Rule 17g-2 Records to be made and retained by nationally recognized statistical rating organizations

Forms and Documents

Forms and supporting documents for this ICR

Document	Type	Status	Availability
Rule 17g-2 Supporting Statement (Final)-2.doc	Supporting Statement A	Uploaded 2014-09-11	Available

IC Document Collections

Information collection document groups

IC ID	Collection	Type	Status	Form
203418	Retaining updated records		Unchanged
203417	Updating record retention policies and procedures		Unchanged
200936	Filing for use of a third-party record custodian		Removed
200935	Requirement to make sample of ratings action histories available		Removed
200934	Cost to new NRSRO's of setting up recordkeeping system (one-time averaged over 3 yrs)		Removed
179758	Rule 17g-2 Records to be made and retained by NRSROs (on-going)		Modified

ICR Details

OMB Control No: 3235-0628	ICR Reference No: 201411-3235-004
Status: Historical Active	Previous ICR Reference No: 201201-3235-008
Agency/Subagency: SEC	Agency Tracking No: TM-270-564
Title: Rule 17g-2 Records to be made and retained by nationally recognized statistical rating organizations
Type of Information Collection: Revision of a currently approved collection	Common Form ICR:  No
Type of Review Request: Regular
OIRA Conclusion Action: Approved without change	Conclusion Date: 11/19/2014
	Date Received in OIRA: 11/19/2014
Terms of Clearance:

table that charts list comparision

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	11/30/2017	36 Months From Approved	06/30/2015
Responses	30	0	23
Time Burden (Hours)	2,457	0	2,987
Cost Burden (Dollars)	0	0	5,933

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Abstract: Rule 17g-2 implements certain statutory provisions of the Credit Rating Agency Reform Act of 2006 by requiring a nationally recognized statistical rating organization or "NRSRO" to make and retain certain records relating to its business and to retain certain other business records, if such records are made. The rule also prescribes the time periods and manner in which all these records must be retained. The collections of information in Rule 17g-2 are designed to allow the Commission to determine whether an NRSRO continues to meet the requirements for registration and is complying with applicable laws and regulations. In particular, the collections of information in Rule 17g-2 will assist the Commission in effectively monitoring, through its examination function, whether an NRSRO is conducting its activities in accordance with Section 15E of the Exchange Act, and applicable Exchange Act rules under the Rating Agency Act.

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Authorizing Statute(s): US Code: 15 USC 78o-7 Name of Law: Credit Rating Agency Reform Act of 2006
   US Code: 15 USC 78c, 78d, 78i, 78j, 78l, 78m, Name of Law: The Securities Exchange Act of 1934
  

Citations for New Statutory Requirements: PL: Pub.L. 111 - 203 939, 939D - 939F Name of Law: Dodd-Frank Wall Street Reform and Consumer Protection Act

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Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
3235-AL15	Final or interim final rulemaking	79 FR 55078	09/15/2014

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Federal Register Notices & Comments

Did the Agency receive public comments on this ICR? No

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Number of Information Collection (IC) in this ICR: 3

table that charts list of burden

IC Title	Form No.	Form Name
Filing for use of a third-party record custodian
Requirement to make sample of ratings action histories available
Rule 17g-2 Records to be made and retained by NRSROs (on-going)
Updating record retention policies and procedures
Retaining updated records
Cost to new NRSRO's of setting up recordkeeping system (one-time averaged over 3 yrs)

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ICR Summary of Burden

table that charts list 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	30	23	0	-2	9	0
Annual Time Burden (Hours)	2,457	2,987	0	-575	45	0
Annual Cost Burden (Dollars)	0	5,933	0	-8,933	3,000	0

Burden increases because of Program Change due to Agency Discretion: Yes

Burden Increase Due to: Changing Regulations

Burden decreases because of Program Change due to Agency Discretion: Yes

Burden Reduction Due to: Changing Regulations

Short Statement: The Commission is repealing paragraph (d)(2) of Rule 17g-2 and re-codifying and enhancing the requirements in paragraph (d)(3) of Rule 17g-2 in new Rule 17g-7. The Commission estimates that these changes will result in a reduction of the PRA burden associated with Rule 17g-2. The Commission is adding paragraph (a)(9) to Rule 17g-2 to identify the policies and procedures an NRSRO is required to establish, maintain, and enforce pursuant to section 15E(h)(4)(A) of the Exchange Act and paragraph (c) of new Rule 17g-8 as a record that must be made and retained. In addition, the Commission is adding new paragraphs to Rule 17g-2 to identify records that must be retained. The Commission is also amending paragraph (c) of Rule 17g-2 to provide that records identified in paragraphs (a)(9), (b)(12), (b)(13), (b)(14), and (b)(15) of Rule 17g-2 must be retained until three years after the date the record is replaced with an updated record, instead of three years after the record is made or received, which is the retention period for other records identified in paragraphs (a) and (b) of Rule 17g-2. The reduction of the costs are due to one time costs have been incurred.

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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]? Yes

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: 09/10/2014

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