Rule 206(4)-6 Under the Investment Advisers Act of 1940 (17 CFR 275.206(4)-6)

Forms and Documents

Document Name	Status
Rule 206(4)-6 Supporting Statement (2013 revision clean).pdf Supporting Statement A	2014-05-22
Rule_text_206(4)-6[1].pdf Supplementary Document	2011-03-28

IC Document Collections

IC ID	Document Title	Status
35418	Rule 206(4)-6 Under the Investment Advisers Act of 1940	Modified

ICR Details

OMB Control No: 3235-0571	ICR Reference No: 201402-3235-005
Status: Historical Active	Previous ICR Reference No: 201103-3235-031
Agency/Subagency: SEC	Agency Tracking No: IM-270-513
Title: Rule 206(4)-6 Under the Investment Advisers Act of 1940 (17 CFR 275.206(4)-6)
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: 07/14/2014
	Date Received in OIRA: 05/22/2014
Terms of Clearance:

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	07/31/2017	36 Months From Approved	07/31/2014
Responses	1,351,000	0	1,245,254
Time Burden (Hours)	230,635	0	225,575
Cost Burden (Dollars)	0	0	0

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Abstract: Rule 206(4)-6 requires investment advisers to adopt and implement written policies and procedures reasonably designed to ensure the adviser votes client proxies in the best interest of the clients. The rule requires disclosure of these policies and procedures to clients, as well as information on how clients can obtain information from the adviser about how the adviser voted the client's securities.

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Authorizing Statute(s): US Code: 15 USC 80b Name of Law: Investment Advisers Act of 1940
  

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:
	78 FR 70975	11/27/2013
30-day Notice:	Federal Register Citation:	Citation Date:
	79 FR 4986	01/30/2014
Did the Agency receive public comments on this ICR? No

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Number of Information Collection (IC) in this ICR: 1

IC Title	Form No.	Form Name
Rule 206(4)-6 Under the Investment Advisers Act of 1940

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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	1,351,000	1,245,254	0	0	105,746	0
Annual Time Burden (Hours)	230,635	225,575	0	0	5,060	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: We have increased the estimated hour burden from 225,575 hours to 230,635 hours based on new information with respect to the estimated average number of clients of SEC-registered investment advisers. This new information is based on data derived from information submitted by advisers on Form ADVs filed through the IARD. The number of hours per response has not changed since the last estimate. The increase in hour burden is entirely due to an increase in the estimated average number of clients of respondents.

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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: 05/22/2014

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