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
01/31/2015
36 Months From Approved
01/31/2012
268,630
0
77,000
162,877
0
64,541
10,534,116
0
7,717,450
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.
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
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.
$3,500
No
No
No
No
No
Uncollected
Mary Simpkins 202 551-5683
No
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.
15c2-12 PRA Extension Supporting Statement v8.docx
Third-Party Disclosure