Form 18-K.SS.2019

SUPPORTING STATEMENT
FOR THE PAPERWORK REDUCTION ACT INFORMATION COLLECTION
FOR FORM 18-K

A.

JUSTIFICATION
1.

Circumstances Making the Collection of Information Necessary

One of the purposes of Securities Exchange Act of 1934 (“Exchange Act”) is to
help ensure that secondary markets for publicly traded securities are fair and honest. One
method by which the Exchange Act carries out this purpose is by requiring issuers that
have securities listed on a national securities exchange to file periodic reports with the
Commission. Issuer periodic reporting requirements are prescribed by the Securities and
Exchange Commission (“Commission”) pursuant to its authority in Section 13(a) of the
Exchange Act. The Commission exercised its authority under Section 13(a) to establish a
periodic reporting system for foreign governments and political subdivisions. The system
is only applicable with respect to issuers with securities registered on national securities
exchanges under Section 12(b) of the Exchange Act. Form 18-K is an annual report that
is filed by foreign governments or political subdivisions of foreign governments that have
securities that are listed on a national securities exchange.
2.

Purpose and Use of the Information Collection

Form 18-K elicits disclosure of information concerning the listed securities of a
foreign government or political subdivision of a foreign government, including external
and internal debt, receipts and expenditures, foreign exchange controls, imports and
exports, and balance of payments. A copy of the issuer’s latest annual budget is required
to be filed as well. In requiring such information, Form 18-K assures that relevant
information about the issuer is available and updated annually, and confirms the accuracy
of previously disclosed information.
3.

Consideration Given to Information Technology

Form 18-K is filed electronically using the Commission’s Electronic Data
Gathering, Analysis and Retrieval (EDGAR) system.
4.

Duplication of Information

Although the statistical data published by each foreign government differs from
country to country, the Commission is not aware of any government that issues securities
in this country that does not make public the data required by Form 18-K. The form,
however, presents the data, otherwise available from a variety of sources, in one cohesive
document.

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5.

Reducing the Burden on Small Entities

Form 18-K is not filed by small entities because it is an annual report form filed
by foreign governments or political subdivisions of foreign governments with securities
listed on a United States exchange.
6.

Consequences of Not Conducting Collection

Form 18-K is required to be filed annually. Any less frequent filing would render
performance comparisons meaningless, and deprive investors of the information
protection of the Exchange Act.
7.

Special Circumstances
There are no special circumstances.

8.

Consultations with Persons Outside the Agency

No comments were received for this request during the 60-day comment period
prior to OMB’s review of this submission.
9.

Payment or Gift to Respondents
No payment or gift to respondents.

10.

Confidentiality
Form 18-K is a public document.

11.

Sensitive Questions

No information of a sensitive nature, including social security numbers, will be
required under this collection of information. The information collection collects basic
Personally Identifiable Information (PII) that may include name, job title, and work
address (governmental address) of submitter. 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.

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12.

Estimate of Respondent Reporting Burden

For purposes of the Paperwork Reduction Act (“PRA”), we estimate that Form
18-K takes approximately 8 hours per response to comply with the collection of
information requirements and is filed by 36 respondents. We derived our burden hour
estimates by estimating the average number of hours it would take an issuer to compile
the necessary information and data, prepare and review disclosure, file documents and
retain records. In connection with rule amendments to the form, we occasionally receive
PRA estimates from public commenters about incremental burdens that are used in our
burden estimates. We believe that the actual burdens will likely vary among individual
companies based on the size and complexity of their organization and the nature of their
operations. We further estimate that100% of the collection of information burden is
carried by the issuer. Based on our estimates, we calculated the total reporting burden to
be 288 hours (8 hours per response x 36 responses). The estimated burden hours are
made solely for the purpose of the Paperwork Reduction Act.
13.

Estimate of Total Annualized Cost Burden

We estimate that there is no cost associated with this information collection
because 100% of the burden is prepared by the issuer.
14.

Costs to Federal Government

The annual cost of reviewing and processing disclosure documents, including
registration statements, post-effective amendments, proxy statements, annual reports and
other filings of operating companies amounted to approximately $102 million in fiscal
year 2018, based on the Commission’s computation of the value of staff time devoted to
this activity and related overhead.
15.

Reason for Change in Burden

The increase in burden of 8 hours is due to an increase in the number of
Form 18-Ks filed with the Commission.
16.

Information Collection Planned for Statistical Purposes
The information collection does 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.

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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 collection does not employ statistical methods.