Industry Alerts & Publications

SEC Updates Guide 3 Statistical Disclosure Requirements

September 28, 2020

The Securities and Exchange Commission recently adopted new rules to update its statistical disclosure requirements for banking registrants, including domestic and foreign bank holding companies, banks, savings and loan holding companies, and savings and loan associations. The rules are contained in a new Item 1400 of Regulation S-K and will replace Industry Guide 3, Statistical Disclosure by Bank Holding Companies. These changes represent the first updates to Guide 3 in more than 30 years. Our Alert regarding this release is available here.

SEC Adopts Changes to Its Disclosure Requirements for Periodic Reports and Registration Statements

September 17, 2020

To our clients and friends:

The SEC recently issued a release revising certain disclosure requirements for periodic reports and registration statements filed with the SEC. Our Alert regarding this release is available here.

ALERT – Federal Reserve Board Clarifies Policies/Timing on Review of Dividends

July 28, 2020

To our clients and friends:

The Federal Reserve recently supplemented its guidance on the payment of dividends by bank and savings and loan holding companies, particularly when a proposed dividend exceeds earnings for the period for which the dividend is being paid. Our Alert regarding this further guidance is available here.

ALERT – SEC Supplements Guidance Regarding COVID-19 Disclosure

July 24, 2020

To our clients and friends:

The SEC recently supplemented its previous guidance for public companies regarding disclosure related to COVID-19 in filings made with the SEC. Our Alert regarding this supplemental guidance is available here.

Alert – SBA extends PPP until August 8 and issues new interim final rule related to the loan forgiveness requirements of the PPP

July 8, 2020

To our clients and friends:
On July 4, 2020, the Paycheck Protection Program Extension Act was signed into law, which extended from June 30, 2020 to August 8, 2020 the deadline to apply for a loan under the U.S. Small Business Administration’s (“SBA”) Paycheck Protection Program (“PPP”). The SBA has an estimated $130 billion remaining in the PPP.

The SBA also recently issued an interim final rule (the “Interim Final Rule”), which amends the SBA’s previously issued interim final rules on PPP loan forgiveness to incorporate certain provisions of the Paycheck Protection Program Flexibility Act of 2020 signed into law on June 5, 2020.

Our Alert summarizes the changes to the loan forgiveness requirements of the PPP implemented by the Interim Final Rule and is available here.