Adding Rule 17a-4(b)(11) burden to Rule 17a-4

Rule 17a-4 requires certain records to be maintained by certain exchange members and registered brokers and dealers.

Rule 17a-4(b)(11) requires preservation of all notices relating to an internal broker-dealer systems provided to the customers of the broker or dealer that sponsors such internal broker-dealer system.

To simplify the ICR process, we are adding Rule 17a-4(b)(11) to the larger information collection Rule 17a-4 in its entirety, and will discontinue ICR 3235-0506 for Rule 17a-4(b)(11) . This will add 315 hours additional hours to Rule 17a-4. (1,196,086 + 315 = 1,196,401)

Rule 17a-4(b)(11) describes the record preservation requirements for those records, including how such records must be kept and for how long.

The Commission also estimates that each respondent would spend an average 3 hours to comply with Rule 17a-4(b)(11) to review and preserve the required records.

The Commission estimates that an employee of a broker-dealer charged to ensure compliance with Rule 17a-4(b)(11) receives annual compensation of $238,000. This compensation is the equivalent of $119 per hour ($238,000 divided by 2,000 pay roll hours per year). Thus, the average cost estimated for each respondent would be $357.00 : Rule 17a-4(b)(11)Record preservation requirements 3 hours at $119/hr =$ 357