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SUPPORTING STATEMENT
For the Paperwork Reduction Act Information Collection Submission for
RULE 12d1-4
A.
JUSTIFICATION
1.
Necessity for the Information Collection
Funds increasingly invest in other funds as a way to achieve asset allocation,
diversification, or other investment objectives. According to staff estimates, approximately 40%
of all registered funds hold an investment in at least one fund, 1 and total net assets in mutual
funds that invest primarily in other mutual funds have grown from $469 billion in 2008 to $2.54
trillion in 2019. 2 Retail investors similarly use fund of funds arrangements as a convenient way
to allocate and diversify their investments through a single, professionally managed portfolio.
For example, a fund of funds may provide an investor with the same benefits as separate direct
investments in several underlying funds, without the increased monitoring and recordkeeping
that could accompany investments in each underlying fund. 3
Section 12(d)(1) of the Act, however, limits the ability of a fund to invest substantially in
securities issued by another fund. On October 7, 2020, the Commission adopted 17 CFR
270.12d1-4 (“rule 12d1-4”) which will permit certain registered funds and BDCs that satisfy
1
Of those funds investing in other funds, 48% invest at least 5% of their assets in other funds, and
26% hold more than 90% of their assets in other funds. See Fund of Funds Arrangements,
Investment Company Act Release No. 34045 (Oct. 7, 2020) (“Adopting Release”).
2
During this period the number of mutual funds utilizing this arrangement grew from 838 to 1,469.
See Investment Company Institute, 2020 Fact Book: A Review of Trends and Activities in the
Investment Company Industry (“2020 ICI Fact Book”), at 244, available at
https://www.ici.org/pdf/2020_factbook.pdf.
3
Target-date funds are a common type of fund of funds arrangement and are designed to make it easier for
investors to hold a diversified portfolio of assets that is rebalanced over time without the need for investors
to rebalance their own portfolio. See Investment Company Advertising: Target Date Retirement Fund
Names and Marketing, Investment Company Act Release No. 29301 (June 16, 2010) [75 FR 35920 (June
23, 2010)] (proposing disclosure requirements for target date retirement funds’ marketing materials).
2
certain conditions to acquire shares of another fund in excess of the limits of section 12(d)(1) of
the Act without obtaining an exemptive order from the Commission. 4 These conditions,
described in more detail below, include requirements that constitute a new collection of
information. This collection of information is voluntary because rule 12d1-4 is an exemptive
rule and, therefore, funds may choose not to rely on the proposed rule.
Voting Provisions. Under rule 12d1-4, where a fund (“acquiring fund”) and its advisory
group (in the aggregate) hold more than 25% of the outstanding voting securities of another fund
(“acquired fund”) that is a registered open-end investment company or registered unit investment
trust (“UIT”), the acquiring fund will be required to vote those securities using mirror voting,
unless certain exceptions apply. 5 If the acquired fund is a closed-end fund, the acquiring fund
and its advisory group must vote its securities using mirror voting if they, in the aggregate, hold
more than 10% of the outstanding voting securities, unless certain exceptions apply. 6 This
requirement is necessary to address the potential for undue influence through voting power based
on the types of acquired fund.
Fund of Funds Investment Agreement. Unless the acquiring fund’s adviser acts as the
acquired fund’s investment adviser, rule 12d1-4 will require that the acquiring fund enter into an
agreement containing certain provisions with the acquired fund effective for the duration of the
funds’ reliance on the rule. Funds subject to this requirement must maintain a copy of these
agreements. This requirement is necessary to provide a method to hold the parties to the
4
See Adopting Release, supra footnote 1.
5
See rule 12d1-4(b)(1)(ii) and (iv). As described in the Adopting Release, in mirror voting, the acquiring
fund votes the shares it holds in the same proportion as the vote of all other holders. In circumstances
where acquiring funds are the only shareholders of an acquired fund, however, pass-through voting may be
used.
3
arrangement to the terms that led each fund’s investment adviser to agree to the arrangement in
the first place.
Management Companies -- Fund Findings. In cases where the acquiring fund is a
management company, 7 rule 12d1-4 will require, prior to the initial acquisition of an acquired
fund in reliance on the rule, the acquiring fund’s investment adviser to evaluate the complexity
of the structure and fees and expenses associated with the acquiring fund’s investment in the
acquired fund, and find that the acquiring fund’s fees and expenses do not duplicate the fees and
expenses of the acquired fund. These evaluations and findings are necessary in order to ensure
that the historical concerns that led to section 12(d)(1), specifically, regarding duplicative fees
and complexity of structure, are addressed.
In cases where the acquired fund is a management company, rule 12d1-4 will require,
prior to the initial acquisition of the acquired fund in reliance on the rule, the acquired fund’s
investment adviser to find that any undue influence concerns associated with the acquiring
fund’s investment in the acquired fund are reasonably addressed and, as part of this finding, the
investment adviser must consider at a minimum certain enumerated factors. These factors are
necessary to focus the analysis of an acquired fund’s adviser on potential ways to reduce the
threat of undue influence, including through redemptions, when an acquiring fund invests in the
acquired fund beyond the section 12(d)(1) limits under the rule.
The rule will further require that each investment adviser report its evaluation, finding,
and the basis for its evaluation or finding to the fund’s board of directors no later than the next
6
See rule 12d1-4(b)(1)(iii) and (iv).
7
“Management companies” are defined as an investment company other than a face amount
certificate company or UIT. 15 U.S.C. 80a-4.
4
regularly scheduled meeting of the board of directors. The rule also will require the acquiring
and acquired funds participating in fund of funds arrangements in accordance with the rule to
maintain and preserve a copy of each fund of funds investment agreement that is in effect, or was
in effect in the past five years, and a written record of the relevant Fund Findings (and the basis
for the Fund Findings) made under the rule. 8 These requirements are necessary to ensure that the
board is able to provide the additional layer of protection for acquiring and acquired funds and
their respective investors against the historical abuses section 12(d)(1) is designed to prevent.
They also help to ensure compliance with the rule’s requirements when utilizing it as an
exemption from section 12(d)(1).
UITs -- Principal Underwriter or Depositor Evaluations. The rule will require that, in
cases where the acquiring fund is a UIT, the UIT’s principal underwriter or depositor must
evaluate the complexity of the structure associated with the UIT’s investment in acquired funds,
and find that the UIT’s fees and expenses do not duplicate the fees and expenses of the acquired
funds that the UIT holds or will hold at the date of deposit. The UIT is also required to keep
records of the finding, and any basis for the finding. 9 This evaluation is necessary to ensure that
concerns regarding duplicative fees are addressed and also to help ensure compliance when
utilizing the rule.
Separate Accounts Funding Variable Insurance Contracts. Lastly, the rule will require
that, with respect to a separate account funding variable insurance contracts that invests in an
acquiring fund, the acquiring fund must obtain a certification from the insurance company
offering the separate account. The certification must state that the insurance company has
8
Rule 12d1-4(b)(2)(i) and (c).
5
determined that the fees and expenses borne by the separate account, acquiring fund, and
acquired fund, in the aggregate, are consistent with the standard set forth in section 26(f)(2)(A)
of the Act. The acquiring fund will be required to keep a record of this certification. 10 This
certification is necessary to ensure that concerns regarding duplicative fees are addressed and
also to help ensure compliance when utilizing the rule.
2.
Purpose and Use of the Information Collection
The purpose of the information collection requirement in rule 12d1-4 is to ensure both
that the concerns that led Congress to adopt section 12(d)(1) are mitigated and also to help
ensure compliance with the rule’s requirements when a fund is relying upon it as an exemption
from that section.
3.
Consideration Given to Information Technology
The information collected under the rule would not be submitted to the Commission. The
proposed rule does not stipulate any particular method for communicating or preserving the
information collected. The Electronic Signatures in Global and National Commerce Act 11 and
the conforming amendments to rules under the Investment Company Act permit funds to
maintain records electronically.
4.
Duplication
The Commission is not aware of any duplicate reporting or recordkeeping requirements
concerning proposed rule 12d1-4.
5.
Effects on Small Entities
9
Rule 12d1-4(b)(2)(ii) and (c).
10
Rule 12d1-4(b)(2)(iii) and (c).
11
P.L. 106-229, 114 Stat. 464 (June 30, 2000).
6
The Commission reviews all rules periodically, as required by the Regulatory Flexibility
Act (5 U.S.C. 601 et seq.), to identify methods to minimize recordkeeping or reporting
requirements affecting small businesses. The requirements of rule 12d1-4 do not distinguish
between small entities and larger entities. The burden on smaller entities may be greater than for
larger entities. This burden includes the cost of establishing and conducting a voting system in
accordance with the rule, negotiating and maintaining fund of fund investment agreements, and
establishing procedures for conducting the required evaluations, findings, and certifications. The
Commission believes, however, that imposing different requirements on smaller investment
companies would not be consistent with investor protection and the purposes of the registration
statements. Further, entities eligible to rely on rule 12d1-4 are required to comply with the
requirements of the rule only if they wish to rely on the rule’s exemptions.
6.
Consequences of Not Conducting Collection
Less frequent information collection would be incompatible with the objectives of rule
12d1-4. The requirements of the rule are necessary to ensure that the concerns in section
12(d)(1) are adequately addressed by funds relying on the rule’s exemptions.
7.
Inconsistencies With Guidelines in 5 CFR 1320.5(d)(2)
Not applicable.
8.
Consultations Outside the Agency
Before adopting proposed rule 12d1-4, the Commission solicited and evaluated public
comment on the collection of information requirement. Specifically, the public was given the
opportunity to comment on the Commission’s estimates for the burdens of rule 12d1-4 as
proposed. While comments were received from filers, investors and other market participants,
7
and were considered by the Commission as discussed in the Adopting Release, most of these did
not relate to the proposed burden estimates for rule 12d1-4. We received one comment on the
collection of information requirements, 12 who suggested that the proposed estimated burdens did
not adequately account for both legal and accounting personnel needing to be involved with the
finding requirement as proposed. In response to this comment, and changes made to the rule as
adopted as influenced by other comments, the Commission made the following adjustments:
•
Voting Provisions. This estimate is as proposed, except that we (1) lowered the
relative amount of funds that are expected to use pass-through voting given the
changes to that requirement, (2) lowered the amount of funds estimated to be
subject to these provisions due to the raised threshold of when pass-through or
mirror voting will be required and (3) also lowered the expected number of votes
per year based upon updated analysis. 13
•
Management Companies -- Fund Findings. We have made some changes to the
estimate from the proposal based upon changes to the rule as adopted. 14 We
increased the number of funds responding to this collection since the final rule
will require both the acquiring and acquired funds to make certain findings under
the rule. We have also increased our estimated burdens regarding initial hour and
12
See Comment Letter of Guggenheim Investments (May 2, 2019).
13
The 2018 proposal of this rule contemplated that 809 funds would be subject to this requirement
based upon a 3% threshold, rather than the 25% and 10% threshold we are adopting. See Fund of
Funds Arrangements, Investment Company Act Release No. 10590 (Dec. 19, 2018) [84 FR 1286
(Feb 1, 2019)] (“2018 FOF Proposing Release”) at n.349 and accompanying text. See also
Adopting Release, supra footnote 1, at nn.735 and 621 and nn.569 through 570 and
accompanying text (outlining updated voting analysis).
14
See 2018 FOF Proposing Release, supra footnote 13, at nn.365-369 and accompanying text.
8
cost burdens due to the increased amount of factors that advisers would need to
consider as part of this collection. In response to a commenter, 15 we adjusted our
estimates regarding the hours and wage rates to conduct evaluations and the
creation, review, and maintenance of written materials. Lastly, we reduced the
estimates regarding annual hour burdens, and eliminated the estimate of external
annual costs, due to the elimination of the requirement to conduct on-going
evaluations.
•
UITs -- Principal Underwriter or Depositor Evaluations. We decreased the total
number of respondents to this item based upon updated analysis as described
above. Also, in response to a commenter, 16 we adjusted our estimates regarding
the hours and wage rates to conduct evaluations and the creation, review, and
maintenance of written materials. 17
•
Separate Accounts Funding Variable Insurance Contracts. We decreased the
total number of respondents to this item based upon updated analysis as described
above. Also, we increased the proposed internal hour burden and time costs to
account for likely attorney and compliance review of the required certification. 18
In addition, the Commission and staff of the Division of Investment Management
participate in an ongoing dialogue with representatives of the investment company industry
15
See supra footnote 12 and accompanying text.
16
Id.
17
See 2018 FOF Proposing Release, supra footnote 13, at nn.373-377 and accompanying text.
18
See 2018 FOF Proposing Release, supra footnote 13, at nn.373-377 and accompanying text. The
rule will not subject an insurance company to a collection of information as section 26(f)(2)(A) of
the Act already requires insurance companies to collect this information.
9
through public conferences, meetings, and informal exchanges. These various forums provide
the Commission and staff with a means of ascertaining and acting upon paperwork burdens that
may confront the industry.
9.
Payment or Gift
Not applicable.
10.
Confidentiality
Not applicable.
11.
Sensitive Questions
Not applicable.
12.
Burden of Information Collection
The following estimates of average burden hours and costs are made solely for purposes
of the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.) and are not derived from a
comprehensive or even representative survey or study of the cost of Commission rules and
forms.
The tables below summarizes the estimated burdens associated with each element of the
collection of information from the proposal and the overall final PRA estimates for internal and
external burdens associated with rule 12d1-4. 19
Table 1: Voting Provisions PRA Estimates
19
The Commission’s estimates of the relevant wage rates in the tables below are based on salary information
for the securities industry compiled by the Securities Industry and Financial Markets Association’s Office
Salaries in the Securities Industry 2013. The estimated wage figures are modified by Commission staff to
account for an 1,800-hour work-year and inflation, and multiplied by 5.35 to account for bonuses, firm size,
employee benefits, overhead, and adjusted to account for the effects of inflation. See Securities Industry
and Financial Markets Association, Report on Management & Professional Earnings in the Securities
Industry 2013 (“SIFMA Report”) for the source of salary data.
10
Internal Hour
Burden1
Wage Rate2
Internal Time Costs
Annual External
Cost Burden
PROPOSED ESTIMA TES FOR MIRROR VOTIN G
Update proxy voting
policies and disclosures
3 hours
Evaluate other votes and
vote accordingly
(per vote
x 3.6 votes)
3 hours
× 3.6
10.8 hours
×
$392
(in-house attorney)
×
$392
(in-house attorney)
$1,176
--
$1,176
× 3.6
$4,233.60
$400
× 3.6
$1,440
Total burden per fund
13.8 hours
$5,409.60
$1,440
Total number of affected
funds
× 793
× 793
× 793
Total proposed burden for
mirror voting
10,943.4 hours
$4,289,812.80
$1,141,920
PROPOSED ESTIMA TES FOR PASS-THROUGH VOTIN G
Update proxy voting
policies and disclosures
3 hours
×
$392
(in-house attorney)
×
$392
(in-house attorney)
$1,176
--
$11,760
× 3.6
$42,336.00
$4,000
× 3.6
$14,400
Communicate with
shareholders and vote
accordingly
(per vote
x 3.6 votes)
30 hours
× 3.6
108 hours
Total burden per fund
111 hours
$43,512
$14,400
Total number of affected
funds
× 16
× 16
× 16
Total proposed burden for
pass-through voting
1,776 hours
$696,192
$230,400
FINA L ESTIMA TES FOR MIRROR-VOTIN G
Update proxy voting
policies and disclosures
3 hours
Conduct voting procedure
(per vote
x 1 vote)
3 hours
×1
3 hours
×
$419
(in-house attorney)
×
$419
(in-house attorney)
$1,257
--
$1,257
×1
$1,257
$400
×1
$400
Total burden per fund
6 hours
$2,514
$400
Total number of affected
funds
× 440
× 440
× 440
Total final burden for
mirror voting
2,640 hours
$1,106,160
$176,000
FINA L ESTIMA TES FOR PA SS-THROUGH VOTIN G
Update proxy voting
policies and disclosures
3 hours
Communicate with
shareholders and vote
accordingly
(per vote
x 1 vote)
30 hours
×1
30 hours
×
$419
(in-house attorney)
×
$419
(in-house attorney)
$1,257
--
$12,570
×1
$12,570
$4,000
×1
$4,000
Total burden per fund
33 hours
$12,570
$4,000
Total number of affected
funds
× 10
× 10
× 10
Total final burden for passthrough voting
330 hours
$125,700
$40,000
11
TOTA L ESTIMA TED BURDENS FOR VOTIN G PROVISIONS
Proposed burden
estimates
12,719.4 hours
Proposed total
respondents
809
Revised burden estimates
2,970 hours
Proposed total
respondents3
450
$4,986,004.80
$1,372,320
$1,231,860
$216,000
Notes:
1. Includes initial burden estimates annualized over a three-year period.
2. See SIFMA Report, supra footnote 19.
3. See Adopting Release, supra footnote 1, at n.735.
Table 2: Fund of Funds Investment Agreements PRA Estimates
Internal Hour
Burden1
Wage Rate2
Annual External
Cost Burden
Internal Time Costs
ESTIMATES FOR FUN D OF FUN DS IN VESTMENT A GREEMEN TS
Negotiating and
memorializing agreement
Establishing recordkeeping
policies and procedures
20 hours
×
$444.33 (blended rate
for in-house attorney,
deputy general
counsel, and
compliance manager)3
3 hours
×
$63
(general clerk)
$189
3 hours
×
$96 (senior computer
operator)
$288
6 hours
×
$63
(general clerk)
$378
6 hours
×
$96 (senior computer
operator)
$576
Recordkeeping
$8,886.6
$978
$1,800
--
Total burden per fund
38 hours
$10,317.6
$2,778
Total number of affected
funds4
× 9,240
× 9,240
× 9,240
Total burden
351,120 hours
$95,334,624
$25,668,720
Notes:
1. Includes initial burden estimates annualized over a three-year period.
2. See SIFMA Report, supra footnote 19.
3. The $444.33 wage rate reflects current estimates of the blended hourly rate for an in-house attorney ($419), deputy general counsel ($602) and
compliance manager ($312). $444.33 is based on the following calculation: ($419+$602+$312) / 3 = $444.33.
4. See Adopting Release, supra footnote 1, at n.738.
Table 3: Management Company Findings PRA Estimates
Initial
Internal
Burden
Hours
Annual
Internal
Hour
Burden
Wage Rate1
Internal
Time
Costs
Initial External
Cost Burden
Annual External
Cost Burden
$7,392
$17,610
$5,870
PROPOSED ESTIMA TES
Conduct
evaluations and
15 hours
+
6 hours
×
$352
(compliance attorney)
12
creation, review,
and maintenance
of written materials
10 hours
×
$317
(senior portfolio
manager)
$3,170
5 hours
×
$511
(chief compliance
officer)
$2,555
5 hours
×
$61
(general clerk)
$305
5 hours
×
$94
(senior computer
operator)
$470
Total burden per
fund
30 hours
10
hours
$13,892
$17,610
$11,740
Total number of
affected funds
× 3,373
× 3,373
× 3,373
× 3,373
× 3,373
Total proposed
burden
101,190
hours
33,730
hours
$46,857,
716
$59,398,530
$39,599,020
×
$293
(blended rate for
compliance attorney
and senior
accountant)2
$8,204
$35,220
$0
10 hours
×
$332
(senior portfolio
manager)
$3,320
5 hours
×
$535
(chief compliance
officer)
$2,675
5 hours
×
$63
(general clerk)
$315
5 hours
×
$96
(senior computer
operator)
$480
FINA L ESTIMA TES
20 hours
Conduct
evaluations and
creation, review,
and maintenance
of written materials
+
8 hours
Total burden per
fund
35 hours
13
hours
$14,994
$35,220
$0
Total number of
affected funds
× 6,178
× 6,178
× 6,178
× 6,178
× 6,178
Total final burden
216,230
hours
80,314
hours
$92,632,
932
$217,589,16
0
$0
TOTA L ESTIMA TED BURDENS FOR FUN D FINDIN GS
Proposed burden
estimates
101,190
hours
Proposed total
respondents
3,373
Revised burden
estimates
216,230
hours
Revised total
respondents3
6,178
33,730
hours
$46,857,
716
$59,398,530
$39,599,020
80,314
hours
$92,632,
932
$217,589,16
0
$0
Notes:
1. See SIFMA Report, supra footnote 19.
2. The $293 wage rate reflects current estimates of the blended hourly rate for a compliance attorney ($368) and senior accountant
13
($218). $293 is based on the following calculation: ($368+$218) / 2 = $293.
3. See Adopting Release, supra footnote 1, at n.740.
Table 4: UIT Evaluation PRA Estimates
Initial
Internal
Burden
Hours
Annual
Internal
Hour
Burden
Wage Rate1
Internal Time
Costs
Initial
External
Cost Burden
Annual External
Cost Burden
$2,400
--
--
PROPOSED ESTIMA TES
Conduct
evaluations and
creation, review,
and maintenance
of written materials
15 hours
×
$352
(compliance
attorney)
$5,280
10 hours
×
$317
(senior portfolio
manager)
$3,170
5 hours
×
$511
(chief compliance
officer)
$2,555
2.5
hours
×
$61
(general clerk)
$152.50
2.5
hours
×
$94
(senior computer
operator)
$235
Total burden per
fund
30 hours
5 hours
$11,392.50
$2,400
Total number of
affected funds
× 306
× 306
× 306
× 306
Total proposed
burden
9,180
hours
1530
hours
$3,486,105
$734,400
--
$5,860
$2,400
$0
$0
FINA L ESTIMA TES
Conduct
evaluations and
creation, review,
and maintenance
of written materials
20 hours
×
$293
(blended rate for
compliance attorney
and senior
accountant)2
10 hours
×
$332
(senior portfolio
manager)
$3,320
5 hours
×
$535
(chief compliance
officer)
$2,675
2.5
hours
×
$63
(general clerk)
$157.50
2.5
hours
×
$96
(senior computer
operator)
$240
Total burden per
fund
35 hours
5 hours
$12,252.50
$2,400
Total number of
affected funds
× 200
× 200
× 200
× 200
Total final burden
7,000
hours
1,000
hours
$2,450,500
$480,000
--
14
TOTA L ESTIMA TED BURDEN S FOR UIT EVA LUATION S
Proposed burden
estimates
9,180
hours
Proposed total
respondents
306
Revised burden
estimates
7,000
hours
Revised total
respondents3
200
1,530
hours
$3,486,105
$734,400
$
1,000
hours
$2,450,500
$480,000
$
Notes:
1. See SIFMA Report, supra footnote 19.
2. The $293 wage rate reflects current estimates of the blended hourly rate for a compliance attorney ($368) and senior accountant
($218). $293 is based on the following calculation: ($368+$218) / 2 = $293.
3. See Adopting Release, supra footnote 1, at n.744.
Table 5: Separate Account Certification PRA Estimates
Internal Hour Burden1
Wage Rate2
Internal Time
Costs
Annual External Cost
Burden
--
PROPOSED ESTIMA TES
Obtain certificates and
maintain records
Total burden per fund
1 hour
×
$61
(general clerk)
$61
1 hour
×
$94
(senior computer operator)
$94
2 hours
$155
Total number of affected funds
× 663
× 663
Total proposed burden
1,326 hours
$102,765
---
FINA L ESTIMA TES
Obtain certificates and
maintain records
1 hour
×
$419 (in-house attorney)
$419
1 hour
×
$71 (compliance clerk)
$71
1 hour
×
$63
(general clerk)
$63
1 hour
×
$96
(senior computer operator)
$96
Total burden per fund
4 hours
$649
Total number of affected funds
× 191
× 191
Total final burden
764 hours
$123,959
--
--
--
TOTA L ESTIMA TED BURDEN S FOR SEPA RA TE A CCOUN T CERTIFICA TION
Proposed burden estimates
1,326 hours
Proposed total respondents
663
Revised burden estimates
764 hours
Revised total
respondents3
191
Notes:
1. Includes initial burden estimates annualized over a three-year period.
2. See SIFMA Report, supra footnote 19.
3. See Adopting Release, supra footnote 1, at n.748.
$102,765
--
$123,959
--
15
Table 6: Rule 12d1-4 Total PRA Estimates
Internal
hour burden
Internal
burden time cost
External
cost burden
Voting Provisions
2,970 hours
$1,231,860
$216,000
Fund of Funds Investment Agreements
351,120 hours
$95,334,624
$25,668,720
Management Company Findings
216,230 hours
$92,632,932
$217,589,160
UIT Evaluations
7,000 hours
$2,450,500
$480,000
Separate Account Certificates
764 hours
$123,959
$0
Total annual burden
578,084
$191,773,875
$243,953,880
Number of funds
÷ 16,259
÷ 16,259
÷ 16,259
Average annual burden per fund
35.55 hours
$11,794.94
$15,004.24
13.
Cost to Respondents
Cost burden is the cost of goods and services purchased to collect the information
required under rule 12d1-4. The cost burden does not include the hour burden discussed in Item
12 above. As outlined in the table above, we estimate the total external cost burden to comply
with rule 12d1-4 to be $243,953,880.
14.
Cost to the Federal Government
The proposed rule would not entail any costs on the federal government.
15.
Changes in Burden
Not applicable. This is the first request for approval of a collection of information for
this proposed rule.
16.
Information Collection Planned for Statistical Purposes
Not applicable.
16
17.
Approval to Omit OMB Expiration Date
Not applicable.
18.
Exceptions to Certification Statement for Paperwork Reduction Act
Submission
Not applicable.
B.
COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS
Not applicable.
| File Type | application/pdf |
| File Title | Paperwork Reduction Act |
| File Modified | 2020-10-21 |
| File Created | 2020-10-21 |