Form ID - Supporting Statement - November 2018

SUPPORTING STATEMENT FOR FORM ID
A.

JUSTIFICATION
1.

Circumstances Making the Collection of Information Necessary

Regulation S-T (17 CFR Part 232) provides the general requirements and
procedures for electronic filings made through the Electronic Data Gathering, Analysis
and Retrieval System (“EDGAR”). It further mandates that all domestic registrants,
foreign private issuers and foreign governments 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 filing requirements, the Commission
developed certain procedures and forms that are unique to EDGAR, including Form ID,
to be used by EDGAR filers.
2.

Purpose and Use of the Information Collection

The information provided on Form ID allows the Commission to assign Central
Index Keys, access codes, and passwords to registrants and others (“filers”), which
permit filing on EDGAR. These are an essential part of the security of EDGAR.
3.

Consideration Given to Information Technology

The form must be submitted to enable filers to use EDGAR. EDGAR is
used to implement improved information dissemination technology. EDGAR is
also designed to reduce the regulatory burdens of paper filings with the
Commission.
4.

Duplication of Information

EDGAR is unique to the Commission; consequently, no duplication of the
form exists.
5.

Reducing the Burden on 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.
6.

Consequences of Not Conducting Collection

Form ID must be used by filers to obtain access codes to permit filing on
EDGAR.

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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 approval.
9.

Payment or Gift to Respondent
Not applicable.

10.

Confidentiality
Form ID is used solely for registering filers on the EDGAR system.

11.

Sensitive Questions

No information of a sensitive nature, including social security numbers, will be
required under this collection of information. The information collection on Form ID
collects basic Personally Identifiable Information (PII) that may include name, address,
phone number, zip code, occupation, job title, work phone, and work email. However, the
agency has determined that the information collection on the Form ID 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.
12.

Estimate of Respondent Reporting Burden

We estimate that 46,842 filers file Form ID and that it takes 0.15 hours per
response, for a total annual burden of 7,026 hours. It is estimated that the filers are
responsible for 100% of the 7,026 burden hours. The estimated hours are made
solely for the purposes of the Paperwork Reduction Act.
Form ID
Form ID
13.

Previously
approved
38728

Annual No. of Filings
Requested

Change

46842

8114

Estimate of Total Annualized Cost Burden

Annual Time Burden (Hrs.)
Previously
Requested
Change
approved
5809
7026
1217

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We estimate that the filer is responsible for 100% of the total reporting burden
imposed by the form and there is no additional cost associated with the information
collection.

14.

Costs to Federal Government

The Commission has no specific information available concerning the cost
for staff processing Form ID.
15.

Reason for Change in Burden

The increase from 5,809 to 7,026 annual burden hours is due to an
adjustment to reflect an increase in the number of filers filing Form ID.
Form ID
Form ID
16.

Previously
approved
38728

Annual No. of Filings
Requested

Change

46842

8114

Annual Time Burden (Hrs.)
Previously
Requested
Change
approved
5809
7026
1217

Information Collections 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
Not applicable.

B.

STATISTICAL METHODS
Not applicable.