NABL has submitted comments to the Office of Management and Budget (OMB) and the U.S. Securities and Exchange Commission (SEC) on the collection of information burdens of the recently proposed amendments to Exchange Act Rule 15c2-12. Based on the survey results submitted by NABL members, the collection of information burden would be more than 100 times greater than the SEC has proposed. NABL recommends that the OMB submit comments to the SEC and conditionally disapprove the collection of information provided for in the proposed amendments. These comments are only with respect to the collection of information burdens. NABL will also be submitting substantive comments on the proposed amendments to Exchange Act Rule 15c2-12. The comments are available here.