How the SEC's Regulation S-X affects banks;

              HOW THE SEC'S REGULATION S-X AFFECTS BANKS
Patrick J. Waide, Jr. Partner, New York Office
Presented before the Fiftieth National Convention, Bank Administration Institute, Chicago-September 1974
When I made the choice of becoming an auditor rather than a tax specialist, I made it primarily on the assumption that I did not want to become a walking textbook of rules, interpretations and case decisions for the remainder of my public accounting career. Maybe I had a distorted view then of the life of a tax specialist. Nevertheless, most of us involved today either in the preparation or the examination of financial statements believe that our lives now have become rounds of continuous reading and memorization of disclosure rules, interpretations and reporting precedents.
INCREASED REPORTING RESPONSIBILITIES
The reporting responsibilities of the chief financial and accounting officers of all publicly owned companies, including banks and bank holding companies, have been expanding at an accelerating rate. In 1973 alone they had to digest the following accounting pronouncements:
• Four Opinions of the Accounting Principles Board
• Seventeen accounting releases of the Securities and Exchange Com­mission
• The Statement on foreign currency translation information of the newly formed Financial Accounting Standards Board
• The New York Stock Exchange "White Paper" relating to recommen­dations
on financial reporting to shareholders and other shareholder matters
As of September 1974 we have had twelve accounting releases of the Securities and Exchange Commission and two interpretations of the Financial Accounting Standards Board. In addition, we have witnessed recently a considerable number of problem bank situations, other financial failures and lawsuits relating to fraudulent financial statements. I mention these latter