2025 17a-25 Supporting Statement

SUPPORTING STATEMENT
For the Paperwork Reduction Act Information Collection
Submission for
Rule 17a-25
OMB Control No. 3235-0540
A.

JUSTIFICATION
1.

Necessity of Information Collection

Rule 17a-25 (17 CFR 240.17a-25) under the Securities Exchange Act of 1934 (15 U.S.C.
78a et. seq.) (“Exchange Act”), requires broker-dealers registered with the Securities and Exchange
Commission (“Commission”) to submit, upon request, information on customer and firm securities
trading in a standardized format. In addition, the rule requires broker-dealers to submit, and keep
current, contact information for the person responsible for processing such requests. The rule is
necessary to support the Commission’s efforts to analyze electronic submissions of transaction
information, thereby facilitating Commission enforcement investigations and other trading
reconstructions.
2.

Purpose and Use of Information Collection

Rule 17a-25 requires registered broker-dealers to submit securities trading data in a uniform
electronic format, preferably using the electronic blue sheets (“EBS”) reporting system utilized by
the Commission, when requested by the Commission staff for enforcement and other regulatory
purposes.1 Rule 17a-25 requires the electronic submission of trading information to include data
elements that assist the Commission staff in conducting complex enforcement inquiries and
investigations. Additionally, the rule requires broker-dealers to submit and keep current, contact
person information for EBS requests. The Commission uses the information collected from EBS
requests for examinations, enforcement inquiries or investigations, and trading reconstructions.
3.

Consideration Given to Information Technology

The EBS system is designed to reduce the burden of collecting and transmitting securities
trading data. This technology increases the speed, accuracy, and availability of trading information,
thereby generating benefits to both investors and the financial markets.
4.

Duplication

As discussed in more detail in Item 8 below, except for some transactional information,
this information collection is not fully duplicative of another information collection either in
substance, functionality, or utility.

1

In July 2017, the Commission retired its custom built EBS system and began using the Blue Sheets as a
service (“BSS”) system operated by the Financial Industry Regulatory Authority (“FINRA”).

5.

Effect on Small Entities

The Commission believes that Rule 17a-25 has a minimal effect on broker-dealers who
qualify as a small business or organization. As discussed in Item 12 below, the Commission
primarily sends EBS requests to the 557 brokers that operate as clearing brokers as they, by nature
of their role in clearing securities transactions for themselves and for other broker-dealers, are
the repository for the trading data. Further, the vast majority of the information required in Rule
17a-25 involves collections of information that broker-dealers already maintain in compliance with
existing regulations, and the rules of the self-regulatory organizations (the registered securities
exchanges and FINRA) currently require broker-dealers to have adequate systems and procedures to
submit the EBS transaction reports.
6.

Consequences of Not Conducting Collection

The Commission requests securities trading data only when necessary for a specific
regulatory purpose.
7.

Inconsistencies with Guidelines in 5 CFR 1320.5(d)(2)

There are no special circumstances. This collection is consistent with the guidelines in 5
CFR 1320.5(d)(2).
8.

Consultations Outside the Agency

The Commission solicited comment on the continuing collection of information in Rule
17a-25, as required under the Paperwork Reduction Act of 1995 (“PRA”). A Federal Register
notice with a 60-day comment period soliciting comments on this collection of information was
published on May 21, 2025.2 The Commission received a comment letter regarding the existing
collection of information, which is discussed in more detail below.3
The commenter stated that certain provisions of Rule 17a-25 are duplicative of the
Consolidated Audit Trail (“CAT”) rules. Specifically, the commenter stated that EBS is
“duplicative of CAT, is not necessary for the proper performance of the functions of the
Commission, and has no practical utility.” 4 We disagree.
EBS is not fully duplicative of the CAT. It differs in substance, functionality, and utility.
EBS provides access to transactional information for certain fixed income products, like bonds,
2

Proposed Collection; Comment Request; Extension: Rule 17a-25, 90 FR 21814 (May 21, 2025) (“60-Day
Notice”).

3

See letter from Howard Meyerson, Managing Director, Financial Information Forum (“FIF”) (July 21,
2025) (“FIF Letter”).

4

See FIF Letter at 3. In addition, the commenter raised concerns regarding CAT costs, the security of EBS,
and possible revisions to Rule 17a-25 to establish an automated request-and-response system centralized
through FINRA. See, e.g., FIF Letter at 3, 6-8. These comments are beyond the limited scope of the PRA
and the renewal sought by the Commission herein for Rule 17a-25, but are being actively considered by the
Commission and its staff in other contexts.

2

that is not captured by the CAT, as well as trade-level information that is not included in the
CAT (e.g., branch office/registered representative number). EBS also contains older data than
the CAT. Moreover, EBS makes it possible for regulatory users to request certain customer
account level information that is no longer required to be reported to the CAT pursuant to
exemptive relief granted by the Commission.5 The national securities exchanges and national
securities association (collectively, “SROs”) that are the Participants to the national market
system plan governing the CAT (the “CAT NMS Plan”) have also recently submitted a proposed
amendment to the CAT NMS Plan that would codify and expand this exemptive relief 6 – a step
that if approved, would increase regulatory reliance on requests to broker-dealers for customer
information such as through EBS.
While there is some transactional information in the CAT that can also be requested
through EBS, the way that CAT information is used by regulators differs because EBS data and
functionality supports different types of analyses than the CAT. Because of these differences,
EBS remains a tool of great practical utility for the Commission in the proper performance of its
functions, including examinations, enforcement inquiries, investigations, and market
reconstructions.
In the 60-Day Notice, the Commission estimated for PRA purposes that it sends
approximately 10,807 electronic blue sheet requests per year to clearing broker-dealers that in
turn submit an average 213,233 responses. 7 The Commission further estimated that each brokerdealer that responds electronically will take 8 minutes, and each broker-dealer that responds
manually will take 1½ hours to prepare and submit the securities trading data requested by the
Commission. This yielded an annual aggregate hour burden estimate for electronic and manual
response firms of 28,562 (213,137 x 8 ÷ 60 = 28,418 hours) + (96 x 1.5 = 144 hours),
respectively. 8
5

See Exchange Act Release No. 88393 (Mar. 17, 2020), 85 FR 16152 (Mar. 20, 2020) (providing
conditional exemptive relief to remove the obligation that the CAT collect (1) individual social security
numbers or tax payer identification numbers and (2) dates of birth and account numbers associated with
natural persons); Exchange Act Release No. 102386 (Feb. 10, 2025), 90 FR 9642 (Feb. 14, 2025)
(providing exemptive relief from the obligation to collect names, addresses, and years of birth for U.S.
natural persons).

6

See Exchange Act Release No. 102665 (Mar. 13, 2025), 90 FR 12845 (Mar. 19, 2025) (proposing to amend
the CAT NMS Plan to codify and expand previously-issued exemptive relief). FIF has supported this
proposal. See letter from Howard Meyerson, Managing Director, FIF, to Commission (July 14, 2025),
available at https://www.sec.gov/comments/4-698/4698-625367-1847814.pdf; letter from Howard
Meyerson, Managing Director, FIF, to Commission (Apr. 9, 2025), available at
https://www.sec.gov/comments/4-698/4698-590975-1712522.pdf.

7

A single EBS request has a unique number assigned to each request (e.g., “0900001”). However, the
number of broker-dealer responses generated from one EBS request can range from one to several
thousand. EBS requests are sent directly to clearing firms, as the clearing firm is the repository for trading
data for securities transactions information provided by the clearing firm and the correspondent firms.
Clearing brokers respond for themselves and other firms they clear for. There were 426,274 responses during
the 24-month period, for an average of 213,137 annual responses.

8

Few respondents submit manual EBS responses. The small percentage of respondents that submit manual
responses do so by hand, via email, spreadsheet, disk, or other electronic media. Thus, the number of
manual submissions (approximately 96 per year) has minimal effect on the total annual burden hours.

3

The commenter stated that the Commission’s estimates of the compliance burden do not
reflect the actual compliance burden. 9 The commenter stated that the Commission did not
consider EBS requests by SROs. However, the SRO EBS rules are independent of Rule 17a-25,
which was modelled after then-existing SRO rules. 10 Accordingly, we are not including EBS
requests sent by SROs in the estimate for Rule 17a-25.
In addition, the commenter stated that the Commission has not considered certain
burdens in connection with its estimates, including overhead needed to be in a position to
respond to EBS requests in a timely manner, data storage and maintenance costs, security costs
related to protecting personal identifiable information (“PII”), personnel costs related to the
management of the data, and processing costs. 11 As noted in Item 4 above, the vast majority of
the information required in Rule 17a-25 involves collections of information that broker-dealers
already maintain in compliance with existing regulations, and the rules of the SROs (the registered
securities exchanges and FINRA) currently require broker-dealers to have adequate systems and
procedures to submit the EBS transaction reports. Further, broker-dealers already maintain all of
the information required for EBS reports pursuant to Exchange Act Rules 17a-3 and 17a-4.
Therefore, to the extent broker-dealers incur burdens or costs related to data creation, storage,
maintenance, management, security, and processing, such costs are either usual and customary, or are
already accounted for by other collections of information. 12
The commenter also stated that the Commission’s estimate of eight minutes as an average
response time for EBS requests is “well below” the actual average response time required for a
broker-dealer to respond to these requests.13 The commenter further stated that broker-dealers that
have acquired other broker-dealers “often must” incur additional costs when responding to requests
when data is stored in multiple systems.14 The commenter did not provide an estimate of the average
response time for EBS requests. In response, we acknowledge that, in some cases, there may be
additional time associated with the interpretation of the request, collection of responsive information
(including across multiple systems), and review of the response. Therefore, we are increasing our
estimate of the response time for electronic responses by 25%, for an average response time of 10
minutes. This yields an annual aggregate hour burden estimate for electronic and manual
response firms of 35,667 (213,137 x 10 ÷ 60 = 35,523 hours) + (96 x 1.5 = 144 hours),
respectively.

9

See FIF Letter at 8. The commenter stated that the Commission provided an hours estimate but did not
provide any cost estimates. See id. Because the Commission estimated that all hourly burdens are internal,
these do not result in Item 13 costs that are submitted to OMB for approval.

10

See Exchange Act Release No. 44494 (June 29, 2001), 66 FR 35836, at 35837 (July 9, 2001) (Rule 17a-25
Adopting Release).

11

See FIF Letter at 8.

12

See Records to be made by certain exchange members, brokers and dealers (OMB Control No. 3235-0033)
and Records to be preserved by certain brokers and dealers (OMB control number 3235-0279).

13

See FIF Letter at 8.

14

See FIF Letter at 9.

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9.

Payment or Gift

The respondents receive no payments or gifts.
10.

Confidentiality

The information in the collections of information discussed above will not be made
publicly available, except as provided by the Privacy Act of 1974 (5 U.S.C. 552a).
11.

Sensitive Questions

The information collection collects elements of PII that is covered by the BSS PIA.
However, the PIA is currently being updated for BSS. The agency has determined that the
information collection does constitute a system of record for purposes of the Privacy Act.
Information is retrieved by a personal identifier and is covered by the SORN SEC-17
“Enforcement Files” and the privacy act statements in forms SEC 1661 and SEC 1662.
12.

Information Collection Burden

The annual hour burden of Rule 17a-25 for individual broker-dealers varies widely due to
differences in the levels of activities of the respondents and because of differences in the current
recordkeeping systems of the respondents. While Rule 17a-25 requires all registered broker-dealers
to be able to provide transaction data to the Commission, the Commission focuses its requests on
clearing brokers as they are the repository for the trading data. Accordingly, all 557 clearing
brokers respond electronically through the EBS system, except in rare instances where they respond
manually. Manual submissions are allowed if there are no other means for the firm to submit
responses electronically. It is estimated that the broker-dealers that respond electronically will take
10 minutes, and the broker-dealers that respond manually will take 1½ hours to prepare and submit
the securities trading data requested by the Commission.
Based on EBS data compiled by the Commission for the period October 1, 2022 to
September 30, 2024, the Commission estimates that it sent 10,807 electronic blue sheet requests to
clearing broker-dealers, who in turn submitted 426,274 responses, for an average of 213,137
responses per year.15 On average, each of the 557 clearing firms electronically submitted
approximately 383 responses per year (213,137 ÷ 557 = 382.65). Accordingly, the annual aggregate
hour reporting burden for electronic responses is estimated to be 35,523 (213,137 x 10 ÷ 60 =
35,523 hours).
The Commission received 192 manual submissions between October 1, 2022 and September
30, 2024, or an average of 96 manual submissions per year. On average, each of the 557 clearing
firms submitted approximately 0.17 manual responses per year (96 ÷ 557 = 0.17). Accordingly,
15

A single EBS request has a unique number assigned to it (e.g., “0900001”). However, the number of
broker-dealer submissions transmitted in response to one EBS request can range from one to thousands.
EBS requests are sent directly to clearing firms, as the clearing firm is the repository for trading data for
securities transactions information provided by the clearing firm and the correspondent firms. Clearing
brokers respond for themselves and other firms for which they clear. There were 426,274 responses during
the 24-month period, for an average of 213,137 annual responses.

5

the annual aggregate hour reporting burden for manual responses is estimated to be 144 (96 x 1.5 =
144 hours). 16
Further, while Rule 17a-25 requires broker-dealers to submit, and keep current, contact
information for the person responsible for processing such requests, the Commission retired its EBS
system and transitioned to using the BSS system operated by FINRA in 2018. Because FINRA
separately requires broker-dealers to submit, and keep current, contact information directly to
FINRA, firms no longer have to submit that information to the Commission. Accordingly, the
Commission eliminated the collection of information burden for that aspect of Rule 17a-25.
Thus, the total number of responses is 213,233 (213,137 electronic responses + 96 manual
responses). The annual aggregate reporting burden for all respondents to the collection of
information requirements of Rule 17a-25 is estimated at 35,667 (213,137 electronic responses x 10
minutes per response ÷ 60 minutes in an hour = 35,523 hours) + (96 manual responses x 1.5 hours
per response= 144 hours).
Summary of Hourly Burdens
Burden
Type

Number of
Respondents

Number of
Annual
Responses
per
Respondent

Time per
Response
(Hours)

Total
Burden
(Hours)

557

382.65

.16667

35,523

557

0.1724

1.5

144

Electronic
Reporting
Manual
Reporting

35,667

Total Aggregate Burden
13.

Costs to Respondents

The Commission estimates that there will be no additional costs to the respondents associated
with the operation and maintenance of the EBS system. In addition, Rule 17a-25 will not impose
any additional recordkeeping requirements for broker-dealers because broker-dealers already
maintain all of the information required for EBS reports pursuant to Exchange Act Rules 17a-3 and
17a-4. Therefore the annualized cost burden is $0.
14.

Costs to Federal Government

The annual cost to the Federal Government for this collection of information is estimated
16

Manual submissions most frequently occur when an analyst requests transaction information that is older
than 6 years (the required retention period). The number of manual submissions (approximately 122 per
year) has a minimal effect on the total annual burden hours.

6

to be $916,160. As noted above, the Commission retired its EBS system and now uses the BSS
system operated by FINRA to send electronic requests for trading data. As such, the Commission no
longer incurs a cost to maintain its own separate EBS system. Instead, it incurs costs to use the BSS
system. In particular, to help administer the BSS system and ensure that submissions are timely and
accurate, the Commission employs two full-time contractors. We estimate an average of $76 for
contractors per hour for those persons, multiplied by a full-time (40 hours per week) working
schedule ($316,160 annually). Infrastructure and support costs to maintain the EBS system are
estimated to be $600,000. Accordingly, total costs for staff, BSS contract and system costs
(including system access, staff training, and system development and enhancement costs), and
dedicated infrastructure costs are thus estimated to be $916,160. Other expenses, including the
professional staff that utilize the information collected as part of their regulatory reviews, as well
as general technology and overhead expenses, would have been incurred without this specific
collection of information and are part of the Commission’s normal labor costs for staff and
facilities.
15.

Changes in Burden

The number of unique EBS requests sent decreased (5,404 17 annual average versus 6,779
annual average from the prior comparable 24-month figure reported in 2022). There was also a
decrease in: (1) the number of electronic responses received (213,137 18 annual average versus
223,057 annual average from the prior comparable 24-month figure reported in 2022); and (2)
the number of manual responses received (96 19 annual average versus 122 annual average from
the prior annual figure reported in 2022). However, the annual aggregate hour reporting burden
increased overall. The increase in burden reflects an increase in the estimated time burden for an
electronic response from 8 minutes per response to 10 minutes per response.
Accounting for all of these changes, the annual aggregate hour reporting burden has
increased from 29,924 in 2022 to 35,667 currently.
16.

Information Collection Planned for Statistical Purposes

Not applicable. The information collection is not used for statistical purposes.
17.

Approval to Omit OMB Expiration Date

The Commission is not seeking approval to omit the expiration date.
18.

Exceptions to Certification for Paperwork Reduction Act Submissions

This collection complies with the requirements in 5 CFR 1320.9.
17

As noted in Item 12, the Commission made 10,807 requests over a 24-month period, for an average of
5,404 requests made per year.

18

As noted in Item 12, the Commission received 426,274 electronic submissions over a 24-month period, for
an average of 213,137 submissions received per year.

19

As noted in Item 12, the Commission received 192 manual submissions over a 24-month period, for an
average of 96 submissions received per year.

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B.

COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS
The collection of information does not involve statistical methods.

8