Rule 17g-7 : Reports to be made public by nationally recognized statistical rating organizations (NRSROs)

Forms and Documents

Document Name	Status
PRA Rule 17g-7 Supporting Statement FINAL (3).pdf Supporting Statement A	2015-04-15
2011 17g-7 Supporting Statement - PR Final.docx Supplementary Document	2015-04-14

IC Document Collections

IC ID	Document Title	Status
216091	17g-7 Current asset-backed securities disclosure burden	New
216079	Rule 17g-7(b) annual disclosure burden	New
216069	Rule 17g-7(a) one time cost burden for outside professionals	New
216068	Rule 17g-7(b) one time disclosure burden associated with enhancements to the 100% Rule	New
216067	Rule 17g-7(a) annual disclosure burden to generate and publish forms	New
216066	Rule 17g-7(a) annual disclosure burden for updating the standardized disclosures	New
191790	Rule 17g-7(a) one-time disclosure burden	Modified

ICR Details

OMB Control No: 3235-0656	ICR Reference No: 201504-3235-007
Status: Historical Inactive	Previous ICR Reference No: 201402-3235-008
Agency/Subagency: SEC	Agency Tracking No: OCR-270-600
Title: Rule 17g-7 : Reports to be made public by nationally recognized statistical rating organizations (NRSROs)
Type of Information Collection: Revision of a currently approved collection	Common Form ICR:  No
Type of Review Request: Regular
OIRA Conclusion Action: Preapproved	Conclusion Date: 06/10/2015
	Date Received in OIRA: 04/15/2015
Terms of Clearance: Resubmit to OMB for review if the collection changes substantively following publication of the final rule.

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	06/30/2018	36 Months From Approved	07/31/2017
Responses	70	0	8,268
Time Burden (Hours)	800,845	0	91,948
Cost Burden (Dollars)	1,666,667	0	0

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Abstract: Rule 17g-7 implements certain statutory provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act relating to nationally recognized statistical rating organizations ("NRSROs"). Paragraph (a) of Rule 17g-7 requires an NRSRO to provide along with any credit rating that it publishes, a report containing an attestation and certain disclosures. Paragraph (b) of Rule 17g-7 requires an NRSRO to make available on its corporate Web site in XBRL format the rating action history of each outstanding credit rating that it determined on or after June 26, 2007.

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Authorizing Statute(s): PL: Pub.L. 111 - 203 932 Name of Law: Dodd-Frank Wall Street Reform and Consumer Protection Act
   US Code: 15 USC 78o-7 Name of Law: Securities Act of 1933
  

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

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Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
3235-AL15	Proposed rulemaking	76 FR 33420	08/08/2011

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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: 7

IC Title	Form No.	Form Name
Rule 17g-7(b) one time disclosure burden associated with enhancements to the 100% Rule
Rule 17g-7(a) one time cost burden for outside professionals
Rule 17g-7(b) annual disclosure burden
Rule 17g-7(a) annual disclosure burden for updating the standardized disclosures
Rule 17g-7(a) annual disclosure burden to generate and publish forms
17g-7 Current asset-backed securities disclosure burden
Rule 17g-7(a) one-time disclosure burden

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ICR Summary of Burden

	Total Request	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	70	8,268	50	0	-8,248	0
Annual Time Burden (Hours)	800,845	91,948	708,747	0	150	0
Annual Cost Burden (Dollars)	1,666,667	0	1,666,667	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: The change in burden is a result of the Amendments to Rule 17g-7 the Commission adopted to implement the attestation and disclosures required by Sections 15E(q) and 15E(s) of the Exchange Act. The Commission modified the the annual time burden estimates in the Adopting Release. The Commission estimates that the Amendments to Rule 17g-7 will result in a one-time burden increase of 38,850 hours and now estimates an ongoing annual time burden increase of 695,947 hours.

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Annual Cost to Federal Government:

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: 04/14/2015

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