Rule 17g-5 Conflicts of Interest

Forms and Documents

Document Name	Status
Rule 17g-5 Supporting Statement.pdf Supporting Statement A	2015-05-18

IC Document Collections

IC ID	Document Title	Status
213119	NRSRO exemption request	Modified
213118	NRSRO conflict policies update	Unchanged
213116	Arranger form upload	Modified
213115	NRSRO template redrafting	Unchanged
213114	Arranger ongoing disclosure	Unchanged
202290	Annual Certification	Unchanged
202289	Arranger transaction disclosures	Unchanged
202288	Arranger disclosure systems	Unchanged
188139	NRSRO structured finance ratings disclosure	Modified

ICR Details

OMB Control No: 3235-0649	ICR Reference No: 201411-3235-006
Status: Historical Active	Previous ICR Reference No: 201409-3235-019
Agency/Subagency: SEC	Agency Tracking No: OCR-270-581
Title: Rule 17g-5 Conflicts of Interest
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: 10/22/2015
	Date Received in OIRA: 05/21/2015
Terms of Clearance:

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	10/31/2018	36 Months From Approved	10/31/2015
Responses	3,620	0	3,620
Time Burden (Hours)	278,051	0	278,052
Cost Burden (Dollars)	67,000	0	67,000

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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 managemnt 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 by addressing potential practices that could impair the objectivity and the quality of a credit rating.

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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

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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:
	80 FR 15039	03/20/2015
30-day Notice:	Federal Register Citation:	Citation Date:
	80 FR 29376	05/21/2015
Did the Agency receive public comments on this ICR? No

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Number of Information Collection (IC) in this ICR: 9

IC Title	Form No.	Form Name
NRSRO structured finance ratings disclosure
Arranger disclosure systems
Arranger transaction disclosures
NRSRO template redrafting
Arranger form upload
NRSRO conflict policies update
Arranger ongoing disclosure
NRSRO exemption request
Annual Certification

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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	3,620	3,620	0	0	0	0
Annual Time Burden (Hours)	278,051	278,052	0	0	-1	0
Annual Cost Burden (Dollars)	67,000	67,000	0	0	0	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 industry-wide change in burden resulting from updated estimates is approximately: a decrease of 12,444 hours in the annual disclosure burden for NRSROs; an increase in the annualized one-time disclosure burden for arrangers of structured finance products of 13,600 hours; an increase in the annual disclosure burden for arrangers of structured finance products of 2,720 hours; and an increase in the annual disclosure burden for arrangers of structured finance products of 102,000 hours. The industry-wide increase in burden resulting from the new rules and amendments to existing rules is approximately: an annualized one-time disclosure burden for NRSROs of 2,240 hours; an annual disclosure burden for arrangers of structured finance products of 119 hours; an annualized one-time reporting burden for NRSROs of 417 hours; and an annualized one-time reporting burden for NRSROs of $67,000 and 500 hours.

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Annual Cost to Federal Government: $0

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]? No

Is this ICR related to the Dodd-Frank Wall Street Reform and Consumer Protection Act, [Pub. L. 111-203]? No

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: 05/21/2015

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