View Information Collection Request (ICR) Package

OMB Control No: 3235-0693	ICR Reference No: 201203-3235-004
Status: Historical Inactive	Previous ICR Reference No:
Agency/Subagency: SEC	Agency Tracking No: TM-270-645
Title: Rule 17g-8 Policies and procedures and Rule 17g-9 Standards of training, experience, and competence for credit analysts
Type of Information Collection: New collection (Request for a new OMB Control Number)	Common Form ICR: No
Type of Review Request: Regular
OIRA Conclusion Action: Preapproved	Conclusion Date: 08/14/2012
	Date Received in OIRA: 05/11/2012
Terms of Clearance:

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	08/31/2015	36 Months From Approved
Responses	20	0	0
Time Burden (Hours)	9,540	0	0
Cost Burden (Dollars)	1,009,000	0	0

Abstract: Rule 17g-8 would require nationally recognized statistical rating organizations ("NRSROs") to establish, maintain and enforce certain policies and procedures relating to credit rating methodologies, the use of credit rating symbols, and look-back procedures for departing NRSRO employees. The Commission's authority to propose the policies and procedures that would be required under proposed Rule 17g-8 arises from certain provisions of the Dodd-Frank Act. For the purposes of estimating the hourly recordkeeping burden associated with proposed Rule 17g-8, part IIIa of this form takes the average hourly burden over the first 3-year period following adoption of the rule, since the initial hourly burden for the proposed rule is greater than the estimated ongoing hourly burden. [(500 initial hourly burden in year 1 + 125 ongoing hourly burden in year 2 + 125 ongoing hourly burden in year 3) / 3 years = 250 hours per year.] Rule 17g-9 implements Section 936 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, which requires the Securities and Exchange Commission to issue rules reasonably designed to ensure that any person employed by a nationally recognized statistical rating organization to determine credit ratings meets standards of training, experience, and competence necessary to produce accurate ratings for the categories of issuers whose securities the person rates and is tested for knowledge of the credit rating process.

Authorizing Statute(s): US Code: 15 USC 78o-8, 78o-7(s), 78o-7(r) Name of Law: Securities Exchange Act of 1934
US Code: 15 USC 78o-7, 78o-7(h)(4)(A)(ii), Name of Law: Securities Exchange Act of 1934

Citations for New Statutory Requirements: PL: Pub.L. 111 - 203 932(a)(4), 932(a)(8) 936, 938 Name of Law: Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010

Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
3235-AL15	Proposed rulemaking	76 FR 33420	06/08/2011

Federal Register Notices & Comments
Did the Agency receive public comments on this ICR? No

Number of Information Collection (IC) in this ICR: 2

IC Title	Form No.	Form Name
IC - 1
IC - 2

ICR Summary of Burden

	Total Request	Change Due to New Statute
Annual Number of Responses	20	20
Annual Time Burden (Hours)	9,540	9,540
Annual Cost Burden (Dollars)	1,009,000	1,009,000

Burden increases because of Program Change due to Agency Discretion: No

Burden Increase Due to:

Burden decreases because of Program Change due to Agency Discretion: No

Burden Reduction Due to:

Short Statement: This is a new rule proposal and will add 9,540 annual hours to the inventory.

Annual Cost to Federal Government: $0

Does this IC contain surveys, censuses, or employ statistical methods? No

Is the Supporting Statement intended to be a Privacy Impact Assessment required by the E-Government Act of 2002? No

Is this ICR related to the Affordable Care Act [Pub. L. 111-148 & 111-152]? No

Is this ICR related to the Dodd-Frank Wall Street Reform and Consumer Protection Act, [Pub. L. 111-203]? Yes

Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)? No

Is this ICR related to the Pandemic Response? Uncollected

Agency Contact: Rose Wells 202 942-0143

View ICR - OIRA Conclusion