# Agency Information Collection Activities; Submission for OMB Review; Comment Request; Extension: Rule 17f-7
*Upon Written Request, Copies Available From:* Securities and Exchange Commission, Office of FOIA Services, 100 F Street NE, Washington, DC 20549-2736
Notice is hereby given that, pursuant to the Paperwork Reduction Act of 1995 (44 U.S.C. 350l-3521) (“Paperwork Reduction Act”), the Securities and Exchange Commission (the “Commission”) has submitted to the Office of Management and Budget (“OMB”) a request for extension of the previously approved collections of information discussed below.
Rule 17f-7 (17 CFR 270.17f-7) permits a fund under certain conditions to maintain its foreign assets with an eligible securities depository, which has to meet minimum standards for a depository. The fund or its investment adviser generally determines whether the depository complies with those requirements based on information provided by the fund's primary custodian (a bank that acts as global custodian). The depository custody arrangement also must meet certain conditions. The fund or its adviser must receive from the primary custodian (or its agent) an initial risk analysis of the depository arrangements, and the fund's contract with its primary custodian must state that the custodian will monitor risks and promptly notify the fund or its adviser of material changes in risks. The primary custodian and other custodians also are required to agree to exercise at least reasonable care, prudence, and diligence.
The collection of information requirements in rule 17f-7 are intended to provide workable standards that protect funds from the risks of using foreign securities depositories while assigning appropriate responsibilities to the fund's primary custodian and investment adviser based on their capabilities. The requirement that the foreign securities depository meet specified minimum standards is intended to ensure that the depository is subject to basic safeguards deemed appropriate for all depositories. The requirement that the fund or its adviser must receive from the primary custodian (or its agent) an initial risk analysis of the depository arrangements, and that the fund's contract with its primary custodian must state that the custodian will monitor risks and promptly notify the fund or its adviser of material changes in risks, is intended to provide essential information about custody risks to the fund's investment adviser as necessary for it to approve the continued use of the depository. The requirement that the primary custodian agree to exercise reasonable care is intended to provide assurances that its services and the information it provides will meet an appropriate standard of care.
The staff estimates that each of approximately 1,264 investment advisers [^1] will make an average of 8 responses annually under the rule to address depository compliance with minimum requirements, any indemnification or insurance arrangements, and reviews of risk analyses or notifications. [^2] The staff estimates each response will take 6 hours, requiring a total of approximately 48 hours for each adviser. [^3] Thus, the total annual burden associated with these requirements of the rule is approximately 60,672 hours. [^4] Assuming an estimated wage rate of approximately $381 per hour, [^5] the total internal cost to the industry is approximately $23,116,032 to comply this aspect of the rule. [^6]
[^1] From a review of the Form N-CEN filings as of September 16, 2025, the Commission staff estimated that 1,264 registered investment advisers managed or sponsored open-end registered funds (including exchange-traded funds) and closed-end registered funds.
[^2] 1,264 advisers × 8 responses = 10,112 responses.
[^3] 8 responses per adviser × 6 hours per response = 48 hours per adviser.
[^4] 1,264 advisers ×48 hours per adviser = 60,672 hours.
[^5] The Commission's estimated relevant wage rates are from SIFMA's Management & Professional Earnings in the Securities Industry 2013, and modified by the Commission staff in 2024 to account for an 1,800-hour work-year and inflation and multiplied by 5.35 to account for bonuses, firm size, employee benefits, and overhead; these estimates yield effective hourly wage figures for compliance managers and trust administrators of $381 and $287, respectively.
[^6] 60,672 hours × $381 per hour (wage rate for compliance managers) = $23,116,032.
In addition, based on public filings made with the Commission, we calculate that there are approximately 87 global custodians that are engaged to perform global custodial services to funds and thus subject to the provisions of rule 17f-7. [^7] This estimate is based on information that is publicly available on Form N-CEN filings. [^8] The staff further estimates that during each year, each of the approximately 87 global custodians will make an average of 4 responses to analyze custody risks and provide notice of any materials changes to custody risks under the rule. [^9] The staff estimates that each response will take 260 hours, requiring approximately 1,040 hours annually per global custodian. [^10] Thus the total annual burden associated with this aspect of the rule is approximately 90,480 hours. [^11] Assuming an estimated wage rate of approximately $287 per hour, the total internal cost to the industry is approximately $25,967,760 to comply with this aspect of the rule. [^12]
[^7] We analyzed Form N-CEN filings for registrants as of September 15, 2025 and based on these filings, we calculated the number of global custodians that have been retained by funds and are subject to the provisions of rule 17f-7 to be 87.
[^8]*See* Item C.12.a.vii.7 of Form N-CEN.
[^9] 87 custodians × 4 responses = 348 responses.
[^10] 260 hours per response × 4 responses per global custodian = 1,040 hours per global custodian.
[^11] 87 global custodians × 1,040 hours per global custodian = 90,480 hours.
[^12] 90,480 hours × $287 per hour (wage rate for trust administrators) = $25,967,760.
The total annual hour burden associated with all collection of information requirements of the rule is therefore 151,152 hours, [^13] and the total internal cost to the industry of the hour burden is approximately $49,083,792. [^14]
[^13] 60,672 hours + 90,480 hours = 151,152 hours.
[^14] $23,116,032 + $25,967,760 = $49,083,792.
The estimate of average burden hours is made solely for the purposes of the Paperwork Reduction Act and is not derived from a comprehensive or even a representative survey or study of the costs of Commission rules and forms. Compliance with the collection of information requirements of the rule is necessary to obtain the benefit of relying on the rule's permission for funds to maintain their assets in foreign custodians. The information provided under rule 17f-7 will not be kept confidential.
An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB Control Number.
The public may view and comment on this information collection request at: *https://www.reginfo.gov/public/do/PRAViewICR?ref_nbr=202512-3235-007* or email comment to *[email protected]* within 30 days of the day after publication of this notice, by April 3, 2026.
Dated: February 26, 2026.
Sherry R. Haywood,
Assistant Secretary.