Rule 17g-8 Policies and procedures and Rule 17g-9 Standards of training, experience, and competence for credit analysts

Forms and Documents

Forms and supporting documents for this ICR

Document	Type	Status	Availability
89 FR 38203 (OMB 3235-0693).pdf	Supplementary Document	Uploaded 2024-08-15	Repair queued
89 FR 66466 (OMB 3235-0693).pdf	Supplementary Document	Uploaded 2024-08-15	Repair queued
PRA Rule 17g-8 and 9 Supporting Statement_2024_renewal.docx	Supporting Statement A	Uploaded 2024-08-02	Repair queued

IC Document Collections

Information collection document groups

IC ID	Collection	Type	Status	Form
216057	Rule 17g-9 cost to retain outside professionals		Modified
216056	Rule 17g-9 credit analyst periodic testing		Modified
216055	Rule 17g-9 analyst standards burden based on number of credit analysts		Modified
216046	Rule 17g-9 maintenance of analyst standards		Modified
216044	Rule 17g-8(c) maintenance of policies and procedures		Modified
216042	Rule 17g-8(b) maintenance of policies and procedures		Modified
216040	Rule 17g-8(a) website publication		Modified
216039	Rule 17g-8(a) maintenance of policies and procedures		Modified

ICR Details

OMB Control No: 3235-0693	ICR Reference No: 202406-3235-015
Status: Active	Previous ICR Reference No: 202102-3235-005
Agency/Subagency: SEC	Agency Tracking No: OCR-270-645
Title: Rule 17g-8 Policies and procedures and Rule 17g-9 Standards of training, experience, and competence for credit analysts
Type of Information Collection: Revision of a currently approved collection	Common Form ICR:  No
Type of Review Request: Regular
OIRA Conclusion Action: Approved without change	Conclusion Date: 10/10/2024
Retrieve Notice of Action (NOA)	Date Received in OIRA: 08/15/2024
Terms of Clearance:

table that charts list comparision

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	10/31/2027	36 Months From Approved	10/31/2024
Responses	80	0	72
Time Burden (Hours)	36,108	0	33,640
Cost Burden (Dollars)	14,397,970	0	640,400

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Abstract: Rule 17g-8 requires nationally recognized statistical rating organizations ("NRSROs") to establish, maintain and enforce certain policies and procedures relating to credit rating methodologies, the use of credit rating symbols, and look-back procedures for departing NRSRO employees. Rule 17g-9 implements Section 936 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, which requires the Securities and Exchange Commission to issue rules reasonably designed to ensure that any person employed by an NRSRO to determine credit ratings meets standards of training, experience, and competence necessary to produce accurate ratings for the categories of issuers whose securities the person rates and is tested for knowledge of the credit rating process.

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Authorizing Statute(s): US Code: 15 USC 78o-8, 78o-7(s), 78o-7(r) Name of Law: Securities Exchange Act of 1934
   US Code: 15 USC 78o-7, 78o-7(h)(4)(A)(ii), Name of Law: Securities Exchange Act of 1934
  

Citations for New Statutory Requirements: PL: Pub.L. 111 - 203 932(a)(4), 932(a)(8) 936, 938 Name of Law: Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010

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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:
	89 FR 38203	05/07/2024
30-day Notice:	Federal Register Citation:	Citation Date:
	89 FR 66466	08/15/2024
Did the Agency receive public comments on this ICR? No

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Number of Information Collection (IC) in this ICR: 8

table that charts list of burden

IC Title	Form No.	Form Name
Rule 17g-8(a) maintenance of policies and procedures
Rule 17g-8(a) website publication
Rule 17g-8(b) maintenance of policies and procedures
Rule 17g-8(c) maintenance of policies and procedures
Rule 17g-9 analyst standards burden based on number of credit analysts
Rule 17g-9 cost to retain outside professionals
Rule 17g-9 credit analyst periodic testing
Rule 17g-9 maintenance of analyst standards

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ICR Summary of Burden

table that charts list 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	80	72	0	8	0	0
Annual Time Burden (Hours)	36,108	33,640	0	2,468	0	0
Annual Cost Burden (Dollars)	14,397,970	640,400	0	13,757,570	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: The cost and hour burden for Rules 17g-8 and 17g-9 has increased due to an increase in the number of NRSROs from 9 to 10 and credit analysts employed by NRSROs from 5,506 to 5,897, and to account for inflation.

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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: 08/15/2024

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