3235-0464 Supporting Statement (2023 Partial Revision)

1
1

SUPPORTING STATEMENT
for the Paperwork Reduction Act
Information Collection Submission for
Rule 101 of Regulation M
Partial Revision
(OMB Control No. 3235-0464)
A.

Justification

1.

Necessity of Information Collection
a.

Background

Congress granted broad rulemaking authority to the Securities and Exchange Commission
(“Commission”) in Sections 9(a), 10(b), and 15(c) under the Securities Exchange Act of 1934
(“Exchange Act”) to combat manipulative abuses in whatever form they may take. In exercising its
authority, the Commission has focused on the market activities of persons participating in a
securities offering and determined that securities offerings present special opportunities for
manipulation that require specific regulatory attention. On December 20, 1996, the Commission
adopted Regulation M, consisting of new Rules 100 through 105, which govern the activities of
underwriters, issuers, selling security holders, and others in connection with a securities offering.
Regulation M significantly eased regulatory burdens on offering participants by eliminating the
trading restrictions for underwriters of actively traded securities; reducing the scope of coverage for
other securities; reducing restrictions on issuer plans; providing a more flexible framework for
stabilizing transactions; and deregulating rights offerings.
b.

Overview of Rule 101

Rule 101 of Regulation M governs underwriters, prospective underwriters, participating
broker-dealers, and their affiliated purchasers (distribution participants). Rule 101 applies only
during a "restricted period," which commences one or five business days prior to the day of the
pricing of the offered security and continues until the distribution is over. The length of the
restricted period is based on the trading volume of the offered security. Rule 101 excludes from its
coverage more actively-traded securities.
New Amendment: On June 7, 2023, the Commission adopted an amendment to except
from Rule 101 of Regulation M nonconvertible debt securities and nonconvertible preferred
securities (together, “Nonconvertible Securities”) of issuers for which the probability of default,
estimated as of the sixth business day immediately preceding the determination of the offering price
and over the horizon of 12 full calendar months from such day, is 0.055% or less, as determined and

2
documented, in writing, by the distribution participant acting as the lead manager (or in a similar
capacity) of a distribution, as derived from a structural credit risk model.1
c.

Information Collection Requirements for Rule 101

Rule 101 requires persons participating in a distribution to collect certain information to
determine whether the rule would apply, and if so, for what period of time. Regulation M
incorporated many previously-existing requirements of the trading practices rules, together with
their information collection requirements. However, by removing many categories of activities,
securities, and persons from anti-manipulation regulation, Regulation M reduced the burdens of
anti-manipulation regulation.
(i).

Exceptions from Rule 101
(a).

Exclusion of Actively-Traded Securities

Rule 101 excepts securities with an average daily trading volume (ADTV) valued at $1
million or more. Rule 101 requires the ADTV to be calculated for the two full calendar months
preceding the filing of the registration statement. To use this exception, a distribution participant
must examine publicly available market data to calculate the ADTV.
(b).

Other Securities

The ADTV of other securities remaining subject to the restrictions of Rule 101 determines
the length of the restricted period for a particular security. As with excepted securities, distribution
participants and issuer participants may obtain publicly available data to calculate ADTV of a
particular security.
(c).

“Affiliated Purchasers”

Rule 101 applies to any "affiliated purchaser" of a distribution participant, issuer, or selling
security holder. Regulation M, however, provides an exception to the definition of affiliated
purchaser where the distribution participant or issuer participant have certain information barriers in
place. This exception requires the participant to establish, maintain, and enforce written policies
and procedures to prevent the flow of information between itself and its affiliates. Such participants
must also obtain an annual, independent assessment of the operation of such policies and
procedures.
(d).
1

De Minimis Exception

See 17 CFR 242.101(c)(2)(i), as amended; see also Removal of References to Credit Ratings From
Regulation M, Exchange Act Release No. 97657 (June 7, 2023), 88 FR 39962 (June 20, 2023) (“2023
Adopting Release”).

3
Rule 101 provides an exception for de minimis violations during the restricted period. This
provision excepts purchases of less than two percent of the ADTV of the security in distribution.
However, this exception is only available where the person making such bid or purchase subject to
the exception has maintained and enforced written policies and procedures reasonably designed to
achieve compliance with the other provisions of Rule 101.
(e).

New Probability-of-Default-Based Exception

Prior to the June 7, 2023 amendments, Rule 101 excepted nonconvertible debt securities,
nonconvertible preferred securities, and asset-backed securities, that were rated by at least one
nationally recognized statistical rating organization, as that term is used in Rule 15c3-1 under the
Securities Exchange Act of 1934 (“Exchange Act”), in one of its generic rating categories that
signifies investment grade (“Investment Grade Exception”). Section 939A of the Dodd-Frank Wall
Street Reform and Consumer Protection Act (“Dodd-Frank Act”) requires the Commission among
other things, to “remove any reference to or requirement of reliance on credit ratings” and
“substitute in such regulations such standard of credit-worthiness” as the Commission determines to
be appropriate for those regulations.2
In accordance with the requirements of Section 939A(b), the Commission adopted an
amendment to Rule 101 to remove the existing Investment Grade Exception for Nonconvertible
Securities. For distributions of Nonconvertible Securities, the Commission adopted a new
exception in Rule 101 for reliance by distribution participants and their affiliated purchasers that
relates to the determination of an issuer’s probability of default as derived from a structural credit
risk model.3
Under the amendment to Rule 101, the exception will be available to Nonconvertible
Securities of issuers for which the probability of default, estimated as of the sixth business day
immediately preceding the determination of the offering price and over the horizon of 12 full
calendar months from such day, is 0.055% or less, as determined and documented, in writing, by the
distribution participant acting as the lead manager (or in a similar capacity) of a distribution, as
derived from a structural credit risk model.
2.

Purpose and Use of the Information Collection

A distribution participant (i.e., the syndicate manager) performs ADTV calculations to
determine whether a security is excepted from Rule 101, or to determine the applicable restricted
period. This information is not used by the Commission.
A distribution participant may establish information barriers to segregate the activities of
itself and its affiliates. Construction of these barriers permits the affiliates of a distribution
participant, issuer or selling security holder to be excepted from Rule 101. The annual audit assures
2

Pub. L. 111-203 sec. 939A(b), 124 Stat. 1376, 1872-90 (2010).

3

See 2023 Adopting Release, at 88 FR 39965.

4
such distribution participant that the policies are effective. The Commission only examines the
policy and audit in investigations of potential violations of the rule.
A distribution participant may establish a written policy for the purpose of avoiding
violations of Rule 101 and specifically to benefit from the provision of the rule that excepts de
minimis violations. The Commission generally does not review a distribution participant's policy.
New Amendment: As discussed in the 2023 Adopting Release, the information collected
under the new amendment will be used to ensure that Nonconvertible Securities that trade primarily
based on their yield and creditworthiness, and are less susceptible to the type of manipulation that
Rule 101 seeks to prevent, are excepted from Rule 101.
3.

Consideration Given to Information Technology

Improvements in telecommunication and data processing technology reduce regulatory
burdens that might otherwise result from Rule 101. The Commission is not aware of any technical
or legal obstacles to reducing the burden through the use of improved information technology.
New Amendment: As discussed in the 2023 Adopting Release, the process for calculating
the probability of default will likely be highly automated, and broker-delears serving as lead
managers will initially comply with this requirement by reprograming systems to create a means to
calculate electronically the probability of default based on manually gathered and entered inputs for
financial modeling.4 The Commission also assumes that broker-dealers serving as lead managers
already have the software and systems in place required to make the probability of default
calculations.
4.

Duplication

The information required by each of the rules described herein does not duplicate that
required by any other federal regulation. At the time Regulation M and related amendments were
proposed, the Commission solicited and received comments without receiving any reference to
federal regulations that may duplicate the requirements mandated by Regulation M. The
Commission continues to believe that there is no duplication of the information required by the rules
described herein.
5.

Effect on Small Entities

The information requirements of Rule 101 apply equally to all entities engaging in an
offering, regardless of the entity’s size. The Commission believes that the requirements of Rules
101 are not unduly burdensome on small entities.
New Amendment:
4

See 2023 Adopting Release, at 88 FR 39992.

5
As discussed in the 2023 Adopting Release, the Commission does not believe that any of
the persons that will be impacted by the amendments are small entities under the relevant
definitions. Small entities include broker-dealers with total capital (net worth plus subordinated
liabilities) of less than $500,000 on the date in the prior fiscal year as of which its audited
financial statements were prepared pursuant to Rule 17a-5(d) under the Exchange Act, 5 or, if not
required to file such statements, a broker-dealer who had total capital (net worth plus
subordinated liabilities) of less than $500,000 on the last day of the preceding fiscal year (or in
the time it has been in business, if shorter), and is not affiliated with any person (other than a
natural person) who is not a small business or small organization. 6 A small business or small
organization, for purposes of “issuers” or “person” other than an investment company, is defined
as a person who, on the last day of its most recent fiscal year, had total assets of $5 million or
less. 7
Based on the Commission’s analysis of the existing information relating to broker-dealers
who are subject to Rule 101, Rule 102, and Rule 17a-4, it is unlikely that any broker-dealer
categorized as a “small business” or “small organization” under Rule 0-10 8 could serve as an
underwriter or other distribution participant, as they would almost certainly have insufficient
capital to participate in underwriting activities. In addition, the Commission continues to believe
that none of the various persons affected by the amendments would qualify as a small entity
under the Rule 0-10 definition as it is unlikely that any issuer of that size had investment grade
securities that were eligible for the Investment Grade Exception. Accordingly, the Commission
believes it is unlikely that, in the future, a small entity may become impacted by the amendments
because broker-dealers who enter this market are likely to have at least $500,000 in total capital,
as described above, or to be affiliated with a person who is not a small business or small
organization as defined under Rule 0–10, and because issuers of securities that are eligible for
the new exceptions provided in Rule 101(c)(2) and in Rule 102(d)(2) are likely to have total
assets greater than $5 million.
For the foregoing reasons, the Commission certified, in the Adopting Release, pursuant to
Section 605(b) of Title 5 of the U.S. Code, that the amendments to Rule 100, Rule 101, Rule
102, and Rule 17a-4 will not have a significant economic impact on a substantial number of
small entities.
6.

Consequences of Not Conducting Collection

Regulation M is designed to preserve the integrity of the securities trading market as an
independent pricing mechanism by prohibiting activities that could artificially influence the market
5

See 17 CFR 240.17a-5(d).

6

See 17 CFR 240.0-10(c).

7

17 CFR 240.0-10(a).

8

17 CFR 240.0-10.

6
for an offered security. Subject to exceptions, Rule 101 prohibits distribution participants and their
affiliated purchasers from directly or indirectly bidding for, purchasing, or attempting to induce
another person to bid for or purchase, a covered security during a restricted period.
New Amendment: In regards to the probability-of-default-based exception, the
information collection is necessary so that only Nonconvertible Securities that trade primarily based
on their yield and creditworthiness, and are less susceptible to the type of manipulation that Rule
101 seeks to prevent, are excepted from Rule 101 of Regulation M.
7.

Inconsistencies With Guidelines in 5 CFR 1320.5(d)(2)

There are no special circumstances. This collection is consistent with the guidelines in 5
C.F.R.1320.5(d)(2).
8.

Consultations Outside the Agency

In regards to the probability-of-default-based exception, the Commission issued a release
soliciting comment on the new “collection of information” requirements and associated paperwork
burdens.9 A copy of the release is attached. The Commission received comments from industry
groups, investors, and other market participants. In addition, the Commission and staff participated
in ongoing dialogue with representatives of various market participants through meetings. Any
comments received on this rulemaking are posted on the Commission’s public website, and made
available through https://www.sec.gov/comments/s7-11-22/s71122.htm. The Commission
considered all comments received prior to publishing the final rule, and explained in the 2023
Adopting Release how the final rule responded to such comments, in accordance with 5 C.F.R.
1320.11(f).
9.

Payment or Gift
Not applicable.

10.

Confidentiality
No assurance of confidentiality is provided.

11.

Sensitive Questions

The information collected pursuant to Rule 101 is obtained and used by syndicate managers
to determine whether a security is excepted from the rule or to determine the applicable restricted
period; however, the information is not directly collected by, or submitted to the SEC, and therefore
does not constitute a Privacy Act system of records.
9

See Removal of References to Credit Ratings From Regulation M, Exchange Act Release No. 94499 (Mar.
22, 2022) [87 FR 18312 (Mar. 30, 2023)] (“Proposal”).

7
New Amendment: In regards to the probability of default exception, the Information
Collection does not collect information about individuals, but rather only business contact
information; therefore, a PIA, SORN, and PAS are not required.
12.

Burden of Information Collection
a.

Restricted Periods

The syndicate manager of each secondary offering calculates the ADTV to determine the
restricted period, if any, that must be observed under Rule 101. In 2019, there were 805 firm
commitment offerings. For each of these, the Commission estimates it takes approximately one
hour to calculate the ADTV and determine the applicable restricted period. Thus, in 2019,
approximately 805 hours in the aggregate are required for these calculations under Rule 101. In
addition, the Commission estimates that in approximately 50 self-underwritten offerings per year
the issuer would calculate the ADTV. Approximately 50 hours are required annually for these
calculations by issuers. In many circumstances, however, the collection of information is
unnecessary because the ADTV is self-evident (i.e., the ADTV is extremely high or extremely low).
This collection is a recordkeeping type of collection.
b.

Information Barriers

The Commission estimates that approximately 100 broker-dealers acting as distribution
participants in offerings covered by Regulation M seek to exempt the activities of an affiliate from
the regulations of Rule 101. The Commission estimates that the annual audit of the written policies
and procedures concerning information barriers takes approximately 10 hours, therefore
approximately 1,000 hours (10 hours times 100 broker-dealers) are required by this exemption.
This collection is a recordkeeping type of collection.
c.

De Minimis Exception

The Commission estimates that approximately 634 broker-dealers annually act as
distribution participants in distributions covered by Regulation M. The FOCUS reports filed with
the Commission as of 9/31/2019 indicate that 634 broker-dealers were involved in activities that
could qualify them as distribution participants in distributions covered by Regulation M. The
Commission estimates that the written policy required for the de minimis exception from Rule 101
takes 40 hours to draft. Approximately 25,360 hours (40 hours times 634 broker-dealers) is
required by this exemption. This collection is a recordkeeping type of collection.
d.

Probabiltiy-of-Default-Based Exception

The amendment to Rule 101 related to the probability of default calculations will result in
two new information collections: an initial burden and an ongoing burden. These are PRA

8
recordkeeping burdens related to gathering data and performing the analysis to calculate the
probability of default pursuant to the amendment to Rule 101.
Under Rule 101, lead managers who choose to make a probability of default
determination in order to rely on the exception for Nonconvertible Securities will incur burdens,
as discussed below. There were 201 lead managing underwriters of Nonconvertible Securities in
2021. The Commission assumes that, on balance, this number will remain consistent given the
capital, expertise, and relationships needed to serve as the lead underwriter of a Nonconvertible
Securities offering. The Commission, therefore, is estimating that 201 respondents will be
subject to PRA burdens under the amendment to Rule 101 related to the probability of default.
i.

Initial Burden

Broker-dealers who are lead managers relying on the probability of default exception to
Rule 101 of Regulation M for Nonconvertible Securities will need to establish a system to gather
the data serving as the inputs and perform the analysis necessary to calculate the probability of
default of the issuer whose securities are the subject of the distribution. This process will likely
be highly automated, and respondents will initially comply with this requirement by
reprograming systems to create a means to calculate electronically the probability of default
based on manually gathered and entered inputs for financial modeling. The respondents who
make probability of default derminations will be broker-dealers serving as lead managers and are
likely to have experience using their own proprietary version of a publicly available structural
credit risk model. The Commission also assumes that broker-dealers serving as lead managers
already have the software and systems in place required to make the calculations. 10 The
Commission estimated in the Adopting Release that the initial configuration of systems will be
handled internally and take 3 hours per respondent, resulting in a total annual industry-wide
initial burden for the proposed amendment to Rule 101 of 301 hours. 11
ii.

Ongoing Burden

An issuer’s probability of default is forward-looking and changes over time, so the
Commission believes that respondents will manually gather the inputs required to calculate an
10

The Commission recognizes that some respondents may choose to utilize the probability of default
estimates that are calculated and made available by a third-party vendor rather than make the determination
themselves. In the Proposal, the Commission noted that the Commission’s burden estimates were based on
respondents gathering the required data and calculating the probability of default, internally, without the
use of third-party vendors, because the Commission lacks granular information from which to base an
estimate of the proportion of respondents that would use vendors. The Commission requested comment on
the extent to which respondents may use third-party vendors, as well as the costs and time burdens of using
such services. See Proposal, 87 FR at 18326 n.129. However, the Commission did not receive comments
in response to this request. For purposes of estimating the PRA burdens under the final rules as amended,
the Commission continues to assume that all respondents will make the probability of default determination
internally with data they have gathered, rather than use third party vendors.

11

201 respondents x 3 hours = 603 hours for the total initial burden. As we plan to request a three-year
approval period, we divide 603 by 3 to get 301 hours per year.

9
issuer’s probability of default each time it participates in a distribution of Nonconvertible
Securities. There were 33,798 offerings of Nonconvertible Securities in 2021. 12 As discussed in
the 2023 Adopting Release, because financial modeling generally, and the probability of default
calculation more specifically, is well-known by industry participants, the Commission believes
that respondents have employees who are familiar with how to gather the required model inputs.
The Commission, therefore, estimates that it will take lead manager respondents roughly one
hour per distribution of Nonconvertible Securities to determine and document, in writing, the
probability of default determination. Accordingly, the Commission estimates that the
amendments to Rule 101 will result in an aggregate annual ongoing industry-wide burden
of 33,798 hours. 13
i. Total Respondent Burden
Based on the above calculations, the Commission estimates that a total of 1,790 respondents
collect information pursuant to Rule 101 (805 firm commitment respondents plus 50 selfunderwritten offering respondents plus 100 affiliate exemption respondents plus 634 de minimus
exemption respondents plus 201 proposed probability of default exemption respondents). The
Commission estimates that the total annual burden under Rule 101 is 61,214 hours (805 firm
commitment hours plus 50 hours for self-underwritten offerings plus 1,000 hours to audit policies
concerning affiliate information barriers plus 25,360 hours to draft policies concerning de minimus
exemptions plus 201 hours initial burden and 33,798 hours ongoing burden related to the
probability-of-default-based exception). All hours in this collection are the recordkeeping type of
collection.
Burden Type
Restricted Period
ADTV
Calculation
SelfUnderwritten
Offering ADTV
Calculation
Audit of WSPs
for Info Barriers
with Affiliates

Respondents Responses per
Year
1,211

1

Approximate
Annual Burden
Hours Per Response
1

Total Burden
Hours

50

1

1

50

100

1

10

1,000

1,211 14

12

This number was obtained from Mergent, a financial data provider.

13

33,798 offerings of Nonconvertible Securities x 1 hour per distribution = 33,798 hours.

14

This estimate was modified in a recent extension, approved by OMB in August 2023, to increase the
number of respondents (and the annual burden) from 805 to 1,211.

10
Firm
Commitment
Underwritten
Offerings de
minimis policy
drafting

641

1

40

25,640 15

Gathering data
and performing
analysis to
calculate the
probability of
default (Rule
101)-- Initial
Gathering data
and performing
analysis to
calculate the
probability of
default (Rule
101)-- Ongoing
Total Aggregate
Burden Hours

201

1

1

201

201

168.15 16

1

33,798

61,900

In addition, there are internal labor compliance cost burdens associated with this rule. The
Commission estimates that a typical employee of a broker-dealer charged to ensure compliance with
Commission regulations receives compensation of $70.00 per hour. The $70.00 per hour figure for
a Compliance Clerk is from SIFMA's Office Salaries in the Securities Industry 2013, modified by
Commission staff to account for an 1800-hour work-year and multiplied by 2.93 to account for
bonuses, firm size, employee benefits and overhead. Based on that estimate, the Commission
estimates that the annual internal compliance cost to comply with Rule 101 is $1,905,050.00
($70.00 per hour times 27,215 hours).
Lead managers may incur costs related to determining the probability of default. The
Commission estimates that it will take a lead manager 3 hours to establish a system to gather the
data serving as the inputs and then perform the analysis necessary to calculate the probability of
default of the issuer whose securities are the subject of the distribution, for an aggregate cost of
15

This estimate was modified in a recent extension, approved by OMB in August 2023, to increase the
number of respondents from 634 to 641 and the annual burden from 25,360 to 25,640.

16

For purposes of creating a submission for the ROCIS system, the number of reponses per respondent per
year was calculated by dividing the total number of estimated responses per year by the number of
responses (33,798/201). This provides the same number of responses (168.15) for each respondent. In
actuality, however, each respondent may have a different number of responses.

11
$218,889.17 The Commission also estimates that it will take a lead manager one hour to gather the
inputs required to calculate probability of default each time it participates in a distribution of
Nonconvertible Securities. There were 33,798 offerings of Nonconvertible Securities in 2021.
Therefore, it is estimated that annually lead managers will spend maximum of $12,268,674 18 in the
aggregate complying with this requirement if all lead managers choose to estimate the probability of
default internally.
13.

Costs to Respondents

There are no external capital, start-up, maintenance or operational cost burdens associated
with this rule.
14.

Costs to the Federal Government

The government does not experience significant costs based on the recordkeeping required
pursuant to Rule 101. The information collected by the respondents is normally reviewed only
pursuant to an investigation, not as a matter of routine.
15.

Changes in Burden

New Amendment: The probability-of-default-based exception will increase the estimated
hour burdens, by adding the following two new ICs, which were previously proposed:
•

•

Gathering data and performing analysis to calculate the probability of default (Rule
101)—Initial (this new IC would add a burden of 201 hours per year. This is lower than
the estimated 237 hours per year that was estimated in the Proposal due to a decrease in
the estimated number of respondents from 237 respondents to 201 respondents); and
Gathering data and performing analysis to calculate the probability of default (Rule
101)—Ongoing (this new IC would add a burden of 33,798 hours. This is higher than the
estimated 19,076 hours per year that was estimated in the Proposal due to an increase in

17

The Commission estimates the wage rate based on salary information for the securities industry compiled
by SIFMA. See Management & Professional Earnings in the Securities Industry—2013, SIFMA (Oct. 7,
2013). These estimates are modified by the Commission staff to account for an 1800 hour work-year and
multiplied by 5.35 (professionals) or 2.93 (office) to account for bonuses, firm size, employee benefits and
overhead. These figures have been adjusted for inflation through Jan. 2023 using data published by the
Bureau of Labor Statistics’ Consumer Price Index inflation calculator, available at
https://www.bls.gov/data/inflation_calculator.htm. 201 lead managers x 3 hours x $363 hour for a
compliance manager = $218,889.

18

Cost estimated is based on the sum of 33,798 offerings multiplied by 1 burden hour multiplied by $363, for
a compliance manager. See Management & Professional Earnings in the Securities Industry—2013,
SIFMA (Oct. 7, 2013). These estimates are modified by the Commission staff to account for an 1800 hour
work-year and multiplied by 5.35 (professionals) or 2.93 (office) to account for bonuses, firm size,
employee benefits and overhead. These figures have been adjusted for inflation through Jan. 2023 using
data published by the Bureau of Labor Statistics’ Consumer Price Index inflation calculator, available at
https://www.bls.gov/data/inflation_calculator.htm.

12
the estimated number of offerings of Nonconvertible Securities from 19,076 in 2020 to
33,798 in 2021).

Information
Collection
Requirement

Gathering data
and performing
analysis to
calculate the
probability of
default (Rule
101)—Initial
Gathering data
and performing
analysis to
calculate the
probability of
default (Rule
101)-- Ongoing

16.

Annual Industry
Burden
Proposed Annual
Previously
Industry Burden for Approved for
Adoption of the
Proposed
Probability of
Probability of
Default Exception
Default
Exception
603 hours for 201
711 hours for 237
respondents at 3 hours respondents at 3
per respondent
hours per
respondent

19,076 hours at 1 hour
per distribution of
Nonconvertible
Securities, with an
estimated 19,076
offerings of
Nonconvertible
Securities in 2020

Change
in
Reason for Change
Burden

-108
hours

33,798 hours at 1 14,722
hour per
hours
distribution of
Nonconvertible
Securities, with
an estaimted
33,798 offerings
of Nonconvertible
Securities in 2021

Lower estimated
number of
respondents for
Adopted Rule

Higher estimated
number of
offerings of
Nonconvertible
Securities for
Adopted Rule

Information Collection Planned for Statistical Purposes
Not applicable. The information collection is not used for statistical purposes.

17.

Approval to Omit OMB Expiration Date
The Commission is not seeking approval to omit the expiration date.

18.

Exceptions to the Certification for Paperwork Reduction Act Submissions
This collection complies with the requirements in 5 CFR 1320.9.

B.

Collections of Information Employing Statistical Methods

13
This collection does not involve statistical methods.