|
| Average Hours per Response (1) | Estimated Cost per Response (2) |
|
| Form | Total | Internal | External |
| | | | | |
| Exempt Filings | | | | |
| Regulation CF (3) | 50.0 | 37.5 | 12.5 | 8,400 |
| Form C – Offering Statement | | | | |
| Form C–U - Offering Progress Update | | | | |
| Form C/A - Amendment to Offering Statement | | | | |
| Form C-AR - Annual Report | | | | |
| Form C-AR/A - Amendment to Annual Report | | | | |
| Form C-TR - Termination of Reporting | | | | |
| | | | |
| Regulation D | | | | |
| Private Placement Memorandum (4) | 700.0 | 525.0 | 175.0 | 117,000 |
| Form D – Notice of Exempt Offering of Securities (5) | 5.0 | 12.5 | 37.5 | 16,100 |
| | | | |
| Regulation A+ | | | | |
| Form 1-A – Offering Statement | 728.0 | 546.0 | 182.0 | 121,700 |
| Form 1-K – Annual Report | 600.0 | 450.0 | 150.0 | 100,300 |
| Form 1-SA - Semi-Annual Report | 188.0 | 141.0 | 47.0 | 31,400 |
| Form 1-U – Current Report | 5.0 | 3.8 | 1.3 | 800 |
| | | | |
| Selected Non-Exempt Filings | | | | - |
| Form S-1 – Offering Statement | 641.0 | 480.8 | 160.3 | 107,100 |
| Form S-11 – Offering Statement | 722.0 | 541.5 | 180.5 | 120,700 |
| Form 8-K – Current Report | 9.0 | 6.8 | 2.3 | 1,500 |
| Form 10-K - Annual Report | 2,255.0 | 1,691.3 | 563.8 | 376,900 |
| Form 10-Q – Quarterly Report | 182.0 | 136.5 | 45.5 | 30,400 |
| | | | |
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| | | | |
| Sources: Individual SEC forms, Facilitating Capital Formation and Expanding Investment Opportunities by Improving Access to Capital in Private Markets |
| 1 For purposes of the Paperwork Reduction Act (the PRA), the SEC allocated the hourly paperwork burden between internal persons and outside professionals, principally lawyers and accountants. For reports pursuant to Reg A+ and Reg CF, the internal/external allocation used is 75%/25% while for Reg D it is 25%/75%. The SEC estimates the average cost of retaining outside professionals - securities attorneys and independent public accounttants - at $400 per hour. |
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| 2 The formula for estimating costs = internal hours x $89.49/hr + external hours x $400/hr. For the cost of internal hours, SPCP used 75% financial manager time at $79.83/hour and 25% chief executive time at $118.48/hour, resulting in an average hourly rate of $89.49. See the May 2022 National Occupational Employment and Wage Estimates, released April 25, 2023, by the U.S. Bureau of Labor Statistics for additional information. |
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| 3 The SEC only publishes a general estimate of the cost and time required to comply with Reg CF. It does not publish detailed estimates of the time and cost to prepare and file the 6 individual reports indicated above. Reg CF also permits withdrawal filings such as C-W (Offering Statement Withdrawal), C-U-W (Broker-Dealer Withdrawal), C-TR-W (Termination of Reporting Withdrawal), and C-AR-W (Annual Report Withdrawal). |
| 4 The SEC does not mandate any particular form for Private Placement Memorandums, however, in practice, most professional prepared PPMs take about as much effort as a Reg 1-A Offering Circular or an S-1 Prospectus, say about 700 hours and follow a very similar disclosure outline. |
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| 5 Form D must be filed 15 days after the "date of first sale" of securities under Reg D. Form D is a brief notice that includes the names and addresses of the company’s promoters, executive officers and directors, and some details about the offering, but contains little other information about the company. |
