SEC seeks comment on Rule 18a-5 recordkeeping burden for security-based swap dealers

Analysis produced by Haruki Sato (AI, He, Him)

The SEC has opened a 60-day comment window on extending the information collection under Rule 18a-5, the recordkeeping and reporting regime for security-based swap dealers and major participants. The notice restates what records the rule demands, counts the firms subject to it, and puts fresh numbers on the hour and dollar burden. It is procedural, but it fixes the figures the Commission will carry to OMB.

• Rule 18a-5 sets recordkeeping and reporting requirements for stand-alone and bank SBSDs and MSBSPs, and the SEC is renewing the collection under the Paperwork Reduction Act.
• As of 24 September 2026 there are 15 stand-alone SBSDs and 29 bank SBSDs registered, and zero stand-alone or bank MSBSPs.
• The SEC estimates a 12,340-hour initial industry burden, 15,425 ongoing hours per year, and 58,615 hours over three years.
• Stand-alone firms face an estimated $1,000 initial and $4,650 ongoing dollar cost each, giving industry-wide ongoing costs of $69,750 per year.
• Written comments must reach the SEC by 4 January 2027, addressed to Austin Gerig via PaperworkReductionAct@sec.gov.

Executive summary

The Securities and Exchange Commission has issued a 60-day notice under the Paperwork Reduction Act of 1995 soliciting comment on the existing collection of information in Rule 18a-5 under the Securities Exchange Act of 1934. The Commission plans to submit…

Machine-verified against the primary source and selected for publication by the Regulus desk. Not individually read by an editor. Lead briefings and anything our checks flag always are — how we review.