Rule 17g-7 : Reports to be made public by nationally recognized statistical rating organizations (NRSROs)

Forms and Documents

Document Name	Status
PRA Rule 17g-7 Supporting Statement_2019_adopting release_revised_10-30-19.docx Supporting Statement A	2019-10-30

IC Document Collections

IC ID	Document Title	Status
237184	Rule 17g-7 one-time burden to update standardized disclosures	New
216091	17g-7 Current asset-backed securities disclosure burden	Removed
216079	Rule 17g-7(b) annual disclosure burden	Modified
216069	Rule 17g-7(a) one time cost burden for outside professionals	Removed
216068	Rule 17g-7(b) one time disclosure burden associated with enhancements to the 100% Rule	Removed
216067	Rule 17g-7(a) annual disclosure burden to generate and publish forms	Unchanged
216066	Rule 17g-7(a) annual disclosure burden for updating the standardized disclosures	Unchanged
191790	Rule 17g-7(a) one-time disclosure burden	Removed

ICR Details

OMB Control No: 3235-0656	ICR Reference No: 201907-3235-041
Status: Active	Previous ICR Reference No: 201805-3235-029
Agency/Subagency: SEC	Agency Tracking No: OCR-270-600
Title: Rule 17g-7 : Reports to be made public by nationally recognized statistical rating organizations (NRSROs)
Type of Information Collection: Revision of a currently approved collection	Common Form ICR:  No
Type of Review Request: Regular
OIRA Conclusion Action: Approved with change	Conclusion Date: 11/13/2019
	Date Received in OIRA: 08/21/2019
Terms of Clearance:

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	11/30/2022	36 Months From Approved	09/30/2021
Responses	40	0	70
Time Burden (Hours)	695,847	0	800,845
Cost Burden (Dollars)	0	0	1,666,667

---

Abstract: Rule 17g-7 implements certain statutory provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act relating to nationally recognized statistical rating organizations ("NRSROs"). Paragraph (a) of Rule 17g-7 requires an NRSRO to provide along with any credit rating that it publishes, a report containing an attestation and certain disclosures. Paragraph (b) of Rule 17g-7 requires an NRSRO to make available on its corporate Web site in XBRL format the rating action history of each outstanding credit rating that it determined on or after June 26, 2007.

---

Authorizing Statute(s): PL: Pub.L. 111 - 203 932 Name of Law: Dodd-Frank Wall Street Reform and Consumer Protection Act
   US Code: 15 USC 78o-7 Name of Law: Securities Act of 1933
  

Citations for New Statutory Requirements: US Code: 15 USC 78o-7(q) and (s) Name of Law: Securities Exchange Act of 1934

---

Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
3235-AM05	Final or interim final rulemaking	84 FR 40247	08/14/2019

---

Federal Register Notices & Comments

Did the Agency receive public comments on this ICR? No

---

Number of Information Collection (IC) in this ICR: 4

IC Title	Form No.	Form Name
Rule 17g-7 one-time burden to update standardized disclosures
Rule 17g-7(b) one time disclosure burden associated with enhancements to the 100% Rule
Rule 17g-7(b) annual disclosure burden
Rule 17g-7(a) annual disclosure burden for updating the standardized disclosures
Rule 17g-7(a) annual disclosure burden to generate and publish forms
17g-7 Current asset-backed securities disclosure burden
Rule 17g-7(a) one time cost burden for outside professionals
Rule 17g-7(a) one-time disclosure burden

---

ICR Summary of Burden

	Total Approved	Previously Approved	Change Due to New Statute	Change Due to Agency Discretion	Change Due to Adjustment in Estimate	Change Due to Potential Violation of the PRA
Annual Number of Responses	40	70	0	10	-40	0
Annual Time Burden (Hours)	695,847	800,845	0	50	-105,048	0
Annual Cost Burden (Dollars)	0	1,666,667	0	0	-1,666,667	0

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

Burden Increase Due to: Changing Regulations

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

Burden Reduction Due to:

Short Statement: The Commission estimates that it would take an NRSRO approximately five hours to update its process for obtaining a reasonable basis to reflect the proposed amendment to the Rule 17g-7(a) exemption, for an industry-wide one-time burden of approximately 50 hours. An administrative correction was made as well. In the previous approval, the one-time burdens were not removed from the 2015 amendments. These one-time burdens are no longer effective as the registrants have made the previous necessary updates to their policies and procedures.

---

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]? Yes

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: 08/21/2019

---