available, accessible, and comparable for investors, other market
participants, and the Commission, as applicable. In addition, for those
Proposed Structured Documents that would be filed or submitted on EDGAR
(i.e., all except for the Rule 19b-4(e) postings), the proposed
structured data requirements would enable EDGAR to perform technical
validations (i.e., programmatic checks to ensure the documents are
appropriately standardized, formatted, and complete) upon intake of the
documents. This could improve the quality of the filed or submitted
data by decreasing the incidence of non-substantive errors (such as the
omission of values from fields that should always be populated).
---------------------------------------------------------------------------

    \335\ See, e.g., Schwarz, Christopher and Barber, Brad M. and
Huang, Xing and Jorion, Philippe and Odean, Terrance, The ``Actual
Retail Price'' of Equity Trades (Sep. 14, 2022), available at
https://ssrn.com/abstract=4189239 (retrieved from SSRN Elsevier
database).
    \336\ See Regulation Best Execution, Release No. 96496 (Dec. 15,
2022), 88 FR 5440, 5477 (Jan. 27, 2023).
---------------------------------------------------------------------------

    Structuring each Proposed Structured Document would enable
functionality that would vary based on the type of disclosures included
in each document. As discussed further in the discussion of individual
proposed forms above, and the discussion of economic benefits below,
structured numeric disclosures lend themselves to mathematical
functionality, such as the identification of statistical outliers
within a given disclosed metric to screen for potential areas of
greater scrutiny.\337\ Structured textual disclosures, on the other
hand, lend themselves to period-over-period redline comparisons,
targeted keyword searching, and more sophisticated sentiment
analysis.\338\ This could facilitate, for example, targeted searching
within broker-dealer significant accounting policy footnotes to
determine the extent to which broker-dealers are adopting a given
revenue recognition policy.
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    \337\ See infra section X.C.2.b. Proposed Structured Documents
that contain numeric disclosures include Form X-17A-5 Part III, Form
17-H, Form CA-1, Form 1, Rule 19b-4(e) information (in some cases),
notices of security-based swap valuation disputes pursuant to Rule
15fi-3(c), and CCO reports required by Rule 15fk-1(c)(2)(ii)(A). See
infra notes 596-599.
    \338\ Proposed Structured Documents that contain textual
disclosures include Form X-17A-5 Part III, Form 17-H, Form CA-1,
Form 1, Form 1-N (execution page only), Form X-17A-19, notices of
security-based swap valuation disputes required by Rule 15fi-3(c),
and CCO reports required by Rule 15fk-1(c)(2)(ii)(A). See id.
---------------------------------------------------------------------------

    The Commission is proposing Inline XBRL for certain affected
documents and portions or portions thereof, rather than proposing
Inline XBRL for all affected documents, because the Commission believes
Inline XBRL is more suitable for certain types of content than other
types. Specifically, the Commission believes Inline XBRL is most
suitable for financial statement disclosures (including footnotes and
schedules thereto), for narrative disclosures (other than brief
descriptions), and for disclosures of numeric details nested within
narrative disclosures. From a technical standpoint, Inline XBRL was
designed to accommodate financial statement information, including the
particular metadata (e.g., the relevant fiscal period, whether the line
item is located on the balance sheet, whether the line item is a credit
or debit) that must be linked to each data point within the financial
statements to fully convey its semantic meaning to a machine reader.
Inline XBRL is also well suited from a technical standpoint of
accommodating lengthier narrative disclosures, including those with
numeric values nested within narrative disclosures, while providing
presentation capabilities that preserve human-readability while
maintaining machine-readability. For other types of disclosures, the
Commission believes requiring custom XML data languages would be more
suitable due to the smaller file sizes of custom XML documents and the
availability of fillable web forms on EDGAR that permit filers or
submitters to input their disclosures into the form rather than
structure the disclosures in custom XML.\339\
---------------------------------------------------------------------------

    \339\ See also infra section X.E.4 (discussing other structured
data languages that would result in smaller file sizes than Inline
XBRL).
---------------------------------------------------------------------------

    For those affected documents where filers are required to attach
copies of

existing materials (such as copies of constitutions, by-laws, written
agreements, applications, and other documents) rather than disclosures
provided pursuant to the Commission's disclosure requirements, the
Commission is proposing to require filers to upload those copies as
unstructured PDF documents. The Commission believes requiring filers to
retroactively structure these existing documents, which were prepared
for purposes outside of fulfilling the Commission's disclosure
requirements, would likely impose costly compliance burdens on filers
without justifying the commensurate informational benefit associated
with more efficient disclosure use. Thus, the Commission does not
believe structured data requirements are warranted for these copies of
existing documents.
    Because the very limited number of Form 1-N and Form 15A filers and
filings could mitigate the benefit derived from machine-readability of
the disclosures contained therein, structured data would not be
required for Forms 1-N and 15A (other than the execution pages of those
Forms). Similarly, structured data for ANE Exception Notices would not
be required, because the limited number of data points on such notices
may lessen the utility of any functionality enabled by structured data
(such as efficient retrieval of individual data points from structured
documents).
    For each proposed structured data requirement, the Commission is
specifying the particular structured data language that filers or
submitters must use, rather than leaving the data language requirement
open-ended. By contrast, an open-ended data language requirement would
allow different filers or submitters of the same document to provide
their disclosures in different structured data languages. In such
instances, data users such as Commission staff and market participants
would be unable to incorporate disclosures from filers or submitters
using one data language into the same datasets and applications as
disclosures of other filers or submitters using different data
languages without undertaking data conversion processes that are
frequently burdensome and imprecise. This may hinder investors, the
Commission, and market participants from efficiently comparing
disclosures across the comprehensive set of entities comprising a given
entity population, and could therefore dampen the benefits that would
otherwise accrue from requiring the disclosures to be machine-readable.

B. Proposed Amendments to Rule 24b-2

    Rule 24b-2 provides procedures that are the exclusive means for
requesting confidential treatment of information required to be filed
under the Exchange Act.\340\ Paragraph (b) of Rule 24b-2 provides that,
except as provided in paragraphs (g) and (h) of the Rule, a person
seeking confidential treatment shall omit from materials filed with the
Commission the confidential portion.\341\ Paragraphs (g) and (h) state
that certain entities, as specified in those paragraphs, shall not omit
the confidential portion from the materials such entities file with the
Commission.\342\ The Commission is proposing to add a new paragraph (j)
to Rule 24b-2. The new paragraph would be subdivided into two parts.
The first sub-paragraph would provide that a broker-dealer shall not
omit the confidential portion from the materials filed in electronic
format pursuant to paragraphs (d) and (k) of Rule 17a-5, Rule 17a-12,
or Rule 17h-2T. The second sub-paragraph would state that an SBSD shall
not omit the confidential portion of materials filed in electronic
format pursuant to Rule 18a-7.
---------------------------------------------------------------------------

    \340\ 17 CFR 240.24b-2(a). However, with regard to Rule 15fi-
3(c) security-based swap valuation dispute notices, see supra note
293 and accompanying text.
    \341\ 17 CFR 240.24b-2(b).
    \342\ 17 CFR 240.24b-2(g); 17 CFR 240.24b-2(h).
---------------------------------------------------------------------------

    The Commission is also proposing to add a new paragraph (k) to Rule
24b-2. The new paragraph would provide that an entity shall not omit
the confidential portion from the material filed in electronic format
on Form CA-1 pursuant to Rule 17ab2-1, but rather may request
confidential treatment of information provided on Form CA-1 by
completing Section X of Form CA-1. The proposed amendment to Rule 24b-2
will facilitate the filing of any information for which confidential
treatment is requested.

VIII. General Request for Comments

    87. The Commission is requesting comments on all aspects of this
proposal. As stated above, the Commission believes that replacing the
current paper copy and email filing and submission methods with a
requirement to post the required supplemental materials on the clearing
agency's website should result in enhanced efficiency for both the
affected filers and the Commission. The Commission also believes that
rescinding Form 19b-4(e) and instead requiring the information
currently contained in Form 19b-4(e) to be publicly posted on the
listing SRO's internet website should result in enhanced efficiency for
both SROs and the Commission. The Commission specifically requests
comment on whether the proposal would reduce the costs associated with
providing these forms and information, or would they create additional
costs or burdens associated with these forms and information.
    88. In addition to the proposed amendments to Regulation S-T,
should the Commission amend any of the other requirements of Regulation
S-T given the filings and submissions proposed to be added to Rule
101(a) of Regulation S-T? If so, why should the requirements be
revised, and how should they be revised?
    89. The Commission also requests comment on how long filers or
submitters of Covered SRO Forms, Forms 19b-4(e), supplementary
materials under Rule 17a-22 and Covered EDGAR Documents should have to
come into compliance with the proposed amendments. In addressing this
issue, specific comment, data, or other information is requested
regarding the amount of time that filers or submitters would need to
come into compliance in an orderly manner. Would filers or submitters
be able to comply with some of the proposed amendments more quickly
than they would be able to comply with other proposed amendments?
Please identify the aspects of the proposed amendments that would
require relatively more or less time to comply. Would a particular
segment of filers or submitters need more or less time to comply with
one or more of the proposed amendments? Please identify with
specificity the segment of filers or submitters and the aspects of the
proposed amendments that would require more or less time to comply.
Would any alternatives identified in the proposal or by commenters
allow filers or submitters to come into compliance more quickly or
require additional time to implement?
    90. Beyond the forms captured in this current proposed rule, would
other forms or filings required under the Exchange Act and its
associated rules and regulations benefit from a Commission requirement
that they be submitted through the EDGAR system in a structured data
language? Explain which forms would benefit from this requirement and
why.
    91. Commenters should, when possible, provide the Commission with
empirical data to support their views. Commenters suggesting
alternative approaches should provide comprehensive proposals,
including any conditions or limitations that they

believe should apply, the reasons for their suggested approaches, and
their analysis regarding why their suggested approaches would satisfy
the objectives of the proposed amendments.

IX. Paperwork Reduction Act

    Certain provisions of the proposal contain ``collection of
information'' requirements within the meaning of the Paperwork
Reduction Act of 1995 (''PRA'').\343\ The titles of these requirements
are:
---------------------------------------------------------------------------

    \343\ 44 U.S.C. 3501 et seq.
---------------------------------------------------------------------------

     Form ID (OMB Control No. 3235-0328)
     Rules 6a-1 and 6a-2, Form 1 (OMB Control No. 3235-0017);
\344\
---------------------------------------------------------------------------

    \344\ See 17 CFR 249.1; 17 CFR 240.6a-1; 17 CFR 240.6a-2.
---------------------------------------------------------------------------

     Rule 6a-3 (OMB Control No. 3235-0021); \345\
---------------------------------------------------------------------------

    \345\ See 17 CFR 240.6a-3.
---------------------------------------------------------------------------

     Rule 6a-4, Form 1-N (OMB Control No. 3235-0554); \346\
---------------------------------------------------------------------------

    \346\ See 17 CFR 249.10, 17 CFR 240.6a-4; 17 CFR 249.10.
---------------------------------------------------------------------------

     Rules 15aa-1 and 15aa-2, Form 15A (OMB Control No. 3235-
0030); \347\
---------------------------------------------------------------------------

    \347\ See 17 CFR 240.15aa-1; 17 CFR 240.15aa-2. Proposed Form
15A currently would apply only to one SRO out of a total of 44 SROs.
Although this proposed form is expected to impact fewer than 10
entities, the Commission is including this PRA analysis. The
Commission has proposed to revise and reinstate collections of
information that were previously approved under Control Nos. 3235-
0030 and 3235-0044. Because the Commission is proposing to
consolidate the collections in amended and re-designated forms, all
collections would be under Control No. 3235-0030 and Control Number
3235-0044 would remain inactive. In addition, because of the length
of time since these control numbers were last active, the Commission
is providing completely new burden estimates.
---------------------------------------------------------------------------

     Rule 17ab2-1, Form CA-1 (OMB Control No. 3235-0195); \348\
---------------------------------------------------------------------------

    \348\ See 17 CFR 240.17ab2-1; 17 CFR 249b.200.
---------------------------------------------------------------------------

     Rule 19b-4(e), Form 19b-4(e) (OMB Control No. 3235-0504);
\349\
---------------------------------------------------------------------------

    \349\ See 17 CFR 240.19b-4(e); 17 CFR 249.820.
---------------------------------------------------------------------------

     Rule 19b-4, Form 19b-4 (OMB Control No. 3235-0045); \350\
---------------------------------------------------------------------------

    \350\ See 17 CFR 240. 17 CFR 249.819; 17 CFR 240.19b-4.
---------------------------------------------------------------------------

     Rule 17a-22, 17 CFR 240.17a-22 (OMB Control No. 3235-
0196);
     Rule 3a71-3(d)--Conditional Exception from De Minimis
Counting Requirement in Connection with Certain Transactions Arranged,
Negotiated or Executed in the United States (OMB Control No. 3235-
0771); \351\
---------------------------------------------------------------------------

    \351\ See 17 CFR 240.3a71-3(d).
---------------------------------------------------------------------------

     Rules 15Fi-3 to 15Fi-5--Risk Mitigation Techniques for
Uncleared Security-Based Swaps (OMB Control No. 3235-0777); \352\
---------------------------------------------------------------------------

    \352\ See 17 CFR 240.15Fi-3, 17 CFR 240.15Fi-4 (``Rule 15Fi-
4''), and 17 CFR 240.15Fi-5 (``Rule 15Fi-5''). The Commission is
only modifying Rule 15fi-3, which relates to the requirement that
SBS Entities reconcile outstanding security-based swaps with
applicable counterparties on a periodic basis. Rule 15fi-3 is
included in the same collection of information as Rule 15Fi-4, which
requires SBS Entities to engage in certain forms of portfolio
compression exercises with their counterparties, as appropriate, and
Rule 15Fi-5, which requires SBS Entities to execute written
security-based swap trading relationship documentation with its
counterparties, and to periodically audit the policies and
procedures governing such documentation. The Commission is not
changing Rules 15Fi-4 and 15Fi-5 pursuant to this rulemaking.
Accordingly, those two rules are not included in the sections that
follow.
---------------------------------------------------------------------------

     Rule 15fk-1(c)(2)(ii)(A) (OMB Control No. 3235-0732);
\353\
---------------------------------------------------------------------------

    \353\ See 17 CFR 240.15Fk-1(c)(2)(ii)(A).
---------------------------------------------------------------------------

     Rule 17a-5--Reports to be Made by Certain Brokers and
Dealers (OMB Control No. 3235-0123); \354\
---------------------------------------------------------------------------

    \354\ See 17 CFR 240.17a-5.
---------------------------------------------------------------------------

     Rule 17a-12--Reports to be Made by Certain OTC Derivatives
Dealers (OMB Control No. 3235-0498); \355\
---------------------------------------------------------------------------

    \355\ See 17 CFR 240.17a-12.
---------------------------------------------------------------------------

     Rule 17a-19 and Form X-17A-19--Report by National
Securities Exchanges and Registered National Securities Associations of
Changes in the Membership Status of Any of Their Members (OMB Control
No. 3235-0133); \356\
---------------------------------------------------------------------------

    \356\ See 17 CFR 240.17a-19; 17 CFR 249.635.
---------------------------------------------------------------------------

     Rule 17h-2T--Reporting Requirements of Risk Assessment
Information for Brokers and Dealers (OMB Control No. 3235-0410); \357\
---------------------------------------------------------------------------

    \357\ See 17 CFR 240.17h-2T.
---------------------------------------------------------------------------

     Rule 18a-7--Reports to be Made by Certain Security-Based
Swap Dealers and Major Security-Based Swap Participants (OMB Control
No. 3235-0749); \358\ and
---------------------------------------------------------------------------

    \358\ See 17 CFR 240.18a-7.
---------------------------------------------------------------------------

     Regulation S-T--General Rules and Regulations for
Electronic Filing (OMB Control Number 3235-0424).
    The Commission is submitting these requirements to the Office of
Management and Budget (``OMB'') for review and approval in accordance
with the PRA and its implementing regulations.\359\ If adopted,
responses to the new collections of information would be mandatory, or
mandatory except to the extent an exception is available. An agency may
not conduct or sponsor, and a person is not required to respond to, a
collection of information unless it displays a currently valid OMB
control number.\360\
---------------------------------------------------------------------------

    \359\ 44 U.S.C. 3507; 5 CFR 1320.11.
    \360\ 5 CFR 1320.11(l).
---------------------------------------------------------------------------

A. Summary of Collection of Information

1. Form ID
    Form ID must be completed and filed with the Commission by all
individuals, companies, and other organizations who seek access to file
electronically on EDGAR.\361\ Accordingly, a filer that does not
already have access to EDGAR must submit a Form ID, along with the
notarized signature of an authorized individual, to obtain an EDGAR
identification number and access codes to file on EDGAR.
---------------------------------------------------------------------------

    \361\ 17 CFR 249.446.
---------------------------------------------------------------------------

2. Rules 6a-1, 6a-2, 6a-3, and Form 1
    Rule 6a-1 under the Exchange Act generally requires that an
applicant seeking to register as a national securities exchange, or
seeking an exemption from such registration based on limited volume,
file an application on Form 1 and correct any inaccuracy therein upon
discovery of such inaccuracy.\362\ Form 1 contains an execution page as
well as 14 exhibits that must be filed by the applicant.\363\ Rule 6a-2
requires a registered national securities exchange or an exempt
exchange to: (1) amend its Form 1 if there are any changes to the
information provided in the initial Form 1; and (2) submit periodic
updates of certain information provided in the initial Form 1, whether
such information has changed or not.\364\ Rule 6a-3 requires a national
securities exchange or an exempt exchange to file certain supplemental
material with the Commission.\365\ Specifically, Rule 6a-3(a)(1)
requires an exchange to file with the Commission any material issued or
made generally available to members of, or participants or subscribers
to, the exchange within 10 days after issuing or making such material
available to such members, participants or subscribers.\366\ Rule 6a-
3(a)(2) provides that, if information required by Rule 6a-3(a)(1) is
available continuously on a website controlled by the exchange, in lieu
of filing such information, the exchange may provide on Form 1 the
URL(s) of the location(s) on the website where the information can be
found, and certify that the information is accurate as of its date and
is free and accessible (without any encumbrances or restrictions) by
the general public.\367\ Rule 6a-3(b) requires an exchange to file,
within 15 days after the end of each calendar month, a report
concerning the securities sold on the exchange during the calendar
month.\368\
---------------------------------------------------------------------------

    \362\ See 17 CFR 240.6a-1.
    \363\ 17 CFR 249.1.
    \364\ See 17 CFR 240.6a-2.
    \365\ See 17 CFR 240.6a-3.
    \366\ 17 CFR 240.6a-3(a)(1).
    \367\ 17 CFR 240.6a-3(a)(2).
    \368\ 17 CFR 240.6a-3(b).
---------------------------------------------------------------------------

    The Commission proposes to amend Rules 6a-1, 6a-2, and 6a-3 under
the Exchange Act, as well as Form 1 and the instructions to Form 1, to
make certain non-substantive changes and to require

the electronic filing of all filings required by Rules 6a-1, 6a-2, and
6a-3.
3. Rule 6a-4 and Form 1-N
    Rule 6a-4 \369\ sets forth the notice registration procedures for
Security Futures Product Exchanges and permits futures exchanges to
submit a notice registration on Form 1-N.\370\ Form 1-N requires
information regarding how the futures exchange operates, its rules and
procedures, corporate governance, its criteria for membership, its
subsidiaries and affiliates, and the security futures products it
intends to trade. Rule 6a-4 also requires entities that have submitted
an initial Form 1-N to file: (1) amendments to Form 1-N in the event
any information provided in the initial Form 1-N is be rendered
inaccurate or incomplete; (2) periodic updates of certain information
provided in the initial Form 1-N; (3) certain information that is
provided to the Security Futures Product Exchange's members; and (4) a
monthly report summarizing the Security Futures Product Exchange's
trading of security futures products.
---------------------------------------------------------------------------

    \369\ 17 CFR 240.6a-4.
    \370\ 17 CFR 249.10.
---------------------------------------------------------------------------

    The Commission proposes to amend Rule 6a-4 under the Exchange Act,
Form 1-N and the instructions to Form 1-N, as well as to make
clarifying changes to Rule 202.3(b)(3) to the Commission's Informal and
Other Procedures, to make certain non-substantive changes and to
require the electronic filing of all submissions required by Rule 6a-4.
4. Rules 15aa-1 and 15aa-2; Form 15A
    Under Exchange Act Rule 15Aa-1, an applicant for registration as a
national securities association must file a registration statement with
the Commission on Form X-15AA-1.\371\ Exchange Act Rule 15Aj-1(a)
requires every association applying for registration or registered as a
national securities association to file with the Commission an
amendment to its registration statement or any amendment or supplement
thereto promptly after discovering any inaccuracy therein. Under
Exchange Act Rule 15Aj-1(b), every association applying for
registration or registered as a national securities association must
file with the Commission a supplement to its registration statement or
any amendment or supplement thereto promptly after discovering any
inaccuracy or any change which renders no longer accurate any
information contained or incorporated therein.\372\ Under Exchange Act
Rule 15Aj-1(c), every association applying for registration or
registered as a national securities association must file annual and
triennial amendments to its registration statement with the
Commission.\373\
---------------------------------------------------------------------------

    \371\ See Exchange Act Rule 15Aa-1, 17 CFR 240.15Aa-1 and 17 CFR
249.801. Currently, FINRA is the only national securities
association registered with the Commission. The NFA, as specified in
Section 15A(k) of the Exchange Act, is also registered as a national
securities association, but only for the limited purpose of
regulating the activities of NFA members that are registered as
brokers or dealers in security futures products under section
15(b)(11) of the Exchange Act. The Commission notes that there are
no burden estimates currently approved by OMB for Exchange Act Rule
15Aa-1.
    \372\ See Exchange Act Rule 15Aj-1(a) and (b), 17 CFR 240.15Aj-
1(a) and (b). These filings are currently submitted on Exchange Act
Form X-15AJ-1, 17 CFR 249.802. See 17 CFR 240.15Aj-1(d).
    \373\ See Exchange Act Rule 15Aj-1(c), 17 CFR 240.15Aj-1(c).
These filings are currently submitted on Exchange Act Form X-15AJ-2,
17 CFR 249.803. See 17 CFR 240.15Aj-1(d). Rule 15Aj-1(c)(1)(ii) also
requires the filing of complete sets of the constitution, by-laws,
rules, and related documents of the association, once every three
years.
---------------------------------------------------------------------------

    The Commission is proposing to amend Rule 15Aa-1 and redesignate it
as Rule 15aa-1,\374\ redesignate Rule 15Aj-1 \375\ as Rule 15aa-2,
redesignate Form X-15AA-1 as Form 15A, amend the instructions to
proposed Form 15A, and repeal Forms X-15AJ-1 and X-15AJ-2 in connection
with the Commission's proposal to require applicants and national
securities associations to electronically file on a duly executed Form
15A the information currently filed on Forms X-15AA-1, X-15AJ-1, and X-
15AJ-2. The Commission is also proposing to revise Rule 15Aa-1 to
require electronic filing and an electronic signature.
---------------------------------------------------------------------------

    \374\ 17 CFR 240.15Aa-1.
    \375\ 17 CFR 240.15Aj-1.
---------------------------------------------------------------------------

    The Commission proposes to redesignate Form X-15AA-1 as Form 15A
and to incorporate in proposed Form 15A information related to
amendments and supplements to the registration statement currently
filed on Form X-15AJ-1 and information related to the annual
consolidated supplement to the registration statement currently filed
on Form X-15AJ-2. New Form 15A would solicit information through
prompts on the form that would better organize the information that is
currently collected through Forms X-15AA-1, X-15AJ-1, and X-15AJ-2.
    Proposed Form 15A would contain eleven sections. Preceding Section
I of proposed Form 15A, the proposed form would contain prompts that
would require the association to note the basis for submitting the Form
15A. The prompts would indicate whether the submission is an initial
application filed pursuant to Rule 15aa-1 or an amendment or
supplement. Section I would be titled ``Organization,'' and it would
solicit information about the association itself and would require the
association to attach Exhibits A through D. Sections II through IX of
proposed Form 15A would solicit information about specific association
rules and other information.
    Section X would require the association to provide the contact
information for its contact employee, and Section XI would provide the
consent to service and attestation.
5. Rule 17ab2-1 and Form CA-1
    Rule 17ab2-1(a) states that an application for registration or for
exemption from registration as a clearing agency or an amendment to any
such application shall be filed with the Commission on Form CA-1, in
accordance with the instructions thereto.\376\ Form CA-1 includes an
execution page and 19 exhibits. Rule 17ab2-1(e) requires an applicant,
a registered clearing agency, or an exempt clearing agency to file an
amendment to correct any information reported at items 1-3 of Form CA-1
if such information is, or becomes, inaccurate, misleading or
incomplete for any reason.\377\ The instructions to Form CA-1 require
an applicant clearing agency to file four completed copies of Form CA-1
with the Commission. In addition, if an item is amended, the
instructions to Form CA-1 require a registered clearing agency or an
exempt clearing agency to repeat all unamended items as they last
appeared on the page on which the amended item appears and to file four
copies of the new page with the Commission.
---------------------------------------------------------------------------

    \376\ 17 CFR 240.17ab2-1(a).
    \377\ 17 CFR 240.17ab2-1(e).
---------------------------------------------------------------------------

    The Commission is proposing to revise certain aspects of Rule
17ab2-1, Form CA-1, and the instructions to Form CA-1 to make certain
non-substantive changes and to require electronic filing of
applications on Form CA-1 and subsequent amendments thereto submitted
by applicants, registered clearing agencies, and exempt clearing
agencies.
6. Rule 19b-4(e) and Form 19b-4(e)
    Rule 19b-4(e) provides that the listing and trading of a new
derivative securities product by an SRO shall not be deemed a proposed
rule change if the Commission has approved, pursuant to section 19(b)
of the Exchange Act,\378\ the SRO's trading rules, procedures, and
listing standards for the product class that would include the new
derivative

securities product, and the SRO has a surveillance program in place for
such product class. Under Rule 19b-4(e)(2)(ii), SROs are required to
submit Form 19b-4(e) \379\ to the Commission within five business days
after commencement of trading a new derivative securities product.\380\
In addition, Rule 19b-4(e)(2)(i) requires an SRO to maintain, on-site,
a copy of Form 19b-4(e) for a prescribed period of time.\381\
---------------------------------------------------------------------------

    \378\ 15 U.S.C. 78s(b).
    \379\ See 17 CFR 249.820.
    \380\ See 17 CFR 240.19b-4(e)(2)(ii).
    \381\ See 17 CFR 240.19b-4(e)(2)(i).
---------------------------------------------------------------------------

    The Commission proposes to amend Rule 19b-4(e) \382\ to rescind
Form 19b-4(e) and instead require the information currently contained
in Form 19b-4(e) to be publicly posted on the listing SRO's internet
website.
---------------------------------------------------------------------------

    \382\ 17 CFR 240.19b-4(e).
---------------------------------------------------------------------------

7. Rule 19b-4(j) and Form 19b-4
    Section 19(b) of the Exchange Act, as amended, requires each SRO to
file with the Commission, in accordance with such rules as the
Commission may prescribe, copies of any proposed rule, or any proposed
change in, addition to, or deletion from the rules of such SRO
(collectively, a ``proposed rule change'') accompanied by a concise
general statement of the basis and purpose of such proposed rule
change.\383\ Rule 19b-4 requires an SRO to submit each proposed rule
change on Form 19b-4.\384\ Form 19b-4 currently requires a description
of the terms of a proposed rule change, the proposed rule change's
impact on various market segments, and the relationship between the
proposed rule change and the SRO's existing rules.\385\ Form 19b-4 also
requires an accurate statement of the authority and statutory basis
for, and purpose of, the proposed rule change, the proposal's impact on
competition, and a summary of any written comments received by the
SRO.\386\ An SRO is required to submit Form 19b-4 to the Commission
electronically, post a copy of the proposed rule change on its public
website within two business days of its filing, and post and maintain a
current and complete set of its rules on its website.\387\
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    \383\ 15 U.S.C. 78s(b).
    \384\ 17 CFR 240.19b-4(b).
    \385\ 17 CFR 249.819.
    \386\ Id.
    \387\ 17 CFR 240.19b-4(b)(1), (l), (m)(1).
---------------------------------------------------------------------------

    Rule 19b-4(j) requires that the signatory to an electronically
submitted rule filing manually sign a signature page or other document
authenticating, acknowledging, or otherwise adopting his or her
signature that appears in typed form within the electronic document,
execute that document before or at the time the rule filing is
electronically submitted, and retain that document for its records in
accordance with Rule 17a-1.\388\ Form 19b-4 and the instructions to
Form 19b-4 require that a duly authorized officer of the SRO manually
sign one copy of the completed Form 19b-4 and that the manually signed
signature page be maintained pursuant to section 17 of the Act.\389\
The Commission proposes to remove these manual requirements from Rule
19b-4(j), Form 19b-4, and the instructions to Form 19b-4.
---------------------------------------------------------------------------

    \388\ 17 CFR 240.19b-4(j).
    \389\ 17 CFR 249.819.
---------------------------------------------------------------------------

8. Rule 17a-22
    Rule 17a-22 currently requires a registered clearing agency to file
with the Commission three paper copies of any material (including, for
example, manuals, notices, circulars, bulletins, lists, or periodicals)
issued, or made generally available, to its participants or other
entities with whom it has a significant relationship, such as pledgees,
transfer agents, or self-regulatory organizations, within 10 days after
issuing, or making generally available, such material.\390\ Under
current Rule 17a-22, when the Commission is not a registered clearing
agency's ARA, the clearing agency must at the same time file one paper
copy of the material with its ARA.\391\
---------------------------------------------------------------------------

    \390\ 17 CFR 240.17a-22.
    \391\ Id.
---------------------------------------------------------------------------

    The proposed amendments to Rule 17a-22 would not change the scope
of supplemental materials that are currently subject to the rule.
However, the proposed amendments would replace the requirement to file
multiple copies of supplemental materials with the Commission and,
where applicable, the ARA in paper form with a requirement to
prominently post such materials on a registered clearing agency's
internet website.\392\ In addition, the proposed amendments would
reduce the timeframe for registered clearing agencies to comply with
the rule from 10 days to 2 business days. As noted above, the two
business day timeframe is consistent with a registered clearing
agency's obligation under Rule 19b-4(m) to update its website to post
any rule changes filed pursuant to section 19(b) of the Exchange
Act.\393\ Because the supplemental materials that are subject to Rule
17a-22 will have already been prepared for distribution to a registered
clearing agency's participants or other entities with whom it has a
significant relationship, those documents should be readily available
for the clearing agency to post on its website within the proposed two
business day timeframe.\394\
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    \392\ By replacing the paper filing requirement for supplemental
materials with an internet posting requirement, proposed Rule 17a-22
would allow all of a registered clearing agency's regulatory
authorities to access the materials; thereby eliminating the need to
file an additional paper copy with the clearing agency's ARA. For
this reason, with respect to a registered clearing agency for which
the Commission is not the ARA, the proposed amendments would remove
the requirement to also file one paper copy of the supplemental
materials with the clearing agency's ARA.
    \393\ See 17 CFR 240.19b-4(m).
    \394\ See supra section III.C.1.
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9. Rules 17a-5, 18a-7, and 17a-12
    The Commission is proposing to amend Rules 17a-5, 18a-7, and 17a-12
to require broker-dealers, SBS Entities, and OTC derivatives dealers to
electronically file with the Commission in Inline XBRL through the
Commission's EDGAR system annual audited reports and related annual
filings. The filings are currently made either in paper, via email, or
voluntarily on the EDGAR system as PDF documents.
    In addition, the Commission is proposing to amend Rule 17a-12 to
require OTC derivatives dealers to file the unaudited FOCUS Report Part
II electronically through the SEC eFOCUS system instead of in paper.
    The Commission is also proposing to allow electronic signatures in
Rule 17a-5, 17a-12, and 18a-7 filings, which includes the FOCUS Report.
    Broker-dealers, SBS Entities, and OTC derivatives dealers file
FOCUS Reports Part II, IIA, or IIC, which are periodic unaudited
reports about their financial and operational condition. The Commission
is proposing corrective and clarifying amendments to FOCUS Report Part
II and amendments to FOCUS Report Part IIC for consistency with FFIEC
Form 031.
10. Rule 17h-2T
    The Commission proposes amending paragraph (a)(2) of Rule 17h-2T to
require that the quarterly and annual risk assessment reports be filed
with the Commission electronically through EDGAR as an Interactive Data
File in accordance with Rule 405 of Regulation S-T. The materials filed
under the rule would not change, but the materials filed would be filed
on EDGAR, and the financial statements required by Item 4 of the Form
would be structured in Inline XBRL.

11. Rule 17a-19 and Form X-17A-19
    In general, Rule 17a-19 requires national securities exchanges and
associations to file with the Commission certain information required
on Form X-17A-19 within five business days of the occurrence of the
initiation of membership, change in membership, or termination of
membership of any member. The Commission proposes amending Rule 17a-19
and Form X-17A-19 to require that filings providing such notifications
be made on EDGAR, in a custom XML-based data language.
12. Rule 3a71-3(d)(1)(vi)
    The ANE Exception is conditioned in part on the Registered Entity
filing with the Commission an ANE Exception Notice, which is a notice
that personnel of the Relying Entity or its agent located in a branch
or office in the United States may conduct ANE Activity in their
capacity as persons associated with the Registered Entity in reliance
on the ANE Exception. Currently, Exchange Act Rule 3a71-3(d)(1)(vi)
requires the Registered Entity to file the ANE Exception Notice by
submitting it to the electronic mailbox specified on the Commission's
website. The Commission is proposing to amend the manner of filing to
require the Registered Entity to file the ANE Exception Notice
electronically through the Commission's EDGAR filing system, but is not
changing the information required from a filer of the ANE Exception
Notice. The Commission also is proposing to require that, if the
Registered Entity later becomes unregistered or otherwise ineligible to
serve as the Registered Entity for purposes of the ANE Exception, the
Registered Entity must promptly withdraw its ANE Exception Notice. In
addition, a Registered Entity whose associated persons will no longer
conduct ANE Activity pursuant to the ANE Exception may withdraw its ANE
Exception Notice. Currently, a Registered Entity who wishes to withdraw
a filed ANE Exception Notice may contact the Commission and request
that the ANE Exception Notice be manually removed from the Commission's
website. The Commission is proposing to require Registered Entities to
file any withdrawal of an ANE Exception Notice electronically through
the Commission's EDGAR filing system.
13. Rule 15fi-3
    Rule 15fi-3 generally requires SBS Entities to: (1) engage in
periodic portfolio reconciliation activities with counterparties who
are also SBS Entities; and (2) establish, maintain, and follow written
policies and procedures reasonably designed to ensure that they engage
in periodic portfolio reconciliation with counterparties who are not
SBS Entities with respect to their outstanding (and uncleared)
security-based swaps.\395\ Rule 15fi-3(c) requires an SBS Entity to
promptly notify the Commission, and any applicable prudential
regulator, of any security-based swap valuation dispute in excess of
$20,000,000 (or its equivalent in any other currency) if not resolved
within: (1) three business days, if the dispute is with a counterparty
that is an SBS Entity; or (2) five business days, if the dispute is
with a counterparty that is not an SBS Entity.\396\ Rule 15fi-3(c) also
requires SBS Entities to notify the Commission and any applicable
prudential regulator, if the amount of any security-based swap
valuation dispute that was the subject of a previous notice increases
or decreases by more than $20,000,000 (or its equivalent in any other
currency), at either the transaction or portfolio level. Each amended
notice is required to be provided to the Commission and any applicable
prudential regulator no later than the last business day of the
calendar month in which the applicable security-based swap valuation
dispute increases or decreases by the applicable dispute amount.\397\
---------------------------------------------------------------------------

    \395\ See 17 CFR 240.15Fi-3(a) and (b). See also supra section
V.C.1.
    \396\ See 17 CFR 240.15Fi-3(c)(1).
    \397\ See 17 CFR 240.15Fi-3(c)(2).
---------------------------------------------------------------------------

    Given that Rule 15fi-3(c) requires that the security-based swap
valuation notices be submitted to the Commission ``in a form and manner
acceptable to the Commission,'' staff has made available two options
for submitting these notices to the Commission, which include either:
(1) an electronic submission using EDGAR or (2) submission to a
dedicated Commission email address. Under both submission types, the
system is capable of accepting the notice in PDF format, either as an
attachment to an email or as an uploaded document to EDGAR. The
Commission is now proposing to amend Rule 15fi-3(c) to affirmatively
require SBS Entities to submit these notices to the Commission
electronically in EDGAR using a custom XML-based data language. This
includes both the initial notice and any subsequent amendments. If
these proposed changes are adopted, SBS Entities would no longer be
able to submit dispute notices to the Commission using a dedicated
email address or in PDF format on EDGAR.
14. Rule 15fk-1(c)(2)(ii)(A)
    Rule 15fk-1(c) currently requires that the CCO of an SBS Entity
prepare and sign a CCO report. The CCO report must be submitted to the
Commission within 30 days following the filing deadline for the SBS
Entity's annual financial report with the Commission.\398\ Rule 15fk-
1(c) does not specify the manner in which the CCO report must be
submitted. Accordingly, pursuant to the current rule, an SBS Entity may
submit its CCO report as a paper or electronic submission.
---------------------------------------------------------------------------

    \398\ 17 CFR 240.15Fk-1(c)(2)(ii)(A).
---------------------------------------------------------------------------

    The proposed amendment to Rule 15fk-1(c)(2)(ii)(A) would not change
what the report must include. Rather, the amendment would require that
the CCO report be submitted electronically in Inline XBRL through
EDGAR. As with other entities that make submissions through EDGAR,
these submissions would be subject to the provisions of Regulation S-T
and the EDGAR Filer Manual, as defined in Rule 11 of Regulation S-
T.\399\
---------------------------------------------------------------------------

    \399\ 17 CFR 232.11.
---------------------------------------------------------------------------

15. Regulation S-T
    The Commission is proposing amendments to Rule 101 of Regulation S-
T to require that broker-dealer and non-bank SBS Entity annual reports
and related annual supplemental reports, national securities exchange
and association changes in member status, SBS Entity CCO reports, and
broker-dealer risk assessment reports be filed electronically with the
Commission. The Commission is also proposing amendments to Rule 405 to
require that broker-dealer and non-bank SBS Entity annual reports and
related annual supplemental reports, SBS Entity CCO reports, broker-
dealer risk assessment reports (in part), clearing agency applications
(in part), and national securities exchange applications (in part) be
filed in Inline XBRL.\400\
---------------------------------------------------------------------------

    \400\ See proposed paragraph (b)(5) of Rule 405 of Regulation S-
T.
---------------------------------------------------------------------------

    The Commission also is proposing that ANE Exception Notices and
withdrawals of ANE Exception Notices be filed with the Commission
electronically using the Commission's EDGAR system. To implement this
requirement, the Commission is proposing amendments to Rule 101 of
Regulation S-T to require that ANE Exception Notices and withdrawals of
ANE Exception Notices be filed electronically with the Commission using
the EDGAR system.\401\ This collection of information is the same as

the collection of information in connection with the proposed
amendments to Exchange Act Rule 3a71-3(d)(1)(vi).
---------------------------------------------------------------------------

    \401\ See proposed paragraph (a)(1)(xxxiii) of Rule 101 of
Regulation S-T.
---------------------------------------------------------------------------

    The Commission also is proposing that initial notices and any
subsequent amendments pursuant to Rule 15fi-3(c) be submitted to the
Commission electronically using the Commission's EDGAR system in a
custom XML-based data language. To implement this requirement, the
Commission is proposing amendments to Rule 101 of Regulation S-T to
require that the notices be submitted electronically to the Commission
using the EDGAR system.\402\ This collection of information is the same
as the collection of information in connection with the proposed
amendments to Exchange Act Rule 15fi-3(c).
---------------------------------------------------------------------------

    \402\ See proposed paragraph (a)(1)(xxxiv) and (d) of Rule 101
of Regulation S-T.
---------------------------------------------------------------------------

B. Proposed Use of Information

1. Form ID
    The information provided on Form ID allows the Commission staff to
review applications for EDGAR access and, if the application is
approved, assign CIKs (if the applicant does not already have a CIK)
and/or access codes to applicants to permit filing on EDGAR. Form ID is
essential to EDGAR security.
2. Rules 6a-1, 6a-2, 6a-3, and Form 1
    The information required pursuant to Rules 6a-1, 6a-2, and 6a-3 is
necessary to enable the Commission to receive accurate and complete
information from applicants seeking registration as national securities
exchanges or an exemption from such registration (``exempt exchanges'')
and from national securities exchanges and exempt exchanges, which
would enable the Commission to exercise its statutory oversight
functions. Without the information submitted pursuant to Rule 6a-1 on
Form 1, the Commission would not be able to determine whether the
applicant has met the criteria for registration (or an exemption from
registration) set forth in section 6 of the Exchange Act. The
amendments, periodic updates of information, supplemental materials,
and monthly reports submitted pursuant to Rules 6a-2 and 6a-3 are
necessary to assist the Commission in its oversight of national
securities exchanges and exempt exchanges.
3. Rule 6a-4 and Form 1-N
    The information obtained under Rule 6a-4 and Form 1-N provides the
Commission with basic information about Security Futures Product
Exchanges. This information enables the Commission to carry out its
statutorily mandated oversight functions and helps ensure that Security
Futures Product Exchanges continue to be in compliance with the
Exchange Act.
4. Rules 15aa-1 and 15aa-2; Form 15A
    The information required pursuant to Rule 15aa-1 is necessary to
enable the Commission to receive accurate and complete information from
applicants seeking registration as national securities association
which would enable the Commission to exercise its statutory oversight
functions. Without the information submitted pursuant to Rule 15aa-1 on
Form 15A, the Commission would not be able to determine whether the
applicant has met the criteria for registration set forth in section
15A of the Exchange Act. The amendments, periodic updates of
information, and supplemental materials submitted pursuant to Rule
15Aa-2 are necessary to assist the Commission in its oversight of
national securities associations.
5. Rule 17ab2-1 and Form CA-1
    The Commission uses the information disclosed on Form CA-1 to: (i)
determine whether an applicant for registration as a clearing agency or
for an exemption from such registration meets the standards for
registration set forth in the Exchange Act; (ii) enforce compliance
with the Exchange Act's registration requirements; and (iii) use as a
reference for specific registered clearing agencies or exempt clearing
agencies for compliance and investigatory purposes. The information
required under Rule 17ab2-1 is essential for the Commission to perform
its statutorily required duties.
6. Rule 19b-4(e) and Form 19b-4(e)
    The information collected pursuant to Rule 19b-4(e) is designed to
maintain an accurate record of all new derivative securities products
by SROs, the listing and trading of which are not deemed to be proposed
rule changes. The Commission reviews compliance with Rule 19b-4(e)
through its routine inspections of the SROs.
7. Rule 19b-4(j) and Form 19b-4
    The information collected pursuant to Rule 19b-4 is designed to
provide the Commission with the information necessary to determine, as
required by the Exchange Act, whether the proposed rule change is
consistent with the Exchange Act and the rules thereunder. The
information is used to determine if the proposed rule change should be
approved, disapproved, suspended, or if proceedings should be
instituted to determine whether to approve or disapprove the proposed
rule change. The Commission reviews compliance with Rule 19b-4 through
its routine inspections of the SROs. The Commission is proposing to
remove a manual signature requirement in the existing collection of
information under Rule 19b-4 and on Form 19b-4 because it believes that
requirement is unnecessary given the electronic signature already
required by Form 19b-4.
8. Rule 17a-22
    The information required to be posted on a registered clearing
agency's website under the proposed amendments to Rule 17a-22 would
assist the Commission in carrying out its statutorily mandated
oversight functions with respect to clearing agencies. The Commission
uses this information to determine: (i) whether a clearing agency is
implementing procedural or policy changes and, if so, whether such
changes are consistent with the purposes of section 17A of the Exchange
Act; and (ii) whether a clearing agency has changed its rules without
filing the actual or prospective change to the Commission as required
by section 19(b) of the Exchange Act. The posting of such information
on a registered clearing agency's website would improve transparency of
a clearing agency's actions and communications to a larger group of
potentially interested persons, including non-member entities that
directly or indirectly use the clearing agency's services, investors,
and the general public.
9. Rules 17a-5, 18a-7, and 17a-12
    Reports required to be made under Rules 17a-5, 18a-7, and 17a-12
are used, among other things, to monitor the financial and operational
condition of broker-dealers, SBS Entities, and OTC derivatives dealers
by Commission staff and, to the extent applicable to the entity, by its
designated examining authority (``DEA''). The reports required under
Rules 17a-5, 18a-7, and 17a-12 are also one of the primary means of
ensuring compliance with the Commission's financial responsibility
rules (e.g., Rule 15c3-1). A firm's failure to comply with these rules
would severely impair the ability of the Commission (and the firm's
DEA, if applicable) to protect investors, including customers and
counterparties of the registrant.
10. Rule 17h-2T
    The information required to be filed with the Commission under Rule
17h-

2T is used by the Commission to monitor the activities of a covered
broker-dealer's affiliates whose business activities are reasonably
likely to have a material impact on the financial and operational
condition of the broker-dealer.
11. Rule 17a-19 and Form X-17A-19
    Upon the Commission's receipt of a Form X-17A-19 filing, the
information is entered into a database, which is regularly shared with
the SROs. Commission staff use the information contained in Form X-17A-
19 to assign the appropriate SRO as DEA for the member firms. This
information is also used by SIPC in determining which SRO is the
collection agent for the SIPC Fund.
12. Rule 3a71-3(d)(1)(vi)
    The information provided by a Registered Entity in connection with
the filing of an ANE Exception Notice pursuant to Exchange Act Rule
3a71-3(d)(1)(vi), and any subsequent withdrawal, assists the Commission
in evaluating market participants' compliance with the limitations on
use of the ANE Exception, as well as assists Relying Entities and their
affiliates in determining whether they have satisfied the ANE
Exception's notice requirement and in monitoring their progress toward
the ANE Exception's cap on inter-dealer security-based swaps. The
proposed amendment to Rule 3a71-3(d)(1)(vi) to move the filing of the
ANE Exception Notice, and any subsequent withdrawal, to the
Commission's EDGAR filing system would facilitate more efficient and
timely transmission, dissemination, and analysis of this information.
13. Rule 15fi-3
    The information shared by counterparties to a security-based swap
transaction periodically during the portfolio reconciliation process,
as contemplated by Rule 15fi-3, plays an important role in assisting
those counterparties in identifying and resolving discrepancies
involving key terms of their transactions on an ongoing basis. This
information also allows those counterparties to improve their
management of internal risks related to the enforcement of their rights
and the performance of their obligations under a security-based swap.
Moreover, requiring SBS Entities to agree in writing with each of their
counterparties on the terms of the portfolio reconciliation (including,
if applicable, agreement on the selection of any third party service
provider who may be performing the reconciliation) helps to minimize
any discrepancies regarding the portfolio reconciliation process
itself, thereby ensuring that it operates in as efficient and cost-
effective means possible. The requirement to report certain unresolved
valuation disputes to the Commission assists the Commission in
identifying potential issues with respect to an SBS Entity's internal
valuation methodology and also could serve as an indication of a
widespread market disruption in cases where the Commission receives a
large number of such notices from multiple firms. The proposed
amendment to Rule 15fi-3 to require submission of the valuation dispute
notices using the Commission's EDGAR system is intended to facilitate
more efficient and secure transmission and efficient and effective
analysis of this information.
14. Rule 15fk-1(c)(2)(ii)(A)
    The information collected under Rule 15fk-1(c) assists the
Commission staff's oversight and examination of SBS Entities compliance
with the business conduct requirements for such entities.
15. Regulation S-T
    The proposed amendments to Rule 101 of Regulation S-T, as part of
implementing the requirement that broker-dealers or SBS Entities use
the EDGAR system to electronically file their annual reports, broker-
dealer risk assessment reports, and CCO reports, as applicable, will be
used by the Commission to streamline and simplify the filing process
for filers and the Commission. In addition, the public filings will be
more quickly available to investors to evaluate and compare these
firms.
    The proposed amendments to Rule 101 of Regulation S-T, as part of
implementing the requirement that filers use the EDGAR system to
provide Rule 3a71-3(d)(1)(vi) and Rule 15fi-3(c) notices, will be used
as described above. Further, the proposed amendments to Rules 201 and
202 of Regulation S-T would preclude the possibility of temporary or
continuing hardship exemptions that otherwise would allow the ANE
Exception Notice (and any subsequent withdrawal) to be filed on paper.
The ANE Exception Notice facilitates the availability of a conditional
exception \403\ premised in part on the public availability of the
notice to Relying Entities.
---------------------------------------------------------------------------

    \403\ See supra section V.B.
---------------------------------------------------------------------------

    The proposed amendments to Rule 405 of Regulation S-T, which would
implement the proposed Inline XBRL requirements for Form 1, Form CA-1,
Form X-17A-5 Part III, Form 17-H, and the CCO reports, will be used to
facilitate the retrieval, comparison, and other analysis of the
disclosures on those forms across respondents and time periods.

C. Respondents

1. Form ID
    The respondents to the collection of information required under
Form ID would be all entities that would be required to file
electronically on EDGAR under the proposal and that do not already have
access to EDGAR. Such respondents must submit a Form ID, along with the
notarized signature of an authorized individual, to obtain an EDGAR
identification number and access codes to file on EDGAR. If the
requirements to file on EDGAR are adopted as proposed, the Commission
estimates that these respondents would include the following entities
not currently registered on EDGAR: 24 national securities exchanges and
exempt exchanges; 2 Security Futures Product Exchanges; 1 registered
national securities association; 12 registered and exempt clearing
agencies; 1,559 broker-dealers; and 24 Registered Entities.
2. Rules 6a-1, 6a-2, 6a-3, and Form 1
    The respondents to the collection of information required under
Rule 6a-1 are new applicants applying to register as a national
securities exchange or seeking an exemption from such registration. The
Commission estimates that it would receive approximately one initial
Form 1 filing per year.
    The respondents to the collection of information required under
Rules 6a-2 and 6a-3 are national securities exchanges and exempt
exchanges. Currently, there are 24 entities registered as national
securities exchanges. These respondents would file annual, triennial,
and periodic amendments to their Form 1 under Rule 6a-2. These
respondents would also file supplemental materials and monthly reports
under Rule 6a-3. There are no exempt exchanges that currently submit
amendments under Rule 6a-2 or supplemental materials and monthly
reports under Rule 6a-3.
3. Rule 6a-4, Form 1-N
    The respondents to the collection of information required under
Rule 6a-4 are futures exchanges that trade security futures products.
Currently, there are two Security Futures Product Exchanges. These
respondents would file annual, triennial, and periodic amendments to
their Form 1-N under Rule 6a-4(b). These respondents would also file
supplemental materials and monthly reports under Rule 6a-4(c).

The Commission estimates that it will not receive any initial Form 1-N
filings.\404\
---------------------------------------------------------------------------

    \404\ The Commission is basing its estimate on its historical
experience with Form 1-N filings. In particular, since the adoption
of the form in 2001, six initial Form 1-N filings have been made by
futures exchanges. Based on the infrequent occurrence of filings,
the Commission believes that zero is a reasonable estimate.
---------------------------------------------------------------------------

4. Rules 15aa-1 and 15aa-2; Form 15A
    The respondents to the collection of information required under
Rule 15aa-1 are new applicants applying to register as a national
securities association. The Commission estimates that it would receive
one initial Form 15A filing per year.\405\
---------------------------------------------------------------------------

    \405\ The Commission notes that since the adoption of section
15A of the Exchange Act as part of the Maloney Act in 1938, only two
national securities associations have registered with the
Commission. Currently, FINRA is the only national securities
association registered with the Commission whereas the NFA is
registered as a national securities association only for the limited
purpose of regulating the activities of NFA members that are
registered as brokers or dealers in security futures products under
section 15(b)(11) of the Exchange Act.
---------------------------------------------------------------------------

    The respondents to the collection of information required under
Rule 15aa-2 are national securities associations currently registered
with the Commission. Currently, there is only one entity that would be
required to file annual, triennial, and periodic amendments to its Form
15A under Rule 15aa-2.
5. Rule 17ab2-1, Form CA-1
    The respondents to the collection of information required under
Rule 17ab2-1 are registered and exempt clearing agencies, as well as
applicants seeking to register as a clearing agency or seeking an
exemption from such registration. Currently, there are nine registered
clearing agencies, only seven of which are operational,\406\ and five
exempt clearing agencies. We estimate that there may be one new
application filed each year.
---------------------------------------------------------------------------

    \406\ The Boston Stock Exchange Clearing Corporation (``BSECC'')
and Stock Clearing Corporation of Philadelphia (``SCCP'') are
currently registered with the Commission as clearing agencies but
conduct no clearance or settlement operations. See Exchange Act
Release No. 6329 (Jan. 3, 2011), 76 FR 1473 (Jan. 10, 2011) (``BSECC
Notice''); Exchange Act Release No. 63268 (Nov. 8, 2010), 75 FR
69730 (Nov. 15, 2010) (``SCCP Notice'').
---------------------------------------------------------------------------

6. Rule 19b-4(e), Form 19b-4(e)
    The respondents to the collection of information required under
Rule 19b-4(e) are SROs that list and trade new derivative securities
products--national securities exchanges. Currently, there are 24
entities registered as national securities exchanges.
7. Rule 19b-4(j), Form 19b-4
    The respondents to the collection of information required under
Rule 19b-4(j) and Form 19b-4 are SROs (as defined by section 3(a)(26)
of the Act), including national securities exchanges, national
securities associations, registered clearing agencies, notice
registered securities future product exchanges, and the MSRB. The
Commission's current approved estimated number of respondents is 42
SROs.\407\
---------------------------------------------------------------------------

    \407\ See FR Doc. 2019-22222, 84 FR 54710 (Oct. 10, 2019)
(Request to OMB for extension of Rule 19b-4 and Form 19b-4; SEC File
No. 270-38; OMB Control No. 3235-0045).
---------------------------------------------------------------------------

8. Rule 17a-22
    The respondents to the collection of information required under
Rule 17a-22 are registered clearing agencies. Currently, there are nine
registered clearing agencies, only seven of which are operational.\408\
---------------------------------------------------------------------------

    \408\ See supra note 419.
---------------------------------------------------------------------------

9. Rules 17a-5, 18a-7, and 17a-12
    The respondents to the annual reports collection of information
required under Rule 17a-5 are broker-dealers. For the 12 months ended
December 31, 2022, the Commission received 1,559 filings of the broker-
dealer annual reports in paper and 1,659 electronically via EDGAR. The
Commission therefore estimates that approximately 3,218 broker-dealers
are required to file annual reports with the Commission. As of June 15,
2022, five of those broker-dealers are ANC broker-dealers required to
file supplemental reports under Rule 17a-5. The respondents to the
annual reports collection of information required under Rule 18a-7 are
SBSDs and MSBSPs that are not prudentially regulated. As of June 15,
2022, there are nine SBSDs and MSBSPs that are not prudentially
regulated. The respondents to the annual reports collection of
information under Rule 17a-12 are OTC derivatives dealers. There are
three OTC derivatives dealers subject to Rule 17a-12.
    There are 460 broker-dealers or stand-alone SBS Entities that filed
FOCUS Report Part II as of March 31, 2022. Of those Part II filers, 4
firms are domestic stand-alone swap dealers and 103 firms are domestic
stand-alone introducing brokers. There are 31 bank SBS Entities that
filed FOCUS Report Part IIC as of March 31, 2022. There are 3,056
broker-dealers that filed FOCUS Report Part IIA as of March 31, 2022.
10. Rule 17h-2T
    The respondents to the collection of information required under
Rule 17h-2T are broker-dealers. There are 241 broker-dealers that must
file quarterly and annual risk assessment reports with the Commission
under Rule 17h-2T.
11. Rule 17a-19 and Form X-17A-19
    The respondents to the collection of information required under
Rule 17a-19 are national securities exchanges and registered national
securities associations. As of June 15, 2022, there are a total of 25
national securities exchanges and registered national securities
associations.
12. Rule 3a71-3(d)(1)(vi)
    The Commission estimates that up to 24 entities that engage in
security-based swap dealing activity may rely on the ANE
Exception.\409\ To satisfy the ANE Exception, each of those up to 24
entities will make use of an affiliated Registered Entity that will be
required to file an ANE Exception Notice and may subsequently decide to
file a withdrawal of the ANE Exception Notice. The proposed amendment
to Rule 3a71-3(d)(1)(vi) does not affect Commission's estimate of the
number of respondents.
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    \409\ See Cross-Border Adopting Release, 85 FR at 6336 n.642.
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13. Rule 15fi-3
    The respondents to the collection of information under Rule 15fi-3
are registered SBS Entities. As of January 4, 2023, 50 entities have
submitted applications for registration as an SBSD; there are no
registered MSBSPs.\410\ In a number of prior releases, including the
release adopting the rules by which SBS Entities can register (and
withdraw from registration) with the Commission, the Commission
estimated that approximately 50 entities may meet the definition of
SBSD, and up to five entities may meet the definition of MSBSP.\411\
The Commission continues to believe that these estimates are
appropriate. Thus, the Commission

preliminarily believes that approximately 55 entities will be required
to register with the Commission under either category, and will
therefore be subject to Rule 15fi-3. When the Commission initially
adopted Rule 15fi-3, it noted that, until SBS Entities were registered
with the Commission, it was difficult for the Commission to determine
the typical number of valuation disputes meeting the applicable
thresholds that SBS Entities would be required to submit on an annual
basis.\412\ Because SBS Entities have been required to submit notices
under Rule 15fi-3(c) for a limited time, it remains difficult to for
the Commission to determine the typical number of dispute notices that
an SBS Entity will submit annually.
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    \410\ See List of Registered Security-Based Swap Dealers and
Major Security-Based Swap Participants, available at https://www.sec.gov/tm/List-of-SBS-Dealers-and-Major-SBS-Participants
(providing the list of registered SBS dealers and major SBS
participants that was updated as of Jan. 4, 2023).
    \411\ See Registration Process for Security-Based Swap Dealers
and Major Security-Based Swap Participants, Exchange Act Release No.
75611 (Aug. 5, 2015), 80 FR 48964, 48990 (Aug.14, 2015). See also
Risk Mitigation Adopting Release, 85 FR at 6383; Trade
Acknowledgment and Verification of Security-Based Swap Transactions,
Exchange Act Release No. 78011 (June 8, 2016), 81 FR 39807, 39830
(June 17, 2016); Capital, Margin, and Segregation Requirements for
Security-Based Swap Dealers and Major Security-Based Swap
Participants and Capital and Segregation Requirements for Broker-
Dealers, Exchange Act Release No. 86175 (June 21, 2019), 84 FR
43872, 43960 (Aug. 22, 2019).
    \412\ See Risk Mitigation Adopting Release 85 FR at 6385-86.
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14. Rule 15fk-1(c)(2)(ii)(A)
    The respondents to the collection of information under Rule 15fk-
1(c) are registered SBS Entities. As of January 4, 2023, there are 50
SBS Entities registered with the Commission. Of these entities, the
Commission estimates that none will be first-time EDGAR users needing
to obtain EDGAR access credentials in order to submit its CCO report
because they have already registered as SBS Entities through EDGAR.
15. Regulation S-T
    The respondents to the collection of information under Regulation
S-T are broker-dealers, SBSDs, MSBSPs, OTC derivatives dealers, and
national securities associations and exchanges. The collection of
information requirements are reflected in the burden hours estimated
for Rule 3a71-3, 15fi-3, 15fk-1, 17a-5, 18a-7, 17a-12, 17a-19, and Rule
17h-2T. The rules in Regulation S-T should not impose any separate
burden.

D. Total Initial and Annual Reporting and Recordkeeping Burdens

1. Form ID
Currently Approved Burden Estimate
    Form ID (OMB Control No. 3235-0328) must be completed and filed
with the Commission by all individuals, companies, and other
organizations who seek access to file electronically on EDGAR.
Accordingly, a filer that does not already have access to EDGAR must
submit a Form ID, along with the notarized signature of an authorized
individual, to obtain an EDGAR identification number and access codes
to file on EDGAR. The Commission currently estimates that Form ID would
take 0.30 hours to prepare, resulting in an annual industry-wide burden
of 17,199 hours.\413\
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    \413\ See Supporting Statement for the Paperwork Reduction Act
Information Collection Submission for Form ID (Dec. 20 2021),
available at https://www.reginfo.gov/public/do/PRAViewDocument?ref_nbr=202112-3235-0328.
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Proposed Revision to Burden Estimate
    The Commission estimates that each filer that currently does not
have access to EDGAR would incur an initial, one-time burden of 0.30
hours to complete and submit a Form ID.\414\ Therefore, the Commission
believes the one-time industrywide reporting burden associated with the
proposed requirements to file on EDGAR is 7.2 hours for national
securities exchanges and exempt exchanges; \415\ .6 hours for security
futures product exchanges; \416\ .3 hours for registered national
securities associations; \417\ 3.6 hours for registered and exempt
clearing agencies; \418\ 467.7 hours for broker-dealers not already
filing their annual audits on EDGAR; \419\ 0 hours for OTC derivatives
dealers not already filing their annual audits on EDGAR; \420\ and 7.2
hours for Registered Entities.\421\
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    \414\ The Commission does not estimate a burden for SBS Entities
since these firms have already filed Form ID so they can file Form
SBSE on EDGAR.
    \415\ 0.30 hours x 24 national securities exchanges and exempt
exchanges = 7.2 hours.
    \416\ 0.30 hours x 2 security futures product exchanges = 0.6
hours.
    \417\ 0.30 hours x 1 registered national securities association
= 0.3 hours.
    \418\ 0.30 hours x 12 currently active registered and exempt
clearing agencies = 3.6 hours.
    \419\ 0.30 hours x 1,559 broker-dealers not already filing on
EDGAR = 467.7 hours.
    \420\ 0.30 hours x 0 OTC derivatives dealers not already filing
on EDGAR = 0 hours.
    \421\ 0.30 hours x 24 Registered Entities = 7.2 hours. The
Commission conservatively estimates that none of the Registered
Entities would already have EDGAR access at the time of filing an
ANE Exception Notice or withdrawal of an ANE Exception Notice, even
though most, if not all, Registered Entities already should have
access to electronic filing on EDGAR at the time of filing an ANE
Exception Notice or a withdrawal of an ANE Exception Notice, as they
likely have used or will have used the system to register or file
other information with the Commission. A Registered Entity that is
an SBSD must file its application for registration electronically on
EDGAR, and this requirement has been in place from the original
compliance date for registration of SBSDs. See 17 CFR 240.15Fb2-
1(c). Additionally, a Registered Entity that is a broker may
voluntarily file electronically on EDGAR certain annual reports.
See, e.g., paragraph (d) of Rule 17a-5; supra note 197 and
accompanying text.
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2. Rules 6a-1, 6a-2, 6a-3 and Form 1
Currently Approved Burden Estimate \422\
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    \422\ For an explanation of the collection of information under
these rules and Form 1, see supra section IX.A.2.
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    Initial filings on Form 1 by applicants seeking registration as a
national securities exchange or an exemption from such registration are
made on a one-time basis. The Commission estimates that it would
receive approximately one initial Form 1 filing per year. The
Commission also estimates that each respondent who submits an initial
Form 1 filing would incur an average burden of 880 hours to complete
and file an initial Form 1.\423\ With respect to amendments to Form 1,
the Commission estimates that each registered or exempt exchange would
file 11 amendments or periodic updates to Form 1 per year.\424\ Hours
required for amendments to Form 1 that must be submitted to the
Commission can vary, depending upon the nature and extent of the
amendment, the exchange's corporate structure, and the exchange's
business activities. The Commission estimates that each exchange would
incur an average burden of 25 hours per filing to comply with Rule 6a-
2.\425\ Accordingly, the estimated average annual burden to update and
amend Form 1 is 275 hours per exchange \426\ and the estimated
aggregate annual burden for all national securities exchanges is 6,600
hours.\427\
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    \423\ See FR Doc. 2022-01616, 87 FR 4297 (Jan. 27, 2022)
(Submission for OMB Review; Comment Request, Extension: Rules 6a-1
and 6a-2, Form 1; SEC File 270-0017; OMB Control No. 3235-0017)
(hereinafter ``Rules 6a-1 and 6a-2 PRA Update'').
    \424\ See Rules 6a-1 and 6a-2 PRA Update.
    \425\ See Rules 6a-1 and 6a-2 PRA Update.
    \426\ 11 Form 1 Amendments annually x 25 burden hours per Form 1
Amendment = 275 burden hours per exchange.
    \427\ 275 burden hours per exchange x 24 national securities
exchanges = 6,660 aggregate burden hours.
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    With respect to supplemental information and monthly reports, the
Commission estimates that each exchange would file such materials 12
times per year. The Commission estimates that each exchange would incur
an average burden of 0.5 hours per filing to comply with Rule 6a-
3.\428\ Accordingly, the estimated average annual burden to submit
supplemental information and monthly reports is six hours per exchange
\429\ and the estimated aggregate annual burden for all exchanges is
144 hours.\430\ Thus, the Commission estimates that the total aggregate
annual burden to comply with Rules 6a-2 and 6a-3 is 6,744 hours.\431\
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    \428\ See FR Doc. 2022-07060, 87 FR 19541 (Apr. 4, 2022)
(Submission for OMB Review; Comment Request; Extension: Rule 6a-3;
SEC File 270-0015; OMB Control No. 3235-0021).
    \429\ 12 filings annually x 0.5 hours per filing = 6 burden
hours per exchange.
    \430\ 6 burden hours per exchange x 24 national securities
exchanges = 144 aggregate burden hours.
    \431\ 6,600 burden hours to comply with Rule 6a-2 + 144 burden
hours to comply with Rule 6a-3 = 6,744 aggregate burden hours.

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Proposed Revision to Burden Estimate
    The Commission recognizes that the proposed amendments to Rules 6a-
1, 6a-2, and 6a-3 would impose certain burdens on respondents. Although
the information to be provided on filings made pursuant to Rules 6a-1,
6a-2, and 6a-3 would not change, respondents would be required to
submit documents electronically. The instructions to Form 1 would be
amended to no longer require respondents to make and submit multiple
copies of the Form 1 submission. Currently, respondents must make two
copies of each filing to be submitted pursuant to Rules 6a-1 and 6a-2.
The Commission believes that generally the time spent making such
copies instead would be spent uploading documents on EDGAR. Where a
filing could include multiple exhibits, the Commission believes that
the time required to upload documents would be less than the time
required to make two copies of each exhibit, particularly when the
exhibit contains numerous pages. Accordingly, the Commission estimates
that, on average, filing an initial Form 1 application electronically
would require two fewer hours of clerical work from the current
baseline. The aggregate initial burden on all respondents submitting an
initial Form 1 application electronically would be two hours less than
the current baseline. Accordingly, the Commission believes that the
aggregate initial burden on all respondents to complete and submit an
initial Form 1 application would be 878 hours.\432\ In addition, the
Commission estimates that, on average, filing amendments to Form 1
electronically would require 1 fewer hour of clerical work from the
current baseline, as the amount of material filed pursuant to Rule 6a-2
may be less than an initial Form 1 application. The aggregate ongoing
burden on all exchanges submitting a periodic amendment electronically
would be 264 hours less than the current baseline.\433\ Accordingly,
the Commission believes that the aggregate ongoing burden on all
exchanges to submit periodic amendments to Form 1 electronically would
be 6,336 hours.\434\
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    \432\ 878 burden hours per initial application x 1 initial
application per year = 878 burden hours.
    \433\ Reduction of 1 hour per response x 264 responses per year
= 264 fewer burden hours.
    \434\ 264 burden hours per exchange x 24 national securities
exchanges = 6,336 aggregate burden hours.
---------------------------------------------------------------------------

    With respect to material filed under Rule 6a-3, while in some
instances there may be a marginal reduction in burden hours associated
with submitting these materials electronically as a result of a
reduction in printing requirements, for purposes of making a PRA burden
estimate the Commission believes that, on average, the most recently
approved baseline represents a reasonable estimate of the burden hours
associated with submitting supplemental information and monthly
reports. The Commission believes that the time required to compile
copies of these materials would, on average, be equivalent to the time
required to upload those filings electronically. The Commission
estimates that, on average, filing supplemental information and monthly
reports electronically would not increase or decrease burden hours from
the current baseline of 0.5 hours. Accordingly, the Commission believes
that the aggregate burden associated with filing supplemental
information and monthly reports would be 180 hours.\435\ Thus, the
Commission believes that the total aggregate annual burden to comply
with Rules 6a-2 and 6a-3 would be 7,212 hours.\436\
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    \435\ 0.5 burden hours x 360 responses per year = 180 burden
hours.
    \436\ 7,032 burden hours to comply with Rule 6a-2 + 180 burden
hours to comply with Rule 6a-3 = 7,212 aggregate burden hours.
---------------------------------------------------------------------------

    The Commission also recognizes that the requirement to tag certain
disclosures (specifically, the financial statements and the manner of
operations description) on the initial Form 1 in Inline XBRL would
impose burdens on respondents. To file reports in Inline XBRL, a filer
must purchase Inline XBRL tagging software to apply Inline XBRL tags to
the reports before filing them on EDGAR, or employ a tagging service
provider to apply the Inline XBRL tags on its behalf. As discussed in
further detail below, the Commission believes this burden would be
mitigated for most exchanges, because most exchanges are affiliated
with public reporting companies subject to existing Inline XBRL
structuring requirements and thus may be able to leverage the
compliance software and experience of their reporting affiliates.\437\
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    \437\ See infra section X.C.2. Currently, 17 of the 24 national
securities exchanges are owned by public companies that file
financial statements and cover page disclosures in EDGAR in Inline
XBRL.
---------------------------------------------------------------------------

    The Commission estimates respondents will incur an average of 10
burden hours to tag the initial Form 1 in Inline XBRL (a total annual
industry-wide burden of 10 hours), and an average of 7 burden hours to
tag financial statements included in annual amendments to Form 1 in
Inline XBRL (a total annual industry-wide burden of 168 hours).\438\
With respect to the external monetary costs (e.g., the costs of
purchasing and renewing the necessary software to tag filings in Inline
XBRL) that are incurred in addition to the internal time burden, the
Commission estimates an annual average cost of $2,500 to tag Form 1
(including initial and subsequent filings) in Inline XBRL (a total
annual industry-wide cost of $60,000).\439\
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    \438\ 10 burden hours to tag Exhibits D, E (in part), and I in
initial Form 1 in Inline XBRL x 1 response per year = 10 burden
hours. 7 burden hours to tag financial statements in annual
amendments to Form 1 in Inline XBRL x 24 responses per year = 168
burden hours.
    \439\ $2,500 per year x 24 exchanges = $60,000. See infra
section X.C.2.b for further detail on structured data (Inline XBRL
and custom XML) compliance costs, including estimated cost ranges
and factors underlying expected variance in structured data costs
across different filers. For example, we expect those exchanges
affiliated with public companies that are subject to Inline XBRL
requirements would incur lower structured data costs than other
exchanges. See infra note 638 and accompanying text. We have
accounted for this expected variance in the calculations of average
burden and cost figures presented in this section.
---------------------------------------------------------------------------

    The Commission also recognizes the requirement to structure certain
other disclosures on Form 1 in a custom XML data language would impose
burdens on respondents.\440\ The Commission estimates respondents will
incur an average of 3 burden hours to structure disclosures in initial
Form 1 filings in custom XML (a total annual industrywide burden of 3
hours), and an average of 2 burden hours to structure disclosures in
subsequent Form 1 filings in custom XML (a total annual industrywide
burden of 528 hours).\441\
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    \440\ This does not include the monthly volume reports that
exchanges must file under Rule 6a-3(b) of the Exchange Act, as we
assume exchanges would file those disclosures, which comprise a very
limited number of data points, using a fillable form that EDGAR
would convert to custom XML. See 17 CFR 240.6a-3(b).
    \441\ 3 burden hours to structure disclosures in initial Form 1
filings in custom XML x 1 response per year = 3 burden hours. 2
burden hours to structure disclosures in subsequent Form 1 filings
in custom XML x 264 responses per year = 528 burden hours. Our
estimates assume exchanges would choose to encode the disclosures in
the Exhibits to Form 1 in custom XML and submit the custom XML
documents directly to EDGAR, rather than manually completing
fillable EDGAR forms to be converted into custom XML documents. See
infra text accompanying note 624.
---------------------------------------------------------------------------

    To summarize, the current estimated annual burden to submit filings
pursuant to Rules 6a-1, 6a-2, and 6a-3 is 7,624 hours.\442\ Under the
proposal, the Commission estimates that the annual burden to submit
these filings would be 8,103 hours.\443\ In addition,

the Commission estimates that the total annual industry-wide external
cost of the proposed Inline XBRL requirements related to Form 1 would
be $62,500.\444\
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    \442\ 880 burden hours for Rule 6a-1 + 6,600 burden hours for
Rule 6a-2 + 144 burden hours for Rule 6a-3 = 7,624 burden hours.
    \443\ 891 burden hours for Rule 6a-1 (878 burden hours to file
electronically + 10 burden hours to tag in Inline XBRL + 3 burden
hours to tag in custom XML) + 7,032 burden hours for Rule 6a-2
(6,336 burden hours to file electronically + 168 burden hours to tag
Exhibits in Inline XBRL + 528 burden hours to structure Exhibits in
custom XML) + 180 burden hours for Rule 6a-3 = 8,103 burden hours.
    \444\ $2,500 industry-wide cost for Rule 6a-1 (to tag in Inline
XBRL an initial Form 1 filing) + $60,000 industry-wide cost for Rule
6a-2 (to tag in Inline XBRL periodic updates to Form 1) = $62,500.
---------------------------------------------------------------------------

3. Rule 6a-4, Form 1-N
Currently Approved Burden Estimate \445\
---------------------------------------------------------------------------

    \445\ For an explanation of the collection of information under
Rule 6a-4 and Form 1-N, see supra section IX.A.3.
---------------------------------------------------------------------------

    Initial filings on Form 1-N by futures exchanges submitting notice
registration as a national securities exchange solely for the purpose
of trading security futures products are made on a one-time basis. The
Commission estimates that it would receive zero initial Form 1-N filing
per year.\446\ The Commission estimates that the total burden for all
respondents to file initial Form 1-N filings per year would be 0 hours
(31 hours/respondent/year x 0 respondents). The Commission estimates
that the total annual burden for all respondents to provide periodic
amendments \447\ to keep the Form 1-N accurate and up to date as
required under Rule 6a-4(b)(1) would be 30 hours (15 hours/respondent
per year x 2 respondents). The Commission estimates that the total
annual burden for all respondents to provide annual amendments under
Rule 6a-4(b)(3) would be 30 hours (15 hours/respondent/year x 2
respondents). The Commission estimates that the total annual burden for
all respondents to provide triennial amendments \448\ under Rule 6a-
4(b)(4) would be 13 hours (20 hours/response x 2 responses every three
years). The Commission estimates that the total annual burden for the
filing of the supplemental information \449\ and the monthly reports
required under Rule 6a-4(c) would be 12 hours (6 hours/respondent per
year x 2 respondents). Thus, the Commission estimates the total annual
burden for complying with Rule 6a-4 is 86 hours.
---------------------------------------------------------------------------

    \446\ The Commission is basing its estimate on its historical
experience with Form 1-N filings. In particular, since the adoption
of the form in 2001, six initial Form 1-N filings have been made by
futures exchanges. Based on the infrequent occurrence of filings,
the Commission believes that zero is a reasonable estimate.
    \447\ 17 CFR 240.6a-4(b)(1).
    \448\ 17 CFR 240.6a-4(b)(3) and (4).
    \449\ 17 CFR 240.6a-4(c).
---------------------------------------------------------------------------

Proposed Revision to Burden Estimate
    The Commission recognizes that the proposed amendments to Rule 6a-4
would impose certain burdens on respondents. Although the information
to be provided on filings made pursuant to Rule 6a-4 would not change,
respondents would be required to submit documents electronically. The
instructions to Form 1-N would be amended to no longer require
respondents to make and submit multiple copies of the Form 1-N
submission. Currently, respondents must make two copies of each filing
in addition to the original Form 1-N to be submitted pursuant to Rule
6a-4. The Commission believes that, generally, the time spent making
such copies instead would be spent uploading documents through EDGAR.
Where a filing could include multiple exhibits, the Commission believes
that, generally, the time required to upload documents would be less
than the time required to make two copies of each exhibit, particularly
when the exhibit contains numerous pages.
    The Commission estimates that, on average, filing an initial Form
1-N filing electronically would require, generally, two fewer hours of
clerical work from the current baseline. Therefore, instead of 31
hours, an initial filing would require 29 hours. However, because the
Commission estimates that there will be zero respondents submitting
initial filings, the burden would remain zero hours (29 hours/
respondent/year x 0 respondents/year).
    The Commission estimates that, on average, periodic amendments to
Form 1-N electronically would require 1 fewer hour of clerical work
from the current baseline. The aggregate ongoing burden on all
respondents submitting periodic amendments electronically would be two
hours fewer than the current baseline. Accordingly, the Commission
estimates that the aggregate burden on all respondents to submit
periodic amendments to Form 1-N would be 28 hours (14 hours/respondent/
year x 2 respondents).
    Similarly, the Commission estimates that, on average filing annual
amendments to Form 1-N electronically would require 1 fewer hour of
clerical work from the current baseline. The aggregate burden on all
respondents submitting annual amendments electronically would be two
hours fewer than the current baseline. Accordingly, the Commission
estimates that the aggregate burden on all respondents to provide
annual amendments to Form 1-N would be 28 hours (14 hours/respondent/
year x 2 respondents).
    The Commission estimates that, on average, filing triennial
amendments to Form 1-N would require 1 fewer hour of clerical work from
the current baseline. Accordingly, the Commission estimates that the
total annual burden for all respondents to provide triennial amendments
to Form 1-N would be 13 hours \450\ (19 hours/response x 2 respondents
per year x .33 responses per year).
---------------------------------------------------------------------------

    \450\ Even with the one hour per response reduction, the annual
total burden would still be 13 hours due to rounding. The annual
burden would be reduced from 13.33 to 12.67, which both round to 13
hours.
---------------------------------------------------------------------------

    With respect to supplemental material filed under Rule 6a-4, while
in some instances there may be a marginal reduction in burden hours
associated with submitting these materials electronically as a result
of a reduction in printing requirements, for purposes of making a PRA
burden estimate the Commission believes that, on average, the most
recently approved baseline represents an appropriate estimate of the
burden hours associated with submitting supplemental information and
monthly reports. The Commission believes that the time required to
compile copies of these materials would, on average, be equivalent to
the time required to upload those filings electronically. The
Commission estimates that, on average, filing supplemental information
and monthly reports electronically would not increase or decrease
burden hours from the current baseline of six hours/respondent/year.
Accordingly, the Commission believes that the aggregate burden
associated with filing supplemental information and monthly reports
would continue to be 12 hours. Thus, the Commission believes that the
total aggregate annual burden to comply with Rule 6a-4 would be 81
hours.\451\
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    \451\ The Commission currently estimates that compliance with
Form 1-N and Rule 6a-4 results in $304 of annual clerical costs
(i.e., mailing forms and copying forms etc.). The Commission
estimates that these costs would be eliminated with the electronic
filing of Form 1-N.
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4. Rules 15aa-1 and 15aa-2; Form 15A
    Initial filings on proposed Form 15A by an applicant seeking
registration as a national securities association are made on a one-
time basis.\452\ The Commission estimates that it would receive one
initial Form 15A filing per year.\453\ Because the Commission believes
that the filing of an initial Form 15A would be substantially similar
to an initial Form 1 filing, the Commission estimates that each
respondent would incur an

average burden of 878 hours to complete and file an initial Form
15A.\454\
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    \452\ For an explanation of the collection of information under
Rules 15Aa-1 and 15Aj-1 that are being redesignated as Rules 15aa-1
and 15aa-2 and Forms X-15AA-1, X-15AJ-1, and X-15AJ-2 that are being
redesignated as Form 15A, see supra section IX.A.4.
    \453\ See Exchange Act Rule 15aa-1, 17 CFR 240.15aa-1 and 17 CFR
249.801.
    \454\ See FR Doc. 2019-04007, 84 FR 8138 (Mar. 6, 2019) (Request
to OMB for Extension of Rule 6a-1, Rule 6a-2 and Form 1; SEC File
270-0017; OMB Control No. 3235-0017) (hereinafter ``Rules 6a-1 and
6a-2 PRA Update''). The Commission currently estimates that an
initial Form 1 filing would incur an average burden of 880 hours,
less the efficiencies contemplated in this propose that no longer
require the submission of duplicate paper copies (a reduction of 2
burden hours per respondent). See supra section IX.D.2.
---------------------------------------------------------------------------

    Based on the number of applications for registration as a national
securities association the Commission has received, the Commission
estimates that it will receive not more than one initial Form 15A
filing per year. The Commission estimates that a respondent would incur
an average burden of 878 hours to file an initial Form 15A.
    With respect to the proposed amendments to proposed Form 15A, the
Commission estimates that each registered association would file 11
amendments or periodic updates to Form 15A per year.\455\ Hours
required for amendments to Form 15A that must be submitted to the
Commission can vary, depending upon the nature and extent of the
amendment, the association's corporate structure, and the association's
business activities. The Commission estimates that an association would
incur an average burden of 24 hours per filing to comply with Rule
15aa-2.\456\ Accordingly, the estimated average annual burden to update
and amend Form 15A is 264 hours per association \457\ for an estimated
aggregate annual burden for all national securities associations of 264
hours.\458\
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    \455\ The Commission believes that the requirements of Rule
15aa-2 are substantively similar to the requirements of Rules 6a-1
and 6a-2. As a result, the Commission believes it can rely on the
past history of amendments and periodic updates submitted under
those rules in determining its estimate of the number of amendments
the Commission will receive under Rule 15A. The Commission estimates
that each registered or exempt exchange would file 11 amendments or
periodic updates to Form 1 per year. The Commission believes that
using an estimate of 11 amendments or periodic updates for Form 15A
is appropriate.
    \456\ Attorney at 10 hours + Accountant at 10 hours + Compliance
Clerk at 4 hours = 24 burden hours. The instructions to Form 15A
would be amended to no longer require respondents to make and submit
multiple copies of the Form 15A submission. Currently, respondents
must make two copies of each filing to be submitted pursuant to Rule
15Aa-1 and 15Aaj-1. The Commission believes that the time spent
making such copies instead would be spent uploading documents
through EDGAR. Where a filing could include multiple exhibits, the
Commission believes that the time required to upload documents would
be less than the time required to make two copies of each exhibit,
particularly when the exhibit contains numerous pages. The
Commission estimates that, on average, filing amendments to Form 15A
electronically would require 1 fewer hour of clerical work compared
to the submission of physical copies as contained in the most recent
PRA updates for Rule 6a-1 and 6a-2.
    \457\ 11 Form 15Aa-2 Amendments annually x 24 burden hours per
Form 15A Amendment = 264 burden hours per association.
    \458\ 264 burden hours per association x 1 national securities
association = 264 aggregate burden hours.
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5. Rule 17ab2-1, Form CA-1
Currently Approved Burden Estimate
    The Commission has previously discussed the requirements of Rule
17ab2-1 and Form CA-1 above in IX.A.5.
    The Commission estimates that, on average, each initial Form CA-1
requires approximately 340 hours to complete and submit for approval,
and that, on average, the Commission receives one application each
year.\459\ This burden is composed primarily of a one-time reporting
burden that reflects the applicant's staff time to prepare and submit
the Form CA-1 to the Commission.\460\ With respect to amendments to
Form CA-1, the Commission estimates that, on average, an amendment
requires 60 hours of the exempt or registered clearing agency's staff
time,\461\ although the time burden related to preparing and submitting
an amendment widely varies depending on the nature of the information
that needs to be updated. The Commission estimates that, on average, it
receives one amendment per year. Accordingly, the Commission estimates
that the aggregate annual burden associated with compliance with Rule
17ab2-1 and Form CA-1 is 400 hours.
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    \459\ See FR Doc. 2020-18498, 85 FR 52178 (Aug. 24, 2020)
(Request to OMB for Extension of Rule 17Ab2-1 and Form CA-1; SEC
File No. 270-203; OMB Control No. 3235-0195).
    \460\ Compliance Attorney at 300 hours + Chief Compliance
Officer at 40 hours = 340 burden hours.
    \461\ Compliance Attorney at 40 hours + Chief Compliance Officer
at 20 hours = 60 burden hours.
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Proposed Revision to Burden Estimate
    The Commission recognizes that the proposed amendments to Rule
17ab2-1 would impose certain burdens on respondents. Although the
information to be provided on filings made pursuant to Rule 17ab2-1
would not change, respondents would be required to submit documents
electronically. The instructions to Form CA-1 would be amended to no
longer require respondents to make and submit multiple copies of the
same form. Currently, respondents must make four copies of Form CA-1.
The Commission believes that the time spent making such copies would
now be spent uploading documents through EDGAR. Where a filing may
include multiple exhibits, the Commission believes that the time
required to upload documents would be slightly less than the time
required to make copies of each exhibit. As the number of exhibits
required to be submitted with Form CA-1 is roughly equivalent to the
number of exhibits required by an initial Form 1 application, the
Commission believes that the overall burden is two hours less (for
either an initial application or an amendment) to make an electronic
filing, compared to making the paper copies. Thus, the Commission
believes that the aggregate annual burden associated with compliance
with Rule 17ab2-1 and Form CA-1, other than the structuring requirement
discussed below, would be approximately 396 hours.
    The Commission also recognizes that the requirement to file Form
CA-1 in Inline XBRL (in part) and in custom XML (in part) would impose
burdens on respondents.\462\ The Commission estimates respondents would
incur an average of 18 burden hours to structure financial statements
and narrative disclosures in initial applications on Form CA-1 in
Inline XBRL (resulting in a total annual industry-wide burden of 18
hours) and an average of 12 burden hours to structure financial
statements and narrative disclosures in subsequent amendments on Form
CA-1 in Inline XBRL (resulting in a total annual industry-wide burden
of 12 hours).\463\ The Commission further estimates respondents would
incur average annual external monetary costs (e.g., the cost of
purchasing and renewing the necessary Inline XBRL tagging software) of
$3,500 to structure financial statements and narrative disclosures
included in Form CA-1 in Inline XBRL (resulting in a total annual
industry-wide burden of an average of $3,500).\464\ The Commission
estimates respondents would incur an average of 3 burden hours to
structure other disclosures in initial applications on Form CA-1 in a
custom XML data language (resulting in a total annual industry-wide
burden of

3 hours) and an average of 2 burden hours to structure those
disclosures in subsequent amendments on Form CA-1 in custom XML
(resulting in a total annual industry-wide burden of 2 hours).\465\ The
proposed structured data requirements for Form CA-1 would thus entail
an estimated total annual industry-wide burden of 21 burden hours and
$3,500 in external monetary costs for initial applications, and an
estimated total annual industry-wide burden of 14 burden hours and
$3,500 in external monetary costs for subsequent amendments.\466\
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    \462\ The proposed amendments would require Schedule A and
Exhibits C, F, H, J, K, L, M, O, R, and S of Form CA-1 to be
structured in Inline XBRL, and would require the execution page and
Exhibits A (in part), B, D, E (in part), I, N, and Q to be
structured in custom XML. See supra notes 34-36 and accompanying
text; see also supra section VII.A.
    \463\ 18 hours per initial application x 1 initial application
per year = 18 aggregate burden hours. 12 hours per subsequent
amendment x 1 subsequent amendment per year = 12 aggregate burden
hours.
    \464\ $3,500 per initial application x 1 initial application per
year = $3,500 aggregate cost per year. $3,500 per subsequent
amendment x 1 subsequent amendment per year = $3,500 aggregate cost
per year.
    \465\ 3 hours per initial application x 1 initial application
per year = 3 aggregate burden hours per year. 2 hours per subsequent
amendment x 1 subsequent amendment per year = 2 aggregate burden
hours per year. Our estimates assume clearing agencies would choose
to encode their disclosures in custom XML and submit the custom XML
documents directly to EDGAR, rather than manually completing
fillable EDGAR forms to be converted into custom XML documents. See
infra text accompanying note 624. Consistent with burden estimates
in prior Commission releases, the burden estimates here assume
Inline XBRL tagging would be done by a compliance attorney, while
custom XML structuring would be done by a programmer. See Shortening
the Securities Transaction Settlement Cycle, Release No. 34-94196
(Feb. 9, 2022), 87 FR 10436, 10491 (Feb. 24, 2022); Money Market
Fund Reforms, Release No. IC-34441 (Dec. 15, 2021), 87 FR 7248, 7332
(Feb. 8, 2022).
    \466\ 18 hours and $3,500 for Inline XBRL structuring + 3 hours
for custom XML structuring = 21 hours and $3,500 per initial
application) x 1 initial application per year = 21 aggregate burden
hours per year and $3,500 in aggregate external monetary cost per
year. 12 hours and $3,500 for Inline XBRL structuring + 2 hours for
custom XML structuring per subsequent amendment = 14 hours and
$3,500 per subsequent amendment x 1 subsequent amendment per year =
14 aggregate burden hours per year and $3,500 in aggregate external
monetary cost per year. See infra Section X.C.2.b for further detail
on structured data (Inline XBRL and custom XML) compliance costs,
including estimated cost ranges and factors underlying expected
variance in structured data costs across different filers.
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6. Rule 19b-4(e), Form 19b-4(e)
Currently Approved Burden Estimate
    The Commission's currently approved estimate to complete and submit
one Form 19b-4(e) is 1 hour, for an aggregate annual burden of 2,331
hours.\467\
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    \467\ See FR Doc. 2022-17308, 87 FR 49894 (Aug. 12, 2022)
(Request to OMB for extension of Rule 19b-4(e) and Form 19b-4(e);
SEC File No. 270-447; OMB Control No. 3235-0504).
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Proposed Revision to Burden Estimate
    The proposed amendment to Rule 19b-4(e) rescinding Form 19b-4(e)
and instead requiring an SRO to publicly report the information
currently provided in Forms 19b-4(e) on its internet website would
impose certain burdens on respondents. Respondents would be required to
use the most recent versions of the XML schema (i.e., data language)
and the associated PDF renderer as published on the Commission's
website to post the information required under proposed Rule 19b-4(e)
for each new derivative securities product. Currently, respondents must
make nine copies of Form 19b-4(e); however, the form consists of a
single page and does not require respondents to submit exhibits. In
some instances there may be a marginal change in burden hours
associated with posting the same information as is required on current
Form 19b-4(e) on a respondent's website. However, given the relatively
small amount of data to be structured, rendered, and posted for each
new derivative securities product, for purposes of making a PRA burden
estimate the Commission believes that, on average, the proposed
requirement to structure the information in a custom XML data language,
render it using the associated PDF renderer, and post it on a
respondent's website would continue to be 1 burden hour for each new
derivative securities product, and that the time to structure, render
and post the first new derivative securities product per respondent
would be an additional 0.5 hours. Accordingly, the Commission believes
that the total additional initial hour burden would be 12 hours and the
total annual hour burden would continue to be 2,331 hours per year
associated with the structuring, rendering, and posting of information
under proposed Rule 19b-4(e).\468\ The Commission does not estimate
respondents would incur external monetary costs under proposed Rule
19b-4(e).
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    \468\ 0.5 burden hours per first response for structuring,
rendering, and posting x 24 respondents) = 12 hours. 1 burden hour
per response for structuring, rendering, and posting in subsequent
years x 2,331 responses) = 2,331 hours. See also infra Section
X.C.2.b, including the text accompanying note 650 (discussing
estimated cost ranges related to the proposed structuring
requirement for Rule 19b-4(e) information). Consistent with
structured data burden estimates in prior Commission releases, the
burden estimates here assume the custom XML structuring would be
done by a programmer. See supra note 485.
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7. Rule 19b-4(j), Form 19b-4
Currently Approved Burden Estimate
    The Commission's currently approved estimated response burden
pursuant to Rule 19b-4 and Form 19b-4 for the 42 respondents is an
aggregate burden of 91,300 hours.\469\
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    \469\ See FR Doc. 2019-22222, 84 FR 54710 (Oct. 10, 2019)
(Request to OMB for extension of Rule 19b-4 and Form 19b-4; SEC File
No. 270-38; OMB Control No. 3235-0045).
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Proposed Revision to Burden Estimate
    The Commission believes that, on average, the removal of the manual
signature and retention requirement would not increase or decrease the
burden hours associated with continuing to file Form 19b-4
electronically because the manual signature and retention requirement
is only a small component of the filing requirement. Accordingly, the
Commission believes that the aggregate burden for SROs associated with
complying with Rule 19b-4 and filing Form 19b-4 would continue to be
91,300 hours.
8. Rule 17a-22
Currently Approved Burden Estimate \470\
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    \470\ The Commission has previously discussed the requirements
of Rule 17a-22 in IX.A.8, supra.
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    The Commission estimates that it receives, on average,
approximately 840 filings per year pursuant to Rule 17a-22.\471\
Although the frequency of filings made by registered clearing agencies
pursuant to Rule 17a-22 varies, the Commission estimates that, on
average, each registered clearing agency submits approximately 120
filings per year.\472\ The Commission estimates that, on average, each
filing requires approximately 0.25 hours (fifteen minutes).\473\ This
figure represents the time it takes for a staff person at a registered
clearing agency to: (i) properly identify a document subject to the
rule; (ii) print and make copies of the document; and (iii) mail the
copies to the Commission and, where applicable, the ARA.\474\
Accordingly, the Commission estimates that the aggregate annual burden
to comply with Rule 17a-22 is 210 hours.\475\ Further, the Commission
estimates that each registered clearing agency will expend a

total of 30 hours per year to comply with Rule 17a-22.\476\
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    \471\ This figure is based on the number of aggregate filings
received by the Commission in 2017, which was the last year for
which the Commission had compiled data at the time of the Rule 17a-
22 PRA update in 2020.
    \472\ See FR Doc. 2020-08336, 85 FR 21910 (Apr. 20, 2020)
(Request to OMB for Extension of Rule 17a-22; SEC File No. 270-202;
OMB Control No. 3235-0196). Given the variability in the number of
filings per clearing agency received each year, the Commission
estimated an average of 120 annual filings per clearing agency by
averaging the approximate number of filings received in the most
recent year for which the Commission has obtained data (840 filings)
by the number of registered clearing agencies (7 clearing agencies).
    \473\ See id.
    \474\ Although current Rule 17a-22 requires duplicate filings
when the Commission is not a registered clearing agency's ARA, the
Commission believes that the additional burden of making a duplicate
filing would be minimal because the rule applies only to materials
that have already been published by the registered clearing agency.
    \475\ 7 registered clearing agencies x 120 responses per
clearing agency x .25 hours = 210 burden hours.
    \476\ 840 total responses x .25 hours/7 active clearing agencies
= 30 burden hours.
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Proposed Revision to Burden Estimate
    The Commission recognizes that the proposed amendments to Rule 17a-
22 would impose certain burdens on respondents. Although the scope of
supplemental materials subject to Rule 17a-22 would not change,
respondents would be required to prominently post certain supplemental
materials on their internet websites within two business days after
issuing, or making generally available, such materials to their
participants or other entities with whom they have a significant
relationship. Currently, respondents must file with the Commission
three paper copies of certain supplemental materials issued, or made
generally available, to their participants or other entities with whom
they have a significant relationship within 10 days after issuing, or
making generally available, such materials. In addition, when the
Commission is not a respondent's ARA, the respondent must file at the
same time one paper copy of the materials with its ARA.
    While there may be a marginal reduction in burden hours associated
with replacing the paper filing requirement under Rule 17a-22 with an
electronic filing requirement via a registered clearing agency's
website, the Commission believes that, for purposes of making a PRA
burden estimate, the current baseline represents a reasonable estimate
of the burden hours associated with filing supplemental materials. The
Commission believes that the time required to compile and mail copies
of supplemental materials would, on average, be equivalent to the time
required to post these materials on a clearing agency's website such
that they would be readily identifiable and accessible on the
website.\477\ Moreover, the Commission believes that reducing the
timeframe under Rule 17a-22 from 10 days to 2 business days would not
increase the burden hours associated with compliance with Rule 17a-22.
The Commission estimates that, on average, filing supplemental
materials electronically via a registered clearing agency's internet
website would not increase or decrease burden hours from the current
baseline of 0.25 hours. Accordingly, the Commission believes that each
registered clearing agency will continue to expend a total of 30 hours
per year to comply with Rule 17a-22.\478\ Thus, the Commission believes
that the aggregate annual burden associated with compliance with Rule
17a-22 would continue to be 210 hours.\479\
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    \477\ See Section III.D.3. (explaining the Commission's
interpretation of the requirement to ``prominently post''
supplemental materials on a clearing agency's website pursuant to
the proposed amendments to Rule 17a-22).
    \478\ 840 total responses x .25 hours/7 active clearing agencies
= 30 burden hours.
    \479\ 7 registered clearing agencies x 120 responses per
clearing agency x .25 hours = 210 burden hours.
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9. Rules 17a-5, 18a-7, and 17a-12
a. Requirement To File Annual Reports on EDGAR Using Structured Data
Currently Approved Burden Estimate
    Rules 17a-5, 17a-12, and 18a-7 require broker-dealers, OTC
derivatives dealers, and SBS Entities that are not prudentially
regulated, respectively, to file annual reports, including financial
statements and supporting schedules that must be audited by a PCAOb-
registered independent public accountant in accordance with PCAOB
standards. Under Rule 17a-5, each broker-dealer is estimated to have an
annual reporting burden of 12 hours, resulting in an annual industry
burden of 44,148 hours.\480\ Under Rule 17a-12, each OTC derivatives
dealer is estimated to have an annual reporting burden of 100 hours,
resulting in an annual industry burden of 200 hours.\481\ Under Rule
18a-7, each MSBSP is estimated to have an annual reporting burden of 10
hours, resulting in an annual industry burden of 40 hours and each SBSD
is estimated to have an annual reporting burden of 17 hours, resulting
in an annual industry burden of 102 hours.\482\
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    \480\ See Supporting Statement for the Paperwork Reduction Act
Information Collection Submission for Rule 17a-5 (July 29, 2021),
available at https://www.reginfo.gov/public/do/PRAViewDocument?ref_nbr=202107-3235-022.
    \481\ See Supporting Statement for the Paperwork Reduction Act
Information Collection Submission for Rule 17a-12 (Jan. 11, 2022),
available at https://www.reginfo.gov/public/do/PRAViewDocument?ref_nbr=202110-3235-010.
    \482\ See Supporting Statement for the Paperwork Reduction Act
Information Collection Submission for Rule 18a-7 (Apr. 15, 2021),
available at https://www.reginfo.gov/public/do/DownloadDocument?objectID=110893201.
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Proposed Revision to Burden Estimate
    In the context of Nationally Recognized Statistical Rating
Organizations (``NRSROs''), the Commission estimated that it would take
an NRSRO, on average, sixteen hours on a one-time basis to become
familiar with the EDGAR system.\483\ The Commission believes that this
estimate would also apply to entities that are new filers on EDGAR
under the proposed amendments to Rules 17a-5, 18a-7, and 17a-12.
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    \483\ See Nationally Recognized Statistical Rating
Organizations, Release No. 72936 (Aug. 27, 2014), 79 FR 55077,
55235-6 (Sept. 15, 2014).
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    As stated above, the Commission estimates that for the 12 months
ended December 31, 2022, the Commission received 1,559 filings of the
annual reports required by paragraph (d) of Rule 17a-5 in paper.\484\
Based on this estimate, the Commission estimates that approximately
1,559 broker-dealers that are required to file annual reports with the
Commission will be new EDGAR filers. The broker-dealers that have filed
annual reports on EDGAR have EDGAR access credentials and are familiar
with the mechanics of filing on EDGAR. The Commission estimates the one
time industry-wide burden for broker-dealers to acquire EDGAR access
and familiarize themselves with EDGAR would be approximately 24,944
hours.\485\ ANC broker-dealers must also file annual reports under the
proposed amendments to Rule 17a-5, so there would be no additional
burden attributable to requiring the electronic filing on EDGAR of ANC
broker-dealer supplemental reports under paragraph (k) of Rule 17a-5.
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    \484\ See supra section IV.A.1.
    \485\ 1,559 broker-dealers x 16 hours = 24,944 hours.
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    In addition, as stated above, the Commission estimates that nine
non-bank SBSDs and MSBSPs would be required to file annual reports
under proposed paragraph (c) of Rule 18a-7 and that these firms would
be new EDGAR filers. However, since these firms are already filing Form
SBSE on EDGAR, the Commission does not estimate any burden for these
firms to familiarize themselves with EDGAR.
    The Commission estimates that the one-time burden for an OTC
derivatives dealer to familiarize itself with EDGAR would be
approximately 16 hours. However, because all three OTC derivatives
dealers already voluntarily file their annual reports on EDGAR, the
Commission estimates that the one-time industry-wide burden would be
zero hours.
    The current PRA burden for paragraph (d) of Rule 17a-5 includes an
annual industry-wide cost of approximately $28,512 in postage costs to
mail the annual reports to the Commission and the current PRA burden
for paragraph (k) of Rule 17a-5 includes an annual industry-wide cost
of approximately $85 in postage costs to mail the supplemental reports
to the Commission. Under the proposal, broker-dealers would no longer
incur these costs. Under the proposal, broker-dealers, OTC derivatives
dealers, SBSDs, and MSBSPs filing their annual

reports electronically must keep the original notarized oath or
affirmation for a period of not less than six years, the first two
years in an easily accessible place. The Commission believes that the
proposed requirement to keep the notarized oath or affirmation would
not materially increase a broker-dealer's recordkeeping burden.
    Under the proposal, broker-dealers, OTC derivatives dealers, SBSDs,
and MSBSPs would be required to file their annual reports and related
filings (including compliance reports, exemption reports, accountant's
reports, and supplemental reports) in Inline XBRL. To file reports in
Inline XBRL, a filer must purchase Inline XBRL tagging software to
apply Inline XBRL tags to the reports before submitting them to EDGAR,
or employ a tagging service provider to apply the Inline XBRL tags to
the reports on its behalf. As described in further detail in the
subsequent economic analysis of proposed structured data requirements,
the Commission expects the burdens associated with tagging the annual
reports and related filings in Inline XBRL will vary based on the size
of the respondent and whether the respondent is affiliated with a
public reporting company that is already subject to Inline XBRL
requirements.\486\
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    \486\ See infra Section X.C.2.b, including the text accompanying
notes 632-634 and 639. We have accounted for this expected variance
in the calculations of average burden and cost figures presented in
this section. We have accounted for this expected variance in the
calculations of average burden and cost figures presented in this
section. Consistent with structured data burden estimates in prior
Commission releases, the burden estimates here assume Inline XBRL
tagging would be done by a compliance attorney. See supra note 485.
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    On average, we estimate respondents will incur 6 burden hours and
$1,200 in external cost for the first response to be tagged in Inline
XBRL, and will incur 4 burden hours and $800 in external cost to tag
subsequent responses in Inline XBRL. Therefore, the Commission
estimates the total initial industry-wide internal burden and external
cost would be 19,308 hours and $3,861,600 for broker-dealers (including
OTC derivatives dealers); and the total initial industry-wide internal
burden and external cost would be 54 hours and $10,800 for SBSDs and
MSBSPs.\487\ The Commission estimates the total ongoing annual
industry-wide internal burden and external cost would be 12,872 hours
and $2,574,400 for broker-dealers (including OTC derivatives dealers);
and 36 hours and $7,200 for SBSDs and MSBSPs.\488\
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