Form 10-Q.SupportingStatement.Final.2025

SUPPORTING STATEMENT
FOR THE PAPERWORK REDUCTION ACT INFORMATION COLLECTION
SUBMISSION FOR FORM 10-Q
A.

JUSTIFICATION
1.

Circumstances Making the Collection of Information Necessary

Section 13(a) of the Securities Exchange Act of 1934 (“Exchange Act”) requires
every issuer of a security registered pursuant to Section 12 to file periodic and current
reports with the Commission. Section 15(d) of the Exchange Act requires each issuer that
has filed a registration statement that has become effective under the Securities Act of
1933 to file periodic reports and documents pursuant to Section 13 of the Exchange Act.
Form 10-Q (17 CFR 249.308a) is the form used by issuers to satisfy their
quarterly reporting obligations pursuant to Section 13 or 15(d) of the Exchange Act.
Form 10-Q requires financial and certain other information concerning the issuer.
2.

Purpose and Use of the Information Collection

Form 10-Q filings include financial and other information that is intended to
provide investors with information needed to make informed investment decisions and to
promote confidence in the trading markets.
3.

Consideration Given to Information Technology

All Form 10-Qs filed with the Commission are required to be filed electronically
on the Electronic Data Gathering, Analysis, and Retrieval (EDGAR) system.
4.

Duplication of Information
No similar information is available from other sources.

5.

Reducing the Burden on Small Entities

Form 10-Q is a quarterly report that is required to be filed by Exchange Act
reporting issuers, which generally are not small entities.
6.

Consequences of Not Conducting Collection

Investors would not have timely information if less frequent collections are
conducted.
7.

Special Circumstances
There are no special circumstances.
1

8.

Consultations with Persons Outside the Agency

No comments were received for this requesting during the 60-day comment
period prior to OMB’s review of this extension request.
9.

Payment of Gift to Respondents
No payment or gift has been provided to any respondents.

10.

Confidentiality
Form 10-Q is a public document.

11.

Sensitive Questions

No information of a sensitive nature, including social security numbers, will be
required under this collection of information. The information collection collects basic
Personally Identifiable Information (PII) that may include name and job title. However,
the agency has determined that the information collection does not constitute a system of
record for purposes of the Privacy Act. Information is not retrieved by a personal
identifier. In accordance with Section 208 of the E-Government Act of 2002, the agency
has conducted a Privacy Impact Assessment (PIA) of the EDGAR system, in connection
with this collection of information. The EDGAR PIA, published on February 18, 2025, is
provided as a supplemental document and is also available at
https://www.sec.gov/privacy.
12.

Estimate of Respondent Reporting Burden
Estimated Reporting Burden
Information
Collection
Title

OMB Control
Number

Number of
Responses

Burden
Hours

Form 10-Q

3235-0070

19,419

2,624,187

For purposes of the Paperwork Reduction Act (“PRA”), we estimate that Form
10-Q takes approximately 180.18 hours per response to comply with the collection of
information requirements and that, on an annual basis, there are approximately 6,473
respondents (calculated based on the average annual number of respondents for the
period 2022 through 2024), each of whom makes three Form 10-Q filings with
Commission annually, for a total of approximately 19,419 Form 10-Q filings per year
(6,473 respondents x 3 filings per respondent). We derived our burden hour estimates by
estimating the average number of hours it would take an issuer to compile the necessary
information and data, prepare and review disclosure, file documents, and retain records.
2

In connection with rule amendments to the form, we occasionally receive PRA estimates
from public commenters about incremental burdens that are used in our burden estimates.
We believe that the actual burdens will likely vary among individual companies based on
the size and complexity of their organization and the nature of their operations.
We further estimate that 75% of the collection of information burden is carried by
the issuer internally and that 25% of the burden of preparation is carried by outside
professionals retained by the issuer to assist in the preparation of the form. Based on our
estimates, we calculated the total reporting burden to be 2,624,187 hours ((180.18 hours
per response x 75%) x 19,419 responses). For administrative convenience, the
presentation of the total related to the paperwork burden hours has been rounded to the
nearest whole number. The estimated burden hours is made solely for the purpose of the
PRA.
13.

Estimate of Total Annualized Cost Burden
Estimated Cost Burden
Information
Collection
Title

OMB Control
Number

Number of
Responses

Cost
Burden

Form 10-Q

3235-0070

19,419

$524,837,313

We estimate that 25% of the 180.18 hours per response (45.045 hours per
response) is prepared by outside professionals. We estimate an hourly cost of
approximately $600 for outside professional services used in connection with public
company reporting. This estimate is based on our consultations with registrants and
professional firms who regularly assist registrants in preparing and filing disclosure
documents with the Commission. Our estimates reflect average burdens, and, therefore,
some companies may experience costs in excess of our estimates and some companies
may experience costs that are lower than our estimates.
Based on our estimates, we calculated the total annual cost to be $524,837,313
($600 per hour x 45.045 hours per response x 19,419 responses). For administrative
convenience, the presentation of the total cost burden has been rounded to the nearest
dollar. The cost estimate is made solely for the purpose of the PRA.
14.

Costs to Federal Government

The annual cost of reviewing and processing disclosure documents, including
registration statements, post-effective amendments, proxy statements, annual reports and
other filings of operating companies amounted to approximately $131,724,880 in fiscal
year 2023, based on the Commission’s computation of the value of staff time devoted to
this activity and related overhead.

3

15.

Reason for Change in Burden
Estimated Burden Hours and Cost Burden Changes
Information
Collection Title

OMB
Control
Number

Burden Hours
Adjustment

Cost Burden
Adjustment

Form 10-Q

3235-0070

(473,897)

$114,580,159

The decrease in burden of 473,897 hours and the increase of $114,580,159 in cost
burden are due to adjustments. The decrease in the burden hours reflects a decrease in the
estimated number of annual Forms 10-Q responses (from 22,925 responses to 19,419
responses).
The increase in cost burden reflects the Commission’s increase in the cost burden
per hour estimate from $400 per hour to $600 per hour for outside professionals. That
increase is offset, in part, by the decrease in the estimated number of annual Form 10-Q
responses.
16.

Information Collection Planned for Statistical Purposes
The information collection is not planned for statistical purposes.

17.

Approval to Omit Expiration Date

We request authorization to omit the expiration date on the electronic version of
the form. Including the expiration date on the electronic version of the form will result in
increased costs, because the need to make changes to the form may not follow the
application’s scheduled version release dates. The OMB control number will be
displayed.
18.

Exceptions to Certification for Paperwork Reduction Act Submissions
There are no exceptions to certification for PRA submissions.

B.

STATISTICAL METHODS
The information collection does not employ statistical methods.

4