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.
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.
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.
PRA Rule 17g-8 and 9 Supporting Statement_2018 renewal_final revised.docx
Rule 17g-9 annual recordkeeping costs to retain outside professionals