Pursuant to 5
CFR 1320.11(c), OMB files this comment on this information
collection request (ICR. The agency shall examine public comment in
response to the NPRM and will describe in the supporting statement
of its next collection any public comments received regarding the
collection as well as why (or why it did not) incorporate the
commenter’s recommendation. The next submission to OMB must include
the draft final rule.
Inventory as of this Action
Requested
Previously Approved
11/30/2018
36 Months From Approved
11/30/2018
156,390
0
156,390
634,457
0
634,457
9,760,000
0
9,760,000
Rule 15c2-12 is intended to enhance
disclosure, and thereby reduce fraud, in the municipal securities
market by establishing standards for obtaining, reviewing, and
disseminating information about municipal securities by their
underwriters.
US Code:
15
USC 78o(c) Name of Law: Securities Exchange Act of 1934
The information collection
associated with Rule 15c2-12 applies to broker-dealers, issuers of
municipal securities, and the MSRB. The Commission is changing the
estimated burdens for brokers-dealers, issuers and the MSRB as a
result of amendments to Rule 15c2-12 proposed by the Commission.
For broker-dealers, the Commission has estimated that the proposed
amendments would require broker-dealers to spend ten additional
hours, per broker-dealer, to determine whether issuers or obligated
persons have failed to comply, in all material respects, with any
previous undertakings in a written contract or agreement specified
in Rule 15c2-12(b)(5)(i), resulting in an additional 2,500 hours
annually. The Commission has also estimated that each broker-dealer
would incur a one-time paperwork burden of 30 minutes each to have
its internal compliance attorney prepare and issue a notice
advising its employees about the proposed revisions to Rule
15c2-12, including any updates to policies and procedures affected
by the proposed amendments, resulting in a one-time burden of 125
hours. For issuers, the Commission has estimated that the proposed
amendments would increase the total number of event notices
submitted by issuers annually by approximately 2,200 notices. Based
on the estimate that each event notice would take on average
approximately two hours to prepare and submit, the proposed
amendments would result in an additional 4,400-hour burden to
issuers, and a total burden on issuers of 603,658 hours. The
Commission has also estimated that issuers that use the services of
a designated agent for submission of event notices to the MSRB
could incur additional costs of approximately six percent
associated with the proposed amendments, so that the average total
annual cost that would be incurred by issuers that use the services
of a designated agent under the proposed amendments would be
$10,335,000. The Commission has estimated that the proposed
amendments would require the MSRB to spend approximately 1,162
hours in the first year to implement the necessary modifications to
EMMA to add additional disclosure events for a total one-time
first-year burden of 13,861 hours, but would not increase the
MSRB’s current burden of 12,699 hours in subsequent years. Thus,
the Commission has estimated that the proposed amendments to Rule
15c2-12 would result in a total industry-wide one-time hour burden
increase of approximately 1,287 hours and a total industry-wide
ongoing annual hour burden increase of approximately 6,900
hours.
No
No
No
No
No
Uncollected
Mary Simpkins 202
551-5683
No
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:
(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;
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.
PRA SUPPORTING STATEMENT FINAL.pdf
Issuers Annual Filing Third-Party Disclosure