On April 20, the Division of Corporation Finance of the Securities and Exchange Commission issued guidance with respect to certain matters relating to management’s discussion and analysis and certain accounting policies of smaller financial institutions. Staff stated that "we frequently issue comments on several topics that impact Management’s Discussion and Analysis (MD&A) and accounting policy disclosures. We are issuing this guidance to summarize our observations on such matters in order to assist smaller financial institutions in enhancing the disclosure they provide investors in the reports they file with the Commission."
The guidance relates to the following topics: allowance for loan losses, charge-off and non-accrual policies, commercial real estate, impairment based on collateral value, credit risk concentrations, troubled debt restructurings and modifications, other real estate owned, deferred taxes, and FDIC-assisted acquisitions.
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