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.
Inventory as of this Action
Requested
Previously Approved
05/31/2000
12/31/2001
06/30/2001
8,506
0
8,506
2,127,185
0
0
42,542,000
0
0
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.
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:
(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;
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.