Rule 206(4)-7 requires investment
advisers registered with the Commission to adopt and implement
compliance policies and procedures, to review those policies and
procedures annually, and to designate a chief compliance
officer.
US Code:
15
USC 80b Name of Law: Investment Advisers Act of 1940
We have increased the estimated
annual aggregate burden from 865,360 to 1,007,228 hours based on
(1) an increase in the number of SEC-registered investment advisers
and (2) the burden associated with developing policies and
procedures to comply with new rule 206(4)-5 and related amendments
to rules 204-2 and 206(4)-3. We also estimate that certain
investment advisers will incur additional one-time costs of
$3,462,400 to engage outside legal services to assist in drafting
policies and procedures to comply with the new rule and rule
amendments.
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.