Comment Letter

SEC: Update of Statistical Disclosures for Bank and Savings and Loan Registrants

Monday, November 25, 2019

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In this November 2019 letter, the CAQ shares views and input on the Securities and Exchange Commission’s Proposed Rule, Update of Statistical Disclosures for Bank and Savings and Loan Registrants. Providing its comments through the lens of the public company audit profession, the CAQ expresses general support for the Commission’s effort to streamline and modernize Guide 3 for bank holding company registrants, including the elimination of outdated or duplicative disclosures and the codification of Guide 3 into new Subpart 1400 of Regulation S-K. The CAQ offers suggestions to help the Commission achieve its objective and to enable registrants and auditors to avoid unnecessary challenges when applying the proposed disclosure requirements—while still providing useful information for investors.