Rule 15c3-4; Internal Risk Management Control Systems.

Forms and Documents

Document Name	Status
2009 Rule 15c3-4 justification.DOC Supporting Statement A	2009-11-02

IC Document Collections

IC ID	Document Title	Status
43025	Rule 15c3-4; Internal Risk Management Control Systems.	Modified

ICR Details

OMB Control No: 3235-0497	ICR Reference No: 200911-3235-001
Status: Historical Active	Previous ICR Reference No: 200610-3235-004
Agency/Subagency: SEC	Agency Tracking No: TM-270-441
Title: Rule 15c3-4; Internal Risk Management Control Systems.
Type of Information Collection: Extension without change of a currently approved collection	Common Form ICR:  No
Type of Review Request: Regular
OIRA Conclusion Action: Approved without change	Conclusion Date: 03/23/2010
	Date Received in OIRA: 01/13/2010
Terms of Clearance:

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	03/31/2013	36 Months From Approved	03/31/2010
Responses	5	0	6
Time Burden (Hours)	1,567	0	1,200
Cost Burden (Dollars)	404,200	0	136,698

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Abstract: Rule 15c3-4 requires OTC derivatives dealers to establish and document a risk management control system. In addition, the Rule establishes basic principles and minimum standards governing the creation, execution, and review of a firm's risk management control system. These principles and standards are designed to ensure the integrity of the risk measurement, monitoring, and management process.

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Authorizing Statute(s): US Code: 15 USC 78o Name of Law: Securities Exchange Act of 1934
  

Citations for New Statutory Requirements: None

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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:
	74 FR 54860	10/23/2009
30-day Notice:	Federal Register Citation:	Citation Date:
	75 FR 1002	01/07/2010
Did the Agency receive public comments on this ICR? No

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Number of Information Collection (IC) in this ICR: 1

IC Title	Form No.	Form Name
Rule 15c3-4; Internal Risk Management Control Systems.

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ICR Summary 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	5	6	0	0	-1	0
Annual Time Burden (Hours)	1,567	1,200	0	0	367	0
Annual Cost Burden (Dollars)	404,200	136,698	0	0	267,502	0

Burden increases because of Program Change due to Agency Discretion: No

Burden Increase Due to:

Burden decreases because of Program Change due to Agency Discretion: No

Burden Reduction Due to:

Short Statement: The number of respondents decreased by one, from six OTC derivatives dealers to five. The Commission also has adjusted the cost, based on updated salary information, from $205 per hour to $285 per hour. Finally, this PRA includes in the Total Annualized Cost Burden the costs associated with the burden to maintain the system incurred by registered OTC derivatives dealers. While the last PRA did estimate the burden hours associated with the annual maintenance of an OTC derivatives dealer's risk management control system, it did not include that estimate when calculating the Total Annualized Cost Burden (instead only the burden relative to the establishing and documenting the risk management control system were included in the cost estimate.

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Annual Cost to Federal Government: $24,000

Does this IC contain surveys, censuses, or employ statistical methods? No

Is the Supporting Statement intended to be a Privacy Impact Assessment required by the E-Government Act of 2002? No

Is this ICR related to the Affordable Care Act [Pub. L. 111-148 & 111-152]? Uncollected

Is this ICR related to the Dodd-Frank Wall Street Reform and Consumer Protection Act, [Pub. L. 111-203]? Uncollected

Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)? No

Is this ICR related to the Pandemic Response? Uncollected

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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: 01/13/2010

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