Rachel,
Thank you for comments.
We agree that the number of responses could have been more accurately captured.
To that end, we added an IC to capture those firms which disclose financial
statements electronically. We opted to use a separate IC for this group because
the burden is significantly different; therefore, by using a separate IC, we are
able to capture the full number of responses without throwing askew the overall
average response time. However, we decided not to break out the existing IC
because it falls with in the ROCIS triple constraints for determining the number
of ICs (i.e., affected public, obligation to respond, and line of business). We
did not view this as a disconnect with the supporting statements in that the
supporting statements provide a level of additional detail beyond the ROCIS data
pages.
Please let me know if
you have additional questions.
Happy
Holidays,
Darrin
693-4129
From: Potter,
Rachel F. [mailto:[email protected]]
Sent: Thursday, December 21, 2006 12:29
PM
To: King, Darrin - OASAM;
Subject: OMB comments on
1210-0065
Darrin and
Susan,
I have reviewed the ICR for
the final PTE for securities lending (1210-0065) and have a few comments.
First, I'm wondering if the financial statement and the lending and compensation
agreements should be two different ICs in ROCIS. Since you have broken
these out for burden calculation in the supporting statement, it seems
artificial to put them back together for ROCIS
purposes.
Second, for the electronic
disclosures of financial statements (90% of all responses), DOL has assumed a
response time of 0 minutes. While this makes sense on one level because
the marginal cost (in terms of time) of sending an additional email is zero, by
not including this figure in the calculation, the total number of annual
responses in ROCIS is only shown as 2,000. This figure should show 8,000,
because while there is minimal burden associated with electronic disclosure, it
is still a required response. I think this may be easy to correct once the
ICs are broken out.
I have opened ROCIS up for
amendment, but feel free to call if you have questions or want to discuss.
Happy
holidays!
-
Rachel