Principal Transaction Exemption
OMB Number 1210-0157
October 2017
Justification for Nonmaterial/Non-substantive Change
The Department is hereby submitting a nonmaterial/non-substantive change request to the Office of Management and Budget (OMB) regarding a modification made by the Department’s Final Conflict of Interest Rule to the information collection request (ICR) contained in the Department’s Principal Transaction Exemption. The exemption was approved by OMB under control number 1210-0157 and is scheduled to expire on June 30, 2019.
The information collections in the Department’s Principal Transactions Exemption contain start-up costs, which were described as Year 1 costs in the original ICR, and ongoing costs, which were described as Year 2 and Year 3 costs in the original ICR. The Department’s Final Rule extends the transition period through July 1, 2019. This rule has the effect of making the Year 2 and Year 3 costs inactive for the remainder of the existing approval of the ICR and spreads the Year 1 costs across the full existing three year approval period.
The modification to the ICR is deregulatory, because it eliminates the requirement to produce a total of 6 million disclosures during the second and third years of the ICR’s approval period resulting in a total hour burden reduction of approximately 112,000 hours (at an equivalent cost of $6.2 million) and a total cost savings of approximately $862.9 million during the second and third years of the ICR approval period only. This savings produces an annualized reduction in the number of responses over the three year period shown in ROCIS of 1,979,000 disclosures (due to rounding), an annualized reduction of the hour burden of 38,000 hours (due to rounding), and a $287,600,000 reduction to the cost burden (due to rounding).
For purposes of ROCIS database entries, the burden has been reduced over the three-year approval period to 821,000 responses (rounded), 15,000 hours (rounded), and $651,800,000 (rounded) annually.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | NOTE TO REVIEWER: |
| Author | Anja Decressin |
| File Modified | 0000-00-00 |
| File Created | 2021-01-21 |