Rule 17g-5 Conflicts of Interest

Forms and Documents

Forms and supporting documents for this ICR

Document	Type	Status	Availability
89 FR 38202 (OMB 3235-0649).pdf	Supplementary Document	Uploaded 2024-08-14	Repair queued
89 FR 66153 (OMB 3235-0649).pdf	Supplementary Document	Uploaded 2024-08-14	Repair queued
Rule 17g-5 Supporting Statement.docx	Supporting Statement A	Uploaded 2024-08-05	Available

IC Document Collections

Information collection document groups

IC ID	Collection	Type	Status	Form
237181	Annual Certification		Modified
213116	Arranger form upload		Modified
213114	Arranger ongoing disclosure		Modified
202290	Exemption to the rule with respect to ratings of certain structured finance products		Modified
202289	Arranger transaction disclosures		Modified
188139	NRSRO structured finance ratings disclosure		Modified

ICR Details

OMB Control No: 3235-0649	ICR Reference No: 202406-3235-016
Status: Active	Previous ICR Reference No: 202102-3235-004
Agency/Subagency: SEC	Agency Tracking No: OCR-270-581
Title: Rule 17g-5 Conflicts of Interest
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: 08/14/2024
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	117,776	0	4,852
Time Burden (Hours)	61,899	0	263,306
Cost Burden (Dollars)	14,126,044	0	0

---

Abstract: Rule 17g-5 implements certain statutory provisions of the Credit Rating Agency Reform Act of 2006 ("Rating Agency Act") by prohibiting, or requiring the management and disclosure of, any potential conflict of interest relating to the issuance of credit ratings by a nationally recognized statistical rating organization or "NRSRO." This collection of information is necessary to address potential practices that could impair the objectivity and the quality of a credit rating.

---

Authorizing Statute(s): US Code: 15 USC 780-7 Name of Law: Credit Rating Agency Reform Act of 2006
  

Citations for New Statutory Requirements: US Code: 15 USC 780-7 Name of Law: Credit rating Agency Reform Act

---

Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
	Not associated with rulemaking

---

Federal Register Notices & Comments
60-day Notice:	Federal Register Citation:	Citation Date:
	89 FR 38202	05/07/2024
30-day Notice:	Federal Register Citation:	Citation Date:
	89 FR 66153	08/14/2024
Did the Agency receive public comments on this ICR? No

---

Number of Information Collection (IC) in this ICR: 6

table that charts list of burden

IC Title	Form No.	Form Name
Annual Certification
Arranger form upload
Arranger ongoing disclosure
Arranger transaction disclosures
Exemption to the rule with respect to ratings of certain structured finance products
NRSRO structured finance ratings disclosure

---

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	117,776	4,852	0	112,924	0	0
Annual Time Burden (Hours)	61,899	263,306	0	-201,407	0	0
Annual Cost Burden (Dollars)	14,126,044	0	0	14,126,044	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: Yes

Burden Reduction Due to: Miscellaneous Actions

Short Statement: There are significant changes to the annual aggregate cost and hour burden for Rule 17g-5 due to a decrease in the estimated number of new asset-backed securities transactions based on updated estimates using current data. Also, the method for estimating the number of new asset-backed securities transactions has been updated to reflect the calculation method set forth in the 2019 Rule Amendment Release. The cost and hour burden relating to the certification requirement under Rule 17g-5(e) has decreased due to the reduction in the number of NRSROs subject to the certification requirement from 9 to 6, as only 6 NRSROs are registered in the issuer of asset-backed securities rating class. Finally, the overall cost estimate has been updated to account for inflation.

---

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

---

Common Form ICR:  No

---

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: 08/14/2024

---