60 day notice

SECURITIES AND EXCHANGE COMMISSION
Proposed Collection; Comment Request
Upon Written Request, Copies Available From:
Securities and Exchange Commission
Office of FOIA Services
100 F Street, NE,
Washington, DC 20549-2736
Extension: Rule 17g-4
SEC File No. 270-566, OMB Control No. 3235-0627
Notice is hereby given that pursuant to the Paperwork Reduction Act of 1995 (44 U.S.C.
3501 et seq.) (“PRA”), the Securities and Exchange Commission (“Commission”) is soliciting
comments on the existing collection of information provided for in Rule 17g-4 (17 CFR 240.17g-4)
under the Securities Exchange Act of 1934 (15 U.S.C. 78a et seq.) (“Exchange Act”). The
Commission plans to submit this existing collection of information to the Office of Management
and Budget (“OMB”) for extension and approval.
The Credit Rating Agency Reform Act of 2006 added a new section 15E, “Registration
of Nationally Recognized Statistical Rating Organizations,”1 to the Exchange Act. Pursuant to
the authority granted under section 15E of the Exchange Act, the Commission adopted Rule
17g-4, which requires that a nationally recognized statistical rating organization (“NRSRO”)
establish, maintain, and enforce written policies and procedures to prevent the misuse of material
nonpublic information, including policies and procedures reasonably designed to prevent: (a) the
inappropriate dissemination of material nonpublic information obtained in connection with the
performance of credit rating services; (b) a person within the NRSRO from trading on material
nonpublic information; and (c) the inappropriate dissemination of a pending credit rating action.2
There are 10 credit rating agencies registered with the Commission as NRSROs under
section 15E of the Exchange Act, which have already established the policies and procedures
1
2

15 U.S.C. 78o-7.
See 17 CFR 240.17g-4; Release No. 34-55231 (Feb. 2, 2007), 72 FR 6378 (Feb. 9, 2007);
Release No. 34-55857 (June 5, 2007), 72 FR 33564 (June 18, 2007).

-2required by Rule 17g-4. Based on staff experience, an NRSRO is estimated to spend an average
of approximately 10 hours per year reviewing its policies and procedures regarding material
nonpublic information and updating them (if necessary), resulting in an average industry-wide
annual hour burden of approximately 100 hours.3
Written comments are invited on: (a) whether the proposed collection of
information is necessary for the proper performance of the functions of the Commission,
including whether the information shall have practical utility; (b) the accuracy of the
Commission's estimates of the burden of the proposed collection of information; (c) ways to
enhance the quality, utility, and clarity of the information on respondents; and (d) ways to
minimize the burden of the collection of information on respondents, including through the use
of automated collection techniques or other forms of information technology. Consideration will
be given to comments and suggestions submitted in writing within 60 days of this publication.
The Commission may not conduct or sponsor a collection of information unless it
displays a currently valid control number. No person shall be subject to any penalty for failing to
comply with a collection of information subject to the PRA that does not display a valid OMB
control number.
Please direct your written comments to: Charles Riddle, Acting Chief Information
Officer, Securities and Exchange Commission, c/o Candace Kenner, 100 F St NE, Washington,
DC 20549 or send an email to: PRA_Mailbox@sec.gov.
signed by
EDUARDO Digitally
EDUARDO ALEMAN
2018.11.28
ALEMAN Date:
15:45:31 -05'00'

Eduardo Aleman
Assistant Secretary
November 28, 2018

3

10 currently registered NRSROs x 10 hours = 100 hours.