SEC's Dusty Form T-4 Endures: Exemptions for Elite Few
Published Date: 6/4/2025
Notice
Summary
The SEC wants to keep using Form T-4, which companies file to ask for special permission under a law from 1939. Only about three companies a year fill it out, spending around 5 hours each, mostly with help from pricey experts. The SEC is asking for your thoughts by August 4, 2025, to make sure this form is still useful and not too much work or cost.
Analyzed Economic Effects
2 provisions identified: 0 benefits, 2 costs, 0 mixed.
Small Number of Issuers Must File Form T-4
Form T-4 is used by an issuer to ask for an exemption under Section 304(c) of the Trust Indenture Act of 1939. About 3 issuers file Form T-4 each year, and each filing takes about 5 hours to prepare, with the filer doing about 1 hour per filing (total annual filer burden = 3 hours).
Outside Professional Fees for Form T-4 Filings
Most of the work to prepare Form T-4 is done by outside professionals: 4 hours per filing at an estimated $600 per hour. That equals $2,400 in professional fees per filing and a total annual cost burden of $7,200 for the roughly 3 filings each year.
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