30 day notice

SECURITIES AND EXCHANGE COMMISSION
Submission for OMB Review; Comment Request
Upon Written Request Copies Available From:
Securities and Exchange Commission
Office of FOIA Services
100 F Street, NE
Washington, DC 20549-2736

Extension: Rule 17g-4
SEC File No. 270-566, OMB Control No. 3235-0627
Notice is hereby given that pursuant to the Paperwork Reduction Act of 1995 (44 U.S.C.
3501 et seq.) (“PRA”), the Securities and Exchange Commission (“Commission”) has submitted to
the Office of Management and Budget (“OMB”) a request for approval of extension of the
previously approved collection of information provided for in Rule 17g-4 (17 CFR 240.17g-4)
under the Securities Exchange Act of 1934 (15 U.S.C. 78a et seq.) (“Exchange Act”).
The Credit Rating Agency Reform Act of 2006 added a new section 15E, “Registration
of Nationally Recognized Statistical Rating Organizations,”1 to the Exchange Act. Pursuant to
the authority granted under section 15E of the Exchange Act, the Commission adopted Rule
17g-4, which requires that a nationally recognized statistical rating organization (“NRSRO”)
establish, maintain, and enforce written policies and procedures to prevent the misuse of material
nonpublic information, including policies and procedures reasonably designed to prevent: (a) the
inappropriate dissemination of material nonpublic information obtained in connection with the
performance of credit rating services; (b) a person within the NRSRO from trading on material
nonpublic information; and (c) the inappropriate dissemination of a pending credit rating action.2

1
2

15 U.S.C. 78o-7.
See 17 CFR 240.17g-4; Release No. 34-55231 (Feb. 2, 2007), 72 FR 6378 (Feb. 9, 2007);
Release No. 34-55857 (June 5, 2007), 72 FR 33564 (June 18, 2007).

-2There are 10 credit rating agencies registered with the Commission as NRSROs under
section 15E of the Exchange Act, which have already established the policies and procedures
required by Rule 17g-4. Based on staff experience, an NRSRO is estimated to spend an average
of approximately 10 hours per year reviewing its policies and procedures regarding material
nonpublic information and updating them (if necessary), resulting in an average industry-wide
annual hour burden of approximately 100 hours.3
The Commission may not conduct or sponsor a collection of information unless it
displays a currently valid OMB control number. No person shall be subject to any penalty for
failing to comply with a collection of information subject to the PRA that does not display a
valid OMB control number.
Background documentation for this information collection may be viewed at the
following website: www.reginfo.gov. Comments should be directed to: (i) Desk Officer for the
Securities and Exchange Commission, Office of Information and Regulatory Affairs, Office of
Management and Budget, Room 10102, New Executive Office Building, Washington, DC 20503,
or by sending an email to: [email protected]; and (ii) Charles Riddle, Acting Chief
Information Officer, Securities and Exchange Commission, c/o Candace Kenner, 100 F St NE,
Washington, DC 20549 or send an email to: [email protected]. Comments must be
submitted to OMB within 30 days of this notice.

Eduardo A. Aleman
Deputy Secretary

February 1, 2019
3

10 currently registered NRSROs x 10 hours = 100 hours.

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