Rule 17g-8 Policies and procedures and Rule 17g-9 Standards of training, experience, and competence for credit analysts

Forms and Documents

Document Name	Status
PRA 17g-8 & 17g-9 Combined Supporting Statement 3Apr2012.docx Supporting Statement A	2012-04-24

IC Document Collections

IC ID	Document Title	Status
201507	IC - 2	New
201506	IC - 1	New

ICR Details

OMB Control No: 3235-0693	ICR Reference No: 201412-3235-007
Status: Historical Inactive	Previous ICR Reference No:
Agency/Subagency: SEC	Agency Tracking No: TM-270-645
Title: Rule 17g-8 Policies and procedures and Rule 17g-9 Standards of training, experience, and competence for credit analysts
Type of Information Collection: New collection (Request for a new OMB Control Number)	Common Form ICR:  No
Type of Review Request: Regular
OIRA Conclusion Action: Comment filed on proposed rule	Conclusion Date: 12/12/2014
	Date Received in OIRA: 12/12/2014
Terms of Clearance: Pursuant to 5 CFR 1320.11(c), OMB files this comment on this information collection request (ICR. The agency shall examine public comment in response to the NPRM and will describe in the supporting statement of its next collection any public comments received regarding the collection as well as why (or why it did not) incorporate the commenter’s recommendation. The next submission to OMB must include the draft final rule.

	Inventory as of this Action	Requested	Previously Approved
Expiration Date		36 Months From Approved
Responses	0	0	0
Time Burden (Hours)	0	0	0
Cost Burden (Dollars)	0	0	0

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Abstract: Rule 17g-8 would require nationally recognized statistical rating organizations ("NRSROs") to establish, maintain and enforce certain policies and procedures relating to credit rating methodologies, the use of credit rating symbols, and look-back procedures for departing NRSRO employees. The Commission's authority to propose the policies and procedures that would be required under proposed Rule 17g-8 arises from certain provisions of the Dodd-Frank Act. For the purposes of estimating the hourly recordkeeping burden associated with proposed Rule 17g-8, part IIIa of this form takes the average hourly burden over the first 3-year period following adoption of the rule, since the initial hourly burden for the proposed rule is greater than the estimated ongoing hourly burden. [(500 initial hourly burden in year 1 + 125 ongoing hourly burden in year 2 + 125 ongoing hourly burden in year 3) / 3 years = 250 hours per year.] Rule 17g-9 implements Section 936 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, which requires the Securities and Exchange Commission to issue rules reasonably designed to ensure that any person employed by a nationally recognized statistical rating organization to determine credit ratings meets standards of training, experience, and competence necessary to produce accurate ratings for the categories of issuers whose securities the person rates and is tested for knowledge of the credit rating process.

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Authorizing Statute(s): US Code: 15 USC 78o-7, 78o-7(h)(4)(A)(ii), Name of Law: Securities Exchange Act of 1934
   US Code: 15 USC 78o-8, 78o-7(s), 78o-7(r) Name of Law: Securities Exchange Act of 1934
  

Citations for New Statutory Requirements: PL: Pub.L. 111 - 203 932(a)(4), 932(a)(8) 936, 938 Name of Law: Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010

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Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
3235-AL15	Proposed rulemaking	76 FR 33420	06/08/2011

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Federal Register Notices & Comments

Did the Agency receive public comments on this ICR? No

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Number of Information Collection (IC) in this ICR: 2

IC Title	Form No.	Form Name
IC - 1
IC - 2

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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: This is a new rule proposal and will add 9,540 annual hours to the inventory.

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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]? Yes

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: 12/12/2014

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