On March 1st, 2017, the Securities and Exchange Commission (“Commission”) issued a request for comment (“RFC”) seeking comment on Industry Guide 3, “Statistical Disclosure by Bank Holding Companies” (“Guide 3”). Guide 3, which applies to the description of business portions included or incorporated by reference in bank holding company (BHC) registration statements, was originally published in 1976, and was last updated in 1986.

The RFC seeks public input on a variety of issues, including how and to what extent Guide 3 can be improved, whether new or revised disclosure is needed, the elimination of duplicative or overlapping disclosure in Guide 3 and whether the Guide 3 disclosures, which are not Commission rules or requirements, should be codified as Commission rules. The RFC is also considering new disclosures that could be included in Guide 3 in order to address changes in the financial services industry. Last, the RFC asks whether registrants in the financial industry other than BHCs should be subject to the Guide 3 disclosures. The RFC is part of the Commission’s disclosure effectiveness initiative undertaken during former Chair White’s leadership.