SEC seeks OMB extension for Rule 101 Regulation M information collection
Approximately 2,110 distribution participants must comply with the extended collection beginning after the comment period ends on Oct. 26, 2026.
The Securities and Exchange Commission (SEC) has submitted to the Office of Management and Budget (OMB) a request to extend the previously approved information collection for Rule 101 of Regulation M (17 CFR 242.101) under the Securities Exchange Act of 1934. The request is filed under OMB Control No. 3235-0464.
Rule 101 prohibits distribution participants from purchasing securities at specified times during a distribution. Covered persons may rely on exceptions such as calculating the average daily trading volume, estimating default probability for certain nonconvertible securities, maintaining information barriers between affiliates, and adopting a written policy for de minimis transactions.
The SEC estimates roughly 2,110 respondents per year will be required to comply. Each respondent is projected to incur about 25.796 burden hours, for a total industrywide burden of approximately 54,429 hours. The estimated internal labor cost across the industry is $7,239,057, or about $3,430.83 per respondent.
Comments on the collection request may be submitted electronically at https://www.reginfo.gov/public/do/PRAViewICR?ref_nbr=202607-3235-006 or by email to the address provided in the notice. The comment period closes on October 26, 2026.
The notice was dated September 22, 2026, and signed by Sherry R. Haywood, Assistant Secretary of the SEC.
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