Pursuant to 5
CFR 1320.11(c), OMB files this comment on this information
collection request (ICR). In accordance with 5 CFR 1320, OMB is
withholding approval at this time. The agency shall examine public
comment in response to the NPRM and will include in the supporting
statement of the next ICR--to be submitted to OMB at the final rule
stage--a description of how the agency has responded to any public
comments on the ICR, including comments on maximizing the practical
utility of the collection and minimizing the burden.
Inventory as of this Action
36 Months From Approved
Form S-1 under the Securities Act is
used by domestic issuers who are not eligible to use other forms to
register offering of their securities.
The proposals in Release No.
33-9186 would remove references to credit ratings and replace them
with alternate criteria pursuant to Section 939A of the Dodd-Frank
Act. The increase in the burden associated with Form S-1 is the
result of an estimate that if the proposals are adopted, certain
issuers currently eligible to use Form S-3 would no longer be
eligible to use the form and would instead file on Form S-1. As a
result, the number of respondents on Form S-1 would increase if the
proposal is adopted. The proposal would result in an annual time
burden increase of 3,398 hours and an increase in the cost burden
of $4,077,814 for services of outside professionals.
Blair Petrillo 202
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
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
(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
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.