Proposed Rule 17i-5 would require that an SIBHC create and maintain certain records for at least three years. An SIBHC is required to make and keep records reflecting (i) the results of quarterly stress tests; (ii) that the firm had created a contingency plan to respond to certain possible funding and liquidity difficulties; and (iii) the basis for credit risk weights. Further, Rule 17i-5 requires that an SIBHC maintain these and other records for at least three years in an easily accessible place. On average, an SIBHC will spend approximately 64 hours each quarter to create a record regarding stress tests, or approximately 256 hours each year. In addition, an SIBHC will generally spend about 40 hours to create and document a contingency plan regarding funding and liquidity of the affiliate group. Further, an SIBHC will establish approximately 20 new counterparty arrangements each year, and will take, on average, about 30 minutes to create a record regarding the basis for credit risk weights for each such counterparty. Finally, an SIBHC will generally require about 24 hours per year to maintain the specified records.
Consequently, the total burden relating to Rule 17i-5 is approximately 330 hours in the first year and approximately and 290 hours each year thereafter for each SIBHC, and approximately 990 hours in the first year and 870 hours each year thereafter for all three SIBHCs combined.
We estimate that it would cost each SIBHC about $10,520 to document a contingency plan regarding funding and liquidity of the affiliate group. We estimate that an SIBHC would incur an annual cost of about $104,192 to create a record regarding stress tests as required by Rule 17i-5. Further, we estimate that, on average, an SIBHC would incur an annual cost of approximately $1,620 to create a record regarding the basis for credit risk weights. Further, we estimate that, on average, an SIBHC would incur an annual cost of $6,264 to maintain records pursuant to Rule 17i-5. Thus, we estimate that the total dollar cost of the one-time and ongoing paperwork burden associated with Rule 17i-5 for all SIBHCs would be approximately $367,788.
13. Estimate of Total Annualized Cost Burden
The information technology (IT) systems used by IBHCs to manage risk, make and retain records and reports, and calculate capital differ widely based on the types of business and the size of the IBHC. We believe that an IBHC will upgrade its IT systems with relation to four of the SIBHC framework Rules: Rule 17i-4 (requires an SIBHC to document its internal risk management control systems), Rule 17i-5 (requires an SIBHC to create and maintain records), Rule 17i-6 (requires an SIBHC to create and make reports to the Commission), and Rule 17i-7 (requires that an SIBHC compute allowable capital and allowances for market, credit, and operational risk). It is impossible to determine what percentage of these IT systems costs may be attributable to any particular SIBHC framework Rule, so we will allocate them equally (i.e., 25% of the total cost to each of these four Rules). We believe the costs to upgrade IT systems would be one-time costs.
These IBHCs IT systems may be in varying stages of readiness to meet the requirements of the rules. The staff estimated, when these rules were proposed, that it would cost an IBHC between $1 million and $10 million to upgrade its IT systems to comply with the SIBHC framework of rules, depending on the state of development of its IT systems. We believe this estimate to be fairly sound because no commenter disagreed with it. Thus, on average, it would cost each of the three SIBHCs about $5.5 million to upgrade their IT systems, or approximately $16.5 million in total. As described above, we allocate approximately 25% of this cost, or $4,125,000, as attributable to Rule 17i-5.
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:
(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;
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.
Rule 17i-5 SuppState.doc
Rule 17i-5 (17 CFR 240.17i-5): Record Creation, Maintenance, and Access Requirements for Supervised Investment Bank Holding Companies.