Form 10-Q.SS.07-26-2022

SUPPORTING STATEMENT
FOR THE PAPERWORK REDUCTION ACT INFORMATION COLLECTION
SUBMISSION FOR FORM 10-Q
A.

JUSTIFICATION
1.

Circumstances Making the Collection of Information Necessary

Section 13(a) of the Securities Exchange Act of 1934 (“Exchange Act”) requires
every issuer of a security registered pursuant to Section 12 to file periodic and current
reports with the Commission. Section 15(d) of the Exchange Act requires each issuer
that has filed a registration statement that has become effective under the Securities Act
of 1933 to file periodic reports and documents pursuant to Section 13 of the Exchange
Act.
Form 10-Q is the form used by issuers to satisfy their quarterly reporting
obligations pursuant to Section 13 or 15(d) of the Securities Exchange Act. Form 10-Q
requires financial and certain other information concerning the issuer.
2.

Purpose and Use of the Information Collection

The report on Form 10-Q includes financial and other information that is intended
to provide investors with fundamental and material information needed to make informed
investment decisions and to promote confidence in the trading markets.
3.

Consideration Given to Information Technology

All Form 10-Qs filed with the Commission are required to be filed electronically
on the Electronic Data Gathering, Analysis, and Retrieval (EDGAR) system.
4.

Duplication of Information
No similar information is available from other sources.

5.

Reducing the Burden on Small Entities
Form 10-Q is quarterly report that is not filed by small entities.

6.

Consequences of Not Conducting Collection

Investors would not have timely information if less frequent collections are
conducted.
7.

Special Circumstances
There are no special circumstances.
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8.

Consultations with Persons Outside the Agency

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

Payment of Gift to Respondents
No payment or gift has been provided to any respondents.

10.

Confidentiality
Form 10-Q is a public document.

11.

Sensitive Questions

No information of a sensitive nature, including social security numbers, will be
required under this collection of information. The information collection collects basic
Personally Identifiable Information (PII) that may include name and job title. However,
the agency has determined that the information collection 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 February 5, 2020, is
provided as a supplemental document and is also available at
https://www.sec.gov/privacy.
12.

Estimate of Respondent Reporting Burden
Estimated Reporting Burden
Information
Collection
Title

OMB Control
Number

Number of
Responses

Burden
Hours

Form 10-Q

3235-0070

22,925

3,130,752

For purposes of the Paperwork Reduction Act (“PRA”), we estimate that Form
10-Q takes approximately 182.0866302 hours per response to comply with the collection
of information requirements and approximately 22,925 are filed with Commission
annually. We derived our burden hour estimates by estimating the average number of
hours it would take an issuer to compile the necessary information and data, prepare and
review disclosure, file documents and retain records. In connection with rule
amendments to the form, we occasionally receive PRA estimates from public
commenters about incremental burdens that are used in our burden estimates. We believe
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that the actual burdens will likely vary among individual companies based on the size and
complexity of their organization and the nature of their operations. We further estimate
that 75% of the collection of information burden is carried by the issuer internally and
that 25% of the burden of preparation is carried by outside professionals retained by the
company to assist in the preparation of the form. Based on our estimates, we calculated
the total reporting burden to be 3,130,752 hours ((0.75 x 182.0866302) hours per
response x 22,925 responses). For administrative convenience, the presentation of the
total related to the paperwork burden hours has been rounded to the nearest whole
number. The estimated burden hours is made solely for the purpose of the Paperwork
Reduction Act.
13.

Estimate of Total Annualized Cost Burden

Estimated Cost Burden
Information
Collection
Title

OMB Control
Number

Number of
Responses

Cost
Burden

Form 10-Q

3235-0070

22,925

$414,613,154

We estimate that 25% of the 182.0866302 hours per response (45.52165755
hours) is prepared by outside parties. We estimate an hourly cost of approximately
$397.00 for outside legal and accounting services used in connection with public
company reporting. This estimate is based on our consultations with registrants and
professional firms who regularly assist registrants in preparing and filing disclosure
documents with the Commission. Our estimates reflect average burdens, and, therefore,
some companies may experience costs in excess of our estimates and some companies
may experience costs that are lower than our estimates. Based on our estimates, we
calculated the total annual cost to be $414,613,154 ($397.2973466 per hour x
45.52165755 hours per response x 22,925 responses). For administrative convenience,
the presentation of the total cost burden has been rounded to the nearest dollar. The cost
estimate is made solely for the purpose of the Paperwork Reduction Act.
.
14.

Costs to Federal Government

The annual cost of reviewing and processing disclosure documents, including
registration statements, post-effective amendments, proxy statements, annual reports and
other filings of operating companies amounted to approximately $125,800,170 in fiscal
year 2021, based on the Commission’s computation of the value of staff time devoted to
this activity and related overhead.

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15.

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

16.

Information Collection Planned for Statistical Purposes
The information collection is not planned for statistical purposes.

17.

Approval to Omit 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

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

B.

STATISTICAL METHODS
The information collection does not employ statistical methods.

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