Goldman Sachs Group Inc took a step toward greater transparency by pledging to disclose more about how it makes money, seeking to rebut criticism that it has been putting its own interest ahead of clients.

Goldman, due to report quarterly earnings next week, for the first time will break out how much it earns from trading on its own behalf rather than for clients. Other changes will aim to avoid conflicts of interest and ensure that staff are trained to think about the firm's reputation in their day-to-day activities.

The investment bank released a 63-page report on Tuesday that details 39 plans for how it will change after years of investor accusations that its financial statements are opaque and client complaints about conflicts of interest.

The internal review was kicked off after Goldman was accused by U.S. securities regulators of creating and selling collateralized debt obligations linked to subprime mortgages without telling investors that hedge fund Paulson & Co had helped choose and bet against the debt.

Goldman agreed in July to pay $550 million to settle the lawsuit brought by the U.S. Securities and Exchange Commission, one of the biggest arising from the U.S. housing and credit crises.

The report also follows the passage of a sweeping financial regulatory reform bill last summer that, in part, sought to restrict big Wall Street firms' ability to make bets with their own capital.

'BLACK BOXES'

Goldman is going down the road of trying to repair its image, said Alan Villalon, an analyst at Nuveen Asset Management, in Minneapolis. This is a step in the right direction, but it's only a step. What investors really want to know now is, what is the true earnings power of this company going forward.

Goldman shares edged higher in morning trading, gaining 43 cents to $170.19. The shares have gradually recovered from a steep drop that followed the disclosure of the SEC suit last April, rising about 6 percent.

Goldman said it would start reporting more details about whether trading revenue comes from facilitating client transactions or from investing on its own behalf. The change comes in response to widespread criticism that the bank does not adequately disclose how it makes money.

People have been asking for more information from Goldman for a long time. Black boxes are terrific when earnings are going up, but once things turn sour, investors get aggravated that they can't find out more, said Marshall Front, chairman at Front Barnett Associates in Chicago, which does not own Goldman shares.

Goldman Sachs earned a record $13.39 billion in 2009. The bank's results have been on a roller-coaster ride over the last five years, rising to an eye-popping $11.6 billion in 2007 before dropping to $2.32 billion in 2008, only to reach a record high the following year.

BLANKFEIN UNSCATHED

Goldman's 2010 results are on track to be down from 2009; the bank earned just $5.49 billion in the first nine months of the year. The bank is scheduled to report fourth-quarter results on January 19 under its new disclosure framework.

Goldman said it would set up a new committee to ensure that clients are being treated fairly.

The report focuses mainly on disclosure and oversight, and makes few recommendations for how Goldman will change the way it does business day to day.

It says nothing, for example, about replacing Chief Executive Lloyd Blankfein, widely criticized for his response to the SEC lawsuit and allegations that the bank's activities were rife with conflicts of interest that were not always disclosed to clients.

Michael Holland, who oversees $4 billion of assets as chairman of Holland & Co, called Goldman's planned changes yet one more smart move in a series of things they've done to repair the damage to their reputation during and after the financial crisis.

Much of the report focuses on how to deal with so-called structured products like the CDO that was at issue in the SEC suit.

Goldman said a key objective of the report was to repair any damage to the reputation of the firm -- famously described by a Rolling Stone magazine article as a great vampire squid ... jamming its blood funnel into anything that smells like money.

The Goldman report said: In particular, our approach must be: not just 'can we' undertake a given business activity, but 'should we.'

As part of the internal review, Goldman talked to more than 200 of its clients worldwide, some of whom criticized the firm for emphasizing its own interests and short-term compensation at their expense.

Partly in response, Goldman said it will seek to put increased weight on reputational risk management as well as emphasizing client service and client relationships.

(Additional reporting by Maria Aspan; editing by John Wallace)

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