Rule 17g-8 Policies and procedures and Rule 17g-9 Standards of training, experience, and competence for credit analysts

Forms and Documents

Document Name	Status
PRA Rule 17g-8 and 9 Supporting Statement FINAL.docx Supporting Statement A	2015-04-10

IC Document Collections

IC ID	Document Title	Status
216057	Rule 17g-9 annual recordkeeping costs to retain outside professionals	New
216056	Rule 17g-9 annual recordkeeping burden per credit analyst	New
216055	Rule 17g-9 annual recordkeeping burden based on number of credit analysts	New
216047	Rule 17g-9 one-time recordkeeping burden based on number of credit analysts	New
216046	Rule 17g-9 annual recordkeeping	New
216045	Rule 17g-9 one-time recordkeeping	New
216044	Rule 17g-8(c) annual recordkeeping burden	New
216043	Rule 17g-8(c) one-time recordkeeping burden	New
216042	Rule 17g-8(b) annual recordkeeping burden	New
216041	Rule 17g-8(b) one-time recordkeeping burden	New
216040	17g-8(a) internet website publication annual burden	New
216039	Rule 17g-8(a) annual recordkeeping burden	New
216038	Rule 17g-8(a) one-time recordkeeping burden	New
201507	IC - 2	Removed
201506	IC - 1	Removed

ICR Details

OMB Control No: 3235-0693	ICR Reference No: 201412-3235-009
Status: Historical Active	Previous ICR Reference No: 201412-3235-007
Agency/Subagency: SEC	Agency Tracking No: OCR-270-645
Title: Rule 17g-8 Policies and procedures and Rule 17g-9 Standards of training, experience, and competence for credit analysts
Type of Information Collection: New collection (Request for a new OMB Control Number)	Common Form ICR:  No
Type of Review Request: Regular
OIRA Conclusion Action: Approved without change	Conclusion Date: 06/10/2015
	Date Received in OIRA: 04/10/2015
Terms of Clearance:

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	06/30/2018	36 Months From Approved
Responses	130	0	0
Time Burden (Hours)	34,394	0	0
Cost Burden (Dollars)	1,357,866	0	0

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Abstract: Rule 17g-8 would require nationally recognized statistical rating organizations ("NRSROs") to establish, maintain and enforce certain policies and procedures relating to credit rating methodologies, the use of credit rating symbols, and look-back procedures for departing NRSRO employees. Rule 17g-9 implements Section 936 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, which requires the Securities and Exchange Commission to issue rules reasonably designed to ensure that any person employed by a nationally recognized statistical rating organization to determine credit ratings meets standards of training, experience, and competence necessary to produce accurate ratings for the categories of issuers whose securities the person rates and is tested for knowledge of the credit rating process.

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Authorizing Statute(s): US Code: 15 USC 78o-7, 78o-7(h)(4)(A)(ii), Name of Law: Securities Exchange Act of 1934
   US Code: 15 USC 78o-8, 78o-7(s), 78o-7(r) Name of Law: Securities Exchange Act of 1934
  

Citations for New Statutory Requirements: PL: Pub.L. 111 - 203 932(a)(4), 932(a)(8) 936, 938 Name of Law: Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010

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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: 13

IC Title	Form No.	Form Name
Rule 17g-8(b) annual recordkeeping burden
Rule 17g-8(c) one-time recordkeeping burden
Rule 17g-8(c) annual recordkeeping burden
Rule 17g-9 one-time recordkeeping
Rule 17g-9 annual recordkeeping
Rule 17g-9 one-time recordkeeping burden based on number of credit analysts
Rule 17g-9 annual recordkeeping burden based on number of credit analysts
IC - 1
IC - 2
Rule 17g-8(a) one-time recordkeeping burden
Rule 17g-8(a) annual recordkeeping burden
17g-8(a) internet website publication annual burden
Rule 17g-8(b) one-time recordkeeping burden
Rule 17g-9 annual recordkeeping burden per credit analyst
Rule 17g-9 annual recordkeeping costs to retain outside professionals

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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	130	0	140	0	-10	0
Annual Time Burden (Hours)	34,394	0	43,934	-7,040	-2,500	0
Annual Cost Burden (Dollars)	1,357,866	0	2,366,866	-939,000	-70,000	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: Yes

Burden Reduction Due to: Miscellaneous Actions

Short Statement: Rule 17g-8 and Rule 17g-9 are new collections of information.

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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: 04/10/2015

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