Rule 17g-5 Conflicts of Interest

Forms and Documents

Document Name	Status
2012_-_Rule_17g-5_Supporting_Statement[1].pdf Supporting Statement A	2012-09-24

IC Document Collections

IC ID	Document Title	Status
202290	Annual Certification	New
202289	Arranger Transaction Type 2	New
202288	Arranger Transaction Type 1	New
188139	Structured Finance Ratings Disclosure	Modified

ICR Details

OMB Control No: 3235-0649	ICR Reference No: 201205-3235-001
Status: Historical Active	Previous ICR Reference No: 201203-3235-009
Agency/Subagency: SEC	Agency Tracking No: TM-270-581
Title: Rule 17g-5 Conflicts of Interest
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 without change	Conclusion Date: 11/01/2012
	Date Received in OIRA: 09/24/2012
Terms of Clearance:

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	11/30/2015	36 Months From Approved	11/30/2012
Responses	15,290	0	230
Time Burden (Hours)	168,900	0	168,940
Cost Burden (Dollars)	0	0	0

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Abstract: Rule 17g-5 implements certain statutory provisions of the Credit Rating Agency Reform Act of 2006 ("Rating Agency Act") by prohibiting, or requiring the managemnt and disclosure of, any potential conflict of interest relating to the issuance of credit ratings by a nationally recognized statistical rating organization or "NRSRO". This collection of information is necessary by addressing potential practices that could impair the objectivity and the quality of a credit rating.

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Authorizing Statute(s): US Code: 15 USC 780-7 Name of Law: Credit Rating Agency Reform Act of 2006
  

Citations for New Statutory Requirements: US Code: 15 USC 780-7 Name of Law: Credit rating Agency Reform Act

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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 31408	05/25/2012
30-day Notice:	Federal Register Citation:	Citation Date:
	77 FR 44699	07/30/2012
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
Structured Finance Ratings Disclosure
Arranger Transaction Type 1
Arranger Transaction Type 2
Annual Certification

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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	15,290	230	0	0	15,060	0
Annual Time Burden (Hours)	168,900	168,940	0	0	-40	0
Annual Cost Burden (Dollars)	0	0	0	0	0	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 Commission's annual time burden estimate has decreased from 168,940 to 168,900 hours due to a decrease in the Commission's estimate of the number of NRSROs subject to the rule from 30 to 10.

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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: 09/24/2012

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