DATA

STRATEGY

FISCAL YEARS 2022–2026

Enhance use of data assets

Design and build integrated 

data infrastructure

Promote data awareness 

and literacy

Strengthen data management 

and governance
This SEC Data Strategy is a publication of the Office of the Chief Data Officer and does not necessarily 

reflect the views of the Commission, the Commissioners, or other staff of the Commission.
Contents

About the SEC Data Strategy . . . . . . . . . . . . . . . . . . . . . . . . . . iv

Data Vision . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

Message from the Chief Data Officer . . . . . . . . . . . . . . . . . . .  

The Vital Role of Data to the SEC Mission . . . . . . . . . . . . . . .  

Data-Related Goals and Initiatives . . . . . . . . . . . . . . . . . . . . . .  

Strategy Roadmap . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

Endnotes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
iv | U.S. Securities and Exchange Commission

About the SEC Data Strategy

The SEC’s Office of the Chief Data Officer (OCDO) developed this 

Data Strategy with advice from the SEC’s Data Management Board

The goals and initiatives guide the agency’s Data Management Program1

and support the Commission’s Strategic Plan for Fiscal Years 2022 

through 2026

2

The Data Management Program includes enterprise-level data 

management projects and responsibilities and has the following overall 

objectives: enabling collaborative management of data as a strategic 

enterprise asset; ensuring secure, efficient, and effective collection, 

management, use, protection, dissemination, and generation of data 

within the SEC; and ensuring, to the extent practicable, that the SEC 

maximizes the value and use of data to carry out its mission
FY 2022–FY 2026 DATA STRATEGY | 1

Data Vision 

The SEC enables high-quality staff data analysis, provides well-structured data to the public, 

and manages data as a strategic asset.

Figure 1: Goals and Initiatives Summary

Goal 1

Enhance use 

of data assets

Goal 2

Design and build 

integrated data 

infrastructure 

Goal 3

Promote data awareness 

and literacy

Goals and 

Initiatives

SUMMARY

Goal 4

Strengthen data 

management and 

governance
The availability and accuracy of 

data that the agency generates, 

collects, and releases has always 

been viewed as a defining feature 

of U.S. capital markets that inspire

investor trust and confidence

Austin Gerig

Chief Data Officer
FY 2022–FY 2026 DATA STRATEGY | 3

Message from the Chief Data Officer

AUSTIN GERIG

CHIEF DATA OFFICER

Data has always been central to the SEC’s regulatory mission. For 

example, public companies must disclose to investors material 

and accurate information regarding their operations, financial 

condition, and management; and brokers, dealers, and other 

intermediaries must keep and preserve business records and 

records concerning securities transactions. The availability and 

accuracy of data that the agency generates, collects, and releases 

has always been viewed as a defining feature of U.S. capital 

markets that inspires investor trust and confidence. In this sense, 

the agency’s data constitutes a public good that we must carefully 

protect and manage. 

Title II of the Foundations for Evidence-Based Policymaking Act of 2018,3

 also known as 

the Open, Public, Electronic, and Necessary (OPEN) Government Data Act, sets forth a 

framework for managing government information as a strategic asset at each stage of the 

information’s life cycle to promote accessibility and usability. This framework has accelerated 

ongoing data-related initiatives and provided another impetus to meet the challenges of today’s 

increasingly complex, fast-paced, and interconnected markets. The OPEN Government Data 

Act makes agency chief data officers responsible for managing data assets;4 improving the 

agency’s infrastructure for data asset accessibility; and coordinating with others in the agency 

responsible for using, protecting, disseminating, and generating data to ensure that the data 

needs of the agency are met. 

This Data Strategy establishes an agenda for implementing certain OPEN Government Data 

Act requirements and improving the management and use of data at the SEC. The goals 

described are foundational and interrelated, but are also designed to allow priorities to shift 

in response to changing market trends and the agency’s evolving needs. Our embrace of agile 

project management and our use case-driven approach to investments will help ensure our 

efforts remain focused on value-generating activities.

It is my honor to serve as the SEC’s first Chief Data Officer and present this Data Strategy. 

I look forward to advancing the Data Strategy’s goals in close partnership with all of the 

agency’s divisions and offices.

Austin Gerig

Chief Data Officer
4 | U.S. Securities and Exchange Commission

The Vital Role of Data to the 

SEC Mission

Important developments in the creation of core data assets, in the implementation of new 

technologies that enabled more effective transmission or analysis of data, and in uses of data 

to enhance protection of investors or improve policy stand out as key milestones that have 

shaped SEC efforts to accomplish its regulatory mission. 

Figure 2: Data-Related Milestones 

1933 – 1940

The enactment of federal securities 

laws established the modern regulatory paradigm of the SEC collecting 

information from regulated entities 

for the benefit of the investing public. 

1983

The Commission began developing 

an electronic disclosure system.5

1993

The Commission began requiring 

disclosures to be filed electronically 

in its Electronic Data Gathering, 

Analysis, and Retrieval (EDGAR) 

system.6

2005

The Commission adopted Regulation National Market System (NMS) 

to, among other things, facilitate the 

collection, consolidation, and dissemination of information for the U.S. 

equities market.7

2009 • The Commission brought an 

insider trading case that relied on 

staff analysis of trade data.8

• The Commission began requiring 

operating companies and mutual 

funds to submit disclosures 

utilizing eXtensible Business 

Reporting Language (XBRL).9

• An agency-wide technology 

initiative consolidated multiple, 

dispersed repositories for tips 

and complaints into a single, 

searchable database for staff use.10

2010 • The staff of the Commission and 

the Commodity Futures Trading 

Commission issued a joint report 

on the “Flash Crash” of May 6, 

2010.11

• The enactment of the Dodd-Frank 

Wall Street Reform and Consumer 

Protection Act enabled the collection of security-based swaps 

data.12

• The SEC’s Division of Enforcement 

created a new Market Abuse 

Unit.13 Subsequently, Market 

Abuse Unit staff leveraged 

trading data to bring numerous 

enforcement actions for insider 

trading, hacking schemes, cherrypicking, front-running, and other 

trading abuses.14
FY 2022–FY 2026 DATA STRATEGY | 5

2012

The Commission adopted Regulation NMS Rule 613, requiring 

self-regulatory organizations to 

create the Consolidated Audit Trail.15

The Consolidated Audit Trail tracks 

orders throughout their life cycle, 

providing a comprehensive view 

of orders and executions across 

U.S. markets. 

2013

The agency implemented a Market 

Information Data Analytics System 

(MIDAS), which allows for the efficient collection and analysis of equity 

and futures order book data.16

2016 • New data analytics, including 

the use of artificial intelligence, 

machine learning, and natural 

language processing techniques, 

were used to identify registrants 

with elevated risk profiles,17

and a new exam analytics tool 

strengthened staff analysis of 

registrant trading activities.18

• The Commission adopted reforms 

to modernize and enhance 

the reporting and disclosure 

of information by registered 

investment companies and to 

enhance liquidity risk management 

by open-end funds, including 

mutual funds and exchangetraded funds.19

2018

The Commission’s adoption of 

amendments requiring the use of the 

Inline format for operating company 

financial statement information and 

mutual fund risk/return summary 

information enhanced the utility of 

that information.20

2020 • The SEC’s Office of the Chief Data 

Officer was created.21

• New data on private funds (e.g., 

hedge funds and private equity 

funds) collected through Form 

PF enabled risk-targeted SEC 

examinations of private fund 

advisers and addressed a data 

gap in the Financial Stability 

Oversight Council’s assessment 

of systemic risk in the U.S. 

financial markets.22

2021

The Consolidated Audit Trail data 

facilitated the agency’s inquiry into 

the extraordinary market volatility in 

early 2021.23

2022

The Commission brought a frontrunning case that was uncovered by 

staff analysis of Consolidated Audit 

Trail data.24
6 | U.S. Securities and Exchange Commission

Data-Related Goals and Initiatives

GOAL 1. Enhance use of data assets

Emphasize accessibility, structuring, and use of data assets to strengthen staff analysis and 

drive value for the public.

1.1 Maximize SEC use of core data assets25

Enhance data tools, infrastructure, and controls to enable faster and more costeffective data analysis to assess market developments and risks, prioritizing uses of 

data assets that have the greatest potential to advance the SEC’s regulatory mission. 

1.2 Enable new combinations of data to facilitate discovery of vital 

regulatory insights 

Enhance data tools, infrastructure, standards, and controls to enable staff to combine 

data for analysis to more effectively gain regulatory insights and prevent, detect, and 

enforce against improper behavior.

1.3 Increase accessibility and usability of disclosure data in electronic filings 

Enhance the accessibility and usability of public disclosures in electronic filings by 

improving mechanisms for ascertaining needs of data users (both outside and inside 

the SEC) and translating feedback regarding data quality into work product that 

informs recommendations for future rulemaking.
FY 2022–FY 2026 DATA STRATEGY | 7

GOAL 2. Design and build integrated data 

infrastructure 

Create a data environment that supports a seamless user experience that is governed by 

consistent standards, enables collaborative analysis and insight sharing, integrates services 

from multiple providers as needed, and enhances data security.

2.1 Promote seamless integration of data and analytics services

Recommend data architecture for an enterprise data infrastructure to support 

analytics platforms and to facilitate collaborative data analysis between and within 

divisions and offices. Leverage cloud computing capabilities to manage large-scale 

data assets more efficiently and to facilitate collaboration. 

2.2. Establish and apply uniform data and data architecture26 standard

Establish and apply data and data architecture standards consistently across all data 

assets to facilitate work across data assets, reduce data siloes, enhance collaboration, 

facilitate blending of different data assets, and streamline data management.

2.3 Implement enhanced data security controls

Automate data categorization and security responses, focusing on tagging and 

managing access to sensitive information, to support data governance, compliance 

with government mandates,27 and effective monitoring of data usage.
8 | U.S. Securities and Exchange Commission

Goal 3. Promote data awareness and literacy

Increase use of analytical tools with a focus on the needs of SEC staff. Build a data culture 

characterized by widespread data literacy and data-driven decision-making, including 

through workforce training on data approaches and techniques.

3.1 Promote a data-driven culture

Carry out an enterprise-wide change management and communications plan to 

strengthen staff commitment to data hygiene best practices. A data culture in which 

every staff member recognizes the importance of being a responsible steward of data 

and practicing data-driven decision-making will help the SEC fully leverage data as a 

strategic asset.

3.2 Expand the SEC’s internal data catalog to promote data awareness and 

facilitate collaboration

Augment the SEC’s data catalog as a means of promoting change management 

through community building around increased data awareness and literacy. Use 

the catalog to strengthen the staff’s understanding of data management best practices, 

promote data-driven decision-making, and help scale capabilities and talent across 

the Commission.
FY 2022–FY 2026 DATA STRATEGY | 9

Goal 4. Strengthen data management 

and governance

Design and implement use case-oriented data management practices that balance security and 

usability, facilitate collaboration, enhance analysis, and improve the quality of SEC data.

4.1 Enhance data policies

Enhance existing data policies and implement new policies to simplify data governance across the Commission and strengthen data protection. Address categorization 

of data, metadata capture, and governance of data access and sharing. 

4.2 Institute an enterprise-wide data quality program

Institute SEC-wide data quality processes to identify, catalog, and remediate data 

quality issues across data assets. Assign staff members responsibility for defining 

quality standards (based on industry standards, where possible) and developing 

plans for remediating identified quality issues. Include data quality descriptions in 

catalog records.

4.3 Establish an evaluation framework for data assets, infrastructure, uses, 

and policies 

Develop a framework to assess the value, cost, and risk of agency data acquisition 

and retention plans, data services infrastructure, data usage, and data controls, 

policies, and procedures. 
10 | U.S. Securities and Exchange Commission

Strategy Roadmap

Following publication of this Data Strategy, OCDO will work with agency stakeholders to 

develop an implementation plan in accordance with agency resourcing decisions. 

Figure 3: Strategy Roadmap

Phase 1 FY 2022–FY 2023

Provide an upgraded environment and 

implement additional security controls 

for data in the cloud

Develop data standards and data 

architecture standards 

Phase 2 FY 2023–FY 2024

Migrate additional data assets to 

upgraded environment and further 

implement enhanced security controls 

Work to align data standards and 

data architecture standards for core 

data assets 

Phase 3 FY 2025–FY 2026

Continue implementation of enhanced 

security controls

Work to align data standards and data 

architecture standards for additional 

data assets

Goal 1

Enhance use of 

data assets

Goal 2

Design and build integrated

data infrastructure

Phase 1 FY 2022–FY 2023

Enhance access to, and use of, 

market and industry data

Phase 2 FY 2023–FY 2024

Expand insights from market data 

to disclosure data

Enable staff to blend disparate data 

Phase 3 FY 2025–FY 2026

Expand access to core data assets 

Increase accessibility and usability 

of disclosure data 
FY 2022–FY 2026 DATA STRATEGY | 11

Goal 3

Promote data awareness 

and literacy

Goal 4

Strengthen data management and governance

Phase 1 FY 2022–FY 2023

Expand the data user community 

Promote collaboration among 

divisions and offices 

Phase 2 FY 2023–FY 2024

Enhance staff data literacy and 

analytical capabilities through training 

Phase 3 FY 2025–FY 2026

Integrate data literacy and analytical 

skills throughout all divisions and 

offices 

Phase 1 FY 2022–FY 2023

Establish data policies 

Apply data policies to core 

data assets

Phase 2 FY 2023–FY 2024

Apply data policies to core 

data assets

Institute proactive data quality 

management for core data 

assets 

Phase 3 FY 2025–FY 2026

Apply data policies to 

additional data assets 

Institute proactive data quality 

management for additional 

data assets
12 | U.S. Securities and Exchange Commission

ENDNOTES

1 The Data Management Program

encompasses enterprise-level data 

management projects and responsibilities. 

The Data Management Board provides 

advice and recommendations on oversight 

of the Data Management Program. The 

Board is composed of senior officials from 

across the SEC who have authority over data 

management and use, and who have insight 

into alignment between the SEC’s mission 

and its data management needs. See Sec. 

& Exch. Comm’n, SEC Data Managemen

Board Charter (Nov. 2, 2021) (last visited 

Dec. 3, 2022). The Data Management 

Program does not encompass data-related 

initiatives of individual divisions and offices.

2 The Commission’s Strategic Plan for Fiscal 

Years 2022 through 2026 has three primary 

goals: (1) protect the investing public against 

fraud, manipulation, and misconduct; (2) 

develop and implement a robust regulatory 

framework that keeps pace with evolving 

markets, business models, and technologies; 

and (3) support a skilled workforce that is 

diverse, equitable, and inclusive and is fully 

equipped to advance agency objectives. 

The Commission developed these goals 

to advance the SEC’s mission, which is to 

protect investors, maintain fair, orderly, 

and efficient markets, and facilitate capital 

formation. See Press Release, Sec. & Exch.

Comm’n, SEC Publishes FY22-26 Strategic

Plan (Nov. 23, 2022).

3 See Foundations for Evidence-Based 

Policymaking Act of 2018, Pub. L. No. 115-

435, 132 Stat. 5529 (Jan. 14, 2019).

4 The OPEN Government Data Act defines the

term “data” to mean “recorded information, 

regardless of form or the media on which the 

data is recorded” and the term “data asset” 

to mean “a collection of data elements or 

data sets that may be grouped together.” 

44 U.S.C. 3502(16) and (17).

5 See Sec. & Exch. Comm’n, Electronic Filin

and the EDGAR System: A Regulatory 

Overview (last visited Dec. 3, 2022).

6 See id.

7 See Press Release, Sec. & Exch. Comm’n

SEC Adopts Regulation NMS and Provisions 

Regarding Investment Advisers Act of 1940

(Apr. 7, 2005).

8 See Press Release, Sec. & Exch. Comm’n

SEC Charges Wall Street Professionals 

and Others in Insider Trading Ring

(Feb. 5, 2009).

9 See Sec. & Exch. Comm’n, Structure

Disclosure at the SEC: History and 

Rulemaking (last visited Dec. 3, 2022).

10 See Sec. & Exch. Comm’n Fiscal Year 201

Performance and Accountability Report

(Nov. 15, 2010) at 11.

11 See Sec. & Exch. Comm’n, Finding

Regarding the Market Events of May 6, 

2010: Report of the Staffs of the CFTC and 

SEC to the Joint Advisory Committee on 

Emerging Regulatory Issues (Sep. 30, 2010).

12 See Title VII of the Dodd-Frank Wall Street 

Reform and Consumer Protection Act, 

Pub. L. No. 111-203, 124 Stat. 1376 

(Jul. 21, 2010).

13 See Sec. & Exch. Comm’n, Fiscal Year 201

Performance and Accountability Report

(Nov. 15, 2010) at 10.

14 See, e.g., Press Release, Sec. & Exch.

Comm’n, SEC Charges Investment Advisers

with Cherry Picking, Obtains Asset Freeze

(Jun. 23, 2021); Press Release, Sec. & Exch.

Comm’n, SEC Charges Investment Adviser

and Its COO with Defrauding Clients (Jun. 

29, 2021); Press Release, Sec. & Exch.

Comm’n, SEC Charges Hedge Fund Trader

in Lucrative Front-Running Scheme (Jul. 2, 

2021); Press Release, Sec. & Exch. Comm’n

SEC Charges Netflix Insider Trading Ring

(Aug. 25, 2021); Press Release, Sec. & Exch.

Comm’n, SEC Charges Quant Analyst in

Multimillion Dollar Front-Running Scheme

(Sep. 23, 2021).

15 See Press Release, Sec. & Exch. Comm’n

SEC Approves New Rule Requiring 

Consolidated Audit Trail to Monitor and 

Analyze Trading Activity

(Jul. 11, 2012).
FY 2022–FY 2026 DATA STRATEGY | 13

16 See Sec. & Exch. Comm’n, MIDAS: Marke

Information Data Analytics System (last 

visited Dec. 3, 2022); Sec. & Exch. Comm’n

Agency Financial Report Fiscal Year 2014

at 14, 18 (reporting the development of 

MIDAS to collect and analyze market data, 

permitting staff to better use data to monitor 

the integrity of markets); Gregg E. Berman, 

Associate Director, Off. of Analytics and 

Rsch., Div. of Trading and Markets, Sec. & 

Exch. Comm’n, Address at SIFMA TEC

Conference: Transformational Technologies, 

Market Structure, and the SEC (Jun. 18, 

2013) (describing the original impetus 

of MIDAS as to be able to more readily 

reconstruct market-wide events like the 

Flash Crash).

17 See Scott W. Bauguess, Deputy Director 

and Deputy Chief Economist, Div. of Econ. 

and Risk Analysis, Sec. & Exch. Comm’n

Address at American Accounting Association 

Midwest Region Meeting: Has Big Data 

Made Us Lazy? (Oct. 21, 2016).

18 See Sec. & Exch. Comm’n, Off

Compliance Inspections And Examinat

National Exam Program Examination 

Priorities for 2016 (Jan. 11, 2016).

19 See Press Release, Sec. & Exch. Comm’n

SEC Adopts Rules to Modernize Information 

Reported by Funds, Require Liquidity Risk 

Management Programs, and Permit Swing 

Pricing (Oct. 13, 2016).

20 See Press Release, Sec. & Exch. Comm’n

SEC Adopts Inline XBRL for Tagged 

Data (Jun. 28, 2018). See generally Sec. & 

Exch. Comm’n, Structured Disclosure at th

SEC: History and Rulemaking (last visited 

Dec. 3, 2022).

21 See Press Release, Sec. & Exch. Comm’n

Austin Gerig Named as SEC’s Chief Data 

Officer (Jan. 16, 2020).

22 See Sec. & Exch. Comm’n, Annual Staf

Report Relating to the Use of Form PF 

Data (Nov. 2, 2020).

23 See Sec. & Exch. Comm’n, Staff Repor

on Equity and Options Market Structure 

Conditions in Early 2021 (Oct. 14, 2021).

24 See Press Release, Sec. & Exch. Comm’n

SEC Charges Financial Services Professional 

and Associate in $47 Million Front-Running 

Scheme (Dec. 14, 2022).

25 In this document, our use of the phrase “core 

data assets” refers to data assets prioritized 

in Data Management Program initiatives as 

approved by the Data Management Board.

26 In this document, we use the term “data 

architecture” to refer to a form of enterprise 

architecture comprising models, policies, 

rules, and standards that govern the collection, storage, arrangement, integration, 

and use of data in an organization such as 

the SEC.

27 See, e.g., Off. of Mgmt. & Budget, Exec. 

Off. of the President, OMB M-22-09, 

Moving the U.S. Government Toward Zero 

Trust Cybersecurity Principles (Jan. 26, 

2022) (calling for categorization of data 

based on protection needs, which would 

build a foundation to automate security 

access rules).


U.S. SECURITIES AND EXCHANGE COMMISSI

Washington, DC 20549