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

ICR 199810-3235-010

OMB: 3235-0279

Federal Form Document

Forms and Documents
Document
Name
Status
No forms / supporting documents in this ICR. Check IC Document Collections.
IC Document Collections
ICR Details
3235-0279 199810-3235-010
Historical Inactive 199712-3235-016
SEC
Records To Be Preserved by Certain Exchange Members, Brokers, and Dealers -- Rule 17a-4
Revision of a currently approved collection   No
Regular
Comment filed on proposed rule and continue 12/29/1998
Retrieve Notice of Action (NOA) 10/26/1998
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.

None
None


No

1
IC Title Form No. Form Name
Records To Be Preserved by Certain Exchange Members, Brokers, and Dealers -- Rule 17a-4

Yes
No

$0
No
No
Uncollected
Uncollected
Uncollected
Uncollected

  No

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.
10/26/1998


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