Attachment 1

Attachment 1: Estimated burden cost

(Each regulation is described in the response to Question 12)

Entity	Annual burden hours (per entity)	Annual cost (per entity)	Aggregate annual burden hours (all entities)	Aggregate annual cost (all entities)
15 SDRs	235	$17,855	3,525	$267,823
40 SEFs	1,790	$286,004	71,600	$11,440,168
18 DCMs	1,790	$286,004	32,220	$5,148,076
12 DCOs	3,870	$444,043	46,440	$5,328,511
125 SD/MSPs	1,411	$207,208	176,375	$25,900,973
250 Non-SD/MSPs[1]	463	$160,179	115,750	$40,044,685

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⁴As explained in response to questions 5 and 12, there are an estimated 30,000 non-SD/MSP counterparties. However, the Commission estimates that only 1,000 of these non-SD/MSP counterparties serve as reporting counterparties and that the majority of these reporting non-SD/MSP counterparties, estimated to be 75% (or 750 counterparties), contract with a third-party service provider to fulfill their reporting obligations. The Commission cannot readily quantify the fees charged by third-party vendors to provide this service; however, the costs to the estimated 250 non-SD/MSP reporting counterparties that will perform their own reporting are presented in this table.