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COMMENT
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OMB Control No:
3235-0737
ICR Reference No:
202601-3235-021
Status:
Received in OIRA
Previous ICR Reference No:
202302-3235-009
Agency/Subagency:
SEC
Agency Tracking No:
IM
Title:
Rule 22e-4 (17 CFR 270.22e-4) under the Investment Company Act 0f 1940, Investment Company Liquidity Risk Management Programs
Type of Information Collection:
Extension without change of a currently approved collection
Common Form ICR:
No
Type of Review Request:
Regular
Date Submitted to OIRA:
04/10/2026
Requested
Previously Approved
Expiration Date
36 Months From Approved
07/31/2026
Responses
12,186
12,270
Time Burden (Hours)
202,699
193,241
Cost Burden (Dollars)
40,536,600
37,628,716
Abstract:
Rule 22e-4 under the Investment Company Act of 1940 requires an open-end management investment companies (but not money market funds) and an exchange-traded fund that redeems in kind to establish a written liquidity risk management program that is designed to assess and manage the fund's liquidity risk. The requirements under rule 22e-4 that a fund and In-Kind ETF, as applicable, adopt a written liquidity risk management program, report to the board, maintain a written record of how the highly liquid investment minimum was determined and written policies and procedures for responding to a shortfall of the fund’s highly liquid investment minimum, which includes reporting to the fund’s board of directors (for funds that do not primarily hold highly liquid investments), establish written policies and procedures regarding how the fund will engage in redemptions in kind, and retain certain other records are all collections of information under the PRA. In addition, the requirement under rule 22e-4 that the principal underwriter or depositor of a UIT assess the liquidity of the UIT on or before the date of the initial deposit of portfolio securities into the UIT and retain a record of such determination for the life of the UIT, and for five years thereafter, is also a collection of information under the PRA. The respondents to rule 22e-4 are open-end management investment companies (including, under certain circumstances, In-Kind ETFs but excluding money market funds), and the principal underwriters or depositors of UITs under certain circumstances. Compliance with rule 22e-4 is mandatory. The information collection requirements of rule 22e-4 are designed to ensure that funds maintain comprehensive, written liquidity risk management programs that promote compliance with the federal securities laws and protect investors. The information collections also assist the Commission’s examination staff in assessing the adequacy of funds’ liquidity risk management programs and identifying weaknesses in a fund’s liquidity risk management if violations occur or are uncorrected.
Authorizing Statute(s):
US Code:
15 USC 80a
Name of Law: Investment Company Act of 1940
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:
91 FR 4775
02/02/2026
30-day Notice:
Federal Register Citation:
Citation Date:
91 FR 18520
04/10/2026
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
Rule 22e-4 (17 CFR 270.22e-4) under the Investment Company Act of 1940, "Liquidity risk management programs"
ICR Summary of Burden
Total Request
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
12,186
12,270
0
0
-84
0
Annual Time Burden (Hours)
202,699
193,241
0
0
9,458
0
Annual Cost Burden (Dollars)
40,536,600
37,628,716
0
0
2,907,884
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:
Currently, the approved total annual hour burden for complying with rule 22e-4 is 193,241 hours. The new estimate of the total annual hour burden is 202,699 hours. The increase of 9,458 hours is due to an increase in the estimated number of affected entities, as well as revisions in the manner of calculation. The current total annual external cost burden is $37,628,716; we estimate a new external cost burden of $40,536,600. This increase is due to the increase in the number of fund complexes subject to the rule and the staff’s determination to revise the manner in which it calculates these estimates.
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.
No
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:
Alexis Hassell 202 551-5616
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:
04/10/2026
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