Rules 7a-15 - 7a-37.SS.2019

SUPPORTING STATEMENT FOR RULES 7a-15 THROUGH 7a-37
UNDER THE TRUST INDENTURE ACT

A.

JUSTIFICATION
1.

Circumstances Making the Collection of Information Necessary

Rules 7a-15 through 7a-37 under the Trust Indenture Act of 1939 (“TIA”) set
forth requirements governing applications for exemption filed pursuant to Section 304(c)
or 304(d) of the TIA, applications for qualification of indentures filed pursuant to Section
307 of the TIA, statements of eligibility and qualification of trustees filed pursuant to
Section 305, 307 or 310(a) of the TIA, applications for the stay of the trustee’s duty to
resign filed pursuant to Section 310(b) of the TIA, and reports filed pursuant to Section
314(a) of the TIA.
2.

Purpose and Use of the Information Collection

Trust Indenture Act Rules 7a-15 through 7a-37 do not directly impose any
information collection requirements. Rather, they set forth guidelines as to how to
present information required by various TIA forms. The information required by the TIA
forms is necessary to determine whether the requirements of the TIA are satisfied.
3.

Consideration Given to Information Technology

The Commission collects information electronically through its Electronic Data
Gathering, Analysis and Retrieval (EDGAR) system.
4.

Duplication of Information

We are not aware of any rules that substantially duplicate, overlap, or conflict
with Trust Indenture Act Rules 7a-15 through 7a-37.
5.

Reducing the Burden on Small Entities

Rule 7a-15 through Rule 7a-37 have little impact on small entities since issuers
who qualify as a “small business” or a “small organization” under the Securities Act and
Exchange Act would rarely, if ever, issue debt securities that would be subject to the
Trust Indenture Act.
6.

Consequences of Not Conducting Collection

Trust Indenture Act Rules 7a-15 through 7a-37 are disclosure guidelines and do
not directly result in any collection of information. The forms to which the rules relate
(for which separate OMB submissions are made) are filed only once and fewer
collections would not satisfy statutory mandates.

2

7.

Special Circumstances
There are no special circumstances.

8.

Consultations with Persons Outside the Agency

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

Payment or Gift to Respondents
No payment or gift to respondents.

10.

Confidentiality
All documents filed with the Commission are public documents.

11.

Sensitive Questions

No information of a sensitive nature, including social security numbers, will be
required under this collection of information. The information collection does not collect
personally identifiable information (PII). The agency has determined that a system of
records notice (SORN) and privacy impact assessment (PIA) are not required in
connection with the collection of information.
12.

Estimate of Respondent Reporting Burden

Trust Indenture Act Rules 7a-15 through 7a-37 are assigned one burden hour for
administrative convenience because the rules set forth guidelines on the presentation of
information that must appear in other filings under the Trust Indenture Act.
13.

Estimate of Total Annualized Cost Burden

Trust Indenture Act Rules 7a-15 through 7a-37 do not directly impose any costs
on respondents.
14.

Costs to Federal Government
There is no cost to Federal Government.

15.

Reason for Change in Burden
There is no change in burden.

3

16.

Information Collection Planned for Statistical Purposes
The information collection does not employ statistical methods.

17.

Approval to Omit OMB Expiration Date
The Commission is not seeking approval to omit the expiration date.

18.

Exceptions to Certification for Paperwork Reduction Act Submissions

There are no exceptions to certification for Paperwork Reduction Act
submissions.

B.

STATISTICAL METHODS
The information collection does not employ statistical methods.