Goldman Sachs included an estimate of "reasonably possible" losses from legal proceedings in its annual report following a request from the Securities and Exchange Commission for additional information in correspondence letters with the investment bank.

In a letter to the SEC dated Feb 22, Goldman Sachs proposes the inclusion of a disclosure stating that it could lose as much as $3.4bn in such damages from litigation involving securities that it underwrote over the past few years, as of December 2010. Goldman later reduced that estimate to $2.7bn in its most recent quarterly report.