Municipal Securities Disclosure (17 CFR 240.15c2-12)

Forms and Documents

Document Name	Status
15c2-12 PRA Extension Supporting Statement v8.docx Supporting Statement A	2011-10-28

IC Document Collections

IC ID	Document Title	Status
34930	Third-Party Disclosure	Modified
199950	Recordkeeping	New

ICR Details

OMB Control No: 3235-0372	ICR Reference No: 201110-3235-016
Status: Historical Active	Previous ICR Reference No: 200812-3235-015
Agency/Subagency: SEC	Agency Tracking No: TM -270-330
Title: Municipal Securities Disclosure (17 CFR 240.15c2-12)
Type of Information Collection: Revision of a currently approved collection	Common Form ICR:  No
Type of Review Request: Regular
OIRA Conclusion Action: Approved without change	Conclusion Date: 01/30/2012
	Date Received in OIRA: 10/31/2011
Terms of Clearance: Pre-approval contingent upon no substantive changes to this collection after adoption of the final rule. Otherwise this collection should be re-submitted to OMB for review.

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	01/31/2015	36 Months From Approved	01/31/2012
Responses	268,630	0	77,000
Time Burden (Hours)	162,877	0	64,541
Cost Burden (Dollars)	10,534,116	0	7,717,450

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Abstract: Rule 15c2-12 is intended to enhance disclosure, and thereby reduce fraud, in the municipal securities market by establishing standards for obtaining, reviewing, and disseminating information about municipal securities by their underwriters.

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Authorizing Statute(s): US Code: 15 USC 78b Name of Law: Securities Exchange Act of 1934
   US Code: 15 USC 78c Name of Law: Securities Exchange Act of 1934
   US Code: 15 USC 78j Name of Law: Securities Exchange Act of 1934
   US Code: 15 USC 78o Name of Law: Securities Exchange Act of 1934
   US Code: 15 USC 78o-4 Name of Law: Securities Exchange Act of 1934
   US Code: 15 USC 78q Name of Law: Securities Exchange Act of 1934
   US Code: 15 USC 78w Name of Law: Securities Exchange Act of 1934
  

Citations for New Statutory Requirements: None

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Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
3235-AJ66	Final or interim final rulemaking	75 FR 33100	06/10/2010

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Federal Register Notices & Comments

Did the Agency receive public comments on this ICR? Yes

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Number of Information Collection (IC) in this ICR: 2

IC Title	Form No.	Form Name
Third-Party Disclosure
Recordkeeping

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ICR Summary of Burden

	Total Approved	Previously Approved	Change Due to New Statute	Change Due to Agency Discretion	Change Due to Adjustment in Estimate	Change Due to Potential Violation of the PRA
Annual Number of Responses	268,630	77,000	0	191,630	0	0
Annual Time Burden (Hours)	162,877	64,541	0	98,336	0	0
Annual Cost Burden (Dollars)	10,534,116	7,717,450	0	2,816,666	0	0

Burden increases because of Program Change due to Agency Discretion: Yes

Burden Increase Due to: Changing Regulations

Burden decreases because of Program Change due to Agency Discretion: No

Burden Reduction Due to:

Short Statement: Both costs and the time burden has increased due to the adoption of amendments to the existing information collection. The annual time burden has increased 98,336 hours and estimated costs have increased $2,816,666 annually. For broker-dealers, the Commission estimated that 20% increase in the number of issuers with offerings would increase the annual burden for all broker dealers by 20%. Thus, the annual burden for broker dealers would increase by 50 hours to 300 total hours. In addition, the Commission estimates that a broker-dealer will incur a one-time paperwork burden to have its internal compliance attorney prepare and issue a notice advising its employees about the final revisions to the Rule, which would take approximately 30 minutes to prepare. This one-time burden would total 125 hours, which is approximately 42 hours on an annualized basis. The Commission estimates that the number of issuers with paperwork burden as a result of the amendments will increase by 20%, from 10,000 issuers estimated in the proposing release, to 12,000 issuers. The additional issuers will increase the aggregate number of annual filings, event notices, and failure to file notices each year. For MSRB, the Commission estimates that the total burden of collecting, indexing, storing, retrieving and disseminating information requested by the public will increase by approximately 29%, or 2,030 hours. The commission estimates that MSRB will have costs no more than approximately $10,000. The Commission estimates that 10,000 issuers who currently submit documents to MSRB electronically would have to file 6 notices per year, at $8 per notice, for a total of $480,000. These 10,000 issuers would also have a one-time cost to revise a continuing disclosure agreement to reflect the amendment at $1,000,000. The Commission has annualized this amount to $333,333.

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Annual Cost to Federal Government: $3,500

Does this IC contain surveys, censuses, or employ statistical methods? No

Is the Supporting Statement intended to be a Privacy Impact Assessment required by the E-Government Act of 2002? No

Is this ICR related to the Affordable Care Act [Pub. L. 111-148 & 111-152]? No

Is this ICR related to the Dodd-Frank Wall Street Reform and Consumer Protection Act, [Pub. L. 111-203]? No

Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)? No

Is this ICR related to the Pandemic Response? Uncollected

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Common Form ICR:  No

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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:

(a) It is necessary for the proper performance of agency functions;

(b) It avoids unnecessary duplication;

(c) It reduces burden on small entities;

(d) It uses plain, coherent, and unambiguous language that is understandable to respondents;

(e) Its implementation will be consistent and compatible with current reporting and recordkeeping practices;

(f) It indicates the retention periods for recordkeeping requirements;

(g) It informs respondents of the information called for under 5 CFR 1320.8 (b)(3) about:

(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;

(h) It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to be collected.

(i) It uses effective and efficient statistical survey methodology (if applicable); and

(j) It makes appropriate use of information technology.

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.

Certification Date: 10/31/2011

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