Rule 17g-10 Certification of providers of third-party due diligence services in connection with asset-backed securities & Form ABS Due Diligence-15E

Forms and Documents

Document Name	Status
Form 15E Rule 17g-10 and Form ABS Due Diligence-15E annual disclosure burden Form	New
Rule 17g-10 and Form ABS Due Diligence-15E SS FINAL.pdf Supporting Statement A	2015-04-09

IC Document Collections

IC ID	Document Title	Status
201505	Rule 17g-10 and Form ABS Due Diligence-15E annual disclosure burden Form	New
201503	Rule 17g-10 and Form ABS Due Diligence-15E one-time disclosure burden and cost	New

ICR Details

OMB Control No: 3235-0694	ICR Reference No: 201504-3235-005
Status: Historical Active	Previous ICR Reference No:
Agency/Subagency: SEC	Agency Tracking No: OCR-270-597
Title: Rule 17g-10 Certification of providers of third-party due diligence services in connection with asset-backed securities & Form ABS Due Diligence-15E
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: 05/14/2015
	Date Received in OIRA: 04/10/2015
Terms of Clearance:

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	05/31/2018	36 Months From Approved
Responses	30	0	0
Time Burden (Hours)	3,613	0	0
Cost Burden (Dollars)	150,000	0	0

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Abstract: Rule 17g-10 and proposed new Form ABS Due Diligence-15E is designed to achieve the objective stated in Section 15E(s)(4)(B) of the Exchange Act; namely, that a provider of third-party due diligence services conducts a thorough review of data, documentation, and other relevant information necessary for an NRSRO to provide an accurate credit rating. They also are designed – in combination with the disclosure requirement in proposed new paragraph (a)(2) of Rule 17g-7 – to achieve the objective stated in Section 15E(s)(4)(D) of the Exchange Act; namely, to allow the public to determine the adequacy and level of due diligence services provided by a third party.

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Authorizing Statute(s): PL: Pub.L. 111 - 203 932(a)(8) Name of Law: Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010
   US Code: 15 USC 78o-7(s) Name of Law: U.S. Securities Exchange Act of 1934
  

Citations for New Statutory Requirements: US Code: 15 USC 78o-7(s) Name of Law: U.S. Securities Exchange Act of 1934

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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
60-day Notice:	Federal Register Citation:	Citation Date:
	79 FR 55078	09/15/2014
30-day Notice:	Federal Register Citation:	Citation Date:
	79 FR 55078	09/15/2014
Did the Agency receive public comments on this ICR? No

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Number of Information Collection (IC) in this ICR: 2

IC Title	Form No.	Form Name
Rule 17g-10 and Form ABS Due Diligence-15E one-time disclosure burden and cost
Rule 17g-10 and Form ABS Due Diligence-15E annual disclosure burden	15E	FORM ABS DUE DILIGENCE-15E

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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	30	0	30	0	0	0
Annual Time Burden (Hours)	3,613	0	3,613	0	0	0
Annual Cost Burden (Dollars)	150,000	0	150,000	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: Rule 17g-10 and Form ABS Due Diligence-15E are a new rule and form.

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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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