Rule 17g-3 Annual audited financial statements to be furnished by nationally recognized statistical rating organizations

Forms and Documents

Document Name	Status
PRA_17g-3_Supporting_Statement (Final) (3).docx Supporting Statement A	2014-09-12

IC Document Collections

IC ID	Document Title	Status
213083	Preparation of Rule 17g-3(a)(7) Internal Controls Report	New
179754	Annual audited financial statements to be furnished by nationally recognized statistical rating organizations	Modified

ICR Details

OMB Control No: 3235-0626	ICR Reference No: 201409-3235-018
Status: Historical Inactive	Previous ICR Reference No: 201301-3235-002
Agency/Subagency: SEC	Agency Tracking No: TM 270-565
Title: Rule 17g-3 Annual audited financial statements to be furnished by nationally recognized statistical rating organizations
Type of Information Collection: Revision of a currently approved collection	Common Form ICR:  No
Type of Review Request: Regular
OIRA Conclusion Action: Comment filed on proposed rule and continue	Conclusion Date: 11/28/2014
	Date Received in OIRA: 09/12/2014
Terms of Clearance: Prior to submission of the collection associated with the final rule, SEC will determine whether a SORN is needed for this collection, and if not, then it should revise this collection accordingly. Pursuant to 5 CFR 1320.11(c), OMB files this comment on this information collection request (ICR. The agency shall examine public comment in response to the NPRM and will describe in the supporting statement of its next collection any public comments received regarding the collection as well as why (or why it did not) incorporate the commenter’s recommendation. The next submission to OMB must include the draft final rule.

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	02/29/2016	36 Months From Approved	02/29/2016
Responses	10	0	10
Time Burden (Hours)	2,000	0	2,000
Cost Burden (Dollars)	416,700	0	150,000

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Abstract: Rule 17g-3 implements certain statutory provisions of the Credit Rating Agency Reform Act of 2006 ("Rating Agency Act") by requiring a nationally recognized statistical rating organization or "NRSRO" to furnish audited financial statements to the Securities and Exchange Commission. This collection of information is necessary to allow the Commission to oversee NRSROs registered with the Commission with respect to their financial condition and to monitor compliance with the Rating Agency Act and its implementing regulations.

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Authorizing Statute(s): US Code: 15 USC 78c, 78d, 78i, 78j, 78l, 78m, Name of Law: Securities Exchange Act of 1934
   US Code: 15 USC 78o-7(k). Name of Law: Credit Rating Agency Reform Act of 2006
  

Citations for New Statutory Requirements: PL: Pub.L. 111 - 203 939, 939D - 939F Name of Law: Dodd-Frank Wall Street Reform and Consumer Protection Act

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

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Federal Register Notices & Comments

Did the Agency receive public comments on this ICR? Yes

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

IC Title	Form No.	Form Name
Preparation of Rule 17g-3(a)(7) Internal Controls Report
Annual audited financial statements to be furnished by nationally recognized statistical rating organizations

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Burden increases because of Program Change due to Agency Discretion: Yes

Burden Increase Due to: Changing Regulations

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

Burden Reduction Due to:

Short Statement: The Commission amended paragraphs (a) and (b) of Rule 17g-3 to implement the rulemaking mandated by Section 15E(c)(3)(B) of the Exchange Act, added by the Dodd-Frank Act. The amendments added new paragraph (a)(7) to require an NRSRO to include an unaudited report on the NRSRO's internal control structure with its annual submission of reports pursuant to Rule 17g-3. The time burden change is due to an increase of 1,650 annual hours and the cost change is due to an increase of $333,333 that are both attributable to new Rule 17g-3(a)(7).

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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

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Common Form ICR:  No

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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: 09/10/2014

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