October 8, 2012

Division of Corporation Finance Staff Discussed Frequent Areas of Comments for Banks and Savings Institutions

Holland & Knight Bulletin
Nicole M. Maron

On September 12, 2012, the chief accountant and the associate chief accountant of the Division of Corporation Finance discussed frequent areas of staff comment for banks and savings institutions, including the following:

  • loans and allowances: second liens loans, credit loss disclosures, credit trends and allowance releases, and small financial institutions
  • troubled debt restructurings and modifications
  • deferred tax assets
  • purchased credit-impaired loans
  • goodwill impairment testing
  • FDIC-assisted acquisitions
  • fair value disclosures
  • mortgage repurchase reserves
  • other frequent areas of comment including MD&A disclosures, Item 4.02 Form 8-Ks, MSR disclosures, Basel III capital/liquidity rations, reporting considerations for bank holding companies under the JOBS Act, sovereign debt exposures and VAR disclosures


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