Banking

“As an agency designed to serve the American people, it is imperative to constantly look back on the SEC’s rules and engage the public on ways to improve. Today, we are asking for public comment on whether Industry Guide 3 continues to elicit the information that investors need for informed investment and voting decisions.”

- SEC Acting Chairman Michael Piwowar

On March 1, 2017, the SEC voted to publish a request for public comment on disclosures mandated by Industry Guide 3—Statistical Disclosure by Bank Holding Companies. The agency is seeking input from investors, registrants and others on ways to improve disclosures for bank holding companies, inquiring whether Guide 3 remains capable of gathering the information needed for investors to make informed funding and voting decisions. Additionally, the SEC is examining what new types of disclosures about bank holding company activities might be necessary.

As public banks and companies continue to grow, whether through mergers and acquisitions or organically, it’s not unusual for them to forget about important regulations.

In this blog, we wanted to focus on the requirements of the Securities and Exchange Commission (SEC) that require companies to provide an annual report on internal controls for their fiscal year end.[1] In particular, these internal control report requirements impact accelerated and large accelerated filers.[2]