, Statistical Disclosure by Bank Holding Companies. The CAQ expresses support for the SEC’s efforts to modernize Guide 3 and agrees with the Commission’s observations that disclosure requirements in US Generally Accepted Accounting Principles, International Financial Reporting Standards, and other SEC regulations have evolved since Guide 3 was first published in 1976, resulting in duplicative disclosure requirements for bank holding company registrants. The CAQ encourages the Commission to conduct outreach with investors and other users of financial statements to obtain input regarding disclosures that are most relevant and helpful.