SEC Provides Guidance on Disclosure of Sovereign Debt Exposures

White & Case LLP

On January 6, 2012, the Securities and Exchange Commission (SEC) published guidance (CF Disclosure Guidance: Topic No. 4) setting forth the views of the Staff of the SEC's Division of Corporation Finance urging banks and other financial institutions to enhance disclosure of their exposure to debt instruments of European countries. The guidance is driven by current uncertainties in connection with European sovereign debt exposures, together with a concern that there is a lack of transparent, comparable information.

The guidance is intended to expand current disclosure requirements in the MD&A, risk factors and, with respect to bankholding companies, disclosure required by Industry Guide.

The guidance recommends that issuers provide...

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