Rule 15c3-1 Supporting Statement

SUPPORTING STATEMENT
for the Paperwork Reduction Act Information Collection Submission for
Rule 15c3-1 – Net Capital Requirements for Brokers or Dealers
This submission is being made pursuant to the Paperwork Reduction Act of 1995, 44
U.S.C. Section 3501 et seq.
A.

Justification
1.

Necessity of Information Collection

Rule 15c3-1 1 under the Securities Exchange Act of 1934 (“Exchange Act”) 2 is intended
to ensure that broker-dealers registered with the Securities and Exchange Commission
(“Commission”) at all times have sufficient liquid capital to protect the assets of customers and
to meet their responsibilities to other broker-dealers. 3 Rule 15c3-1 generally defines the term
“net capital” as a broker-dealer’s net worth (assets minus liabilities), plus certain subordinated
liabilities, less certain assets that are not readily convertible into cash (e.g., fixed assets), and less
a percentage (haircut) of certain other liquid assets (e.g., securities). 4
Rule 15c3-1 is an integral part of the Commission’s financial responsibility program for
broker-dealers. In particular, Rule 15c3-1 facilitates the monitoring of the financial condition of
broker-dealers by the Commission and the broker-dealer’s designated examining authority
(“DEA”). If the information were not required to be collected, the Commission and the DEAs
will not be able to monitor the financial condition of broker-dealers, exposing their customers
and counterparties to increased risk.
2.

Purpose and Use of the Information Collection

Rule 15c3-1 is intended to help ensure that broker-dealers maintain at all times sufficient
liquid resources to meet all liabilities, particularly the claims of customers, by requiring that
broker-dealers maintain a minimum amount of net capital. A broker-dealer’s minimum net
capital requirement is the greater of: (1) a fixed minimum amount set forth in Rule 15c3-1 based
on the types of business that the broker-dealer conducts; 5 or (2) a financial ratio. 6 Exchange Act
Section 15(c)(3) and Rule 15c3-1 promulgated thereunder prohibit a broker-dealer from effecting
transactions in securities while not in compliance with its minimum net capital requirement.
Various provisions of Rule 15c3-1 require that broker-dealers provide written notification
to the Commission and/or their DEA under certain circumstances. For example, a broker-dealer
1

17 CFR 240.15c3-1.

2

15 U.S.C. § 78 et seq.

3

See Net Capital Rule, Exchange Act Release No. 39455 (Dec. 17, 1997), 62 FR 67996 (Dec. 30, 1997).

4

See 17 CFR 240.15c3-1(c)(2).

5

See 17 CFR 240.15c3-1(a)(2)–(9).

6

See 17 CFR 240.15c3-1(a)(1)(i)–(iii).

carrying the account of an options market maker must file a notice with the Commission and the
DEA of both the carrying firm and the market maker prior to effecting transactions in the
account. 7 In addition, the carrying firm must notify the Commission and the appropriate DEA if
a market maker fails to deposit the required equity with the carrying broker-dealer relating to the
market maker’s account within the prescribed time period or if certain deductions and other
amounts relating to the carrying firm’s market maker accounts computed in accordance with
Rule 15c3-1 exceeds 1,000% of the carrying broker-dealer’s net capital. 8 In addition, a brokerdealer electing to compute its net capital using the alternative method under paragraph (a)(1)(ii)
of Rule 15c3-1 must notify its DEA of the election in writing, and thereafter must continue to
compute its net capital in this manner unless a change is approved upon application to the
Commission. 9
There are also certain recordkeeping requirements under Rule 15c3-1. For example, a
broker-dealer must keep a record of who is acting as an agent in a securities loan transaction and
records with respect to obtaining DEA approval prior to withdrawing capital within one year of a
contribution. 10 These records help the Commission and its staff, as well as DEAs, facilitate the
monitoring of the financial condition of broker-dealers.
Appendix C to Rule 15c3-1 requires broker-dealers that consolidate their financial
statements with a subsidiary or affiliate, under certain circumstances, to submit to their DEA an
opinion of counsel. 11 The opinion of counsel must state, among other things, that the brokerdealer may cause that portion of the net assets of a subsidiary or affiliate related to its ownership
interest in the entity to be distributed to the broker-dealer within 30 calendar days. 12
Appendix E to Rule 15c3-1 provides an alternative method for determining certain net
capital charges for certain broker-dealers (“alternative net capital firms” or “ANC firms”). 13
Appendix G to Rule 15c3-1 requires the holding company of an ANC firm that has a principal
regulator to file certain periodic reports with the Commission, preserve certain records, and
notify the Commission of certain events. The notification provisions of Appendix G are
designed to give the Commission advance warning of situations that may pose material financial
and operational risks to the broker-dealer and its holding company. These provisions are integral
to Commission supervision of broker-dealers that use Appendix E.
3.

Consideration Given to Information Technology

7

See 17 CFR 240.15c3-1(a)(6)(vi).

8

See 17 CFR 240.15c3-1(a)(6)(iv)(B); 17 CFR 240.15c3-1(a)(6)(v).

9

See 17 CFR 240.15c3-1(a)(1)(ii).

10

See 17 CFR 240.15c3-1(c)(2)(iv)(B); 17 CFR 240.15c3-1(c)(2)(i)(G)(2).

11

See 17 CFR 240.15c3-1c(b)(1).

12

See 17 CFR 240.15c3-1c(b)(2).

13

See 17 CFR 240.15c3-1e.

2

The method of computing net capital varies by size and complexity of a broker-dealer.
Most large broker-dealers subject to Rule 15c3-1 utilize automated systems for computing their
net capital and minimum requirements. Smaller broker-dealers with simple balance sheets may
compute their net capital on a manual basis. The information collections however do not require
that respondents use any specific information technology system either to prepare or submit
information collections under Rule 15c3-3, as amended.
4.

Duplication

We are not aware that this information collection duplicates any existing information
collection.
5.

Effects on Small Entities

Small entities may be affected to the extent they are required to maintain a minimum
amount of net capital under Rule 15c3-1. However, there are different requirements for small
entities subject to Rule 15c3-1. Most of these entities are not affected by the information
collection provisions of Rule 15c3-1.
6.

Consequences of not Conducting Collection

If the required activities were not required to be collected, or were required to be
conducted less frequently, the Commission and the DEAs will not be able to monitor the
financial condition of broker-dealers, exposing their customers and counterparties to increased
risk and lessening the protection afforded to the public.
7.

Inconsistencies with Guidelines in 5 CFR 1320.5(d)(2)

There are no special circumstances. This collection is consistent with the guidelines in 5
CFR 1320.5(d)(2).
8.

Consultations Outside the Agency

The required Federal Register notice with a 60-day comment period soliciting comments
on this collection of information was published. No public comments were received.
9.

Payment or Gift

No payments or gifts have been provided to respondents.
10.

Confidentiality

The Commission regards information obtained pursuant to the filings and notices
required by Rule 15c3-1 to be confidential. Such information is of a financial nature and
generally is not disclosed to the public. The statutory basis for the Commission’s refusal to
disclose such information to the public is the exemption contained in section (b)(4) of the
Freedom of Information Act, 5 U.S.C. 552, which provides that the requirement of public

3

dissemination does not apply to commercial or financial information which is privileged or
confidential.
11.

Sensitive Questions

The collections of information do not expressly include Personally Identifiable
Information (“PII”). 14 At the same time, however, Commission staff understands that there may
be instances when certain information (including, but not limited to, a person’s name, email, or
phone number) could be provided by a respondent in response to one of the collections of
information. However, Commission staff does not envision any circumstances in which a social
security number will be provided pursuant to any of the collections of information. As such, we
believe that the treatment of any PII with the collection of information associated with Rule 15c31 is not likely to implicate the Federal Information Security Management Act of 2002 or the
Privacy Act of 1974.
12.

Burden of Information Collection

Based on experience with the industry, the Commission estimates that broker-dealers
annually file approximately 902 notices under Rule 15c3-1 and that a broker-dealer will spend
approximately 30 minutes preparing and filing these notices. Therefore, the Commission
estimates a total annual reporting burden of 451 hours. 15
Paragraph (c)(2)(iv)(B) of Rule 15c3-1 requires a broker-dealer to make disclosures to,
and obtain certain agreements from, securities lending principals in situations where the firm
participates in the settlement of a securities lending transaction but wants to be deemed an agent
for purposes of Rule 15c3-1. The Commission estimates that 5% of the 122 broker-dealers, or
approximately 6 firms, engaged in securities lending will need to modify their standard
agreements. The Commission estimates each of these firms will spend approximately 20 hours
of employee resources updating their standard agreement template. Therefore, the Commission
estimates that the total one-time recordkeeping burden will be approximately 120 hours. 16
Paragraph (c)(2)(i)(G)(2) of Rule 15c3-1 requires that a broker-dealer treat as a liability
any capital contribution that is intended to be withdrawn within one year of its contribution. The
amendment also includes the presumption that capital withdrawn within one year of contribution
is presumed to have been intended to be withdrawn within one year, unless the broker-dealer
receives permission in writing for the withdrawal from its DEA. The Commission estimates that
90 broker-dealers will seek to obtain permission from their DEA in writing to withdraw capital
within one year of its contribution, and that it will take a broker-dealer approximately one hour

14

The term “Personally Identifiable Information” refers to information which can be used to distinguish or
trace an individual’s identity, such as their name, social security number, biometric records, etc. alone, or
when combined with other personal or identifying information which is linked or linkable to a specific
individual, such as date and place of birth, mother’s maiden name, etc.

15

902 notices x (30 minutes / 60 minutes) = 451 hours.

16

6 broker-dealers x 20 hours per firm = 120 hours. The three-year annualized number for this one time
burden is 40 hours (120 hours / 3 years = 40), or 6.67 hours per firm.

4

to prepare and submit the request to its DEA to withdraw capital. Therefore, the Commission
estimates that the total annual reporting burden will be approximately 90 hours. 17
With respect to Appendices E and G of Rule 15c3-1, the following estimates are based on
the assumption that 10 broker-dealers will ultimately compute deductions for market risk under
Appendix E. Currently, there are 5 ANC firms, and the Commission expects that 5 additional
firms will apply to compute deductions for market risk under Appendix E. 18 The Commission
estimates that each broker-dealer that applies will incur a one-time recordkeeping burden of
approximately 1,000 hours to create and compile the various documents to be included with the
application and to work through the application process, with an aggregate one-time
recordkeeping burden of 5,000 hours or an annualized burden of 1,666.65 per year. 19
The Commission estimates that an ANC firm using Appendices E and G to Rule 15c3-1
spends approximately 5,600 hours per year to review and update the models it uses to assess
market and credit risk and approximately 160 hours each quarter, or approximately 640 hours per
year, to back test the models. Consequently, the Commission estimates that the total annual
recordkeeping burden associated with reviewing and back testing mathematical models for the 5
ANC firms will be approximately 31,200 hours, 20 and approximately 20,800 hours 21 for the 5
broker-dealers expected to become ANC firms, resulting in an aggregate annual recordkeeping
burden of 52,000 hours. 22
The Commission estimates that the average amount of time necessary to prepare and file
the monthly reports required by Appendix G will be approximately 8 hours per month, or 96
hours per year. The Commission estimates that the average amount of time necessary to prepare
and file the quarterly reports will be approximately 16 hours per quarter, or 64 hours per year.
The Commission estimates that the average amount of time necessary to prepare and file the
annual audit reports will be approximately 200 hours per year. Consequently, the Commission
estimates that the total annual reporting burden of Appendix G for the 5 ANC firms will be
approximately 1,800 hours, 23 and the total annual reporting burden for the 5 broker-dealers

17

90 broker-dealers x 1 hour = 90 hours.

18

The Commission expects that these 5 firms will register as ANC firms over the next three years. However,
until their registrations are complete, these firms will not be subject to the annual burdens discussed
throughout Item 12. Therefore, the Commission has taken this fact into consideration in its calculations.

19

The three-year annualized number for this one-time burden is 333.33 per firm (1,000 hours / 3 years =
333.33), or 1,666.65 hours for the industry (333.33 hours x 5 firms).

20

(5,600 hours + 640 hours) x 5 broker-dealers = 31,200 hours.

21

(Y1: 0 hours) + (Y2: 5,600 hours + 640 hours = 6,240 hours) + (Y3: 5,600 hours + 640 hours = 6,240
hours) = 12,480 hours / 3 years = 4,160 x 5 ANC broker-dealers = 20,800 hours.

22

31,200 hours + 20,800 hours = 52,000 hours.

23

(96 hours + 64 hours + 200 hours) x 5 ANC broker-dealers = 1,800 hours.

5

expected to become ANC firms will be approximately 1,200 hours, 24 resulting in an aggregate
annual reporting burden of 3,000 hours. 25
The Commission expects that any additional burden associated with the requirements of
Appendix G relating to preserving records will be minimal because a prudent firm that manages
risk on a group-wide basis will make and preserve these records in the ordinary course of its
business. The Commission estimates that the average one-time burden of making and preserving
these records will be approximately 40 hours and that the average annual burden will be
approximately 290 hours. Consequently, the Commission estimates that the annual
recordkeeping burden for the 5 ANC firms will be approximately 1,450 hours. 26 The
Commission estimates that the total one-time and annual recordkeeping burden for the 5 brokerdealers expected to become ANC firms will be approximately 200 hours 27 and 966.65 hours, 28
respectively. Therefore, Commission estimates an aggregate annualized recordkeeping burden
of approximately 2,483.65 hours. 29
The Commission estimates that ANC firms will spend a total of approximately one hour
per year to comply with the notification provisions of Appendix G, resulting in a total annual
reporting burden of 5 hours 30 for the 5 ANC firms, and 3.35 hours 31 for the 5 broker-dealers
expected to become ANC firms, resulting in an aggregate reporting burden of 8.35 hours. 32
The Commission also estimates that each broker-dealer will spend approximately 250
hours per year reviewing and updating its risk management control system, resulting in an
aggregate annual recordkeeping burden of 1,250 for the 5 ANC firms, 33and 833.35 for the 5
broker-dealers expected to become ANC firms 34 totaling 2,083.35 hours. 35

24

(Y1: 0 hours) + (Y2: 96 hours + 64 hours + 200 hours = 360 hours) + (Y3: 96 hours + 64 hours + 200 hours
= 360 hours) = 720 hours / 3 years = 240 hours x 5 broker-dealers = 1,200 hours.

25

1,800 hours + 1,200 hours = 3,000 hours.

26

290 hours x 5 broker-dealers = 1,450 hours.

27

40 hours x 5 broker-dealers = 200 hours. The three-year annualized number for this one-time burden is
66.666, rounded to 66.67 hours (200 hours / 3 years = 66.666, rounded to 66.67 hours).

28

(Y1: 0 hours) + (Y2: 290 hours) + (Y3: 290 hours) = 580 hours / 3 years = 193.33 hours x 5 broker-dealers
= 966.65 hours.

29

1,450 hours (5 ANC firms) + 67 hours (5 broker-dealers expected to become ANC firms) + 966.65 hours (5
broker-dealers expected to become ANC firms) = 2,483.65 hours.

30

1 hour x 5 broker-dealers = 5 hours.

31

(Y1: 0 hours) + (Y2: 1 hour) + (Y3: 1 hour) = 2 hours / 3 years = .67 hours x 5 broker-dealers = 3.35 hours.

32

5 hours (5 ANC firms) + 3.35 hours (5 broker-dealers expected to become ANC firms) = 8.35 hours.

33

250 hours x 5 broker-dealers = 1,250 hours.

34

(Y1: 0 hours) + (Y2: 250 hours) + (Y3: 250 hours) = 500 hours / 3 years = 166.67 hours x 5 broker-dealers
= 833.35 hours.

35

1,250 hours (5 ANC firms) + 833.5 hours (5 broker-dealers expected to become ANC firms) = 2,083.5
hours.

6

Therefore, the total annual hour burden for Appendices E and G to Rule 15c3-1 is
61,241.65 hours. 36
A broker-dealer is required to take a 15% haircut on its proprietary positions in
commercial paper, nonconvertible debt, and preferred stock unless the broker-dealer establishes,
documents, maintains, and enforces written policies and procedures for determining
creditworthiness. 37 The staff estimates that approximately 351 broker-dealers will establish,
document, maintain, and enforce policies and procedures that are reasonably designed to
determine whether a security or a money market instrument has a minimal amount of credit
risk. 38 If the security or money market instrument has a minimal amount of credit risk, the
broker-dealer can take haircuts on the security or money market instrument pursuant to
paragraphs (c)(2)(vi)(E), (c)(2)(vi)(F)(1), (c)(2)(vi)(F)(2) and (c)(2)(vi)(H) of Rule 15c3-1. The
staff estimates that, on average, broker-dealers will spend 25 hours developing policies and
procedures or revising their current policies and procedures for evaluating creditworthiness for
the purposes of Rule 15c3-1, resulting in an aggregate one-time recordkeeping burden of 8,775
hours. 39
The staff also estimates that, on average, each broker-dealer will spend an additional 10
hours a year reviewing and adjusting its own standards for evaluating creditworthiness.
Therefore, the Commission estimates that the total annualized recordkeeping burden to the
industry will be approximately 3,510 annual hours. 40 Consequently, the Commission estimates
that the total annual burden associated with evaluating creditworthiness under Rule 15c3-1 will
be approximately 4,092.66 hours. 41
Therefore, the total annual hour burden for the current PRA collection under Rule 15c3-1
is 65,915.31 hours. 42

36

1,666.65 + 52,000 + 3,000 + 2,483.3 + 8.35 + 2,083.35 = 61,241.65 hours.

37

Removal of Certain References to Credit Ratings under the Securities Exchange Act of 1934, Exchange Act
Release No. 71194 (Dec. 27, 2013), 79 FR 1522 (Jan. 8, 2014).

38

The number of 351 broker-dealers was obtained by reviewing broker-dealer Financial and Operational
Combined Single (or “FOCUS”) Reports for the third-quarter of 2016 and then calculating how many firms
reported holding proprietary debt positions. For FOCUS Part II filers, the balances examined were
“Bankers Acceptances” (line item 370) and “Corporate Obligations” (line item 400). For FOCUS CSE
filers, the balances examined were: “Money Market Instruments” (line item 8240), “Private Label
Mortgage Backed Securities” (line item 8250), “Other Asset Backed Securities” (line item 8260) and
“Corporate Debt” (line item 8270). For Part IIA filers, the balance examined was “Debt Securities” (line
item 419). Broker-dealers that hold preferred stock also may hold positions in debt securities. However,
because preferred stock is not a separate line item on the FOCUS Report, broker-dealers that hold only
preferred stock and no other debt securities are not included in this estimate.

39

351 broker-dealers x 25 hours = 8,775 hours.

40

351 broker-dealers x 10 hours = 3,510 hours. The Commission estimates that broker-dealers will use a
controller to do this work.

41

See supra note 40. 2,923.83 hours + 1,168.83 hours = 4,092.66 hours.

42

451 +40 + 90 + 61,241.65 = 61,822.65; 61,822.65 hours + 4,092.66 hours = 65,915.31 hours.

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Nature of Information Collection
Burden

Type of
Burden

Total Number
of
Respondents

Total
Number of
Responses
Per Year

Initial
Burden Per
Response Per
Year Per
Respondent

Ongoing
Burden Per
Response
Per Year Per
Respondent

Total
Annualized
Burden Per
Year Per
Respondent

Total
Annualized
Reporting
Burden For
All
Respondents

Small
Business
Entities
Affected

Rule 15c3-1: Notices

Reporting

902

1

0

0.5

0.5

451

290

Paragraph (c)(2)(iv)(B): Disclosures and
Agreements

Recordkeeping

6

1

6.67

0

6.67

40

0

Paragraph (c)(2)(i)(G)(2): Capital
Withdrawal Liability

Reporting

90

1

0

1

1

90

29

Appendix E computations for ANC firms

Recordkeeping

5

1

333.33

0

333.33

1,666.65

0

Reviewing and back testing models for
existing ANC firms

Recordkeeping

5

1

0

6,240

6,240

31,200

0

Reviewing and back testing models for new
ANC firms

Recordkeeping

5

1

0

4,160

4,160

20,800

0

Appendix G monthly reports for existing
ANC firms

Reporting

5

12

0

8

96

480

0

Appendix G quarterly reports for existing
ANC firms

Reporting

5

4

0

16

64

320

0

Appendix G annual reports for existing
ANC firms

Reporting

5

1

0

200

200

1,000

0

Appendix G monthly reports for new ANC
firms

Reporting

5

12

0

5.33

64

320

0

Appendix G quarterly reports for new ANC
firms

Reporting

5

4

0

10.67

42.67

213.35

0

Appendix G annual reports for new ANC
firms

Reporting

5

1

0

133.33

133.33

666.65

0

Appendix G recordkeeping for existing
ANC firms

Recordkeeping

5

1

0

290

290

1,450.00

0

Appendix G recordkeeping for new ANC
firms (initial)

Recordkeeping

5

1

13.33

0

13.33

66.65

0

Appendix G recordkeeping for new ANY
firms (ongoing)

Recordkeeping

5

1

0

193.33

193.33

966.65

0

Appendix G notification provision for
existing ANC firms

Reporting

5

1

0

1

1

5

0

Appendix G notification provision for new
ANC firms

Reporting

5

1

0

0.67

0.67

3.35

0

Appendix G updating risk management
profile for existing ANC firms

Recordkeeping

5

1

0

250

250

1,250

0

Appendix G updating risk management
profile for new ANC firms

Recordkeeping

5

1

0

166.67

166.67

833.35

0

Creating procedures to determine
creditworthiness to avoid 15% haircut

Recordkeeping

351

1

25

8.33

8.33

2,923.83

139

8

Reviewing procedures to determine
creditworthiness to avoid 15% haircut

Recordkeeping

351

1

10

3.33

3.33

Totals

13.

1,168.83

139

65,915.31

Costs to Respondents

Approximately 81 broker-dealers file consolidated financial reports, of which
approximately 20 obtain an opinion of counsel under Appendix C of Rule 15c3-1. The
Commission estimates that the approximate cost to broker-dealers to obtain an opinion of
counsel to file the consolidated financial reports as required under Appendix C of Rule 15c3-1
will be $8,000. This figure is based on an estimate of 20 hours per opinion for an outside
counsel at $400 per hour. 43 The total costs for all respondents will be $160,000. 44

Nature of Information Collection Burden

Type of
Burden

Total Number
of
Respondents

Opinion of counsel to file consolidated
financial reports under Appendix C

Reporting

20

Total
Number of
Responses
Per Year

Initial
Burden Per
Response Per
Year Per
Respondent

Ongoing
Burden Per
Response
Per Year Per
Respondent

Total
Annualized
Burden Per
Year Per
Respondent

1

$0.00

$8,000.00

$8,000.00

Totals

14.

Total
Annualized
Reporting
Burden For
All
Respondents

Small
Business
Entities
Affected

$160,000.00

0

$160,000.00

Costs to Federal Government

Not applicable. Rule 15c3-1 will not result in any costs to the federal government
beyond normal full-time employee labor costs, nor does Rule 15c3-1 require the Commission to
hire any new employees or reallocate existing employees to ensure compliance with the rule.
15.

Changes in Burden

The change in the recordkeeping and reporting burden between the Supporting Statement
released on April 13, 2014 45 is mostly due to the changes in the estimated number of ANC
broker-dealers subject to Rule 15c3-1 and the estimated number of broker-dealers expected to
apply to be ANC broker-dealers over the next three years. Additionally, the number of brokerdealers reporting holding proprietary debt positions has decreased from 434 broker-dealers to
351.
Therefore, as described in section 12 above, the compliance burden increased from 63,136 hours
to 68,256.85 hours. There is no change in the current cost estimate of $160,000.
43

$400 x 20 hours = $8,000. See PRA Analysis in Financial Responsibility Rules for Broker-Dealers,
Exchange Act Release No. 70072 (July 30, 2013), 78 FR 51823 (Aug. 21, 2013) (citing PRA Analysis in
Product Definitions Adopting Release, 77 FR at 48334 (providing an estimate of $400 an hour to engage an
outside attorney)). See also Crowdfunding; Final Rule, Exchange Act Release No. 76324 (Oct. 30, 2015),
80 FR 71387 (Nov. 16, 2015). The Commission recognizes that the costs of retaining outside professionals
may vary depending on the nature of the professional services, but for purposes of this PRA analysis, the
Commission estimates that such costs will be an average of $400 per hour.

44

20 opinions x $8,000 = $160,000.

45

Available at https://www.reginfo.gov/public/do/PRAViewDocument?ref_nbr=201405-3235-004.

9

16.

Information Collection Planned for Statistical Purposes

Not applicable. The information collection is not used for statistical purposes.
17.

OMB Expiration Date Display Approval

The Commission is not seeking approval to not display the OMB approval expiration
date.
18.

Exceptions to Certification for Paperwork Reduction Act Submissions

This collection complies with the requirements in 5 CFR 1320.9.
B.

Collections of Information Employing Statistical Methods
This collection does not involve statistical methods.

10