View Information Collection Request (ICR) Package
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Please note that the OMB number and expiration date may not have been determined when this Information Collection Request and associated Information Collection forms were submitted to OMB. The approved OMB number and expiration date may be found by clicking on the Notice of Action link below.
View ICR - OIRA Conclusion
OMB Control No:
3235-0110
ICR Reference No:
202502-3235-010
Status:
Active
Previous ICR Reference No:
202205-3235-010
Agency/Subagency:
SEC
Agency Tracking No:
CF
Title:
Form T-1 - Statement of eligibility and qualification under the Trust Indenture Act of 1939 of a Corporation designated to act as a Trustee
Type of Information Collection:
Extension without change of a currently approved collection
Common Form ICR:
No
Type of Review Request:
Regular
OIRA Conclusion Action:
Approved with change
Conclusion Date:
09/17/2025
Retrieve Notice of Action (NOA)
Date Received in OIRA:
06/24/2025
Terms of Clearance:
OMB understands that SEC is in the process of revising its methodologies to estimate annualized costs to the Federal government for all its relevant collections of information. OMB anticipates that future extensions of this OMB control number will reflect the revised methodologies. Supporting statement updated during OMB review.
Inventory as of this Action
Requested
Previously Approved
Expiration Date
09/30/2028
36 Months From Approved
09/30/2025
Responses
2
0
2
Time Burden (Hours)
8
0
8
Cost Burden (Dollars)
13,200
0
8,800
Abstract:
A corporation proposing to serve as trustee under an indenture to be qualified under the Trust Indenture Act of 1939 (“Act”) must state its eligibility and qualification on a Form T-1 (17 CFR 269.1) filed with the Securities and Exchange Commission (“Commission”). The information called for relates to a potential trustee’s eligibility to serve. The form requires the potential trustee to show that it has the authority to exercise trust powers and to include a copy of a call sheet filed with the banking authorities disclosing summary financial information. Other information discloses possible conflicts of interest, which would disqualify the trustee from serving. An independent trustee is necessary to protect the debt holders and to enforce the terms of the indenture. This information relates to affiliations with the issuer and its underwriters, the amount of voting securities of the trustee, outstanding trusteeships under other indentures of the same issuer, interlocking directorates and similar relationships with the issuer or its underwriters, voting securities of the trustee owned by the issuer or its officials, voting securities of the trustee owned by underwriters of the issuer, securities of the issuer owned or held by the trustee, securities of underwriters owned or held by the trustee ownership or holdings by the trustee of voting securities of affiliates of the issuer and ownership by the trustee of any person owning 50% or more of the voting securities of the issuer. Form T-1 is reviewed by the staff in deciding whether to qualify an indenture relating to debt securities offered to the public in an offering registered with the Commission under the Securities Act of 1933 or, if the offering is not registered, upon application for qualification under the Form T-3 pursuant to the Act. The information in the Form T-1 provides a basis for deciding that the corporate trustee is qualified. If the information contained in Form T-1 was not collected, the basis for that decision would be unavailable.
Authorizing Statute(s):
US Code:
15 USC 77aaa et seq.
Name of Law: Trust Indenture Act of 1939
Citations for New Statutory Requirements:
None
Associated Rulemaking Information
RIN:
Stage of Rulemaking:
Federal Register Citation:
Date:
Not associated with rulemaking
Federal Register Notices & Comments
60-day Notice:
Federal Register Citation:
Citation Date:
90 FR 11769
03/11/2025
30-day Notice:
Federal Register Citation:
Citation Date:
90 FR 26843
06/24/2025
Did the Agency receive public comments on this ICR?
No
Number of Information Collection (IC) in this ICR:
1
IC Title
Form No.
Form Name
Form T-1 - Statement of eligibility and qualification under the Trust Indenture Act of 1939 of a Corporation designated to act as a Trustee
SEC-1836
Form T-1
ICR Summary of Burden
Total Approved
Previously Approved
Change Due to New Statute
Change Due to Agency Discretion
Change Due to Adjustment in Estimate
Change Due to Potential Violation of the PRA
Annual Number of Responses
2
2
0
0
0
0
Annual Time Burden (Hours)
8
8
0
0
0
0
Annual Cost Burden (Dollars)
13,200
8,800
0
0
4,400
0
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:
Annual Cost to Federal Government:
Does this IC contain surveys, censuses, or employ statistical methods?
No
Does this ICR request any personally identifiable information (see
OMB Circular No. A-130
for an explanation of this term)? Please consult with your agency's privacy program when making this determination.
Yes
Does this ICR include a form that requires a Privacy Act Statement (see
5 U.S.C. §552a(e)(3)
)? Please consult with your agency's privacy program when making this determination.
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]?
No
Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)?
No
Is this ICR related to the Pandemic Response?
No
Agency Contact:
Pearl Crawley 202 551-3256 crawleyp@sec.gov
Common Form ICR:
No
On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
(a) It is necessary for the proper performance of agency functions;
(b) It avoids unnecessary duplication;
(c) It reduces burden on small entities;
(d) It uses plain, coherent, and unambiguous language that is understandable to respondents;
(e) Its implementation will be consistent and compatible with current reporting and recordkeeping practices;
(f) It indicates the retention periods for recordkeeping requirements;
(g) It informs respondents of the information called for under 5 CFR 1320.8 (b)(3) about:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
(h) It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to be collected.
(i) It uses effective and efficient statistical survey methodology (if applicable); and
(j) It makes appropriate use of information technology.
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.
Certification Date:
06/24/2025
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