Proposed Rule 17a-4(b)(17)

The Commission recently adopted amendments to Rules 101 and 102 of Regulation M that remove the Investment Grade Exceptions and add, in their place, new exceptions for Nonconvertible Securities. Certain provisions of the final amendments contain “collection of information” requirements, which were submitted to OMB in a revision to 3235-0464. In addition, and to facilitate Commission examinations of broker-dealers who rely on the new exception in Rule 101 or Rule 102 of Regulation M, the Commission adopted a new paragraph (17) of Rule 17a-4(b) that requires broker-dealers to preserve the written probability of default determination relied upon pursuant to Rule 101(c)(2)(i) or Rule 102(d)(2)(i), as applicable. The new collection of information in Rule 17a-4(b)(17) is in this control number 3235-0806.

The latest form for Proposed Rule 17a-4(b)(17) expires 2026-10-31 and can be found here.

Preserving the written probability of default calculation (Rule 17a-4)-Initial

Federal Enterprise Architecture: Economic Development - Financial Sector Oversight