Rule 17g-2 Records to be made and retained by nationally recognized statistical rating organizations

Forms and Documents

Document Name	Status
Rule 17g-2 Supporting Statement (2).pdf Supporting Statement A	2012-06-21

IC Document Collections

IC ID	Document Title	Status
200936	Filing for use of a third-party record custodian	New
200935	Requirement to make sample of ratings action histories available	New
200934	Cost to new NRSRO's of setting up recordkeeping system	New
179758	Rule 17g-2 Records to be made and retained by nationally recognized statistical rating organizations	Modified

ICR Details

OMB Control No: 3235-0628	ICR Reference No: 201201-3235-008
Status: Historical Active	Previous ICR Reference No: 200902-3235-004
Agency/Subagency: SEC	Agency Tracking No: TM-270-564
Title: Rule 17g-2 Records to be made and retained by nationally recognized statistical rating organizations
Type of Information Collection: Extension without change of a currently approved collection	Common Form ICR:  No
Type of Review Request: Regular
OIRA Conclusion Action: Approved with change	Conclusion Date: 06/21/2012
	Date Received in OIRA: 04/11/2012
Terms of Clearance: Updated supporting statement.

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	06/30/2015	36 Months From Approved	06/30/2012
Responses	23	0	30
Time Burden (Hours)	2,987	0	12,000
Cost Burden (Dollars)	5,933	0	11,850

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Abstract: Rule 17g-2 implements certain statutory provisions of the Credit Rating Agency Reform Act of 2006 by requiring a nationally recognized statistical rating organization or "NRSRO" to make and retain certain records relating to its business and to retain certain other business records, if such records are made. The rule also prescribes the time periods and manner in which all these records must be retained. The collection of information included in Rule 17g-2 is designed to ensure that an NRSRO makes and retains records that assists the Securities and Exchange Commission in monitoring, through its examination authority, whether an NRSRO continued to meet the requirements for registration as an NRSRO.

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Authorizing Statute(s): US Code: 15 USC 78o-7 Name of Law: Credit Rating Agency Reform Act of 2006
   US Code: 15 USC 78c, 78d, 78i, 78j, 78l, 78m, Name of Law: The 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:
	Not associated with rulemaking

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Federal Register Notices & Comments
60-day Notice:	Federal Register Citation:	Citation Date:
	77 FR 5584	02/03/2012
30-day Notice:	Federal Register Citation:	Citation Date:
	77 FR 21819	04/11/2012
Did the Agency receive public comments on this ICR? No

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Number of Information Collection (IC) in this ICR: 4

IC Title	Form No.	Form Name
Cost to new NRSRO's of setting up recordkeeping system
Requirement to make sample of ratings action histories available
Filing for use of a third-party record custodian
Rule 17g-2 Records to be made and retained by nationally recognized statistical rating organizations

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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	23	30	0	0	-7	0
Annual Time Burden (Hours)	2,987	12,000	0	0	-9,013	0
Annual Cost Burden (Dollars)	5,933	11,850	0	0	-5,917	0

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

Burden Increase Due to:

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

Burden Reduction Due to:

Short Statement: The reduction in the annual time burden of 9,013 hours is due to the number of respondents decreasing from 30 to 10 NRSROs and the expectation of significantly fewer new NRSRO applicants during this collection period. The Commission had assumed there would be 30 NRSROs when the rule was adopted. This number was based on the belief that 30 companies would register as NRSROs with the Commission. We have revised the estimate to reflect the current number of 10 NRSROs.

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Annual Cost to Federal Government: $0

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: 04/11/2012

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