Rule 17g-5 Conflicts of Interest

ICR 201409-3235-019

OMB: 3235-0649

Federal Form Document

Forms and Documents
Document
Name
Status
Supporting Statement A
2014-09-16
ICR Details
3235-0649 201409-3235-019
Historical Active 201205-3235-001
SEC TM-270-581
Rule 17g-5 Conflicts of Interest
Revision of a currently approved collection   No
Emergency 11/10/2014
Approved without change 11/19/2014
Retrieve Notice of Action (NOA) 09/17/2014
  Inventory as of this Action Requested Previously Approved
05/31/2015 6 Months From Approved 11/30/2015
3,620 0 15,290
278,052 0 168,900
67,000 0 0

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.
When the amendments to Rule 17g-5 rule were first proposed in 2011, the accompanying Federal Register release indicated that the proposed amendments “do not contain a collection of information requirement within the meaning of the PRA.” Since that time, the Commission has carefully re-considered the operation of these rules and has determined that these amendments would in fact supplement and modify the existing collection of information contained in Rule 17g-5. Accordingly, the Commission included PRA estimates in the Federal Register release in which it adopted the final amendments to the rule. Because of this revised approach, the attached supporting statement includes PRA burdens that have not previously been reviewed by OMB. Because a PRA submission has not previously been made in connection with these amendments, the Commission is requesting approval of the revised collection of information for a six-month period under the emergency review process. Approval of this request would be consistent with the effective date of the amended rules while providing sufficient time for the Commission to request approval of an extension of this collection of information for a full three-year period using the standard review process, including publication in the Federal Register of all applicable requests for public comment.

US Code: 15 USC 780-7 Name of Law: Credit Rating Agency Reform Act of 2006
  
US Code: 15 USC 780-7 Name of Law: Credit rating Agency Reform Act

3235-AL15 Final or interim final rulemaking 79 FR 55077 09/15/2014

No

  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 3,620 15,290 0 498 -12,168 0
Annual Time Burden (Hours) 278,052 168,900 0 235,272 -126,120 0
Annual Cost Burden (Dollars) 67,000 0 0 67,000 0 0
Yes
Changing Regulations
Yes
Changing Regulations
As detailed in the supporting statement, the Commission has added provisions to Rule 17g-5 that contain information collection requirements under the Paperwork Reduction Act. The Commission has also revised previously approved one-time burdens that have been incurred.

$0
No
No
No
Yes
No
Uncollected
Rose Wells 202 942-0143

  No

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:
 
 
 
 
 
 
 
    (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;
 
 
 
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.
09/17/2014


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