Form SE.SS.2018

SUPPORTING STATEMENT
FOR THE PAPERWORK REDUCTION ACT INFORMATION COLLECTION
SUBMISSION FOR FORM SE

A.

JUSTIFICATION
1.

Circumstances Making the Collection of Information Necessary

Regulation S-T (17 CFR Part 232 et seq.) provides the general requirements and
procedures for electronic filing using the Electronic Data Gather, Analysis and Retrieval
(“EDGAR”) System. It further mandates that all domestic registrants, foreign private
issuers and foreign governments to file their securities documents electronically with the
Commission. This includes registration statements under the Securities Act of 1933 and
registration statements, reports and other documents under the Securities Exchange Act
of 1934. To facilitate the changing filing requirements, the Commission developed
certain procedures and forms that were unique to the EDGAR filing system, including
Form SE to be used by EDGAR filers.
2.

Purpose and Use of the Information Collection

Form SE is used by registrants to file paper copies of exhibits that would be
difficult or impossible to submit electronically. The information contained in Form SE is
used by the Commission to identify paper copies of exhibits.
3.

Consideration Given to Information Technology

Form SE is used to implement improved information dissemination
technology. The EDGAR system is designed to reduce the regulatory burdens of
paper filings with the Commission.
4.

Duplication of Information

EDGAR system function is unique to the Commission; consequently, no
duplication of the forms exists.
5.

Reducing the Burden on Small Entities

Small entities are permitted to file Form SE if they meet the requirements
of filing paper copies of exhibits that would be difficult or impossible to submit
electronically, but we do not expect the filing of Form SE to have a significant
economic impact on a substantial number of small entities. EDGAR has been
designed to accommodate small entities to the greatest degree possible while still
providing for the public electronic dissemination of information.

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6.

Consequences of Not Conducting Collection

Form SE must be used every time a registrant submits paper copies of
exhibits to the Commission in order to identify them.
7.

Special Circumstances
Not applicable.

8.

Consultations With Persons Outside the Agency

No comments were received on this request during the 60–day comment
period prior to OMB’s review of this submission.
9.

Payment or Gift to Respondents
Not applicable.

10.

Confidentiality
Form SE is available for public review.

11.

Sensitive Questions

No information of a sensitive nature, including social security numbers,
will be required under this collection of information. The information collection
collects basic Personally Identifiable Information (PII) that may include: name,
address and zip code. However, the agency has determined that the information
collection does not constitute a system of record for purposes of the Privacy Act.
Information is not retrieved by a personal identifier. In accordance with Section
208 of the E-Government Act of 2002, the agency has conducted a Privacy
Impact Assessment (PIA) of the EDGAR system, in connection with this
collection of information. The EDGAR PIA, published on January 29, 2016, is
provided as a supplemental document and is also available at
https://www.sec.gov/privacy.

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12.

Estimate of Respondent Reporting Burden

For purposes of the Paperwork Reduction Act (“PRA”), we estimate that
Form SE takes approximately 0.10 hours per response to comply with the
collection of information requirements and is filed by 19 respondents. We
derived our burden hour estimates by estimating the average number of hours it
would take an issuer to compile the necessary information and data, prepare and
review disclosure, file documents and retain records. In connection with rule
amendments to the form, we occasionally receive PRA estimates from public
commenters about incremental burdens that are used in our burden estimates. We
believe that the actual burdens will likely vary among individual issuers based on
the nature of their operations. We further estimate that 100% of the collection of
the information burden is carried by the registrant. Based on our estimate, we
calculated the total reporting burden to be 2 hours (0.10 hours per response x 19
responses). For administrative convenience, the total burden hours has been
rounded to the nearest whole number. The burden estimate for the hours is made
solely for the purpose of the Paperwork Reduction Act.
13.

Estimate of Total Annualized Cost Burden
There is no outside cost associated with the preparation of Form SE.

14.

Costs to Federal Government

The cost to the government for processing Form SE is approximately
$1,000 because it is a one page cover sheet that identifies attached information.
15.

Reason for Change in Burden

The decrease of one burden hours is due to an adjustment. The decrease
in burden hours is due to a decrease in the number of Forms SE filed with the
Commission.
16.

Information Collection Planned for Statistical Purposes
Not applicable.

17.

Approval to Omit OMB Expiration Date

We request authorization to omit the expiration date on the electronic version of
the form. Including the expiration date on the electronic version of the form will result in
increased costs, because the need to make changes to the form may not follow the
application’s scheduled version release dates. The OMB control number will be
displayed.
18.

Exceptions to Certification for Paperwork Reduction Act Submissions

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Not applicable.

B.

STATISTICAL METHODS
Not applicable.