SEC seeks comment on extending Rule 18a-5 recordkeeping collection
The proposal covers security-based swap dealers and major participants, with comments due by Jan. 4 2027.
The Securities and Exchange Commission announced that it will submit the existing collection of information under Rule 18a-5 to the Office of Management and Budget for extension and approval, per the Paperwork Reduction Act of 1995. The notice, identified as FR Doc 2026-22346, carries OMB Control No. 3235-0745.
Rule 18a-5 sets recordkeeping and reporting obligations for security-based swap dealers (SBSDs) and major security-based swap participants (MSBSPs). Required records include trade blotters, general ledgers, customer account ledgers, stock records, memoranda of brokerage and proprietary orders, confirmations, accountholder information, options positions, trial balances, net-capital computations, associated-person applications, reserve calculations, unverified transactions, political contributions, and compliance documentation.
As of September 24 2026, the Commission lists 15 stand-alone SBSDs, zero stand-alone MSBSPs, 29 bank SBSDs and zero bank MSBSPs. The agency estimates an initial industry hour burden of 12,340 hours and an ongoing annual burden of 15,425 hours, totaling 58,615 hours over three years. Financially, each stand-alone SBSD faces an initial cost of about $1,000 for recordkeeping software and an ongoing cost of $4,650 for storage hardware and space, yielding an industry-wide initial burden of $15,000 and an annual burden of $69,750, or $224,250 over three years.
The SEC invites written comments on the necessity, utility, burden accuracy, and possible burden-reduction methods for this collection. Comments should be directed to Austin Gerig, Director/Chief Data Officer, via email to the address provided, no later than January 4 2027.
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