Banks
3 SEC staff comments and 10 disclosure examples from companies in this industry.
SIC codes included: 6022 State Commercial Banks, 6021 National Commercial Banks, 6029 Commercial Banks, NEC, 6035 Savings Institution, Federally Chartered, 6036 Savings Institutions, Not Federally Chartered
Disclosure examples by topic
Banks: Fair value: Level 3 measurements3 examplesBanks: Insider trading policies (Item 408(b))2 examplesBanks: Credit losses (CECL, ASC 326)2 examplesBanks: Critical accounting estimates (MD&A)1 exampleBanks: Key performance indicators & metrics1 exampleBanks: Discontinued operations (ASC 205-20)1 example
What the SEC staff asked companies in this industry
Liquidity & Capital Resources (1)KPIs, Metrics & Earnings Calls (1)IFRS & Foreign Private Issuers (1)Errors, Restatements & Item 4.02 (1)
Kentucky First Federal Bancorp (KFFB) · 2026-01-27 · Form 10-K for the Fiscal Year Ended June 30, 2025 · Comment 1 · Liquidity and Capital Resources, page 23 Agreed to revise
Staff comment: We note your disclosure, here and on page 16, that deposit inflows are a primary source of funds. We also note your disclosure that First Federal of Kentucky entered into a formal written agreement with the OCC and that the OCC has imposed individual minimum capital requirements. To the extent that these items remain in place, please revise your future filings, here or elsewhere as appropriate, to clarify whether they affect the ability of any of your entities to be considered well-capitalized, regardless of actual capital levels. If so, disclose whether you have any restrictions on or waiver requirements for rolling brokered deposits, and quantify any related impact for the periods… letter →
Company response: In response to the Staff’s comment, while the Company acknowledges that the OCC has imposed individual minimum capital requirements on its indirect subsidiary, First Federal of Kentucky (the “Bank”), the Bank has not been designated as “less than well capitalized” and has maintained capital levels in excess of the noted individual minimum capital requirements. As such there have been no restrictions or waiver requirements imposed on the Bank for rolling brokered deposits or other types of wholesale deposits. Nevertheless, pursuant to the Staff’s comment, to the extent that these items remain in place, the Company will revise its future filings in all appropriate circumstances to clarify… response letter →
Macro Bank Inc. (BMA) · 2026-01-15 · Form 20-F for Fiscal Year Ended December 31, 2024 Response Dated September 30, 2025 · Comment 1 · Analysis of the allowance for loan losses and other financing, page 134 Awaiting / response not in dataset
Staff comment: We acknowledge your response to prior comment one. Please revise future filings to provide qualitative information, including a narrative explanation, to explain the reasons for the changes in the expected credit loss (“ECL”) allowance during each period presented. Refer to IFRS 7.35H, .35I and .B8D for guidance. letter →
Macro Bank Inc. (BMA) · 2026-01-15 · Form 20-F for Fiscal Year Ended December 31, 2024 Response Dated September 30, 2025 · Comment 2 · Credit loss expense on financial assets, page 162 Awaiting / response not in dataset
Staff comment: We acknowledge your response to prior comment two. Please address the following: • Please tell us and revise future filings, as needed, to define "Charged-off Loans" and "Amounts Written Off" clearly identifying the differences between each term as used in your prior reconciliation. • Please provide us a reconciliation showing how the credit loss expense recognized for 2024 and 2023 is presented in the ECL rollforward line-items on page 134. Please separately identify amounts related to each various cause (e.g., "Charged- off Loans" and IAS 29 restatement). • Please consider revising your ECL rollfoward, supporting disclosure or other disclosure in future filings to more clearly show the… letter →
Templates & resources
- AICPA & CIMA – SEC reporting resources (AICPA & CIMA · Professional body · Free / member)
- BDO Accounting, Reporting & Compliance Hub (ARCH) (BDO · Firm guide · Free)
- Deloitte DART – Roadmap Series (Deloitte · Firm guide · Free)
- Grant Thornton Insights (Grant Thornton · Firm guide · Free)
- KPMG Financial Reporting View (KPMG · Firm guide · Free)
- PwC Viewpoint (PwC · Firm guide · Free / paid)
- RSM Financial Reporting Resource Center (RSM · Firm guide · Free)
- SEC – Corporation Finance Interpretations (SEC · Regulator · Free)
- SEC – Financial Reporting Manual (SEC · Regulator · Free)
- The Monday Filer – SEC reporting Excel templates (The Monday Filer · Template vendor · Paid)
- UnfoldCFO – 10-K Disclosure Checklist (UnfoldCFO · Template vendor · See site)
- Workiva Marketplace – SEC Reporting Process Checklist (Workiva · Template vendor · Requires Workiva license)