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3235-0033 199810-3235-009
Historical Inactive 199810-3235-004
SEC
Records To Be Made by Certain Exchange Members, Brokers, and Dealers -- Rule 17a-3
Revision of a currently approved collection   No
Regular
Comment filed on proposed rule and continue 12/29/1998
Retrieve Notice of Action (NOA) 10/26/1998
The information collection in this reproposed rule is not approved at this time. The agency appears to seriously understate the burden of this collection. For example, the agency cites state regulator complaints that local offices are often poorly organized and inefficiently run, hindering examination. However, in the estimates of the costs of the rule, the agency states that creation of the records is already an accepted business practice and required by SROs. This statement raises doubts about the expected impact of this additional rule. In addition, the agency appears to omit the additional costs required by the increased post traffic required by the rule, (about 6.6 million dollars based on 20 million records a year, .66 million dollars for 2 million responses) and any costs associated with modifying computer systems to generate the additional records.
  Inventory as of this Action Requested Previously Approved
03/31/1999 12/31/2001 06/30/1999
7,769 0 7,769
1,941,062 0 0
0 0 0