Rule 15c3-3 provides for the
protection of customer funds and securities in the custody of a
broker-dealer. The Rule sets forth standards for (i) a
broker-dealer's acceptance, custody, and use of customer
securities, and (ii) the maintenance of reserves with respect to
customer deposits and monies obtained from the use of customer
securities. The Commission is adopting new requirements designed to
eliminate conflicting and duplicative customer protection,
recordkeeping, and reporting regulations applicable to security
futures products.
a. Burdens The annual
record-keeping hour burden of 77,166 hours listed on OMB Form 83-I
reflects a 41,385 decrease from the current OMB inventory of
118,551 hours. This change is due to a decrease in the number of
broker-dealers and a decrease in the number of accounts of
broker-dealers subject to paragraph (o) of Rule 15c3-3, but is
partially offset by an increase in the number of notices filed each
year. Due to the fact that the calculation of burden hours is based
on a number of factors (e.g., some respondents must make weekly
calculations and others make monthly calculations, and certain of
the burden hours are based on the number of accounts held by a
distinct few of those respondents) for purposes of the Form 83-I,
the staff has divided the total number of annual burden hours
(77,166) by the number of respondents (344) to reach a number of
hours per respondent (224.32). This was broken down by reporting
(relating to the notices filed with the Commission) and
recordkeeping (all other requirements described above). Reporting
of 33 total hours divided by 334 equals approximately .09 hours per
respondent, and 224.32 - .09 = 224.23. b. Costs The annual
reporting and record-keeping cost burden of $447,150 each year as
listed on OMB Form 83-I is $622,850 less than the current OMB
inventory of $1,070,000. This decrease is due to the decrease in
the number of accounts held by broker-dealers subject to paragraph
(o) of Rule 15c3-3. Due to the fact that the calculation of costs
is based on a number of factors that are not directly related to
the calculation of burden hours above, for purposes of the Form
83-I, the staff has divided the total costs ($447,150) by the
number of respondents (344) to reach a number of cost per
respondent ($1,299.85). All of those costs related to reporting of
information to customers.
$0
No
No
Uncollected
Uncollected
Uncollected
Uncollected
Bonnie Gauch 202
942-0765
No
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.
Rule 15c3-3 Supporting Statement.doc
Customer Protection - Reserves and Custody of Securities (17 CFR 240.15c3-3)