May 17, 2007

Pulled from the OMB's Rear End

by PG

Looking at Form 20-F (used by foreign private issuers to comply with SEC regulations), I noticed the little OMB approval box at the top. OMB approval is important; a notice at the bottom of the form's first page says, "Persons who respond to the collection of information contained in this form are not required to respond unless the form displays a currently valid OMB control number." What distubed me is that the "Estimated average burden hours per response" for this form is 2631.00.

Where did the OMB get that number? That's got to be a misplaced decimal point, otherwise the SEC estimates that it will take more time to respond to this request for information than the average BigLaw associate bills in a year. Yes, there are multiple registration statements and reports that go "on" the form, but it's still slightly mind-boggling to think that the easy version of compliance for a single company could occupy one lawyer for over a year. Then again, I suppose that's what in-house counsel's for.

May 17, 2007 9:27 PM | TrackBack
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