Rule 17g-8 Policies and procedures and Rule 17g-9 Standards of training, experience, and competence for credit analysts

Forms and Documents

Document Name	Status
PRA Rule 17g-8 and 9 Supporting Statement_2018 renewal_final revised.docx Supporting Statement A	2018-10-22

IC Document Collections

IC ID	Document Title	Status
216057	Rule 17g-9 annual recordkeeping costs to retain outside professionals	Modified
216056	Rule 17g-9 annual recordkeeping burden per credit analyst	Modified
216055	Rule 17g-9 annual recordkeeping burden based on number of credit analysts	Unchanged
216047	Rule 17g-9 one-time recordkeeping burden based on number of credit analysts	Removed
216046	Rule 17g-9 annual recordkeeping	Modified
216045	Rule 17g-9 one-time recordkeeping	Removed
216044	Rule 17g-8(c) annual recordkeeping burden	Unchanged
216043	Rule 17g-8(c) one-time recordkeeping burden	Removed
216042	Rule 17g-8(b) annual recordkeeping burden	Unchanged
216041	Rule 17g-8(b) one-time recordkeeping burden	Removed
216040	17g-8(a) internet website publication annual burden	Unchanged
216039	Rule 17g-8(a) annual recordkeeping burden	Unchanged
216038	Rule 17g-8(a) one-time recordkeeping burden	Removed

ICR Details

OMB Control No: 3235-0693	ICR Reference No: 201806-3235-011
Status: Active	Previous ICR Reference No: 201412-3235-009
Agency/Subagency: SEC	Agency Tracking No: OCR-270-645
Title: Rule 17g-8 Policies and procedures and Rule 17g-9 Standards of training, experience, and competence for credit analysts
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: 10/24/2018
	Date Received in OIRA: 06/08/2018
Terms of Clearance:

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	10/31/2021	36 Months From Approved	10/31/2018
Responses	80	0	130
Time Burden (Hours)	26,454	0	34,394
Cost Burden (Dollars)	521,600	0	1,357,866

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Abstract: Rule 17g-8 would require nationally recognized statistical rating organizations ("NRSROs") to establish, maintain and enforce certain policies and procedures relating to credit rating methodologies, the use of credit rating symbols, and look-back procedures for departing NRSRO employees. Rule 17g-9 implements Section 936 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, which requires the Securities and Exchange Commission to issue rules reasonably designed to ensure that any person employed by a nationally recognized statistical rating organization to determine credit ratings meets standards of training, experience, and competence necessary to produce accurate ratings for the categories of issuers whose securities the person rates and is tested for knowledge of the credit rating process.

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Authorizing Statute(s): US Code: 15 USC 78o-8, 78o-7(s), 78o-7(r) Name of Law: Securities Exchange Act of 1934
   US Code: 15 USC 78o-7, 78o-7(h)(4)(A)(ii), Name of Law: Securities Exchange Act of 1934
  

Citations for New Statutory Requirements: PL: Pub.L. 111 - 203 932(a)(4), 932(a)(8) 936, 938 Name of Law: Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010

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Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
	Not associated with rulemaking

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Federal Register Notices & Comments
60-day Notice:	Federal Register Citation:	Citation Date:
	83 FR 6908	02/15/2018
30-day Notice:	Federal Register Citation:	Citation Date:
	83 FR 22300	05/14/2018
Did the Agency receive public comments on this ICR? No

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Number of Information Collection (IC) in this ICR: 8

IC Title	Form No.	Form Name
Rule 17g-8(a) annual recordkeeping burden
17g-8(a) internet website publication annual burden
Rule 17g-8(b) annual recordkeeping burden
Rule 17g-8(c) annual recordkeeping burden
Rule 17g-9 annual recordkeeping
Rule 17g-9 annual recordkeeping burden based on number of credit analysts
Rule 17g-9 annual recordkeeping burden per credit analyst
Rule 17g-9 annual recordkeeping costs to retain outside professionals
Rule 17g-8(a) one-time recordkeeping burden
Rule 17g-8(c) one-time recordkeeping burden
Rule 17g-9 one-time recordkeeping
Rule 17g-8(b) one-time recordkeeping burden
Rule 17g-9 one-time recordkeeping burden based on number of credit analysts

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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	80	130	0	0	-50	0
Annual Time Burden (Hours)	26,454	34,394	0	0	-7,940	0
Annual Cost Burden (Dollars)	521,600	1,357,866	0	0	-836,266	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:

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Annual Cost to Federal Government: $0

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]? 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: 06/08/2018

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