Overview
Title
Proposed Agency Information Collection Activities; Comment Request
Agencies
ELI5 AI
The Federal Reserve wants people to share their thoughts on keeping the same forms that help them understand who works in certain bank jobs and when those people leave. They want to know if these forms are still useful and how they can make them easier to fill out.
Summary AI
The Board of Governors of the Federal Reserve System is seeking public feedback on its proposal to extend the use of two forms, Form MSD-4 and Form MSD-5, for three additional years without any changes. These forms are used by municipal securities dealers associated with banks to manage information about their employees and their employment termination. The Board is interested in comments about the necessity and effectiveness of these forms and how they might lessen the burden on those required to use them. Comments must be submitted by February 21, 2025.
Abstract
The Board of Governors of the Federal Reserve System (Board) invites comment on a proposal to extend for three years, without revision, the Uniform Application for Municipal Securities Principal or Municipal Securities Representative Associated with a Bank Municipal Securities Dealer (Form MSD-4) and Uniform Termination Notice for Municipal Securities Principal or Municipal Securities Representative Associated with a Bank Municipal Securities Dealer (Form MSD-5; OMB No. 7100-0100).
Keywords AI
Sources
AnalysisAI
The Federal Register notice invites public comments on a proposal from the Board of Governors of the Federal Reserve System to extend the usage of two forms, Form MSD-4 and Form MSD-5, for an additional three years, without making any revisions. These forms are relevant for municipal securities dealers associated with banks. They collect information about employees taking on certain roles and track the reasons and dates when such employees leave these positions.
General Summary
These forms are crucial tools for managing the administrative details of people working in specific roles in the securities sector linked to banks. Specifically, Form MSD-4 gathers personal history and professional qualifications for employees assuming responsibilities as municipal securities principals or representatives. Form MSD-5, on the other hand, records when these employees cease their involvement and why. The Board is seeking feedback from the public on the ongoing relevance, effectiveness, and possible improvements of these forms. They request comments be sent by February 21, 2025.
Significant Issues and Concerns
One key concern is that the document neglects to explain why continuing the use of these forms is necessary, which might cause readers to question their practical importance. The document uses complex legal terms that could obscure its meaning, especially for those unacquainted with such regulatory language. Furthermore, there's no mention of any updates or streamlining, indicating a missed opportunity to enhance efficiency or modernize the data collection process.
The notice estimates the burden these forms place on respondents but doesn't clarify how it arrived at these calculations. Providing a detailed methodology would offer more transparency and potentially greater accuracy. Furthermore, the document does not outline how public comments could lead to meaningful changes or highlight any past revisions initiated by stakeholder input. This might discourage public engagement if they feel their feedback lacks impact.
Impact on the Public
For the general public, especially those affiliated with municipal securities and banking sectors, this document could contribute to maintaining the status quo in how certain employment-related information is processed. Stakeholders directly impacted by these forms, such as bank employees working within municipal securities, could experience both positive and negative effects. On the positive side, continuity without changes might mean maintaining a familiar process without adjusting to new administrative requirements. However, it could also imply that inefficiencies persist, potentially creating unnecessary paperwork or failing to integrate more advanced, user-friendly data collection methods.
Influence on Specific Stakeholders
The individuals directly responsible for completing these forms, like staff within securities departments of banks, could benefit or suffer depending on their circumstances. If these forms are deemed outdated or cumbersome, they may advocate for the introduction of streamlined or digital solutions. Conversely, entities accustomed to the current system might find comfort in the lack of changes, avoiding the need for additional training or adjustments.
In conclusion, while this Federal Reserve Systems notice appears routine, it opens the door for discourse on balancing thorough information collection and minimizing the administrative burden. The absence of modernization or responsiveness to comments could be areas of improvement that affect both efficiency and stakeholder satisfaction.
Issues
• The document does not provide detailed information on why the extension of the information collections (Forms MSD-4 and MSD-5) is necessary, which might lead to questioning the practical utility of these forms.
• The description of the information collection's purpose and utility is somewhat legalistic and may not be immediately clear to audiences unfamiliar with regulatory language.
• The document does not specify any efforts to update or streamline the forms or procedures (no revision is proposed), which could raise concerns about potential inefficiencies or lack of modernization in data collection processes.
• The estimated burden hours and the reasoning behind these estimates are not explained in detail, which could lead to questions about the methodology's validity.
• There is no discussion of how comments submitted will influence potential changes or how past comments have led to any revisions, which may suggest a lack of responsiveness to stakeholder input.
• The document lacks detail on how automated collection techniques might be used to minimize the burden on respondents, merely mentioning it as a point of consideration.
• The language used to describe submission methods and other bureaucratic processes could be simplified to make it more accessible for the general public.