SEC Extends Recordkeeping Requirement for Broker-Dealers Under Rule 17a-4(b)(17)
The extension applies to broker-dealers that rely on the Rule 101(c)(2)(i) or Rule 102(d)(2)(i) exceptions, effective upon publication.
The SEC has submitted to OMB a request to extend the information-collection approval for Rule 17a-4(b)(17) (17 CFR 240.17a-4(b)(17)), OMB Control No. 3235-0806, as announced in the Federal Register (Vol. 91, No. 184, page 60665, FR Doc No. 2026-19558).
Rule 17a-4(b)(17) obligates broker-dealers that rely on the exception in Rule 101(c)(2)(i) or Rule 102(d)(2)(i) for nonconvertible debt securities and nonconvertible preferred securities to preserve the written probability-of-default determination for not less than three years, with the first two years kept in an easily accessible location.
The Commission estimates an initial burden of 25 hours per respondent to update policies and systems; assuming all 275 respondents are new entrants, the total annual industry-wide initial burden is 2,292 hours. An ongoing annual burden of 10 hours per firm is projected, resulting in a total ongoing burden of 2,750 hours.
Comments on the collection request must be submitted within 30 days of the day after publication, by October 26, 2026, via https://www.reginfo.gov/public/do/PRAViewICR?ref_nbr=202607-3235-009 or by email to the address provided in the notice.
The notice is dated September 22, 2026 and signed by Sherry R. Haywood, Assistant Secretary.
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