Records To Be Preserved by Certain Exchange Members, Brokers, and Dealers -- Rule 17a-4

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Forms and supporting documents for this ICR

Document	Type	Status	Availability

No forms / supporting documents in this ICR. Check IC Document Collections.

IC Document Collections

Information collection document groups

IC ID	Collection	Type	Status	Form
34751	Records To Be Preserved by Certain Exchange Members, Brokers, and Dealers -- Rule 17a-4		Migrated

ICR Details

OMB Control No: 3235-0279	ICR Reference No: 199810-3235-010
Status: Historical Inactive	Previous ICR Reference No: 199712-3235-016
Agency/Subagency: SEC	Agency Tracking No:
Title: Records To Be Preserved by Certain Exchange Members, Brokers, and Dealers -- Rule 17a-4
Type of Information Collection: Revision of a currently approved collection	Common Form ICR:  No
Type of Review Request: Regular
OIRA Conclusion Action: Comment filed on proposed rule and continue	Conclusion Date: 12/29/1998
	Date Received in OIRA: 10/26/1998
Terms of Clearance: The recordkeeping requirement in this reproposed rule is not approved at this time. The agency appears to significantly understate the likely costs of this rule. For example, the agency cites state regulators as needing this rule because of the serious recordkeeping problems in many local officers. However, the agency cites a total cost per local office of 1 to 4 thoasand dollars for setting up such a system. This low estimate appears to imply that there isn't that much for each office to do, and that maintaining such a system is costless. In addition, this cost estimate was not published as part of the proposed rule and was not subject to public comment. The agency also does not account for the costs of starting and maintaining the state record depositories or the potential costs of revising computer systems to generate, store, and transmit the additional records required by this rule. Finally, the agency does not state that these proposed rules are necessary or would be the most efficient way to remedy the state regulators' complaints. The agency should clearly state that it believes and supports the states' complaints and examine other alternative means of accomplishing their goals, such as a stronger requirement that records be produced in a timely fashion. Otherwise, this collection would appear to not minimize burden on respondents.

table that charts list comparision

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	05/31/2000	12/31/2001	06/30/2001
Responses	8,506	0	8,506
Time Burden (Hours)	2,127,185	0	0
Cost Burden (Dollars)	42,542,000	0	0

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Abstract: The Commission is reproposing amendments to Rule 17a-4 which would require broker-dealers to keep certain records. The records would be important for regulatory investigations and examinations and for the protection of the public.

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Authorizing Statute(s): None

Citations for New Statutory Requirements: None

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Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:

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Federal Register Notices & Comments

Did the Agency receive public comments on this ICR? No

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Number of Information Collection (IC) in this ICR: 1

table that charts list of burden

IC Title	Form No.	Form Name
Records To Be Preserved by Certain Exchange Members, Brokers, and Dealers -- Rule 17a-4

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Burden increases because of Program Change due to Agency Discretion: Yes

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

Is the Supporting Statement intended to be a Privacy Impact Assessment required by the E-Government Act of 2002? No

Is this ICR related to the Affordable Care Act [Pub. L. 111-148 & 111-152]? Uncollected

Is this ICR related to the Dodd-Frank Wall Street Reform and Consumer Protection Act, [Pub. L. 111-203]? Uncollected

Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)? Uncollected

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: 10/26/1998

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