OMB Supporting Statement DUSTR Adpoting.Final.5-17-2019

SUPPORTING STATEMENT FOR FINAL RULES
UNDER THE SECURITIES ACT OF 1933 AND
THE SECURITIES EXCHANGE ACT OF 1934
This submission, pursuant to the Paperwork Reduction Act of 1995, 44 U.S.C.
§3501, et seq., consists of this supporting statement and the following attachments:
A.

JUSTIFICATION

1.

CIRCUMSTANCES MAKING THE COLLECTION OF INFORMATION
NECESSARY

On August 17, 2018, the Securities and Exchange Commission (the
“Commission”) adopted rule and form amendments to address disclosure requirements
that have become redundant, duplicative, overlapping, outdated, or superseded as a result
of other Commission disclosure requirements, U.S. Generally Accepted Accounting
Principles (“U.S. GAAP”), International Financial Reporting Standards (“IFRS”), or
changes in the information environment. The amendments impact the following
information collections: Form S-1 (OMB Control No. 3235-0065); Form S-3 (OMB
Control No. 3235-0073); Form S-11 (OMB Control No. 3235-0067); Form S-4 (OMB
Control No. 3235-0324); Form F-1 (OMB Control No. 3235-0258); Form F-3 (OMB
Control No. 3235-0256); Form F-4 (OMB Control No. 3235-0325); Form 1-A (OMB
Control No. 3235-0286); Form 1-SA (OMB Control No. 3235-0721); Form 10 (OMB
Control No. 3235-0064); Form 20-F (OMB Control No. 3235-0288); Form 10-Q (OMB
Control No. 3235-0070); and Form 10-K (OMB Control No. 3235-0063). The
amendments are a result of the Division of Corporation Finance’s Disclosure
Effectiveness Initiative and a part of the Commission’s efforts to implement title LXXII,
section 72002(2) of the Fixing America’s Surface Transportation Act.
A copy of Commission Release No. 33-10532, which contains the amendments, is
attached.
2.

PURPOSE OF THE INFORMATION COLLECTION

The purpose of the amendments is to facilitate the disclosure of information to
investors, while simplifying and updating disclosure requirements, without significantly
altering the total mix of information provided to investors.
3.

CONSIDERATION GIVEN TO INFORMATION TECHNOLOGY

The collection of information requirements of the amendments are set forth in
amended rules and forms. All of the affected forms are filed electronically with the
Commission using the Commission’s Electronic Data Gathering, Analysis and Retrieval
(“EDGAR”) system.

4.

DUPLICATION OF INFORMATION
The amendments do not duplicate, overlap, or conflict with other federal rules.

5.

REDUCING THE BURDEN ON SMALL ENTITIES

The amendments would affect all registrants that file the affected registration
statements and periodic and current reports. As the purpose of the amendments is to
address current Commission disclosure requirements that have become redundant,
duplicative, overlapping, outdated, or superseded, the Commission preliminarily believes
that the amendments would not have a significant impact on small businesses.
6.

CONSEQUENCES OF NOT CONDUCTING COLLECTION

The amendments affect numerous Commission collections of information as
indicated in this supporting statement by removing redundant, duplicative, overlapping,
outdated or superseded disclosure in those registration statements and reports. The
regulations and forms set forth the disclosure requirements for registration periodic and
current reports filed by companies to help investors make informed investment and
voting decisions. Less frequent collection would deprive investors of access to
information that is important to their voting and investment decisions.
7.

SPECIAL CIRCUMSTANCE
There are no special circumstances in connection with these amendments.

8.

CONSULTATIONS WITH PERSONS OUTSIDE THE AGENCY

The Commission issued a release soliciting comment on the new “collection of
information” requirements and associated paperwork burdens. Comments on
Commission releases are generally received from registrants, investors, and other market
participants. In addition, the Commission and staff participate in an ongoing dialogue
with representatives of various market participants through public conferences, meetings
and informal exchanges. The Commission considered all comments received.
Comments received are available at https://www.sec.gov/comments/s7-1516/s71516.htm. Commission received no substantive comments relating to our
Paperwork Reduction Act analysis.
9.

PAYMENT OR GIFT TO RESPONDENTS
No payment or gift has been provided to any respondents.

10.

CONFIDENTIALITY

All documents submitted to the Commission are available to the public via the
EDGAR system.

2

11.

SENSITIVE QUESTIONS

The following information collections collect basic Personally Identifiable
Information (PII) that may include a name and job title: Form S-1, Form S-3, Form S-4,
Form S-11, Form F-1, Form F-3, Form F-4, Form 1-A, Form 1-SA, Form 10, Form 10-K,
Form 10-Q, and Form 20-F. However, the agency has determined that the information
collection does not constitute a system of record for purposes of the Privacy Act.
Information is not retrieved by a personal identifier. In accordance with Section 208 of
the E-Government Act of 2002, the agency has conducted a Privacy Impact Assessment
(PIA) of the EDGAR system, in connection with this collection of information. The
EDGAR PIA, published on January 29, 2016, is provided as a supplemental document
and is also available at https://www.sec.gov/privacy.
No information of a sensitive nature, including social security numbers, will be
required under Regulation S-K, and Regulation S-X. These collections of information do
not collect personally identifiable information (PII). The agency has determined that a
system of records notice (SORN) and privacy impact assessment (PIA) are not required
in connection with the collection of information.
12. and 13.

ESTIMATES OF HOUR AND COST BURDENS1

The amendments update and simplify several current disclosure requirements.
Specifically, the amendments:


Eliminate certain Commission disclosure requirements that are redundant or
duplicative of requirements in U.S. GAAP, IFRS, or other Commission disclosure
requirements;



Streamline certain overlapping Commission disclosure requirements by deleting
or integrating provisions that address disclosure topics that are covered by other
Commission disclosure rules;



Revise certain Commission disclosure requirements that are outdated; and



Revise certain superseded Commission disclosure requirements to update and
conform these provisions to recent legislation, more recently updated Commission
disclosure requirements, or more recently updated U.S. GAAP requirements.

The amendments to eliminate the redundancy, duplication, and overlap in current
Commission disclosure requirements should result in fewer rules and requirements for
1

The paperwork burdens for Regulation S-X and Regulation S-K are imposed through the forms
that are subject to the requirements in these regulations and are reflected in the analysis of those
forms. To avoid a PRA inventory reflecting duplicative burdens and for administrative
convenience, we assign a one-hour burden to each of these regulations.

3

respondents to consider in their compliance efforts even as they are preparing a
substantially similar level of disclosures. As such, except for the amendment to eliminate
the requirement to disclose the ratio of earnings to fixed charges, which may decrease the
paperwork burden, we believe that the elimination of these redundant, duplicative, and
overlapping Commission requirements would marginally reduce, if at all, respondents’
overall paperwork burden.
Similarly, we expect that the amendments to eliminate outdated requirements
would marginally reduce the information collection burden on respondents by eliminating
any efforts that were undertaken to prepare these disclosures. With the exception of the
amendments to require the disclosure of an issuer’s website address and the ticker symbol
of their common equity that is publicly traded and the amendments to eliminate the
requirement to provide market price disclosure for such common equity, the amendments
related to outdated requirements would have no change or a minimal reduction in the
paperwork burden associated with preparing such information when respondents are
providing information in response to Forms 10, 10-K, 20-F, S-1, and F-1.
Finally, we believe that our amendments to update superseded Commission
disclosure requirements would marginally reduce, if at all, respondents’ collection of
information burden, except for the extension of the application of Rule 3-04 of
Regulation S-X to interim period disclosures,2 which we estimate may marginally
increase the paperwork burden. While we intend to eliminate any existing confusion
related to contradictory and inconsistent requirements, in many instances, we believe
respondents are not providing information in response to the requirements that we are
deleting. Instead, we believe they provide information in response to U.S. GAAP or
other Commission disclosure requirements that have been updated more recently, rather
than the superseded requirement subject to the amendments. As a result, we do not
believe these amendments would result in a change to respondents’ overall paperwork
burden.
For purposes of our analysis of the amendments, we have assumed that the
impacted disclosures are prepared internally without the assistance of outside
professionals. As such, the estimated increases or reductions in the paperwork burdens
are reflected solely in hours.
Incremental Paperwork Burden under the Amendments for Exchange Act Forms
Table 1 reflects the reduction in burden hours on the listed Exchange Act forms
from the amendments to eliminate the requirement to disclose the market prices for an
issuer’s common equity for the two most recent fiscal years. We estimate that affected
respondents would experience a two hour reduction in their annual paperwork burden for

2

The extension of Rule 3-04 of Regulation S-X addresses both overlapping and superseded
disclosure issues and is presented in both Sections III.B.2 and V.B.2 of the Adopting Release.

4

the forms listed below.3 We also estimate that there are a total of 8,862 annual responses
made in connection with Forms 10-K and 20-F.
Table 1

Form 10-K
Form 20-F

Estimated number
of annual
responses
(A)
8,137
725

Reduction in
incremental burden
hours/form (B)
(2)
(2)

Total incremental
burden hours
reduction
(C)=(A)*(B)
(16,274)
(1,450)

Internal company
time
(D)=(C)
(16,274)
(1,450)

The amendments to interim periods extend the requirements under Rule 3-04 of
Regulation S-X to disclose changes in stockholders’ equity and dividends per share for
each class of shares. Currently, these disclosures are not required for interim periods.
While this creates a new disclosure requirement, this new disclosure is generally readily
available from the respondents’ preparation of other aspects of its interim financial
statements. As a result, we estimate that the amendments would increase the paperwork
burden by 0.5 hours each time such information is required for inclusion in Forms 10,
10-Q, and 1-SA. We also estimate that there are a total of 23,178 annual responses in
connection with the listed Exchange Act forms. Table 2 reflects this nominal increase in
burden hours for these new interim period disclosures in the listed Exchange Act forms.
Table 2

Form 10
Form 10-Q
Form 1-SA

Estimated number
of annual
responses
(A)
216
22,907
55

Increase in
incremental burden
hours/form (B)
0.5
0.5
0.5

Total incremental
burden hours
increase
(C)=(A)*(B)
108
11,453.5
27.5

Internal company
time
(D)=(C)
108
11,453.5
27.5

Incremental Paperwork Burden under the Amendments for Securities Act
Registration Statements
Table 3 reflects the reduction in burden hours on the listed Securities Act forms
that would result from the amendments to eliminate the requirement to disclose the
market prices for an issuer’s common equity for the two most recent fiscal years. As
noted above, we estimate that affected respondents would experience a two hour
reduction in their annual paperwork burden for the forms listed below. We also estimate
3

In the Proposing Release we included estimates for the minimal paperwork burden increase
associated with the amendments to require disclosure of an issuer’s ticker symbol and internet
address. Upon further consideration, we are not making a separate burden adjustment for these
two amendments. We believe the burdens for these amendments will mainly be incurred upon
initial disclosure and not in subsequent periods and that the burden associated with these
amendments are fully offset by the elimination of the market price disclosures discussed here.
Accordingly, we believe the two-hour reduction in burden hours here will encompass the
combined effect of these related changes.

5

that there are a total of 1,618 annual responses made in connection with the listed
Securities Act forms.
Table 3

Form S-1
Form S-4
Form S-11
Form F-1
Form F-4

Estimated number
of annual
responses
(A)
901
551
64
63
39

Reduction in
incremental burden
hours/form (B)
(2)
(2)
(2)
(2)
(2)

Total incremental
burden hours
reduction
(C)=(A)*(B)
(1,802)
(1,102)
(128)
(126)
(78)

Internal company
time
(D)=(C)
(1,802)
(1,102)
(128)
(126)
(78)

Table 4 reflects the increase in burden hours for the listed Securities Act forms
related to the amendments to extend to interim periods the requirements in Rule 3-04 of
Regulation S-X to disclose changes in stockholders’ equity and dividends per share for
each class of shares, as discussed above. As a result, we estimate that the amendments
would increase the paperwork burden by 0.5 hour and that there are a total of 1,730
annual responses in connection with the listed Securities Act forms. The following table
reflects this nominal increase in burden hours for these new interim period disclosures on
the listed Securities Act forms.
Table 4

Form S-1
Form S-4
Form S-11
Form F-1
Form F-4
Form 1-A

Estimated number
of annual
responses
(A)
901
551
64
63
39
112

Increase in
incremental burden
hours/form (B)
0.5
0.5
0.5
0.5
0.5
0.5

Total incremental
burden hours
increase
(C)=(A)*(B)
450.5
275.5
32
31.5
19.5
56

Internal company
time
(D)=(C)
450.5
275.5
32
31.5
19.5
56

Table 5 reflects the change in burden hours in the listed Securities Act forms that
would result from the amendments to Items 503(d) and 601(b)(12) of Regulation S-K that
eliminate the requirement that issuers disclose the ratio of earnings to fixed charges when
the issuer is registering debt securities, or the ratio of combined fixed charges and
preference dividends to earnings when the issuer is registering preference securities.
Depending on the size and complexity of an issuer, the paperwork burden associated with
these requirements may vary significantly. We estimate that affected issuers would on
average experience a four hour reduction in the paperwork burden of the forms listed
below. We also estimate that there are a total of 1,722 annual responses made in
connection with the referenced forms.

6

Table 5

Form S-1
Form S-3
Form S-4
Form S-11
Form F-1
Form F-3
Form F-4

14.

Estimated number
of annual
responses
(A)
450
800
300
32
32
78
30

Reduction in
incremental burden
hours/form (B)
(4)
(4)
(4)
(4)
(4)
(4)
(4)

Total incremental
burden hours
reduction
(C)=(A)*(B)
(1,800)
(3,200)
(1,200)
(128)
(128)
(312)
(120)

Internal company
time
(D)=(C)
(1,800)
(3,200)
(1,200)
(128)
(128)
(312)
(120)

COST TO FEDERAL GOVERNMENT
The estimated cost of preparing the amendments was approximately $150,000.

15.

REASON FOR CHANGES IN BURDEN

The amendments will increase the burdens for registrants to prepare and review
the disclosure of their ticker symbol, internet address, and interim disclosure of changes
in stockholders’ equity and dividends per share for each class of shares. However, the
amendments will reduce the burdens for registrants by eliminating the requirement to
disclose the market prices for an issuer’s common equity for the two most recent fiscal
years for listed securities and the requirement to disclose the ratio of earnings to fixed
charges when debt securities are registered and the ratio of combined fixed charges and
preference dividends to earnings when preferred securities are registered. As we have
assumed that the changes will only impact the internal efforts to respond to the collection
of information, Table 6 illustrates only the changes in hour burdens from the burden
estimates currently approved by OMB. Additionally, the Supporting Statement for the
Proposed Rules included changes to the burden hours for Forms SF-1 and SF-3 to only
reflect the amendments related to the issuer’s ticker symbol and internet address. As
noted in footnote 3, because we have not separately reflected the burden hours for those
two amendments in the adopting release, this document does not include any change in
the burden estimates for Forms SF-1 and SF-3. Column (A) represents the current
burden hour inventory approved by OMB. Column (B) represents the new burden
estimates under the amendments. Column (C) represents the program change, which
encompasses the change in the burden estimates attributable to the amendment. For the
net change in burdens and costs expected to result for each of the individual collections
of information, see the attached short statements.

7

Table 6:4

Form 10-K
Form 10-Q
Form 10
Form 20-F
Form 1-SA
Form S-1
Form S-3
Form S-4
Form S-11
Form F-1
Form F-3
Form F-4
Form 1-A

16.

Current Burden Hours
(A)

Revised Burden Hours
(B)

14,217,344
3,241,957
11,774
480,226
8,763
150,998
196,930
565,079
12,514
26,980
4,760
14,245
98,309

14,201,070
3,253,411
11,882
478,776
8,791
147,846
193,730
563,052
12,290
26,757
4,448
14,066
98,365

Program Change
Burden Hours
(C)
(16,274)
11,454
108
(1,450)
28
(3,152)
(3,200)
(2,027)
(224)
(223)
(312)
(179)
56

INFORMATION COLLECTION PLANNED FOR STATISTICAL
PURPOSES
The information collections do not employ statistical methods.

17.

APPROVAL TO OMIT OMB EXPIRATION DATE

We request authorization to omit the expiration date on the electronic version of
the form. Including the expiration date on the electronic version of the form will result in
increased costs because the need to make changes to the form may not follow the
application’s scheduled version release dates. The OMB control number will be
displayed.
18.

EXCEPTIONS TO CERTIFICATION FOR PAPERWORK REDUCTION
ACT SUBMISSIONS

There are no exceptions to certification for Paperwork Reduction Act
submissions.
B.

STATISTICAL METHODS
The information collections do not employ statistical methods.

4

Figures in Table 6 have been rounded to the nearest whole number.

8

FORM 10-K SHORT STATEMENT
The amendments adopted in Release No. 33-10532 address disclosure
requirements that have become redundant, duplicative, overlapping, outdated, or
superseded as a result of other Commission disclosure requirements, U.S. Generally
Accepted Accounting Principles, International Financial Reporting Standards, or changes
in the information environment. The purpose of the rule amendments is to facilitate the
disclosure of information to investors, while simplifying and updating disclosure
requirements, without significantly altering the total mix of information provided to
investors. We anticipate that the amendments will decrease the burdens and costs for
registrants to prepare and review filings for many forms and will increase the burden and
costs for a limited number of forms. For purposes of the PRA, we estimate that the
amendments to Form 10-K will result in a net decrease of 16,274 burden hours. We have
not provided an estimate for professional cost changes because we have assumed that the
changes will only impact the internal efforts to respond to the collection of information.

9

FORM 10-Q SHORT STATEMENT
The amendments adopted in Release No. 33-10532 address disclosure
requirements that have become redundant, duplicative, overlapping, outdated, or
superseded as a result of other Commission disclosure requirements, U.S. Generally
Accepted Accounting Principles, International Financial Reporting Standards, or changes
in the information environment. The purpose of the rule amendments is to facilitate the
disclosure of information to investors, while simplifying and updating disclosure
requirements, without significantly altering the total mix of information provided to
investors. We anticipate that the amendments will decrease the burdens and costs for
registrants to prepare and review filings for many forms and will increase the burden and
costs for a limited number of forms. For purposes of the PRA, we estimate that the
amendments to Form 10-Q will result in a net increase of 11,454 burden hours. We have
not provided an estimate for professional cost changes because we have assumed that the
changes will only impact the internal efforts to respond to the collection of information.

10

FORM 10 SHORT STATEMENT
The amendments adopted in Release No. 33-10532 address disclosure
requirements that have become redundant, duplicative, overlapping, outdated, or
superseded as a result of other Commission disclosure requirements, U.S. Generally
Accepted Accounting Principles, International Financial Reporting Standards, or changes
in the information environment. The purpose of the rule amendments is to facilitate the
disclosure of information to investors, while simplifying and updating disclosure
requirements, without significantly altering the total mix of information provided to
investors. We anticipate that the amendments will decrease the burdens and costs for
registrants to prepare and review filings for many forms and will increase the burden and
costs for a limited number of forms. For purposes of the PRA, we estimate that the
amendments to Form 10 will result in a net increase of 108 burden hours. We have not
provided an estimate for professional cost changes because we have assumed that the
changes will only impact the internal efforts to respond to the collection of information.

11

FORM 20-F SHORT STATEMENT
The amendments adopted in Release No. 33-10532 address disclosure
requirements that have become redundant, duplicative, overlapping, outdated, or
superseded as a result of other Commission disclosure requirements, U.S. Generally
Accepted Accounting Principles, International Financial Reporting Standards, or changes
in the information environment. The purpose of the rule amendments is to facilitate the
disclosure of information to investors, while simplifying and updating disclosure
requirements, without significantly altering the total mix of information provided to
investors. We anticipate that the amendments will decrease the burdens and costs for
registrants to prepare and review filings for many forms and will increase the burden and
costs for a limited number of forms. For purposes of the PRA, we estimate that the
amendments to Form 20-F will result in a net decrease of 1,450 burden hours. We have
not provided an estimate for professional cost changes because we have assumed that the
changes will only impact the internal efforts to respond to the collection of information.

12

FORM 1-SA SHORT STATEMENT
The amendments adopted in Release No. 33-10532 address disclosure
requirements that have become redundant, duplicative, overlapping, outdated, or
superseded as a result of other Commission disclosure requirements, U.S. Generally
Accepted Accounting Principles, International Financial Reporting Standards, or changes
in the information environment. The purpose of the rule amendments is to facilitate the
disclosure of information to investors, while simplifying and updating disclosure
requirements, without significantly altering the total mix of information provided to
investors. We anticipate that the amendments will decrease the burdens and costs for
registrants to prepare and review filings for many forms and will increase the burden and
costs for a limited number of forms. For purposes of the PRA, we estimate that the
amendments to Form 1-SA will result in a net increase of 28 burden hours. We have not
provided an estimate for professional cost changes because we have assumed that the
changes will only impact the internal efforts to respond to the collection of information.

13

FORM S-1 SHORT STATEMENT
The amendments adopted in Release No. 33-10532 address disclosure
requirements that have become redundant, duplicative, overlapping, outdated, or
superseded as a result of other Commission disclosure requirements, U.S. Generally
Accepted Accounting Principles, International Financial Reporting Standards, or changes
in the information environment. The purpose of the rule amendments is to facilitate the
disclosure of information to investors, while simplifying and updating disclosure
requirements, without significantly altering the total mix of information provided to
investors. We anticipate that the amendments will decrease the burdens and costs for
registrants to prepare and review filings for many forms and will increase the burden and
costs for a limited number of forms. For purposes of the PRA, we estimate that the
amendments to Form S-1 will result in a net decrease of 3,152 burden hours. We have
not provided an estimate for professional cost changes because we have assumed that the
changes will only impact the internal efforts to respond to the collection of information.

14

FORM S-3 SHORT STATEMENT
The amendments adopted in Release No. 33-10532 address disclosure
requirements that have become redundant, duplicative, overlapping, outdated, or
superseded as a result of other Commission disclosure requirements, U.S. Generally
Accepted Accounting Principles, International Financial Reporting Standards, or changes
in the information environment. The purpose of the rule amendments is to facilitate the
disclosure of information to investors, while simplifying and updating disclosure
requirements, without significantly altering the total mix of information provided to
investors. We anticipate that the amendments will decrease the burdens and costs for
registrants to prepare and review filings for many forms and will increase the burden and
costs for a limited number of forms. For purposes of the PRA, we estimate that the
amendments to Form S-3 will result in a net decrease of 3,200 burden hours. We have
not provided an estimate for professional cost changes because we have assumed that the
changes will only impact the internal efforts to respond to the collection of information.

15

FORM S-4 SHORT STATEMENT
The amendments adopted in Release No. 33-10532 address disclosure
requirements that have become redundant, duplicative, overlapping, outdated, or
superseded as a result of other Commission disclosure requirements, U.S. Generally
Accepted Accounting Principles, International Financial Reporting Standards, or changes
in the information environment. The purpose of the rule amendments is to facilitate the
disclosure of information to investors, while simplifying and updating disclosure
requirements, without significantly altering the total mix of information provided to
investors. We anticipate that the amendments will decrease the burdens and costs for
registrants to prepare and review filings for many forms and will increase the burden and
costs for a limited number of forms. For purposes of the PRA, we estimate that the
amendments to Form S-4 will result in a net decrease of 2,027 burden hours. We have
not provided an estimate for professional cost changes because we have assumed that the
changes will only impact the internal efforts to respond to the collection of information.

16

FORM S-11 SHORT STATEMENT
The amendments adopted in Release No. 33-10532 address disclosure
requirements that have become redundant, duplicative, overlapping, outdated, or
superseded as a result of other Commission disclosure requirements, U.S. Generally
Accepted Accounting Principles, International Financial Reporting Standards, or changes
in the information environment. The purpose of the rule amendments is to facilitate the
disclosure of information to investors, while simplifying and updating disclosure
requirements, without significantly altering the total mix of information provided to
investors. We anticipate that the amendments will decrease the burdens and costs for
registrants to prepare and review filings for many forms and will increase the burden and
costs for a limited number of forms. For purposes of the PRA, we estimate that the
amendments to Form S-11 will result in a net decrease of 224 burden hours. We have not
provided an estimate for professional cost changes because we have assumed that the
changes will only impact the internal efforts to respond to the collection of information.

17

FORM F-1 SHORT STATEMENT
The amendments adopted in Release No. 33-10532 address disclosure
requirements that have become redundant, duplicative, overlapping, outdated, or
superseded as a result of other Commission disclosure requirements, U.S. Generally
Accepted Accounting Principles, International Financial Reporting Standards, or changes
in the information environment. The purpose of the rule amendments is to facilitate the
disclosure of information to investors, while simplifying and updating disclosure
requirements, without significantly altering the total mix of information provided to
investors. We anticipate that the amendments will decrease the burdens and costs for
registrants to prepare and review filings for many forms and will increase the burden and
costs for a limited number of forms. For purposes of the PRA, we estimate that the
amendments to Form F-1 will result in a net decrease of 223 burden hours. We have not
provided an estimate for professional cost changes because we have assumed that the
changes will only impact the internal efforts to respond to the collection of information.

18

FORM F-3 SHORT STATEMENT
The amendments adopted in Release No. 33-10532 address disclosure
requirements that have become redundant, duplicative, overlapping, outdated, or
superseded as a result of other Commission disclosure requirements, U.S. Generally
Accepted Accounting Principles, International Financial Reporting Standards, or changes
in the information environment. The purpose of the rule amendments is to facilitate the
disclosure of information to investors, while simplifying and updating disclosure
requirements, without significantly altering the total mix of information provided to
investors. We anticipate that the amendments will decrease the burdens and costs for
registrants to prepare and review filings for many forms and will increase the burden and
costs for a limited number of forms. For purposes of the PRA, we estimate that the
amendments to Form F-3 will result in a net decrease of 312 burden hours. We have not
provided an estimate for professional cost changes because we have assumed that the
changes will only impact the internal efforts to respond to the collection of information.

19

FORM F-4 SHORT STATEMENT
The amendments adopted in Release No. 33-10532 address disclosure
requirements that have become redundant, duplicative, overlapping, outdated, or
superseded as a result of other Commission disclosure requirements, U.S. Generally
Accepted Accounting Principles, International Financial Reporting Standards, or changes
in the information environment. The purpose of the rule amendments is to facilitate the
disclosure of information to investors, while simplifying and updating disclosure
requirements, without significantly altering the total mix of information provided to
investors. We anticipate that the amendments will decrease the burdens and costs for
registrants to prepare and review filings for many forms and will increase the burden and
costs for a limited number of forms. For purposes of the PRA, we estimate that the
amendments to Form F-4 will result in a net decrease of 179 burden hours. We have not
provided an estimate for professional cost changes because we have assumed that the
changes will only impact the internal efforts to respond to the collection of information.

20

FORM 1-A SHORT STATEMENT
The amendments adopted in Release No. 33-10532 address disclosure
requirements that have become redundant, duplicative, overlapping, outdated, or
superseded as a result of other Commission disclosure requirements, U.S. Generally
Accepted Accounting Principles, International Financial Reporting Standards, or changes
in the information environment. The purpose of the rule amendments is to facilitate the
disclosure of information to investors, while simplifying and updating disclosure
requirements, without significantly altering the total mix of information provided to
investors. We anticipate that the amendments will decrease the burdens and costs for
registrants to prepare and review filings for many forms and will increase the burden and
costs for a limited number of forms. For purposes of the PRA, we estimate that the
amendments to Form 1-A will result in a net increase of 56 burden hours. We have not
provided an estimate for professional cost changes because we have assumed that the
changes will only impact the internal efforts to respond to the collection of information.

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