SEC Comment Letter 0000000000-23-013397 to SCHWAB CHARLES CORP (SCHW, SCHW-PD, SCHW-PJ) (CIK 0000316709) (SCHW)
SCHWAB CHARLES CORP (SCHW, SCHW-PD, SCHW-PJ) (CIK 0000316709)
Date: Dec. 7, 2023 · CIK: 0000316709 · Accession: 0000000000-23-013397
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File numbers found in text: 001-09700
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United States securities and exchange commission logo
December 7, 2023
Peter Crawford
Chief Financial Officer
The Charles Schwab Corporation
3000 Schwab Way
Westlake, TX 76262
Re:The Charles Schwab Corporation
Form 10-K for the Fiscal Year Ended December 31, 2022
Form 10-Q for the Quarterly Period Ended June 30, 2023
File No. 001-09700
Dear Peter Crawford:
We have reviewed your filing and have the following comments.
Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments.
Annual Report on Form 10-K for the Fiscal Year Ended December 31, 2022
Risk Management
Market Risk, page 46
1.We note your response to comment 1, in which you note that you believe that qualitative
information about your use of EVE, combined with your presentation of sensitivity
analysis for your exposure to interest revenue simulations, provides investors with the
best understanding of your exposure to market risks. We also note your qualitative
discussion of the key areas that management monitors to remain within your risk
appetite. In the subsequent quarters, your EVE discussion in the relevant 10-Qs do not
discuss whether your assumptions, guidelines or other actions were changed as interest
rates or other factors changed. Please confirm that you will expand your qualitative
discussion in future filings, to address any qualitative changes made to your models,
assumptions, targets or management actions as a result of material changes to the key
inputs during the periods presented. Please provide us with your proposed disclosures.
FirstName LastNamePeter Crawford
Comapany NameThe Charles Schwab Corporation
December 7, 2023 Page 2
FirstName LastName
Peter Crawford
The Charles Schwab Corporation
December 7, 2023
Page 2
2.Similarly, in response to comment 2, you indicate the variables that contain assumptions,
without providing disclosure about the assumptions themselves (e.g. prepayment speeds,
term structure models, non-maturity deposit behavior, etc.). The subsequent quarterly
reports note the same general areas where assumptions support your risk management
evaluations, without significantly addressing changes to those assumptions, including in
response to the substantial increase in rates. To the extent that the key assumptions used to
support your quantitative evaluation of interest rate risk simulations change as a result of
significant changes to market rates, address those changes in your market risk disclosure
for the relevant periods. For instance, we note that during the period you expanded your
presentation of the impact of interest rate changes from a single 100 basis point
increase/decrease, to instead present 50, 100 and 200 basis points increase/decrease.
However, your presentation continues to assume a "gradual increase or decrease" while
referencing other simulations, including instantaneous and/or non-parallel shifts. Given
the significant changes in interest rates that have occurred during the current year, provide
your analysis as to why you have chosen not to only present the sensitivity analysis based
on the gradual rate increase scenario.
We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
Please contact Marc Thomas at 202-551-3452 or Robert Klein at 202-551-3847 if you
have questions regarding comments on the financial statements and related matters. Please
contact Robert Arzonetti at 202-551-8819 or Christian Windsor at 202-551-3419 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Finance