Rule 17g-5 Conflicts of Interest

Forms and Documents

Forms and supporting documents for this ICR

Document	Type	Status	Availability
Rule 17g-5 Supporting Statement_2018 final.pdf	Supporting Statement A	Uploaded 2018-09-26	Available

IC Document Collections

Information collection document groups

IC ID	Collection	Type	Status	Form
213119	NRSRO exemption request		Removed
213118	NRSRO conflict policies update		Removed
213116	Arranger form upload		Modified
213115	NRSRO template redrafting		Removed
213114	Arranger ongoing disclosure		Unchanged
202290	Annual Certification		Unchanged
202289	Arranger transaction disclosures		Unchanged
202288	Arranger disclosure systems		Removed
188139	NRSRO structured finance ratings disclosure		Unchanged

ICR Details

OMB Control No: 3235-0649	ICR Reference No: 201809-3235-006
Status: Historical Inactive	Previous ICR Reference No: 201411-3235-006
Agency/Subagency: SEC	Agency Tracking No: OCR-270-581
Title: Rule 17g-5 Conflicts of Interest
Type of Information Collection: Extension without change of a currently approved collection	Common Form ICR:  No
Type of Review Request: Regular
OIRA Conclusion Action: Improperly submitted and continue	Conclusion Date: 10/04/2018
	Date Received in OIRA: 09/26/2018
Terms of Clearance: Given the large burden and cost changes described in this package, this ICR does not appear to constitute an "extension without change." Please resubmit this package as a revision and describe the change in burden under question 15 of the supporting statement.

table that charts list comparision

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	10/31/2018	36 Months From Approved	10/31/2018
Responses	3,620	0	3,620
Time Burden (Hours)	278,051	0	278,051
Cost Burden (Dollars)	67,000	0	67,000

---

Abstract: Rule 17g-5 implements certain statutory provisions of the Credit Rating Agency Reform Act of 2006 ("Rating Agency Act") by prohibiting, or requiring the managemnt and disclosure of, any potential conflict of interest relating to the issuance of credit ratings by a nationally recognized statistical rating organization or "NRSRO". This collection of information is necessary by addressing potential practices that could impair the objectivity and the quality of a credit rating.

---

Authorizing Statute(s): US Code: 15 USC 780-7 Name of Law: Credit Rating Agency Reform Act of 2006
  

Citations for New Statutory Requirements: US Code: 15 USC 780-7 Name of Law: Credit rating Agency Reform Act

---

Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
	Not associated with rulemaking

---

Federal Register Notices & Comments
60-day Notice:	Federal Register Citation:	Citation Date:
	83 FR 28274	06/18/2018
30-day Notice:	Federal Register Citation:	Citation Date:
	83 FR 42958	08/24/2018
Did the Agency receive public comments on this ICR? No

---

Number of Information Collection (IC) in this ICR: 5

table that charts list of burden

IC Title	Form No.	Form Name
NRSRO structured finance ratings disclosure
Arranger transaction disclosures
Arranger form upload
Arranger ongoing disclosure
Annual Certification
Arranger disclosure systems
NRSRO template redrafting
NRSRO conflict policies update
NRSRO exemption request

---

Burden increases because of Program Change due to Agency Discretion: Yes

Burden Increase Due to: Miscellaneous Actions

Burden decreases because of Program Change due to Agency Discretion: No

Burden Reduction Due to:

Short Statement: The previous one-time burdens at the time of rule amendment were removed, and one IC was adjusted because of a rounding error.

---

Annual Cost to Federal Government: $0

Does this IC contain surveys, censuses, or employ statistical methods? No

Does this ICR request any personally identifiable information (see OMB Circular No. A-130 for an explanation of this term)? Please consult with your agency's privacy program when making this determination.     No

Does this ICR include a form that requires a Privacy Act Statement (see 5 U.S.C. §552a(e)(3))? Please consult with your agency's privacy program when making this determination.     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]? No

Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)? No

Is this ICR related to the Pandemic Response? Uncollected

---

Common Form ICR:  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:

(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: 09/26/2018

---