Mar. 10, 2023
March 10, 2023 To the extent the final rule includes the third party reporting requirement, the SEC should clarify its analysis regarding compliance with the Paperwork Reduction Act. Seems like the brokers would be required to fill out some sort of form, and also to keep records. The rules would collect information on people who are not federal employees, eg spouses and children of employees, who are members of the public for purposes of the law. The collection doesnt relate to our official duties, either, since it applies to our personal trading activities. At the very least, the throwaway sentence at the end of Section IV that the PRA does not apply needs more analysis, but based on my experience writing other rules, it absolutely applies in this situation.