Rule 206(4)-6 Under the Investment Advisers Act of 1940 (17 CFR 275.206(4)-6)

Forms and Documents

Document Name	Status
3235-0571 30 Day Notice.pdf Supplementary Document	2020-07-10
3235-0571 60 Day Notice.pdf Supplementary Document	2020-07-10
Rule 206(4)-6 Supporting Statement.pdf Supporting Statement A	2020-04-10

IC Document Collections

IC ID	Document Title	Status
35418	Rule 206(4)-6 Under the Investment Advisers Act of 1940	Modified

ICR Details

OMB Control No: 3235-0571	ICR Reference No: 202002-3235-018
Status: Active	Previous ICR Reference No: 201612-3235-004
Agency/Subagency: SEC	Agency Tracking No: IM-270-513
Title: Rule 206(4)-6 Under the Investment Advisers Act of 1940 (17 CFR 275.206(4)-6)
Type of Information Collection: Extension without change of a currently approved collection	Common Form ICR:  No
Type of Review Request: Regular
OIRA Conclusion Action: Approved without change	Conclusion Date: 08/27/2020
	Date Received in OIRA: 07/10/2020
Terms of Clearance:

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	08/31/2023	36 Months From Approved	08/31/2020
Responses	3,421,935	0	1,531,880
Time Burden (Hours)	464,844	0	261,513
Cost Burden (Dollars)	0	0	0

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Abstract: Rule 206(4)-6 requires investment advisers to adopt and implement written policies and procedures reasonably designed to ensure the adviser votes client proxies in the best interest of the clients. The rule requires disclosure of these policies and procedures to clients, as well as information on how clients can obtain information from the adviser about how the adviser voted the client's securities.

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Authorizing Statute(s): US Code: 15 USC 80b Name of Law: Investment Advisers Act of 1940
  

Citations for New Statutory Requirements: None

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Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
	Not associated with rulemaking

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Federal Register Notices & Comments
60-day Notice:	Federal Register Citation:	Citation Date:
	85 FR 25486	05/01/2020
30-day Notice:	Federal Register Citation:	Citation Date:
	85 FR 41635	07/10/2020
Did the Agency receive public comments on this ICR? No

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Number of Information Collection (IC) in this ICR: 1

IC Title	Form No.	Form Name
Rule 206(4)-6 Under the Investment Advisers Act of 1940

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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	3,421,935	1,531,880	0	0	1,890,055	0
Annual Time Burden (Hours)	464,844	261,513	0	0	203,331	0
Annual Cost Burden (Dollars)	0	0	0	0	0	0

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

Burden Increase Due to:

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

Burden Reduction Due to:

Short Statement: We have increased the estimated hour burden from 261,513 hours to 464,844 hours based on new information with respect to the number of registered investment advisers that provide discretionary asset management services and to the estimated average number of clients per SEC-registered investment adviser. This new information is based on data derived from information submitted by advisers on Form ADVs filed through the IARD. The number of hours per response has not changed since the last estimate. The increase in hour burden is entirely due to an increase in the number of respondents.

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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]? No

Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)? No

Is this ICR related to the Pandemic Response? No

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Common Form ICR:  No

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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: 07/10/2020

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