Rule 17g-2 Records to be made and retained by nationally recognized statistical rating organizations

Forms and Documents

Document Name	Status
3235-0628.pdf Supplementary Document	2023-10-31
3235-0628.pdf Supplementary Document	2023-10-31
17g-2 Supporting Statement.docx Supporting Statement A	2023-10-30

IC Document Collections

IC ID	Document Title	Status
203418	Retaining updated records	Modified
179758	Rule 17g-2 Records to be made and retained by NRSROs (on-going)	Modified

ICR Details

OMB Control No: 3235-0628	ICR Reference No: 202310-3235-026
Status: Received in OIRA	Previous ICR Reference No: 202009-3235-006
Agency/Subagency: SEC	Agency Tracking No: TM-270-564
Title: Rule 17g-2 Records to be made and retained by nationally recognized statistical rating organizations
Type of Information Collection: Revision of a currently approved collection	Common Form ICR:  No
Type of Review Request: Regular	Date Submitted to OIRA: 10/31/2023

	Requested	Previously Approved
Expiration Date	36 Months From Approved	12/31/2023
Responses	20	18
Time Burden (Hours)	2,650	2,151
Cost Burden (Dollars)	0	0

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Abstract: Rule 17g-2 implements certain statutory provisions of the Credit Rating Agency Reform Act of 2006 by requiring a nationally recognized statistical rating organization or "NRSRO" to make and retain certain records relating to its business and to retain certain other business records, if such records are made. The rule also prescribes the time periods and manner in which all these records must be retained. The collections of information in Rule 17g-2 are designed to allow the Commission to determine whether an NRSRO continues to meet the requirements for registration and is complying with applicable laws and regulations. In particular, the collections of information in Rule 17g-2 will assist the Commission in effectively monitoring, through its examination function, whether an NRSRO is conducting its activities in accordance with Section 15E of the Exchange Act, and applicable Exchange Act rules under the Rating Agency Act.

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Authorizing Statute(s): US Code: 15 USC 78o-7 Name of Law: Credit Rating Agency Reform Act of 2006
   US Code: 15 USC 78c, 78d, 78i, 78j, 78l, 78m, Name of Law: The Securities Exchange Act of 1934
  

Citations for New Statutory Requirements: PL: Pub.L. 111 - 203 939, 939D - 939F Name of Law: Dodd-Frank Wall Street Reform and Consumer Protection Act

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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:
	88 FR 44433	07/12/2023
30-day Notice:	Federal Register Citation:	Citation Date:
	88 FR 73924	10/27/2023
Did the Agency receive public comments on this ICR? Yes

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Number of Information Collection (IC) in this ICR: 2

IC Title	Form No.	Form Name
Retaining updated records
Rule 17g-2 Records to be made and retained by NRSROs (on-going)

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ICR Summary of Burden

	Total Request	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	20	18	0	2	0	0
Annual Time Burden (Hours)	2,650	2,151	0	499	0	0
Annual Cost Burden (Dollars)	0	0	0	0	0	0

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

Burden Increase Due to: Miscellaneous Actions

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

Burden Reduction Due to:

Short Statement: Based on staff’s experience, and in response to the comment received, Commission staff believes it is appropriate to increase the estimated average burden per respondent to 265 annual hours, for an ongoing industry burden of 2,650 annual hours. There is also one additional registrant form the previous renewal.

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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]? Yes

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: 10/31/2023

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