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pdfSUPPORTING STATEMENT
for the Paperwork Reduction Act Information Collection Submission for Exchange Act
Rule 3a71-6: Substituted Compliance for Foreign Security-Based Swap Entities
OMB No. 3235-0715
This submission is being made pursuant to the Paperwork Reduction Act of 1995, 44 U.S.C.
Section 3501 et seq.
A.
JUSTIFICATION
1.
Necessity of Information Collection
Various requirements contained in Title VII of the Dodd-Frank Wall Street Reform and
Consumer Protection Act 1 apply to cross-border security-based swap transactions. Accordingly in a
market as global as the security-based swap market, there is a potential that market participants
who engage in cross-border security-based swap activity could be subject to conflicting or
duplicative compliance obligations across multiple jurisdictions. The Commission therefore has
developed a policy and procedural framework under which the Commission will consider
permitting compliance with comparable regulatory requirements in a foreign jurisdiction to
substitute for compliance with certain Title VII requirements relating to security-based swaps (i.e.,
“substituted compliance”).
On April 14, 2016, the Commission adopted the initial set of rules under the Securities
Exchange Act of 1934 (“Exchange Act”) that are intended to implement provisions of Title VII
relating to business conduct standards and the designation of a chief compliance officer for
security-based swap dealers (“SBSDs”) and major security-based swap participants (“MSBSPs” or
collectively with SBSDs, “SBS Entities”) and also address the cross-border application of the rules
and the availability of substituted compliance. 2 Rule 3a71-6 provides that the Commission may,
conditionally or unconditionally, by order, make a determination with respect to a foreign financial
regulatory system that compliance with specified requirements under such foreign financial
regulatory system by a registered non-U.S. SBSD or non-U.S. MSBSP, or class thereof, may
satisfy certain requirements of section 15F of the Exchange Act and certain Commission rules and
regulations. The availability of substituted compliance would be predicated on a determination by
the Commission that the relevant foreign requirements are comparable to the requirements that
otherwise would be applicable, taking into account the scope and objectives of the relevant foreign
requirements, and the effectiveness of supervision and enforcement under the foreign regulatory
regime.
1
Public Law 111–203, 124 Stat. 1376 (2010). Unless otherwise indicated, references to “Title VII” in this
release are to Subtitle B of Title VII of the Dodd-Frank Act.
2
See Business Conduct Standards for Security-Based Swap Dealers and Major Security-Based Swap
Participants, Exchange Act Release No. 77617 (Apr. 14, 2016), 81 FR 29959 (May 13, 2016) (“Business
Conduct Standards Adopting Release”). See also Business Conduct Standards for Security-Based Swap
Dealers and Major Security-Based Swap Participants; Correction, Exchange Act Release 77617A (May 19,
2016), 81 FR 32643 (May 24, 2016).
1
When the Commission adopted Rule 3a71-6 in connection with adopting requirements
related to business conduct standards and the designation of a chief compliance officer, it reserved
the issue as to whether substituted compliance would also be available in connection with other
requirements. 3 The Commission subsequently amended Rule 3a71-6 to provide for the possibility
of substituted compliance in connection with the following Title VII requirements: (1) trade
acknowledgment and verification, 4 (2) capital and margin requirements, 5 (3) recordkeeping and
reporting, 6 and (4) portfolio reconciliation, portfolio compression, and trading relationship
documentation. 7
As provided by Exchange Act Rule 0-13, which the Commission adopted in 2014,
applications for substituted compliance determinations in connection with these requirements
must be accompanied by supporting documentation necessary for the Commission to make the
determination, including information regarding applicable requirements established by the foreign
financial regulatory authority or authorities, as well as the methods used by the foreign financial
regulatory authority or authorities to monitor and enforce compliance with such rules, and
applicants should cite to and discuss applicable precedent. Rule 0-13 also specifies other
prerequisites for the filing of substituted compliance applications (e.g., requirements regarding the
use of English, the use of electronic or paper requests, contact information, and public notice and
comment in connection with complete applications). 8
2.
Purpose and Use of the Information Collection
3
See Business Conduct Standards Adopting Release, 81 FR at 30074 and n. 1438.
4
See Trade Acknowledgment and Verification of Security-Based Swap Transactions, Exchange Act Release
No. 78011 (Jun. 8, 2016), 81 FR 39807, 39827-28 (Jun. 17, 2016) (“SBS Entity Trade Acknowledgement and
Verification Adopting Release”).
5
See Capital, Margin, and Segregation Requirements for Security-Based Swap Dealers and Major SecurityBased Swap Participants and Capital Requirements for Broker-Dealers, Exchange Act Release No. 86175 (Jun.
21, 2019), 84 FR 43872, 39827-28 (Aug. 22, 2019) (“Capital, Margin, and Segregation Requirements Adopting
Release”).
6
See Recordkeeping and Reporting Requirements for Security-Based Swap Dealers, Major Security-Based Swap
Participants, and Broker-Dealers, Exchange Act Release No. 87005 (Sep. 19, 2019), 84 FR 68550, 68597-99 (Dec.
16, 2019) (“SBS Entity Recordkeeping and Reporting Release”).
7
See Risk Mitigation Techniques for Uncleared Security-Based Swaps, Exchange Act Release No. 87782 (Dec. 18,
2019), 85 FR 6359, 6379-80 (Feb. 4, 2020) (“SBS Entity Risk Mitigation Adopting Release”). Due to an
oversight, a supporting statement was not submitted with respect to the amendment to Rule 3a71-6 adopted as
described in that release prior to the rule amendments becoming effective. As noted in the release, the
Commission believed that its prior estimate of the paperwork burden associated with making a substituted
compliance request would be sufficient to cover a combined substituted compliance request that also seeks a
determination for the portfolio reconciliation, portfolio compression, and written trading relationship
documentation requirements that were made eligible for a substituted compliance determination as described in
that release. See Id. at 6389; see also Risk Mitigation Techniques for Uncleared Security-Based Swaps, Exchange
Act Release No. 84861 (Dec. 19, 2018), 84 FR 4614, 4647 (Feb. 15, 2019) (“SBS Entity Risk Mitigation
Proposing Release”). The Commission did not receive any comments on the Paperwork Reduction Act estimates
included in the SBS Entity Risk Mitigation Proposing Release. See SBS Entity Risk Mitigation Adopting Release,
85 FR at 6381.
8
See Application of “Security-Based Swap Dealer” and “Major Security-Based Swap Participant” Definitions
to Cross-Border Security-Based Swap Activities; Republication, Exchange Act Release No. 72472 (June 25,
2014), 79 FR 47277 (Aug. 12, 2014).
2
The Commission will use the information collected pursuant to Exchange Act Rule 3a71-6
to evaluate requests for substituted compliance with respect to the eligible requirements applicable
to SBS Entities. The requests for substituted compliance determinations are required when a
person seeks a substituted compliance determination. Consistent with Exchange Act Rule 0-13(h),
the Commission will publish in the Federal Register a notice that a complete application has been
submitted, and provide the public the opportunity to submit to the Commission any information
that relates to the Commission action requested in the application, subject to requests for
confidential treatment being submitted pursuant to any applicable provisions governing
confidentiality under the Exchange Act. 9
3.
Consideration Given to Information Technology
Exchange Act Rule 0-13 provides that applications for a substituted compliance
determination may be submitted in paper format or electronically. Applications submitted
electronically must be submitted to the electronic mailbox described on the Commission’s Web
site. The rule permits electronic submission of applications in order to reduce the burden on
applicants and streamline the submission process, while also permitting submission of paper
applications to give applicants flexibility in their form of submission.
4.
Duplication
Rule 3a71-6 does not duplicate any existing regulatory requirements. There are no other
rules governing substituted compliance for non-U.S. SBS Entities to satisfy the requirements
identified in Rule 3a71-6.
5.
Effect on Small Entities
Not applicable. None of the respondents subject to the information collection will be a
small entity. 10
6.
Consequences of Not Conducting Collection
The information collection under Rule 3a71-6 is designed to enable the Commission to
permit compliance with comparable regulatory requirements in a foreign jurisdiction to substitute
for compliance with certain Title VII requirements relating to security-based swaps, and thereby
mitigate the threat that a market participant who engages in cross-border security-based swap
transactions could be subject to conflicting or duplicative compliance obligations across multiple
jurisdictions. If the information collection under Rule 3a71-6 is not completed with respect to a
given foreign jurisdiction, the Commission may be unable to make a substituted compliance
9
See Item 10 below.
10
Section 601 of the Regulatory Flexibility Act (“RFA”) defines the term “small entity.” The statute, however,
permits agencies to formulate their own definitions. The Commission has adopted definitions for the term
“small entity” for the purposes of Commission rulemaking in accordance with the RFA. Those definitions,
as relevant to this rulemaking, are set forth in 17 CFR 240.0-10. See Final Definitions of “Small Business”
and “Small Organization” for Purposes of the Regulatory Flexibility Act, Exchange Act Release No. 18452
(Jan. 28, 1982), 47 FR 5215 (Feb. 4, 1982).
3
determination with respect to such foreign jurisdiction.
7.
Inconsistencies with Guidelines in 5 CFR 1320.5(d)(2)
There are no special circumstances. This collection is consistent with the guidelines in 5 CFR
1320.5(d)(2).
8.
Consultations Outside the Agency
The required Federal Register notice with a 60-day comment period soliciting comments
on this collection of information was published. No public comments were received.
9.
Payment or Gift
Not applicable. No payment or gift is provided to respondents.
10.
Confidentiality
The Commission intends to make public the information submitted to it pursuant to any
request for a substituted compliance determination under Rule 3a71-6, including supporting
documentation provided by the requesting party, though requestors may seek confidential
treatment of their applications to the extent permitted under Commission rules. If confidential
treatment is granted, the Commission would keep such information confidential, subject to the
provisions of applicable law (e.g., Exchange Act sections 24(c), 24(d) and 24(f)(2)).
11.
Sensitive Questions
The Information Collection does not collect information about individuals, but rather only business
contact information; therefore, a PIA, SORN, and PAS are not required.
12.
Information Collection Burden
Requests for substituted compliance determinations may come from parties or groups of
parties that would rely on substituted compliance, or from foreign financial regulatory authorities
supervising such parties or their security-based swap activities. The Commission will make any
determinations with respect to particular requirements on a class or jurisdiction basis, depending on
the specific characteristics of the foreign regulatory regime, rather than on a firm-by-firm basis.
Once the Commission has made an affirmative substituted compliance determination with respect
to whether compliance with requirements of a particular jurisdiction may satisfy specified
requirements in Rule 3a71-6(d), other similarly situated non-U.S. SBS Entities within such
jurisdiction would be able to rely on that determination to the extent applicable and subject to any
corresponding conditions. Similarly, if the Commission makes a determination to reject a request
for a substituted compliance determination with respect to a particular jurisdiction, such
determination would apply to other similarly situated entities within such jurisdiction. Therefore, a
non-U.S. SBS Entity would not be required to make a request with respect to whether compliance
with requirements of a particular jurisdiction may satisfy specified requirements in Rule 3a71-6(d)
if the Commission has previously made a substituted compliance determination with respect to
4
whether compliance with requirements of that particular jurisdiction may satisfy those specified
requirements in Rule 3a71-6(d).
The Commission had previously estimated that there may be approximately 22 non-U.S.
entities that may potentially register as SBSDs out of approximately 50 total entities that may
register as SBSDs. 11 Potentially, all non-U.S. SBSDs, or some subset thereof, may seek to rely
on a substituted compliance determination in connection with eligible requirements. 12 However,
the Commission had expected that the great majority of substituted compliance applications
would be submitted by foreign authorities 13 given their expertise in connection with the relevant
substantive requirements, and in connection with their supervisory and enforcement oversight
with regard to SBSDs and their activities. 14 For purposes of PRA assessments, the Commission
estimated that three SBS Entities would submit such applications. 15 Although, as of September
28, 2023, 30 entities had identified themselves as a nonresident SBSD in their application for
registration with the Commission,16 the Commission has issued only one order making
substituted compliance determinations in response to a request from potential registrants. 17 The
Commission continues to believe that its estimate that three such entities will submit applications
remains appropriate for purposes of this PRA assessment because applicants may file additional
11
See Proposed Rule Amendments and Guidance Addressing Cross-Border Application of Certain Security-Based
Swap Requirements, Exchange Act Release No. 85823 (May 10, 2019), 84 FR 24206, 24253 (May 24, 2019). See
also Security-Based Swap Transactions Connected With a Non-U.S. Person's Dealing Activity That Are
Arranged, Negotiated, or Executed by Personnel Located in a U.S. Branch or Office or in a U.S. Branch or Office
of an Agent; Security-Based Swap Dealer De Minimis Exception, Exchange Act Release No. 77104 (Feb. 10,
2016), 81 FR 8597, 8605 (Feb. 19, 2016); Business Conduct Standards Adopting Release, 81 FR at 30090, 30105;
SBS Entity Recordkeeping and Reporting Release, 84 FR at 68607-09; and Capital, Margin, and Segregation
Requirements Adopting Release, 84 FR at 43960-61.
12
The Commission previously estimated that that there may up to five MSBSPs. See Registration Process for
Security-Based Swap Dealers and Major Security-Based Swap Participants, Exchange Act Release No. 75611
(Aug. 5, 2015), 80 FR 48963, 48990 (Aug. 14, 2015) (“SBS Entity Registration Adopting Release”). No
applications for registration as an MSBSP have been filed as of September 28, 2023. If such entities file an
application, itis possible that some subset of those entities will be non-U.S. MSBSPs that will seek to rely on
substituted compliance in connection with eligible requirements.
13
See SBS Entity Risk Mitigation Adopting Release, 85 FR at 6389. See also Business Conduct Standards
Adopting Release, 81 FR at 30097; SBS Entity Trade Acknowledgement and Verification Adopting Release,
81 FR at 39832.
14
See SBS Entity Risk Mitigation Adopting Release, 85 FR at 6384. See also Business Conduct Standards
Adopting Release, 81 FR at 30090; SBS Entity Trade Acknowledgement and Verification Adopting Release,
81 FR at 39832.
15
See SBS Entity Risk Mitigation Adopting Release, 85 FR at 6389. See also Business Conduct Standards
Adopting Release, 81 FR at 30097, n.1582 and accompanying text; SBS Entity Trade Acknowledgement and
Verification Adopting Release, 81 FR at 39832; SBS Entity Recordkeeping and Reporting Adopting Release,
84 FR at 68609; Capital, Margin, and Segregation Requirements Adopting Release, 84 FR at 43967.
16
No entity has registered as a MSBSP. See List of Security-Based Swap Dealers and Major Security-Based
Swap Participants, available at: https://www.sec.gov/tm/List-of-SBS-Dealers-and-Major-SBS-Participants
(providing the list of registered SBSDs and MSBSPs that was updated as of Sept. 28, 2023).
17
See Order Granting Conditional Substituted Compliance in Connection With Certain Requirements
Applicable to Non-U.S. Security-Based Swap Dealers Subject to Regulation in the Swiss Confederation,
Exchange Act Release No. 93284 (Oct. 8, 2021), 86 FR 57455 (Oct. 15, 2021) (File No. S7-07-21). The
Commission’s other substituted compliance orders have been in response to requests from foreign authorities;
see https://www.sec.gov/tm/Jurisdiction-Specific-Apps-Orders-and-MOU.
5
requests.
For purposes of this assessment, the Commission estimated:
•
Three SBSDs or MSBSPs will submit requests for substituted compliance
determinations with respect to the Commission’s business conduct requirements,
chief compliance officer requirements, trade acknowledgement and verification
requirements, and portfolio reconciliation, portfolio compression, and trading
relationship documentation requirements,
•
Three SBSDs or MSBSPs will submit requests for substituted compliance
determinations with respect to the Commission’s capital and margin requirements
promulgated under section 15F of the Exchange Act, and
•
Three SBSDs or MSBSPs will submit requests for substituted compliance
determinations with respect to the Commission’s reporting and recordkeeping
requirements promulgated under section 15F of the Exchange Act.
The Commission staff estimated that the one-time reporting burden associated with each
substituted compliance request pursuant to Rule 3a71-6 in connection with each of these
requirements will occur in the first year and will consist of approximately 80 hours of in-house
counsel time. Thus, the Commission staff estimated the following aggregate burdens for all
respondents associated with preparing and submitting requests for a substituted compliance
determination:
•
240 hours in connection with the Commission’s business conduct requirements, the
Commission’s chief compliance officer requirements, the Commission’s trade
acknowledgement and verification requirements, and the Commission’s portfolio
reconciliation, portfolio compression, and trading relationship documentation
requirements. 18 Based on these calculations, the annualized three year estimate
is 26.67 19 hours per respondent per year and the annualized three-year
estimate of the hourly burden across all respondents is 80 hours per year. 20
•
240 hours in connection with the Commission’s capital and margin requirements
promulgated under section 15F of the Exchange Act. 21 Based on these calculations,
the annualized three-year estimate is 26.67 22 hours per respondent per year and
the annualized three-year estimate of the hourly burden across all respondents
18
80 hours * 3 estimated requests for substituted compliance determinations with respect to business conduct,
chief compliance officer, trade acknowledgement and verification, and portfolio reconciliation, portfolio
compression, and trading relationship documentation requirements = 240 hours.
19
(First year: 80 hours; second year: 0 hours; third year: 0 hours) ÷ 3 years = 26.67 hours per respondent.
20
26.67 hours per respondent * 3 respondents = 80 hours.
21
80 hours * 3 estimated requests for substituted compliance determinations with respect to capital and margin
requirements = 240 hours.
22
(First year: 80 hours; second year: 0 hours; third year: 0 hours) ÷ 3 years = 26.67 hours per respondent.
6
is 80 hours per year. 23
•
240 hours in connection with the Commission’s reporting and recordkeeping
requirements promulgated under section 15F of the Exchange Act. 24 Based on these
calculations, the annualized three-year estimate is 26.67 25 hours per respondent
per year and the annualized three-year estimate of the hourly burden across all
respondents is 80 hours per year. 26
Thus, the total estimated industry-wide burden for preparing and submitting requests
for a substituted compliance determination is 720 hours. 27 Based on these
calculations, the annualized three-year estimate is 80 hours per respondent per year, 28
and the total annualized estimate of the hourly burden across all respondents is
240 hours per year. 29
Summary of Hourly Burdens
A.
Name of Information
Collection
Type of
Burden
Number
of Entities
Impacted
B.
C.
D.
E.
F.
G.
Annual
Responses
Per Entity
Initial
Burden per
Entity per
Response
Initial Burden
Annualized
Per Entity Per
Response
Ongoing
Burden Per
Entity Per
Response
Annual
Burden Per
Entity per
Response
Total Annual
Burden Per
Entity
Total Industry
Burden
Small
Business
Entities
Affected
[ D + E]
[F * B]
[G * A]
[A * 0%]
[C ÷ 3 years]
Rule 3a71-6(d)(1)-(3), (7) 30
Reporting
Rule 3a71-6(d)(4)-(5)
Reporting
Rule 3a71-6(d)(6)
Reporting
3
3
3
1
1
1
80
26.67
0.00
26.67
26.67
80
26.67
0.00
26.67
26.67
80
26.67
0.00
26.67
26.67
TOTAL HOURLY BURDEN FOR ALL RESPONDENTS
13.
Costs to Respondents
The Commission believes that an SBS Entity (or a group of such entities) requesting a
substituted compliance determination will seek outside legal services in the preparation of such
23
26.67 hours per respondent * 3 respondents = 80 hours.
24
80 hours * 3 estimated requests for substituted compliance determinations with respect to reporting and
recordkeeping requirements = 240 hours.
25
(First year: 80 hours; second year: 0 hours; third year: 0 hours) ÷ 3 years = 26.67 hours per respondent.
26
26.67 hours per respondent * 3 respondents = 80 hours.
27
240 hours (business conduct, chief compliance officer, trade acknowledgement and verification, and portfolio
reconciliation, portfolio compression, and trading relationship documentation) + 240 hours (capital and
margin) + 240 hours (reporting and recordkeeping) = 720 hours.
28
[ (80 hours + 80 hours + 80 hours (first year)) + 0 hours (second year) + 0 hours (third year) ] ÷ 3 years = 80
hours per respondent.
29
80 hours per respondent * 3 respondents = 240 hours.
30
We have revised the title of this information collection, but we are not changing the estimated burden. See
supra note 7.
7
80
0
80
0
80
0
240
requests. For PRA purposes, the Commission assumed that three such entities would seek
outside legal services for the first year only and would, on average, consult with outside counsel
for 200 hours. The Commission’s revised estimated hourly rate for an outside attorney in
connection with applications for a substituted compliance determination is $584. The
Commission continues to assume that none of the three respondents would seek outside legal
services for year two or year three (i.e., this would be a one-time cost burden). As such, the
total one-time labor cost per respondent for Rule 3a71-6(d) would be approximately
$350,400.00, 31 or approximately $116,800.00 per respondent per year 32 when annualized
over three years for each request.
The chart below summarizes the estimated cost burden associated with Rule 3a71-6. 33
These total burdens include all collection burdens associated with Rule 3a71-6, including burdens
associated with analyzing and comparing the regulatory requirements of the foreign jurisdiction
with the eligible requirements in Section 15F of the Exchange Act and the rules and regulations
thereunder.
Summary of Dollar Costs
Name of Information Collection
Type of
Burden
A.
B.
Number
of Entities
Impacted
Annual
Responses
Per Entity
C.
Initial Cost
Per Entity
Per Response
D.
E.
F.
G.
Initial Cost
Annualized
Per Entity
Per Response
Ongoing Cost
Per Entity
Per Response
Annual Cost
Per Entity
per Response
Total
Annual
Cost
Per Entity
[C ÷ 3 years]
[ D + E]
[F * B]
Total Industry
Cost
[G * A]
Small
Business
Entities
Affected
[A * 0%]
Rule 3a71-6(d)(1)-(3), (7)
Reporting
3
1
$116,800.00
$38,933.33
$0.00
$38,933.33
$38,933.33
$116,800.00
0
Rule 3a71-6(d)(4)-(5)
Reporting
3
1
$116,800.00
$38,933.33
$0.00
$38,933.33
$38,933.33
$116,800.00
0
Rule 3a71-6(d)(6)
Reporting
3
1
$116,800.00
$38,933.33
$0.00
$38,933.33
$38,933.33
$116,800.00
0
TOTAL COST FOR ALL RESPONDENTS
$350,400.00
Thus, the total estimated industry-wide cost of retaining outside legal services for a
substituted compliance determination is $1,051,200.00, 34 or $350,400.00 per year when
31
Business conduct, chief compliance officer, trade acknowledgement and verification, portfolio reconciliation,
portfolio compression, and trading relationship documentation: 200 hours (average estimated time spent by
outside counsel to help request a substituted compliance determination) × $584 (hourly rate for an outside
attorney) = $116,800.00 + capital and margin: 200 hours (average estimated time spent by outside counsel to
help request a substituted compliance determination) × $584 (hourly rate for an outside attorney) =
$116,800.00 + reporting and recordkeeping: 200 hours (average estimated time spent by outside counsel to
help request a substituted compliance determination) × $584 (hourly rate for an outside attorney) =
$116,800.00. $116,800 x 3 = $350,400.00.
32
$350,400.00 (cost per respondent, over three years) ÷ 3 years = $116,800.00.
33
The chart also reflects the amendment to Rule 3a71-6 described in the SBS Entity Risk Mitigation Adopting
Release. See supra note 7.
34
$116,800.00 (business conduct, chief compliance officer, trade acknowledgement and verification, portfolio
reconciliation, portfolio compression, and trading relationship documentation, and the cybersecurity rule and
form) + $116,800.00 (capital and margin) + $116,800.00 (reporting and recordkeeping) = $350,400.00 × 3
(estimated number of entities that would seek outside counsel to help request a substituted compliance
determination) = $1,051,200.00.
8
annualized over three years. 35
14.
Cost to Federal Government
Not applicable. The Commission does not anticipate any contracting, IT, or development
costs, and does not anticipate hiring new employees in connection with the information collection.
15.
Changes in Burden
The Commission has revised its burden estimates for some of the information collections
as summarized in the table below.
Name of
Information
Collection
Rule 3a71-6(d)(1)-(3), (7)
Annual Industry
Burden
Change in Burden
Reason for Change
$116,800.00
Previous Annual
Industry
Burden Estimate
$84,000.00
$32,800.00
Inflation
Rule 3a71-6(d)(4)-(5)
$116,800.00
$84,000.00
$32,800.00
Inflation
Rule 3a71-6(d)(6)
$116,800.00
$84,000.00
$32,800.00
Inflation
TOTAL ANNUAL CHANGE IN BURDEN $98,400.00
FOR ALL RESPONDENTS:
16.
Information Collection Planned for Statistical Purposes
Not applicable. The information collection is not used for statistical purposes.
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
This collection complies with the requirements in 5 CFR 1320.9.
B.
COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS
This collection does not involve statistical methods.
35
$1,051,200.00 ÷ 3 years = $350,400.00.
9
| File Type | application/pdf |
| File Title | Supporting Statement |
| File Modified | 2024-05-21 |
| File Created | 2024-05-21 |