Notice2022-12018
Submission for OMB Review; Comment Request; Extension: Form N-MFP and Rule 30b1-7
Primary source
Metadata and text below are from the Federal Register, a public-domain U.S. government work. Always verify the official published version before relying on it for any legal matter.
Published
June 6, 2022
Issuing agencies
Securities and Exchange Commission
Full Text
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<title>Federal Register, Volume 87 Issue 108 (Monday, June 6, 2022)</title>
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[Federal Register Volume 87, Number 108 (Monday, June 6, 2022)]
[Notices]
[Pages 34330-34332]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2022-12018]
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SECURITIES AND EXCHANGE COMMISSION
[SEC File No. 270-604, OMB Control No. 3235-0657]
Submission for OMB Review; Comment Request; Extension: Form N-MFP
and Rule 30b1-7
Upon Written Request, Copies Available From: Securities and Exchange
Commission, Office of FOIA Services, 100 F Street NE, Washington, DC
20549-2736
Notice is hereby given that, pursuant to the Paperwork Reduction
Act of 1995 (44 U.S.C. 3501 et seq.), the Securities and Exchange
Commission (the ``Commission'') has submitted to the Office of
Management and Budget (``OMB'') a request for extension of the
previously approved collection of information discussed below.
Section 30(b) of the Investment Company Act of 1940 (``Investment
Company Act'') \1\ provides that ``[e]very registered investment
company shall file with the Commission . . . such information,
documents, and reports (other than financial statements), as the
Commission may require to keep reasonably current the information and
documents contained in the registration statement of such company. . .
.'' \2\ Rule 30b1-7 under the Investment Company Act, entitled
``Monthly Report for Money Market Funds,'' provides that every
registered investment company, or
[[Page 34331]]
series thereof, that is regulated as a money market funds under rule
2a-7 \3\ must file with the Commission a monthly report of portfolio
holdings on Form N-MFP \4\ no later than the fifth business day of each
month.\5\ Form N-MFP sets forth the specific disclosure items that
money market funds must provide. Filers must submit this report
electronically using the Commission's electronic filing system
(``EDGAR'') in Extensible Markup Language (``XML'').
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\1\ 15 U.S.C. 80a-1 et seq.
\2\ 15 U.S.C. 80a-29(b).
\3\ 17 CFR 270.2a-7.
\4\ 17 CFR 274.201.
\5\ 17 CFR 270.30b1-7.
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Compliance with rule 30b1-7 is mandatory for any fund that holds
itself out as a money market fund in reliance on rule 2a-7. Responses
to the disclosure requirements will not be kept confidential. 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.
The following estimates of average burden hours and costs are made
solely for purposes of the Paperwork Reduction Act and are not derived
from a comprehensive or even representative survey or study of the cost
of Commission rules and forms.
The Commission calculates there are currently 353 \6\ money market
funds that report information on Form N-MFP, with approximately 8 \7\
of them being new money market funds that are filing reports on Form N-
MFP for the first time.
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\6\ This calculation is based on staff review of reports on Form
N-MFP filed with the Commission for the month ended December 31,
2021 and includes both feeder and non-feeder money market funds.
\7\ This estimate is based on staff review of reports on Form N-
MFP filed with the Commission for 2019 (16 new funds), 2020 (5 new
funds) and 2021 (2 new funds). Averaging those numbers over three
years provides an estimate of 8 new funds per year.
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We estimate that 35% of money market funds (or 124 money market
funds, broken down into 121 existing funds and 3 new funds) \8\ license
a software solution and file reports on Form N-MFP in house; we further
estimate that each fund that files reports on Form N-MFP in house
requires an average of approximately 47 burden hours to compile
(including review of the information), tag, and electronically file the
Form N-MFP for the first time and an average of approximately 13 burden
hours for subsequent filings.\9\ Therefore, we estimate the per fund
average annual hour burden is 156 hours \10\ for existing funds and 190
hours \11\ for new money market funds. Based on an estimate of 121
existing funds and 3 new funds each year, we estimate that filing
reports on Form N-MFP in house takes 19,446 hours and costs funds, in
aggregate, $6,319,950 per year.\12\
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\8\ The estimate is based on the following calculation: (353
money market funds x 35% = 124 money market funds. Of that amount,
we estimate that 2 are new money market funds (8 new money market
funds each year x 35% = 2.8 funds, rounded to 3). Therefore, 124
money market funds-3 new money market funds = 121 existing money
market funds.
\9\ We understand that the required information is currently
maintained by money market funds pursuant to other regulatory
requirements or in the ordinary course of business. Accordingly, for
the purposes of our analysis, we do not ascribe any time to
producing the required information.
\10\ This estimate is based on the following calculation: 12
filings per year x 13 burden hours per filing = 156 burden hours per
year.
\11\ This estimate is based on the following calculation: (First
month's initial filing x 47 burden hours) + (11 subsequent month
filings x 13 burden hours per filing) = 190 burden hours per year.
\12\ These estimates are based on the following calculations:
existing funds: (156 hours x blended hourly rate of $325 for a
financial reporting manager ($318 per hour), senior accountant ($327
per hour), senior database administrator ($373 per hour), senior
portfolio manager ($360 per hour) and compliance manager ($339 per
hour)) = $50,700. The blended hourly rate was calculated as ($318 +
$237 + $373 + $360 + $339/5 = $325. There are 121 existing money
market funds who use in house solutions x 156 hours with an internal
time cost of $50,700 per fund = 18,876 hours with an internal time
cost of $6,134,700.
New money market funds: (190 hours x blended hourly rate of $325
for a financial reporting manager ($318 per hour), senior accountant
($237 per hour), senior database administrator ($373 per hour),
senior portfolio manager ($360 per hour) and compliance manager
($339 per hour)) = $61,750. The blended hourly rate was calculated
as ($318 + $237 + $373 + $360 + $339/5 = $325. Three new money
market funds x 190 hours with an internal time cost of $61,750 per
fund = 570 hours with an internal time cost of $185,250.
Aggregate annual hourly burden for all funds filing reports on
Form N-MFP in house: 18,876 hours + 570 hours = 19,446 hours.
Aggregate annual costs for all funds filing reports on Form N-
MFP in house: $6,134,700 + $185,250 = $6,319,950.
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We estimate that 65% of money market funds (or 229 money market
funds, broken down into 224 existing funds and 5 new funds) \13\ retain
the services of a third party to provide data aggregation and
validation services as part of the preparation and filing of reports on
Form N-MFP on the fund's behalf; we further estimate that each fund
requires an average of approximately 26 burden hours to compile and
review the information with the service provider prior to
electronically filing the report for the first time and an average of
approximately 9 burden hours for subsequent filings. Therefore, we
estimate the per fund average annual hour burden is 108 hours \14\ for
existing funds and 125 hours \15\ for new money market funds. Based on
an estimate of 224 existing funds and 5 new funds each year, we
estimate that filing reports on Form N-MFP using a service provider
takes 24,817 hours and costs funds, in aggregate, $8,065,525 per
year.\16\ In sum, we estimate that filing reports on Form N-MFP imposes
a total annual hour burden of 44,263 hours,\17\ at an aggregate cost of
$14,385,475 on all money market funds.\18\
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\13\ The estimate is based on the following calculation: (353
money market funds x 65% = 229 money market funds. Of that amount,
we estimate that 5 are new money market funds (8 new money market
funds each year x 65% = 5.2 funds, rounded to 5). Therefore, 229
money market funds - 5 new money market funds = 224 existing money
market funds.
\14\ This estimate is based on the following calculation: 12
filings per year x 9 burden hours per filing = 108 burden hours per
year.
\15\ This estimate is based on the following calculation: (First
month's initial filing x 26 burden hours) + (11 subsequent month
filings x 9 burden hours per filing) = 125 burden hours per year.
\16\ These estimates are based on the following calculations:
Existing funds: (108 hours x blended hourly rate of $325 for a
financial reporting manager ($318 per hour), senior accountant ($237
per hour), senior database administrator ($373 per hour), senior
portfolio manager ($360 per hour) and compliance manager ($339 per
hour)) = $35,100. The blended hourly rate was calculated as ($318 +
$237 + $373 + $360 + $339/5 = $325. There are 224 existing money
market funds who use a third-party service provider x 148 hours with
an internal time cost of $35,100 per fund = 24,192 hours with an
internal time cost of $7,862,400.
New money market funds: (125 hours x blended hourly rate of $325
for a financial reporting manager ($318 per hour), senior accountant
($237 per hour), senior database administrator ($373 per hour),
senior portfolio manager ($360 per hour) and compliance manager
($339 per hour)) = $40,625. The blended hourly rate was calculated
as ($318 + $237 + $373 + $360 + $339/5 = $325. Five new money market
funds x 125 hours with an internal time cost of $40,625 per fund =
625 hours with an internal time cost of $203,125.
Aggregate annual hourly burden for all funds filing reports on
Form N-MFP using a third party service provider: 24,192 hours + 625
hours = 24,817 hours.
Aggregate annual costs for all funds filing reports on Form N-
MFP using a third party service provider: $7,862,400 + $203,125 =
$8,065,525.
\17\ This estimate is based on the following calculation: 19,446
hours for filers licensing a software solution and filing in-house +
24,817 hours for filers using a third-party service provider =
44,263 hours in total.
\18\ This estimate is based on the following calculation:
$6,319,950 (in-house filers) + $6,319,950 (filers using a service
provider) = $14,385,475.
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Cost burden is the cost of goods and services purchased in
connection with complying with the collection of information
requirements of rule 30b1-7 and Form N-MFP. The cost burden does not
include the cost of the hour burden discussed above.
Based on discussions with industry participants, we estimate that
money market funds that file reports on Form N-MFP in house license a
third-party software solution to assist in filing their reports at an
average cost of $3,900 per
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fund per year. In addition, we estimate that money market funds that
use a service provider to prepare and file reports on Form N-MFP pay an
average fee of $9,300 per fund per year. In sum, we estimate that all
money market funds incur on average, in the aggregate, external annual
costs of $2,613,300.\19\
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\19\ This estimate is based on the following calculation: (124
money market funds (121 existing funds + 3 new funds) that file
reports on Form N-MFP in house x $3,900 per fund, per year) + (229
money market funds (224 existing funds + 5 new funds) that file
reports on Form N-MFP using a service provider x $9,300 per fund,
per year) = $2,613,300.
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The public may view background documentation for this information
collection at the following website: <a href="http://www.reginfo.gov">www.reginfo.gov</a>. Find this
particular information collection by selecting ``Currently under 30-day
Review--Open for Public Comments'' or by using the search function.
Written comments and recommendations for the proposed information
collection should be sent within 30 days of publication of this notice
by July 6, 2022 to (i) <a href="/cdn-cgi/l/email-protection#f8b5baa0d6b7b5bad6b7b1aab9d6abbdbba79c9d8b93a7979e9e919b9d8ab897959ad69d9788d69f978e"><span class="__cf_email__" data-cfemail="f4b9b6acdabbb9b6dabbbda6b5daa7b1b7ab9091879fab9b92929d979186b49b9996da919b84da939b82">[email protected]</span></a> and
(ii) David Bottom, Director/Chief Information Officer, Securities and
Exchange Commission, c/o John Pezzullo, 100 F Street NE, Washington, DC
20549, or by sending an email to: <a href="/cdn-cgi/l/email-protection#8adad8cbd5c7ebe3e6e8e5f2caf9efe9a4ede5fc"><span class="__cf_email__" data-cfemail="f7a7a5b6a8ba969e9b95988fb7849294d9909881">[email protected]</span></a>.
Dated: May 31, 2022.
J. Matthew DeLesDernier,
Assistant Secretary.
[FR Doc. 2022-12018 Filed 6-3-22; 8:45 am]
BILLING CODE 8011-01-P
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