3235-0123 Supporting Statement (2025) Final

3235-0123 Supporting Statement (2025) Final.pdf

Rule 17a-5, Form X-17A-5 (FOCUS REPORT)

OMB: 3235-0123

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SUPPORTING STATEMENT
for the Paperwork Reduction Act Information Collection Submission for Rule 17a-5
OMB Control No. 3235-0123
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

Section 17(a)(1) 1 of the Securities Exchange Act of 1934 (“Exchange Act”) provides that
broker-dealers must make and keep records, furnish copies of the records, and make and
disseminate reports as the Securities and Exchange Commission (“Commission”), by rule,
prescribes. Section 17(e)(1)(A) 2 of the Exchange Act requires every broker-dealer registered
with the Commission to file annually with the Commission: (1) a balance sheet and income
statement “certified by a[n] independent public accounting firm, or by a registered public
accounting firm if the firm is required to be registered under the Sarbanes-Oxley Act of 2002”;
and (2) such other financial statements (which shall, as the Commission specifies, be certified)
and information concerning its financial condition as the Commission, by rule, may prescribe. A
“registered public accounting firm” is a public accounting firm registered with the Public
Company Accounting Oversight Board (“PCAOB”). 3 Section 17(e)(2) 4 of the Exchange Act
provides that the Commission, by rule, may prescribe the form and content of the financial
statements and the accounting principles and standards used in their preparation.
Rule 17a-5 under the Exchange Act 5 is a reporting rule for broker-dealers. Rule 17a-5
applies to broker-dealers, including some broker-dealers that are OTC derivatives dealers;
broker-dealers, other than OTC derivatives dealers, that are also registered security-based swap
dealers; and broker-dealers, including OTC derivatives dealers, that are also registered as major
security-based swap participants. Paragraph (a)(1) of Rule 17a-5 requires broker-dealers to file
periodic reports on Form X-17A-5, the Financial and Operational Combined Uniform Single
Report (“FOCUS Report”). The FOCUS Report was designed to eliminate the overlapping
regulatory reports required by various self-regulatory organizations and the Commission and to
reduce reporting burdens.
Under paragraph (a)(2) of Rule 17a-5, the reports provided for in paragraph (a) that must
be filed with the Commission must be filed with the Commission at its principal office and the
regional office of the Commission where the broker-dealer has its principal place of business.
However, under paragraph (a)(3) of Rule 17a-5, the provisions of paragraph (a)(1) do not apply
to members of national securities exchanges or registered national securities associations that
1
2
3
4
5

See 15 U.S.C. § 78q(a)(1).
See 15 U.S.C. § 78q(e)(1)(A).
See Pub. L. No. 107-204 § 2(a)(12).
See 15 U.S.C. § 78q(e)(2).
See 17 CFR 240.17a-5.

maintain records containing the information required by Form X-17A-5 and which transmit to
the Commission copies of the records pursuant to a plan which has been declared effective by the
Commission. As a result, FOCUS Reports required to be filed under paragraph (a)(1) of Rule
17a-5 are generally filed electronically with FINRA 6 via FINRA’s eFOCUS system.
Paragraph (a)(1)(i) of Rule 17a-5 provides that broker-dealers that clear transactions or
carry customer accounts must file Part I of the FOCUS Report monthly. However, in 1996, the
NASD’s plan was amended to eliminate the requirement for member firms to file Part I. 7
Paragraphs (a)(1)(ii) and (iii) of Rule 17a-5 generally require broker-dealers that clear
transactions or carry customer accounts and broker-dealers registered as security-based swap
dealers or major security-based swap participants to file Part II of the FOCUS Report and
broker-dealers that do not clear transactions nor carry customer accounts and that are not
registered as security-based swap dealers or major security-based swap participants to file Part
IIA of the FOCUS Report quarterly. However, paragraph (a)(1)(iv) of Rule 17a-5 requires
broker-dealers to file Part II or Part IIA monthly upon receiving written notice from the
Commission or the designated examining authority (“DEA”) of the broker-dealer. Paragraph
(a)(5) of Rule 17a-5 requires broker-dealers that compute certain capital charges in accordance
with Appendix E to Exchange Act Rule 15c3-1 8 (“ANC broker-dealers”) to file certain
additional monthly and quarterly reports.
Paragraph (c) of Rule 17a-5 requires a broker-dealer to furnish certain financial
information to its customers. 9
Paragraph (d) of Rule 17a-5 requires broker-dealers, subject to limited exceptions, to file
annual reports, which must include a financial report and a compliance report or exemption
report, and generally must include reports prepared by an independent public accountant
covering the financial report and the compliance report or exemption report. Generally, brokerdealers that did not claim they were exempt from Exchange Act Rule 15c3-3, 10 the broker-dealer
customer protection rule, throughout the fiscal year must file compliance reports and brokers that
claim they were exempt from Rule 15c3-3 throughout the fiscal year must file exemption reports.
The annual reports must also be filed with the Securities Investor Protection Corporation
(“SIPC”) if the firm is a member of SIPC, and must generally be provided to all self-regulatory
organizations of which the broker-dealer is a member.

8
9

In 2007, FINRA was created through the consolidation of NASD and the member regulation, enforcement,
and arbitration operations of the New York Stock Exchange.
See Self-Regulatory Organizations; Notice of Filing and Order Granting Accelerated Approval of
Proposed Rule Change by the National Association of Securities Dealers, Inc. Relating to the Association’s
FOCUS Filing Plan, Release No. 34-36780, File No. SR-NASD-96-03 (Jan. 26, 1996), 61 FR 3743, 3745
(Feb. 1, 1996) available at: www.govinfo.gov/content/pkg/FR-1996-02-01/pdf/96-2056.pdf.
See 17 CFR 240.15c3-1e.
Paragraph (c) of Rule 17a-5 is subject to a separate Paperwork Reduction Act filing (OMB Control Number
3235-0199).
See 17 CFR 240.15c3-3.

Paragraph (e)(4) of Rule 17a-5 requires broker-dealers to file with SIPC a report on the
SIPC annual general assessment reconciliation or exclusion from membership forms.
Paragraph (f)(1) of Rule 17a-5 provides that the independent public accountant must be
qualified and independent in accordance with Rule 2-01 of Regulation S-X 11 and must be
registered with the PCAOB if required by the Sarbanes-Oxley Act of 2002. Paragraph (f)(2) of
Rule 17a-5 requires broker-dealers that are required to file annual reports under paragraph (d) of
Rule 17a-5 to file statements regarding their independent public accountant. If the engagement
of the accountant is of a continuing nature, no further filing is required. Otherwise, a new
statement must be filed with the Commission. Paragraph (f)(3) of Rule 17a-5 requires a brokerdealer to file a notice with the Commission if it replaces its accountant.
Paragraph (g) of Rule 17a-5 requires the independent public accountant to undertake to
prepare its reports based on an examination of the financial report and either an examination of
the compliance report or a review of certain statements in the exemption report. The reports
must be prepared in accordance with PCAOB standards.
Paragraph (h) of Rule 17a-5 contains notification requirements related to certain
findings made during the course of preparing the reports of the independent accountant.
Paragraph (k) of Rule 17a-5 requires an ANC broker-dealer to file a supplemental report
on management controls concurrently with its annual reports.
Paragraph (n) of Rule 17a-5 provides that a broker-dealer must notify the Commission if
it changes its fiscal year.
Paragraph (p) of Rule 17a-5 provides that OTC derivatives dealers may comply with
Rule 17a-5 by complying with Exchange Act Rule 17a-12. 12
2025 Rule Amendments
On December 16, 2024, the Commission amended Rule 17a-5 to require annual audited
reports and related annual filings to be filed electronically in Inline eXtensible Business
Reporting Language (“Inline XBRL”) through the Commission’s Electronic Data Gathering and
Retrieval (“EDGAR”) system. 13 The filings were previously made either in paper, via email, or
voluntarily on the EDGAR system as PDF documents. The Commission is also allowing
electronic signatures in Rule 17a-5 filings, which includes the FOCUS Report and the annual
audited reports. The Commission is amending the instructions to Parts II and IIA of the FOCUS
Report to allow only one named officer’s signature when the signature belongs to the firm’s
principal executive officer or principal financial officer (or their comparable officers). Finally,
the Commission is making amendments to FOCUS Report Part II and FOCUS Report Part IIA.
11
12
13

17 CFR 210.2-01.
See 17 CFR 240.17a-12.
Electronic Submission of Certain Materials Under the Securities Exchange Act of 1934; Amendments
Regarding the FOCUS Report; SEC Release Nos. 33–11342; 34–101925; IC– 35420; (Dec. 16, 2024); 90
FR 7250 (Jan. 21, 2025) (File No. S7-08-23).

None of these amendments are expected to impact the ongoing burden of filing FOCUS Report
Parts II or IIA.
2.

Purpose and Use of Information Collection

Reports required to be filed under Rule 17a-5 are used, among other things, to monitor
the financial and operational condition of a broker-dealer by Commission staff and by the
broker-dealer’s DEA. The reports required under Rule 17a-5 are one of the primary means of
ensuring compliance with the broker-dealer financial responsibility rules. A firm’s failure to
comply with these rules would severely impair the ability of the Commission and the firm’s
DEA to protect customers.
FOCUS Report data are used in preparation for broker-dealer examinations and
inspections. The completed forms also are used to determine which firms are engaged in various
securities-related activities, the extent to which they are engaged in those activities, and how
economic events and government policies might affect various segments of the securities
industry.
3.

Consideration Given to Information Technology

The data required in the FOCUS Report are tailored to the complexity of the brokerdealer’s business. The burden is therefore commensurate with the type of business in which the
firm engages. Approximately 90% of FOCUS Reports are filed electronically. Prior to the 2025
amendments, annual reports under paragraph (d) of Rule 17a-5 were generally filed with the
Commission in paper form or electronically through the Commission’s EDGAR system.
2025 Rule Amendments
As stated above, the Commission is amending Rule 17a-5 to require broker-dealers to
electronically file annual audited reports and related annual filings with the Commission in Inline
XBRL through the Commission’s EDGAR system. The Commission is also allowing electronic
signatures in Rule 17a-5 filings.
4.

Duplication

The Commission designed Rule 17a-5 to eliminate duplicative reporting requirements
among the various securities regulatory agencies. Therefore, any duplication of the information
requested is minimal.
5.

Effect on Small Entities

As discussed above, a broker-dealer typically must file one of two alternative quarterly or
monthly reports: (1) a comprehensive FOCUS Report Part II which must be filed by every
broker-dealer that clears transactions or carries customer accounts and OTC derivatives dealers;
or (2) a less detailed FOCUS Report Part IIA which must be filed by broker-dealers that do not
clear transactions or carry customer accounts. Many small broker-dealers file FOCUS Report
Part IIA because they do not clear transactions or carry customer accounts. Part IIA is shorter
4

than Part II. The Commission does not believe any of the firms that file Part II are small firms
since they are clearing firms or firms that carry customer accounts. Even if small firms filed
FOCUS Report Part II, it would be inappropriate to provide these small firms with an exemption
from Rule 17a-5 because the FOCUS Report provides Commission and DEA staff with critical
financial information from the firms responsible for the safekeeping and disposition of customer
funds and securities.
6.

Consequences of Not Conducting Collection

The required reports are used by securities regulators to monitor the financial and
operational condition of broker-dealers. If the required reports were not made, the ability of the
Commission and the DEAs to monitor the financial and operational condition of broker-dealers
would be impaired, potentially affecting regulators’ capability to protect customers. Further, if
the required collections were conducted less frequently, the information in the reports would
become outdated.
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). 14
8.

Consultations Outside the Agency

The Commission requested comment on the collection of information requirements in the
proposing release in March 2023 (the “Proposing Release”). 15 Multiple commenters generally
agreed that the Inline XBRL requirements under the rule amendments will impose additional costs
on affected entities, but disagreed with the Commission’s estimates on the specific nature and
magnitude of such costs.16 The Commission considered these comments. The Commission
estimated at proposal, and continues to estimate for the rule amendments, that certain affected filers
or submitters (specifically, clearing agencies and exchanges not affiliated with public companies)
will incur costs of $20,000 to $30,000 to structure the documents, but that other affected filers or
submitters will incur lower costs. The Commission has, however, increased the burden and cost
estimates for Inline XBRL tagging of the relevant documents. In addition, the Commission
received comment asking to remove the requirement for the annual audit’s oath or affirmation to
be notarized. The Commission considered the comment and agreed that the notarization
requirement can be eliminated.

Rule 17a-5 does not include a recordkeeping or retention requirement in the text of the rule, but the
recordkeeping requirements in Rule 17a-3 (3235-0033) and the record preservation requirements in Rule
17a-4 (3235-0194) apply.
See Electronic Submission of Certain Materials Under the Securities Exchange Act of 1934; Amendments
Regarding the FOCUS Report; SEC Release Nos. 33-11176, 34-97182, IC-34864 (Mar. 22, 2023); 88 FR
23920 (Apr. 18, 2023) (File No. S7-08-23).
The comments on the proposing release are available at https://www.sec.gov/comments/s7-0823/s70823.htm.

Payment or Gift

No payment or gift is provided to respondents.
10.

Confidentiality

Reports filed pursuant to paragraph (a) of Rule 17a-5 are deemed to be confidential
pursuant to paragraph (a)(2) of Rule 17a-5. With respect to the other information collected under
Rule 17a-5, a broker-dealer can request the confidential treatment of the information. 17 If such a
confidential treatment request is made, the information will be treated as confidential to the
extent permitted by law. 18
Subject to the provisions of the Freedom of Information Act, 5 U.S.C. § 552, and the
Commission’s rules under that Act (17 CFR 200.80(b)(4)(iii)), the Commission generally does
not publish or make available information contained in reports, summaries, analyses, letters, or
memoranda arising out of, in anticipation of, or in connection with an examination or inspection
of the books and records of any person or any other investigation.
2025 Rule Amendments
In light of the requirement that the annual reports and related annual filings under Rules
17a-5 be filed electronically on EDGAR, the Commission is amending the confidentiality
provisions of the first sentence of paragraph (e)(3) of Rule 17a-5. The sentence contains
requirements that certain parts of the reports be “bound separately” and that certain pages be
“stamped confidential,” which do not apply to the process of designating portions of the annual
reports confidential when filing them electronically on EDGAR. The Commission is amending
the first sentence of paragraph (e)(3) of Rule 17a-5 to state that the annual reports “may be filed
as: (i) One public document; or (ii) Two documents: (A) A document consisting of the Statement
of Financial Condition, the notes to the Statement of Financial Condition, and the report of the
independent public accountant covering the Statement of Financial Condition, which is not
confidential; and (B) A document containing the balance of the annual reports for which
confidential treatment may be requested and which will be deemed confidential for the purposes
of section 24(b) of the Act.”
11.

Sensitive Questions

The information collection collects basic elements of Personally Identifiable Information
(“PII”) including name, job title, and work address that is covered by the EDGAR PIA. No
information of a sensitive nature, including social security numbers, will be required under this
collection of information. Additionally, the agency has determined that the information
collection does not constitute a system of records for purposes of the Privacy Act. Information is
not retrieved by a personal identifier.
17

See 17 CFR 200.83. Information regarding requests for confidential treatment of information submitted to
the Commission is available at http://www.sec.gov/foia/howfo2.htm#privacy.
See, e.g., 15 U.S.C. 78x (governing the public availability of information obtained by the Commission);
5 U.S.C. 552 et seq.

12.

Information Collection Burden

FOCUS Report Part II.: Broker-dealers that clear transactions or carry customer
accounts and broker-dealers registered as security-based swap dealers, other than OTC
derivatives dealers, and broker-dealers registered as major security-based swap participants are
generally required to file FOCUS Report Part II on a monthly or quarterly basis. 19 Commission
staff estimates that a FOCUS Report Part II takes approximately 12 hours to prepare and file.
(However, as discussed below, for certain broker-dealers, Part II elicits additional information
and requires additional time to prepare). For the year ended December 31, 2022, Part II filers
generally filed the Report monthly, and approximately 461 firms filed FOCUS Report Part II,
resulting in an annual industry-wide burden of approximately 66,384 hours per year. 20 This
estimate is based on Commission staff’s experience reviewing these filings and communicating
with broker-dealers regarding the reports.
For broker-dealers registered as security-based swap dealers or major security-based
swap participants, for certain ANC broker-dealers, and for stand-alone non-ANC broker-dealers
that engage in security-based swap activities, the FOCUS Report Part II elicits additional
information. For non-ANC broker-dealers registered as security-based swap dealers, the
Commission estimates that there is an additional burden of 240 hours per firm per year, and for
non-ANC firms registered as major security-based swap participants, the Commission estimates
that there is an additional burden of 204 hours per firm per year. For ANC broker-dealers
registered as security-based swap dealers, the Commission estimates that there is an additional
burden of 228 per firm per year. For stand-alone non-ANC broker-dealers that engage in
security-based swap activities, the Commission estimates that there is an additional burden of
120 hours per firm per year.
As of March 2023, there was one non-ANC broker-dealer that was registered as a
security-based swap dealer. There were no non-ANC broker-dealers registered as a major
security-based swap participant. However, the Commission will use one entity as its estimate,
since it is possible, over the course of three years, that a non-ANC broker-dealer may register as
a major security-based swap participant. As of March 2023, there were two ANC broker-dealers
registered as security-based swap dealers. As of March 2023, the Commission estimates that 25
stand-alone non-ANC broker-dealers engaged in security-based swap activities.
As a result, the additional annual reporting burden for the one non-ANC broker-dealer
registered as a security-based swap dealer is approximately 240 hours; 21 The additional burden
for one non-ANC broker-dealer registered as a major security-based swap participant is 204
hours; 22 the additional burden for the two ANC broker-dealers registered as security-based swap
dealers is approximately 456 hours; 23 and the additional burden for the 25 stand-alone non-ANC
broker-dealers engaged in security-based swap activities is approximately 3,000 hours. 24
19
20
21
22
23
24

See 17 CFR 240.17a-5(a)(2)(ii), (iv).
12 hours per response x 12 responses per year x 461 respondents = 66,384 hours.
240 x 1 = 240.
204 x 1 = 204.
228 x 2 = 456.
120 x 25 = 3,000.

Therefore, the total annual industry-wide burden attributable to Part II of the FOCUS
Report (paragraph (a)(1)(ii) of Rule 17a-5) is approximately 70,284 hours. 25
FOCUS Report Part IIA: Broker-dealers that do not clear transactions or carry
customer accounts and are not registered as security-based swap dealers or major security-based
swap participants are required to file FOCUS Report Part IIA on a quarterly or monthly basis. 26
Commission staff estimates that each FOCUS Report Part IIA takes approximately 12 hours to
prepare and file. For the 12 months ended December 31, 2022, approximately 2,089 firms filed
FOCUS Report Part IIA quarterly, resulting in an annual reporting burden of 100,272 hours, 27
and 958 firms filed Part IIA monthly, resulting in an annual reporting burden of 137,952
hours. 28
Therefore, the total annual industry-wide reporting burden associated with Part IIA of the
FOCUS Report is approximately 238,224 hours. 29
ANC Broker-Dealer Additional Reports: As explained above, paragraph (a)(5) of
Rule 17a-5 requires ANC broker-dealers to file additional monthly and quarterly reports with the
Commission, and paragraph (k) of Rule 17a-5 requires an ANC broker-dealers to file an annual
supplemental report with the Commission regarding its internal risk management controls. As of
March 2023, there were 5 ANC broker-dealers. The burden estimates are based on Commission
staff’s history and experience reviewing these filings and communicating with ANC brokerdealers regarding the reports.
ANC Additional Monthly Reports: The average amount of time necessary to prepare and
file the required supplemental monthly reports by each firm is estimated to be 4 hours per month.
As a result, each firm is estimated to have an annual reporting burden of 48 hours, 30 resulting in
an annual industry-wide burden of 240 hours. 31
ANC Additional Quarterly Reports: The average amount of time necessary to prepare
and file the required supplemental quarterly reports is estimated to be 8 hours per quarter. As a
result, each firm is estimated to have an annual reporting burden of 32 hours, 32 resulting in an
annual industry-wide burden of 160 hours. 33

26
27
28
29
30
31
32
33

66,384 + 240 hours x 1 respondent + 204 hours x 1 respondents + 228 hours x 2 respondents + 120 hours x
25 respondents = 70,284 hours per year. The Commission also estimated initial burdens of 50 hours, 35
hours, 25 hours, and 20 hours, respectively, for these additional requirements, but as there are no new firms
subject to the requirements since the last submission, there are no initial burdens.
See 17 CFR 240.17a-5(a)(1)(iii) and (iv).
2,089 respondents x 4 responses per year x 12 hours per response = 100,272 hours.
958 respondents x 12 responses per year x 12 hours per response = 137,952 hours.
100,272 hours + 137,952 hours = 238,224 hours per year.
4 hours x 12 responses per year = 48 hours per respondent.
48 hours per respondent x 5 respondents = 240 hours per year.
8 hours x 4 responses per year = 32 hours per respondent.
32 hours per respondent x 5 respondents = 160 hours per year.

ANC Supplemental Annual Reports: The Commission estimates that the average amount
of time necessary to prepare and file the required supplemental annual reports is approximately
40 hours per year. As a result, the annual industry-wide burden associated with this requirement
is approximately 200 hours. 34
Broker-Dealer Annual Reports: As stated above, paragraph (d) of Rule 17a-5 requires
most broker-dealers to file annual reports, including a financial report and either a compliance
report or an exemption report, as well as reports prepared by an independent public accountant
covering the financial report and the compliance report or exemption report. Part III of Form X17A-5 is the cover page for the annual reports. Approximately 3,218 broker-dealers filed annual
reports under paragraph (d) for the 12 months ended December 31, 2022. 35 The reporting
burden associated with Part III of Form X-17A-5 is estimated to be approximately 12 hours per
year, 36 resulting in an annual industry-wide burden of approximately 38,616 hours. 37
A broker-dealer that does not claim it was exempt from Rule 15c3-3 throughout the fiscal
year must file a compliance report with the Commission. As of December 31, 2022, there were
approximately 147 carrying broker-dealers that must comply with Rule 15c3-3 and therefore
must file a compliance report. The Commission estimates that it takes such a firm approximately
60 hours to prepare the financial report and the compliance report, resulting in an annual
industry-wide burden of approximately 8,820 hours. 38
A broker-dealer that claimed it was exempt from Rule 15c3-3 throughout the fiscal year
must file an exemption report with the Commission. As of December 31, 2022, approximately
3,071 broker-dealers filed exemption reports. The Commission estimates that it takes a brokerdealer claiming an exemption from Rule 15c3-3 approximately 7 hours to prepare its financial
report and exemption report, resulting in an annual industry-wide burden of approximately
21,497 hours. 39
Paragraph (d)(6) of Rule 17a-5 requires SIPC member broker-dealers to file a copy of the
annual reports with SIPC. According to SIPC’s 2021 annual report, there were approximately
3,404 SIPC members. The Commission estimates that it takes a broker-dealer approximately 30
minutes (or 0.5 hours) to file the annual reports with SIPC, resulting in an annual industry-wide
third-party reporting burden of approximately 1,702 hours. 40
SIPC Annual General Assessment Reconciliation Report or Exclusion from
Membership Forms: As stated above, paragraph (e)(4) of Rule 17a-5 requires broker-dealers to
file with SIPC a report on the SIPC annual general assessment reconciliation or exclusion from
membership forms. 41 Commission staff estimates that it takes a broker-dealer approximately 5
34
35
36
37
38
39
40
41

40 hours per respondent x 5 respondents = 200 hours per year.
This filing includes Form X-17A-5 Schedule I and Form X-17A-5 Part III.
12 hours x 1 response per year = 12 hours per respondent.
12 hours per respondent x 3,218 respondents = 38,616 hours per year.
60 hours per respondent x 147 respondents = 8,820 hours per year.
7 hours per respondent x 3,071respondents = 21,497 hours per year.
.5 hours per respondent x 3,404 respondents = 1,702 hours per year.
See 17 CFR 240.17a-5(e)(4).

hours to file these forms with SIPC. As stated above, according to SIPC’s 2021 annual report,
there were approximately 3,404 SIPC members, resulting in an estimated annual industry-wide
burden of approximately 17,020 hours. 42
Statement Regarding Independent Public Accountant: Paragraph (f)(2) of Rule 17a-5
requires broker-dealers to prepare a statement providing information regarding the brokerdealer’s independent public accountant and to file it each year with the Commission and its
DEA, except that if the engagement is of a continuing nature, no further filing is required. 43
The Commission estimates that it received approximately 168 statements regarding the
independent public accountant during 2022. It further estimates that 8 of these statements were
from carrying or clearing broker-dealers, and 160 of these statements were from broker-dealers
that neither carry customer accounts nor clear transactions. The Commission estimates that it
takes a carrying or clearing broker-dealer approximately 10 hours, and a broker-dealer that
neither carries customer accounts nor clears transactions approximately 2 hours, to file the
statement regarding the independent public accountant with the Commission, resulting in an
annual burden of approximately 80 hours 44 for non-carrying, non-clearing broker-dealers and for
carrying and clearing firms approximately 320 hours. 45
Notice of Replacement of Accountant: Paragraph (f)(3) of Rule 17a-5 requires a
broker-dealer to file a notice with the Commission if it replaces the independent public
accountant engaged to prepare reports covering the annual reports. 46 The estimated ongoing
burden that may occur once over a three year period associated with this requirement is
approximately 2 hours, or approximately 0.67 hours on an annualized basis. 47 The Commission
estimates that it received approximately 435 of these notices for calendar year 2022, resulting in
a burden of approximately 291 hours on an annualized basis. 48
Change of Fiscal Year: As stated above, under paragraph (n) of Rule 17a-5, a brokerdealer must notify the Commission if it changes its fiscal year. Based on staff experience, the
Commission estimates that 75 broker-dealers will change their fiscal year each year. The
Commission estimates that it takes a broker-dealer approximately 10 minutes to provide this
notice to the Commission. As a result, each firm is estimated to have an annual reporting burden
of approximately 0.167 hours, 49 resulting in an annual industry-wide burden of approximately
13 hours. 50
2025 Rule Amendments
42
43

44
45
46
47
48
49
50

5 hours x 3,404 broker-dealers = 17,020 hours.
See 17 CFR 240.17a-5(f)(2). For most broker-dealers, the engagement with their independent public
accountant is of a continuing nature, and in that case, an annual filing is not required.
10 hours per respondent x 8 respondents = 80 hours per year.
2 hours per response x 160 respondents = 320 hours.
See 17 CFR 240.17a-5(f)(3).
2 hours / 3 years = 0.67 hours per respondent per year.
0.67 hours per year x 435 respondents = 291 hours per year.
10 minutes / 60 minutes = 0.1667 hours.
0.167 hours per respondent x 75 respondents = 13 hours (rounded up from 12.75).

2025 Amendment to Require Filing Annual Audit on EDGAR – Initial Burden: The
Commission is requiring broker-dealers to file the annual audited report and supporting
schedules on EDGAR. The Commission estimates that the one-time burden for a firm to
familiarize itself with EDGAR would be approximately 16 hours. The Commission estimates
that approximate 1,498 broker-dealers were not already filing their annual audit on EDGAR as of
December 31, 2023, resulting in a one-time industry-wide burden of 23,968 hours, 51 or 7,989 on
an annualized basis. 52
2025 Amendment to Require Filing Annual Audit in Inline XBRL – Initial Burden:
The Commission is requiring broker-dealers to file the annual audited report and supporting
schedules on EDGAR in Inline XBRL. On average, respondents are estimated to incur 7 burden
hours for the first response to be tagged in Inline XBRL. The Commission estimates that there
were approximately 3,267 broker-dealers as of December 31, 2023, resulting in an industry-wide
initial internal burden of 22,869 hours, 53 or 7,623 hours on an annualized basis. 54
2025 Amendment to Require Filing Annual Audit in Inline XBRL – Ongoing
Burden: The Commission is requiring broker-dealers to file the annual audited report and
supporting schedules on EDGAR in Inline XBRL. On average, respondents are estimated to
incur an ongoing burden of 4.5 hours to tag responses in Inline XBRL. There were
approximately 3,267 broker-dealers as of December 31, 2023, resulting in an industry-wide
ongoing annual industry-wide ongoing internal burden of 14,702 hours. 55
2025 Corrective and Clarifying Amendments to FOCUS Report Part II – Initial
Burden: The Commission is making corrective and clarifying amendments to FOCUS Report
Part II. The Commission estimates that the amendments will result in an initial burden of 5
hours on each respondent so firms can familiarize themselves with the amendments to FOCUS
Report Part II. As of December 31, 2023, approximately 466 broker-dealers filed FOCUS
Report Part II, resulting in an industry-wide initial burden of 2,330 hours, 56 or 777 hours on an
annualized basis. 57 The Commission believes that these amendments will either have no ongoing
burden on or reduce the ongoing burden because they will reduce questions about where and
how to report items on the form.
2025 Corrective and Clarifying Amendments to FOCUS Report Part IIA – Initial
Burden: The Commission is making technical corrections to FOCUS Report Part IIA to replace
an incorrect cross-reference and correctly conform the FOCUS Report Part IIA to paragraph (d)
of Rule 15c3-1. As technical corrections, these changes were not proposed in the Proposing
Release, but are estimated to have no ongoing burden or reduce the ongoing burden because they
will reduce questions about where and how to report items on the form. Nevertheless, the
51
52
53
54
55
56
57

1,498 respondents x 16 hours = 23,968 hours.
23,968 hours / 3 years = 7,989.33 hours.
3,267 respondents x 7 hours = 22,869 hours.
22,869 hours / 3 years = 7,623 hours.
3,267 respondents x 4.5 hours = 14,701.5 hours.
466 respondents x 5 hours = 2,330 hours.
2,330 hours / 3 years = 776.67 hours.

Commission estimates that the amendments will result in an initial burden of 5 hours on each
respondent so firms can familiarize themselves with the amendments to FOCUS Report Part IIA.
As of December 31, 2023, there were approximately 2,946 broker-dealers filing FOCUS Report
Part IIA, resulting in an industry-wide initial burden of 14,730 hours, 58 or 4910 hours on an
annualized basis. 59
2025 Amendments to FOCUS Report Signature Requirement – Initial Burden: The
Commission is amending the instructions to the FOCUS Report to allow only one named
officer’s signature when the signature belongs to the firm’s principal executive officer or
principal financial officer (or their comparable officers). Signatories on Rule 17a-5 filings may
choose between providing either manual or electronic signatures. This amendment is expected to
result in an initial burden of 1 hour on each filer so that the firm can review the standards for an
electronic signature on the FOCUS Report Part II or IIA, as applicable. The Commission
estimates that there were approximately 3,412 broker-dealers filing FOCUS Report Parts II or
IIA as of December 31, 2023, resulting in an estimated industry-wide initial burden of 3,412
hours, 60 or 1,137 hours on an annualized basis. 61 However, this amendment is expected to either
have no impact on or reduce the ongoing burden on FOCUS Report filers, because they will not
be required to furnish as many signatures as before the amendment, and it may be easier to
prepare electronic signatures rather than manual signatures since firms will already be familiar
with the process and can easily obtain these signatures while working remotely. The
Commission estimates that the amendments will not change the estimated ongoing annual burden
imposed by FOCUS Report Parts II and IIA.
2025 Amendments to CFTC Capital Computation Section of FOCUS Report Part II
– Ongoing Burden: The amendments require stand-alone swap dealers and stand-alone
introducing brokers to complete a new section of FOCUS Report Part II that these types of firms
were not previously required to complete (i.e., Computation of CFTC Minimum Capital
Requirements). Although both the amendment and the associated burden were discussed in the
Proposing Release, it was inadvertently left out of the proposed revision submitted to OMB on
May 31, 2023. The Commission estimates that the amendments would result in an ongoing
annual burden of 1 hour per stand-alone swap dealer or stand-alone introducing broker. The
Commission estimates that, as of December 31, 2023, there were 4 domestic stand-alone swap
dealers and 67 domestic stand-alone introducing brokers filing FOCUS Report Part II under Rule
17a-5, resulting in an estimated industry-wide ongoing burden of 71 hours per year. 62
2025 Amendment to Remove Oath or Affirmation Notarization Requirement –
Initial Burden: The Commission is amending Part III of Form X-17A-5 (i.e., the annual audit’s
cover page) to remove the signature line for the notary public. The Commission received
comment asking us to remove the requirement for the annual audit’s oath or affirmation to be
notarized. The Commission considered the comment and agreed that the notarization
58
59
60
61
62

2,946 respondents x 5 hours = 14,730 hours.
14,730 hours / 3 years = 4910 hours.
1 hour x 3,412 Part II or Part IIA filers under Rule 17a-5 = 3,412 hours.
3,412 hours / 3 years = 1,137.33 hours.
1 hour x 71 Part II filers that are domestic stand-alone swap dealers or stand-alone introducing brokers = 71
hours.

requirement can be eliminated. This amendment is expected to generally either have no impact
on or reduce the ongoing burden on the filers because they will no longer need to obtain
notarization of the annual reports. Nevertheless, the Commission estimates that the amendment
will result in an initial burden of five hours on each firm required to file annual reports and
related annual filings under Rule 17a-5 so firms can familiarize themselves with the change. The
Commission estimates that there were approximately 3,267 broker-dealer filing annual reports as
of December 31, 2023, resulting in an estimated industry-wide initial burden of 16,335 hours, 63
or 5,445 hours on an annualized basis. 64
Total Industry-Wide Burden: The Commission therefore estimates that the total
industry-wide burden associated with Rule 17a-5 is approximately 440,121 hours per year. The
burden is summarized in the table below.
Summary of Hourly Burdens
A.
Name of Information Collection

Type of
Burden

Number of
Entities
Impacted

Annual
Responses
per Entity

Initial
Burden per
Entity per
Response

D.
E.
Initial
Ongoing
Burden
Burden per
Annualized
Entity per
per Entity
Response
per Response
[C ÷ 3 years]

Annual
Burden Per
Entity per
Response

Total Annual
Burden Per
Entity

Total Industry
Burden

[ D + E]

[F * B]

[G * A]

Small
Business
Entities
Affected

FOCUS Report Part II: NonModel Clearing Broker-Dealers

Reporting

461

0.00

12.00

144.00

66,384

FOCUS Report Part II: NonModel Broker-Dealer SBSDs

Reporting

0.00

20.00

240

Reporting

0.00

17.00

204

Reporting

0.00

19.00

228

456

Reporting

0.00

10.00

120

3,000

Reporting

2,089

0.00

12.00

48.00

100,272

895

Reporting

958

0.00

12.00

144.00

137,952

895

ANC Supplemental Monthly
Reports

Reporting

0.00

4.00

48.00

240

ANC Supplemental Quarterly
Reports

Reporting

0.00

8.00

32.00

160

ANC Supplemental Annual
Reports

Reporting

0.00

40.00

200

Annual Audited Reports

Reporting

3,218

0.00

12.00

38,616

895

Compliance Report

Reporting

147

0.00

60.00

8,820

Exemption Report

Reporting

3,071

0.00

7.00

21,497

895

SIPC Annual Reports

Third-Party
Disclosure

3,404

0.00

0.50

1,702

895

FOCUS Report Part II: NonModel Broker-Dealer MSBSPs
FOCUS Report Part II: ANC
Broker-Dealer SBSDs
FOCUS Report Part II: NonModel Stand-alone BrokerDealers with SBS Activities
FOCUS Report Part IIA: NonModel Non-Clearing BrokerDealers-Quarterly
FOCUS Report Part IIA: NonModel Non-Clearing BrokerDealers-Monthly

63
64

3,267 broker-dealers x 5 hours = 16,335 hours.
16,335 hours / 3 years = 5,445 hours.

Summary of Hourly Burdens
A.
Name of Information Collection

Type of
Burden

Number of
Entities
Impacted

Annual
Responses
per Entity

Initial
Burden per
Entity per
Response

D.
E.
Initial
Ongoing
Burden
Burden per
Annualized
Entity per
per Entity
Response
per Response
[C ÷ 3 years]

Annual
Burden Per
Entity per
Response

Total Annual
Burden Per
Entity

Total Industry
Burden

[ D + E]

[F * B]

[G * A]

Small
Business
Entities
Affected

Annual General Assessment
Reconciliation or Exclusion
from Membership Forms

Third-Party
Disclosure

3,404

0.00

5.00

17,020

895

Statement Regarding
Independent Public Accountant
- Carrying or Clearing BrokerDealer

Reporting

0.00

10.00

Statement Regarding
Independent Public Accountant
- Non-Carrying, Non-Clearing
Broker-Dealer

Reporting

160

0.00

2.00

320

112

Notice of Replacement of
Accountant

Reporting

435

0.00

0.007

2.00

0.67

291

Notice of Change of Fiscal Year
End

Reporting

0.00

0.17

Reporting

1,498

16.00

5.33

0.00

5.33

7,989

723

Reporting

3,267

7.00

2.33

0.00

2.33

7,623

723

Reporting

3,267

0.00

4.50

14,702

723

Reporting

466

5.00

1.67

0.00

1.67

777

Reporting

2,946

5.00

1.67

0.00

1.67

4,910

723

Reporting

3,412

1.00

0.33

0.00

0.33

1,137

723

Reporting

0.00

0.25

1.00

Reporting

3,267

5.00

1.67

0.00

1.67

5,445

723

2025 Amendments to Require
Filing Annual Audit on EDGAR
– Initial Burden
2025 Amendments to Require
Filing Annual Audit in Inline
XBRL – Initial Burden
2025 Amendments to Require
Filing Annual Audit in Inline
XBRL – Ongoing Burden
2025 Corrective and Clarifying
Amendments to FOCUS Report
Part II – Initial Burden
2025 Corrective and Clarifying
Amendments to FOCUS Report
Part IIA – Initial Burden
2025 Amendments to FOCUS
Report Signature Requirement –
Initial Burden
2025 Amendments to CFTC
Capital Computation Section of
FOCUS Report Part II –
Ongoing Burden
2025 Amendments to Remove
Oath or Affirmation
Notarization Requirement –
Initial Burden

TOTAL HOUR BURDEN

13.

440,121

Costs to Respondents

Those requirements that are expected to impose a cost burden to respondents are
discussed below.
ANC Supplemental Reports: Paragraph (a)(5) and paragraph (k) of Rule 17a-5 impose
monthly, quarterly, and annual reporting requirements on ANC broker-dealers. The Commission
14

receives these reports via email, EDGAR (annual reports) or firm-specific systems, and therefore
there are no postage costs associated with the requirements.
Annual Reports: Prior to the 2025 amendments, annual reports under paragraph (d) of
Rule 17a-5 may be filed with the Commission in paper or electronically on EDGAR. The 2025
amendments require broker-dealers to file the annual audited report and supporting schedules on
EDGAR. The annual reports must also be filed with the broker-dealer’s DEA and with SIPC if
the broker-dealer is a member of SIPC. Broker-dealers currently generally file the annual reports
with their DEA and with SIPC electronically. The Commission previously estimated an annual
industry-wide cost of approximately $31,022 in postage costs to mail the annual reports to the
Commission. Rule 17a-5 has been amended to require these reports to be filed electronically.
Under the rule amendments, broker-dealers will no longer incur these costs.
A broker-dealer that does not claim it was exempt from Rule 15c3-3 throughout the most
recent fiscal year must file a compliance report with the Commission with its annual reports as
well as an accountant’s reports based on examinations of its financial report and compliance
report. For the year ended December 31, 2022, the Commission estimates that approximately
147 broker-dealers filed compliance reports. The Commission estimates that the cost associated
with the independent public accountant’s examinations of the firm’s financial report and
compliance report will be, on average, approximately $150,000 per broker-dealer per year,
resulting in an industry-wide annual reporting cost of approximately $22,050,000. 65
A broker-dealer that claims it was exempt from Rule 15c3-3 throughout the most recent
fiscal year must file an exemption report with the Commission with its annual reports as well as
an accountant’s reports based on an examination of its financial report and a review of its
exemption report. For the year ended December 31, 2022, the Commission estimates that
approximately 3,071 broker-dealers filed exemption reports. The Commission estimates that the
cost associated with the independent public accountant’s examination of the firm’s financial
report and review of the exemption report will be, on average, approximately $3,000 per brokerdealer per year, resulting in an industry-wide annual reporting cost of approximately
$9,213,000. 66
SIPC Annual General Assessment Reconciliation Report or Exclusion from
Membership Form: Under paragraph (e)(4) of Rule 17a-5, broker-dealers must file with SIPC
a report on the SIPC annual general assessment reconciliation or exclusion from membership
forms. These items may be filed with SIPC either by mail or via email. The Commission
estimates that postage costs to send these items by mail would impose an annual cost of 53 cents
per firm. The Commission estimates that each year, 3,404 firms will file with SIPC a report on
the SIPC annual general assessment reconciliation or exclusion from membership form and that
approximately half of these will be filed in paper, for a total annual industry-wide cost of
approximately $902. 67
65
66
67

$150,000 per year x 147 carrying broker-dealers = $22,050,000.
$3,000 per year x 3,071 non-carrying broker-dealers = $9,213,000.
3,404 respondents / 2 = 1,702 paper filers. $0.53 per year x 1,702 paper filers = $902 per year (rounded
down from $902.06). The costs of paper filing incurred by 1,702 respondents, totaling $902 was averaged
over the entire group of 3,404 respondents, which resulted in an annual cost of $0.265 per respondent.

SIPC Annual Reports: The Commission estimates $0 cost burden for the 3,404 brokerdealers that are members of SIPC to comply with paragraph (d)(6) of Rule 17a-5, because these
firms file the annual reports with SIPC electronically. 68
Statement Regarding Independent Public Accountant and Notice of Replacement of
Accountant: These statements and notices must be filed with the Commission at its principal
office in Washington, DC; the Commission’s office for the region in which the broker-dealer’s
principal place of business is located; and the principal office of the broker-dealer’s
DEA. Broker-dealers file these items with their DEA electronically, and they may send them to
the Commission either in paper or electronically. The Commission estimates that postage costs
to comply with paragraphs (f)(2) and (f)(3) of Rule 17a-5 impose an annual dollar cost of 53
cents per response for those that are filed in paper. The Commission estimates that there are
603 69 responses, and that approximately 160 of them are filed in paper. Further, the Commission
estimates that approximately half of the paper filings (or a total of 80) are statements regarding
the independent public accountant (of which 8 are submitted by clearing or carrying brokerdealers and 72 are submitted by non-clearing and non-carrying broker-dealers). The
Commission also estimates that the remaining paper filings, approximately 80, are notices of the
replacement of the accountant. This results in $4 for 8 paper statements, $38 for 72 paper
statements, and $42 for 80 paper notices, for an annual industry-wide cost of approximately
$84. 70
Notice of Change of Fiscal Year End: The Commission estimates that postage costs to
comply with the requirement to notify the Commission when a firm changes its fiscal year
impose a cost of 53 cents per firm that sends the notice in paper. The Commission estimates that
75 firms send the notice in paper each year, resulting in an annual estimated industry-wide cost
of $40. 71
2025 Amendment to Require Filing Annual Audit in Inline XBRL – Initial Burden:
The Commission is requiring broker-dealers to file the annual audited report and supporting
schedules in Inline XBRL. On average, respondents are estimated to incur $1,600 in external
cost for the first response to be tagged in Inline XBRL. There are 3,267 broker-dealers, resulting

68
69

3,404 respondents x $0.53 per year = $1,804 (rounded down from $1,804.12).
The total number of respondents filing statements regarding independent public accountant and filing
notices of replacement of public accountant totals: 8 +160 + 435 = 603 respondents.
$0.53 per response x 8 paper filings (Statement regarding Independent Public Accountant,
Carrying/Clearing firm) = $4 (rounded down from $4.24); $0.53 per response x 72 paper filings (Statement
regarding Independent Public Accountant, Non-Carrying/Non-Clearing firm) = $38 (rounded down from
$38.16); $0.53 x 80 paper filings (Notice of Replacement of Public Accountant) = $42 (rounded down from
$42.4). Total annual industry cost for all paper filings of statements and notices: $4 + $38+ $42 = $84.
The cost of paper filings for Statement regarding Independent Public Accountant, Non-Carrying/NonClearing firm) of $38 was averaged over all 160 respondents (for annual cost per respondent of $0.24) and
the cost of paper filings for the Notice of Replacement of Public Accountant of $42 was averaged over 435
respondents (for annual cost per respondent of $0.097).
$0.53 per year x 75 broker-dealers = $40 (rounded up from $39.75).

in a total initial industry-wide external cost of $5,227,200, 72 or $1,742,400 on an annualized
basis. 73
2025 Amendment to Require Filing Annual Audit in Inline XBRL – Ongoing
Burden: The Commission is requiring broker-dealers to file the annual audited report and
supporting schedules in Inline XBRL. On average, respondents are estimated to incur $1,000 in
external cost to tag responses in Inline XBRL on an ongoing basis. There are 3,267 brokerdealers, resulting in a total ongoing annual industry-wide internal burden of $3,267,000. 74
Total Industry Cost Burden: Therefore, the total industry-wide dollar cost burden
associated with Rule 17a-5 is estimated to be $36,273,426. The burden is summarized in the
table below.
Summary of Dollar Costs
A.
Name of Information
Collection

Type of
Burden

Number
of
Entities
Impacted

B.
Annual
Responses
per Entity

Initial
Cost per
Entity per
Response

Initial Cost
Annualized
per Entity
per
Response

Ongoing
Cost per
Entity per
Response

Annual
Cost Per
Entity per
Response

Total
Annual
Cost Per
Entity

Total Industry Cost

[ D + E]

[F * B]

[G * A]

[C ÷ 3
years]

Small
Business
Entities
Affected

ANC Supplemental
Monthly Reports

Reporting

ANC Supplemental
Quarterly Reports

Reporting

ANC Supplemental
Annual Reports

Reporting

Rule 17a-5(d)(3):
Compliance Report

Reporting

147

$150,000.00

$22,050,000

Rule 17a-5(d)(4):
Exemption Report

Reporting

3,071

$3,000.00

$9,213,000

895

SIPC Annual Reports

Third-Party
Disclosure

3,404

$0.

$$0

895

Third-Party
Disclosure

1,702

$0.53

$902

895

Reporting

$0.53

Reporting

$0.53

$38

Notice of Replacement
of Accountant

Reporting

$0.53

$42

Notice of Change in
Fiscal Year

Reporting

$0.53

$40

Reporting

3,267

$1,600.00

$533.33

$0.00

$$533.33

$533.33

$1,742,400.00

723

Reporting

3,267

$0.00

$1,000.00

$3,267,000.00

723

SIPC Annual General
Assessment
Reconciliation Report
or Exclusion from
Membership Forms
Statement Regarding
Independent Public
Accountant Carrying or
Clearing Broker-Dealer
Statement Regarding
Independent Public
Accountant – NonCarrying, NonClearing Broker-Dealer

2025 Amendment
to Require Filing
Annual Audit in
Inline XBRL –
Initial Burden
2025 Amendment
to Require Filing
Annual Audit in
Inline XBRL –
Ongoing burden

72
73
74

3,267 respondents x $1,600 = $5,227,200.
$5,227,200 / 3 years = $1,742,400.
3,267 respondents x $1,000 = $3,267,000.

TOTAL COST

14.

$$36,273,426

Costs to Federal Government

Rule 17a-5 is not expected to result in costs to the federal government due to contracting,
information technology, development, hiring one or more new employees, or reallocating
existing employees.
15.

Changes in Burden

The most recent hour burden, approved as part of a routine extension on November 29,
2023, was 397,467 hours. This current submission requests approval for information collections
in the Commission’s 2025 rulemaking. The Commission previously submitted a proposed
revision in connection for the rule amendments which were reviewed by OMB on July 25, 2023.
The current burden of 440,121 hours represents an increase of approximately 42,654 hours. The
increase in burden is due to the revisions in the 2025 rule amendments. The changes in burdens
that were approved by OMB in the November 2023 routine extension are not affected by the rule
amendments are not being changed in this supporting statement.
The most recent cost burden, approved on November 29, 2023, was $31,295,048. The
current burden of $36,273,426 represents an increase of $4,978,378. The increase in cost burden
is due to new costs imposed by the 2025 rule amendments. Cost burdens previously approved on
November 29, 2023, that are not affected by the rule amendments are not being changed in this
supporting statement.
We note that this revision includes three new information collections that were not in the
proposed revision reviewed by OMB on July 25, 2023: (1) 2025 Corrective and Clarifying
Amendments to FOCUS Report Part IIA – Initial Burden; (2) 2025 Amendments to CFTC
Capital Computation Section of FOCUS Report Part II – Ongoing Burden; and (3) 2025
Amendments to Remove Oath or Affirmation Notarization Requirement – Initial Burden. As
explained above, two of these items are expected to either have no ongoing burden or reduce the
ongoing burden; however, the Commission is estimating some initial burdens for firms to
become familiar with these changes. The amendments related to CFTC Capital Computation
Section of FOCUS Report Part II was inadvertently left out of the May 31, 2023 supporting
statement.
In addition, some of the burdens have changed since the 2023 proposal since the
Commission has, after considering public comments, increased the burden and cost estimates for
Inline XBRL tagging of the relevant documents.
The changes in hour and cost burdens are summarized in the table below.

Name of Information
Collection

Prior Annual
Industry
Burden/Cost

Revised Annual
Industry
Burden/Cost

Change in
Burden/Cost

Reason for Change

2025 Amendments to Require
Filing Annual Audit on EDGAR –
Initial Burden
2025 Amendments to Require
Filing Annual Audit in Inline
XBRL – Initial Burden
2025 Amendments to Require
Filing Annual Audit in Inline
XBRL – Ongoing Burden
2025 Corrective and Clarifying
Amendments to FOCUS Report
Part II – Initial Burden
2025 Corrective and Clarifying
Amendments to FOCUS Report
Part IIA – Initial Burden
2025 Amendments to FOCUS
Report Signature Requirement –
Initial Burden
2025 Amendments to CFTC
Capital Computation Section of
FOCUS Report Part II – Ongoing
Burden
2025 Amendments to Remove
Oath or Affirmation Notarization
Requirement – Initial Burden
Cost of Mailing Annual Reports
2025 Amendment to Require
Filing Annual Audit in Inline
XBRL – Initial Burden
2025 Amendment to Require
Filing Annual Audit in Inline
XBRL – Ongoing burden

16.

7,989