SUPPORTING STATEMENT FOR FORM TH
A. Justification
Necessity of Information Collection
Regulation S-T governs the Commission’s Electronic Data
Gathering, Analysis, and Retrieval (“EDGAR”) system. The
EDGAR system is used to electronically submit reports, schedules,
forms and other filings to the Commission. The cornerstone of the
EDGAR rules is Regulation S-T, which provides general instructions
and requirements for filing on EDGAR.
Regulation S-T identifies
filings that must be filed electronically, rules providing exemptions
from electronic filing for specified types of hardships, and rules
discussing treatment of graphic and image material. In order to
facilitate its electronic filing requirements, the Commission
developed special forms that were unique to filing on EDGAR. One
such specialized form is Form TH, which must be filed by any
electronic filer that submits to the Commission, pursuant to a
temporary hardship exemption, a document in paper format that
otherwise would be required to be submitted electronically as
prescribed by Rule 201(a) of Regulation S-T.
Purposes of, and Consequences of Not Requiring, the Information Collection
Form TH provides notification to the Commission that an electronic filer is relying on the temporary hardship exemption. Moreover, the information required by the Commission permits verification of compliance with securities law requirements and assures the public availability and dissemination of such information.
Role of Improved Technology and Obstacles to Reducing Burden
Form TH is used to implement improved information dissemination technology. The EDGAR system is designed to reduce the regulatory burden of paper filings with the Commission.
Efforts to Identify Duplication
The EDGAR system is unique to the Commission; consequently no duplication of Form TH exists.
Effect on Small Entities
Small entities are permitted to file Form TH if they meet the requirements of a temporary hardship exemption, which is outlined in Rule 201 of Regulation S-T, but we do not expect the filing of Form TH to have a significant economic impact on a substantial number of small entities. EDGAR has been designed to accommodate small entities to the greatest degree possible while still providing for the public electronic dissemination of information.
Consequences of Less Frequent Collection
Form TH must be used every time an electronic filer experiences unanticipated technical difficulties preventing the timely preparation and submission of a required electronic filing.
Inconsistencies with Guidelines in 5 C.F.R. 1320.6
Not applicable.
Consultations Outside the Agency
Before being adopted, Form TH was proposed for public comment. No Comments were received on these requests during the 60-day comment period prior to OMB’s review.
Payment or Gift to Respondent
Not applicable.
Assurance of Confidentiality
Form TH is a public document.
Sensitive Questions
Not applicable
Estimate of Respondent Reporting Burden
We estimate that approximately 70 registrants file Form TH and it takes an estimated 0.33 hours per response for a total annual burden of 23 hours. We estimate that 100% of the 23 burden hours are prepared by the company. The estimated hours are made solely for the purposes of the Paperwork Reduction Act.
Estimate of Total Annualized Cost Burden
We estimate that the issuer will prepare 100% of the total reporting burden imposed by the form and there is no additional cost associated with the information collection.
Estimate Cost to the Federal Government
The cost to the Federal Government is minimal for processing Form TH because it is a simple cover sheet that identifies attached information.
Explanation of Changes in Burden
Not applicable.
Information Collections Planned for Statistical Purposes
Not applicable.
Explanation as to Why Expiration Date Will Not Be Displayed
Not applicable.
Exceptions to Certification
Not applicable
B. Collection of Information Employing Statistical Methods
Not applicable.
| File Type | application/msword |
| File Title | SUPPORTING STATEMENT FOR FORM S-8 |
| Last Modified By | crawleyp |
| File Modified | 2009-04-14 |
| File Created | 2009-04-13 |