1557-0184 - Clean

Supporting Statement for

OMB Control No. 1557-0184

Municipal Securities Dealers and

Government Securities Brokers and Dealers –

Registration and Withdrawal

A. Justification.

1. Circumstances that make the collection necessary:

Section 15B¹ and section 15C² of the Securities Exchange Act of 1934 (the “Exchange Act”) require, in part, that all national banks and Federal savings associations (“FSAs”) that act as a municipal securities dealer or a government securities broker/dealer file the relevant form with the appropriate Federal regulatory agency to inform such agency of their broker/dealer activities. This information collection is required to satisfy the requirements of the Exchange Act. National banks and FSAs planning to engage in broker/dealer activities must file the required forms before beginning these activities.

This submission covers the following forms: MSD, MSDW, MSD-4, MSD-5, G-FIN, and G-FINW.

2. Use of the information:

The forms are completed by all national banks, FSAs, and certain national bank and FSA employees that act in a broker/dealer capacity, and are submitted to the OCC. The OCC reviews and files the forms and maintains a detailed record of the information. A copy of the form is sent by the OCC to the Securities and Exchange Commission, which uses the information to monitor security industry participants. The information must be collected to meet the registration requirements of the Exchange Act.

The OCC uses this information to determine which national banks and FSAs are government and municipal securities broker/dealers and to monitor entry into and exit from government and municipal securities broker/dealer activities by institutions and registered persons. Further, the OCC uses the information in planning required national bank and FSA examinations. The information contributes to the OCC's understanding of the national bank or FSA and the scope of its activities and facilitates OCC supervision of and, in case of serious violations of the Exchange Act, termination of broker/dealer activities.

3. Consideration of the use of improved information technology:

The forms are simple to prepare and submit and impose only minimal burden. The OCC offers the documents on its website to reduce burden and, whenever possible, the OCC responds by electronic mail to document requests from registrants.

4. Efforts to identify duplication:

The information obtained in the forms is unique. It identifies the national bank or FSA as a government and/or municipal securities broker and/or dealer, associated and supervisory personnel, and the types of securities activities. In cases where individuals are registered under both the government and municipal securities laws, the OCC will permit those individuals to submit combined information on the MSD-4 and/or the MSD-5.

5. Methods used to minimize burden if the collection has a significant impact on small entities:

This information collection does not have a significant impact on a significant number of small entities. Generally, small national banks and FSAs are not involved in those securities activities that require registration. However, the registration requirement does not adjust form or content for differences in the size of registrants. The information collected is the minimum needed to satisfy the requirements of the Exchange Act.

6. Consequences to the Federal Program if the collection were conducted less frequently:

Reports are required only when the national bank or FSA initially registers with the OCC, withdraws its registration, or when material changes are noted in personnel or the locations of securities activities. The information is collected as changes occur. The information cannot be collected less frequently due to statutory requirements.

7. Special circumstances necessitating collection inconsistent with 5 CFR Part 1320:

Not applicable. This information is collected in a manner consistent with the guidelines in 5 CFR Part 1320.

8. Efforts to consult with persons outside the agency:

The forms are the result of the OCC's consultation with the Treasury Department, the Municipal Securities Rulemaking Board, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Securities and Exchange Commission.

The OCC published a Federal Register notice on February 8, 2013 (78 FR 2720) regarding renewal of this information collection. No comments were received.

9. Payment to respondents:

Not applicable. There is no payment to respondents.

10. Any assurance of confidentiality:

No assurance of confidentiality is provided.

11. Justification for questions of a sensitive nature:

No sensitive questions are asked.

12. Burden estimate:

There are an estimated 24 bank dealers registered with the OCC. The OCC expects to receive 920 various filings per year. The total annual burden for national banks is estimated at 867.25 burden hours. Burden is presented as follows:

24 respondents @ 38.33 responses per year = 920 responses

920 responses @ 0.9427 hour per response = 867.25 burden hours

Form Responses Burden per Response Total Burden

MSD 14 1.5 hours 21.00 hours

MSDW 3 .25 hours 0.75 hours

MSD-4 800 1.0 hours 800.00 hours

MSD-5 75 .25 hours 18.75 hours

G-FIN 26 1.0 hours 26.00 hours

G-FINW 3 .25 hours 0.75 hours

Total: 920 867.25 hours

The OCC estimates the cost of the hour burden to respondents as follows:

Clerical: 10% x 867.25 = 86.73 @ $20 = $ 1,734.50

Managerial/technical: 60% x 867.25 = 520.35 @ $40 = 20,814.00

Senior management/professional: 30% x 867.25 = 260.17 @ $80 = 20,814.00

Total: $ 43,362.50

13. Estimates of annualized costs to respondents:

Not applicable.

14. Estimate of annualized cost to the Federal Government:

Not applicable.

15. Change in burden:

The number of bank dealers changed from 29 to 24. This reflects 5 dealers that withdrew.

Former Burden: 29 Respondents @ 35.3846 Responses per year = 1,026 Total Responses

1,026 Reponses @ 0.86111 Hour Per Response = 884 Total Burden Hours

Current Burden: 24 Respondents @ 38.33 Responses per year = 920 Total Responses

920 Reponses @ 0.9426 Hour Per Response = 867.25 Total Burden Hours

Difference: -5 Respondents; +2.9454 Responses per year; -106 Total Responses

-106 Responses; +.08149 Hours Per Response; -16.75 Total Burden Hours

16. Information regarding collections whose results are planned to be published for statistical use:

Not applicable. This information will not be published for statistical use.

17. Display of expiration date:

Not applicable.

18. Exceptions to certification statement:

None.

B. Collections of Information Employing Statistical Methods.

Not applicable.

1 15 U.S.C. 78o-4.

2 15 U.S.C. 78o-5.