OMWI SDBMS OMB Supporting Statement (3-24-15)

SUPPORTING STATEMENT
FOR THE PAPERWORK REDUCTION ACT SUBMISSION FOR A NEW
INFORMATION COLLECTION
“Supplier Diversity Business Management System”
Justification
1.

Circumstances Making the Collection of Information Necessary

The Securities and Exchange Commission (Commission) is required under Section
342(c) of the Dodd Frank Wall Street and Reform Act (the Dodd-Frank Act) to develop
standards and procedures for ensuring the fair inclusion of minority-owned and women-owned
businesses in all of the Commission’s business activities. 12 U.S.C. § 5452(c)(1). In addition,
the Commission is required to develop standards for coordinating technical assistance to
minority-owned and women-owned businesses. 12 U.S.C. §5452(b)(2)(B). In order to implement
the requirements of Section 342 of the Dodd-Frank Act, the Commission is developing a new
electronic Supplier Diversity Business Management System (the System) to collect up-to-date
business information and capabilities statements from diverse suppliers interested in doing
business with the Commission. The information collected in the System will allow the
Commission to update and more effectively manage its current internal repository of diverse
suppliers. Further, the information in the System will also allow the Commission to measure the
effectiveness of its technical assistance and outreach efforts, and target areas where additional
program efforts are necessary.
2.

Purpose and Use of the Information Collection

The purpose of the proposed information collection is to allow diverse suppliers
interested in doing business with the Commission to provide certain pertinent business
information. This business information will allow the Commission to (1) learn about a potential
supplier’s interest in the Commission’s contracting opportunities, (2) communicate with
interested suppliers when opportunities arise, and (3) gather information on vendors and supplier
diversity program activities to guide initiatives and facilitate Congressionally-mandated
reporting on the Commission’s contract awards.
The System will manage and track all business information, communication and
collateral documentation associated with each supplier registered. Improvement of the supplier
registration and management process is anticipated as follows: 1) suppliers will have the ability
to self-register; 2) accuracy of the data is expected to improve, as much of the data captured will
be entered by the “source” (diverse supplier); 3) external customer service will be improved, as
staff will have the ability to accurately pull tailored supplier listings from the system for
dissemination of Commission contract opportunities; 4) internal customer service will be
improved , as the ability to quickly pull tailored supplier listings will allow for ease in
conducting procurement market research for users of this application throughout the

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Commission; and 5) tracking of outreach efforts, monitoring of communication with vendors,
and overall reporting will be more efficient, as a centralized repository for diverse supplier
information will be created.

3.

Consideration Given to Information Technology

Information will be collected in the System via e-filed, dynamic form-based technology.
The form will be accessible via a web-link. The company point of contact will complete a
profile consisting of basic contact data and information on the capabilities of the business. The
profile will include a series of questions, some of which are based on the data that the individual
enters. Drop-down lists will be included where appropriate to increase ease of use. This also
reduces burden by alleviating the need to fully type out a response to every question. The
information collection is voluntary.
4.

Duplication of Information

Although some basic business data is available in the System for Award Management,
the Commission’s collection of information from diverse suppliers will enable the agency to
specifically target minority-owned and women-owned suppliers, and gauge its outreach efforts
related to those businesses. The collection also will allow suppliers to provide specific
information on capabilities that specifically meet the Commission’s contracting needs. Taken
together, this will allow for the efficient and effective identification of suppliers in a manner that
both fulfils the requirements under Section 342(c) of the Dodd Frank Act, and is tailored to the
Commission’s purchasing space.
5.

Reducing the Burden on Small Businesses

The burden of compliance with the information collection requirement does not
disparately impact small businesses or other small entities. The information being captured is
readily known and available to the respondents. Additionally, the electronic registration format
allows businesses to complete and submit their information online, without any printing, manual
entries, or faxing required.

6.

Consequences of Not Requiring Collection

Without the implementation and use of the information collection, the Commission
would be limited in capturing the outreach and technical assistance information that Congress
requires pursuant to Section 342(c) of the Dodd-Frank Act.
Additionally, the Commission’s business information on diverse suppliers is currently
maintained in disparate locations. Correspondence with diverse suppliers is similarly maintained
in different locations and formats. This lack of a centralized repository for basic business
information, supplier business collateral and communication documentation creates
inefficiencies for staff accessing and utilizing these information sets to deliver appropriate

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program services, and track and report on program activities. Suppliers also do not currently
have the ability to self-register as diverse suppliers with the Commission. Because all entries
must be made manually by Commission staff based on hardcopy paper documents, the process of
collecting the information subject to data loss and data entry error.
7.

Inconsistencies with Guidelines in 5 CFR 1320.8(d)

There are no special circumstances. This collection is consistent with the guidelines in
5 CFR 1320.8(d).
8.

Consultations Outside the Agency

On January 27, 2015, the Commission published a notice in the Federal Register (80 FR
4320) soliciting comments on the proposed information collection for 60 days. The Commission
received no comments.
9.

Payment or Gift to Respondents
There are no gifts or payments to respondents.

10.

Assurance of Confidentiality

The provision of the information on the part of interested vendors is voluntary and is for
basic business profile data that does not require any assurances of confidentiality.

11.

Sensitive Questions
No questions will be asked that are of a personal or sensitive nature.

12.

Estimate of Respondent Reporting Burden

The Commission anticipates that the burdens imposed by the Database may vary slightly
depending on the amount of information the company elects to provide. This is a one-time, initial
burden. With that in mind, the Commission estimates the burdens as follows:
Estimated number of annual responses = 500
Estimated annual reporting burden =

250 hours (30 minutes per submission)

For respondents, assuming an annual income of $43,000 (approximate per capita income in the
U.S) and total labor of 2,080 hours per year, the hourly rate would be $20.70. The Commission
estimates it will take a 30 minute session to complete the form, and therefore the estimated cost
per respondent to complete the form would be approximately $10.30. Assuming 500 suppliers
complete and submit this form, the total cost would be $5,150. This is a one-time cost, as the

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form will be submitted just once. There are no significant subsequent costs associated with this
information collection.
13.

Estimate of Total Annualized Cost Burden
There are no costs associated with this information collection.

14.

Estimate of Cost to Federal Government

The estimated annualized cost to the government, that includes contract cost, design,
development and operations over the three-year term of approval being sought, is approximately
$233,333. The initial cost for design, development and implementation is $450,000 and the
maintenance and operations in the out-years is approximately $125,000. This estimate is solely
for purposes of the Paperwork Reduction Act.
15.

Explanation of Changes in Burden
This is a new collection of information.

16.

Information Collections Planned for Statistical Purposes

Not applicable. The information collected on individual suppliers is not used for
tabulation, statistical analysis or publication. The Commission is required to provide a report to
Congress annually regarding contract awards and total amounts paid to suppliers that have been
identified as minority-owned and/or women-owned businesses. While the report to Congress is
made public, individual business information supplied by contractors is not published.
17.

Display of OMB Expiration Date

We request authorization to omit the expiration date on the electronic version of the form
for design and IT project scheduling reasons. The OMB control number will be displayed
18.

Exceptions to Certification
This collection complies with the requirements in 5 CFR 1320.9.

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