U.S. SECURITIES AND EXCHANGE COMMISSION

STRATEGIC PLAN 2021-2025

Office of the Advocate for 

Small Business 

Capital Formation
This Strategic Plan of the Office of the Advocate 

for Small Business Capital Formation does not 

necessarily reflect the views of the Commission, 

the Commissioners, or staff of the Commission.
STRATEGIC PLAN 2021–2025 | 1

MESSAGE FROM THE DIRECTOR OF 

THE OFFICE OF THE ADVOCATE FOR 

SMALL BUSINESS CAPITAL FORMATION

No longer a startup within the U.S. Securities and Exchange Commission (SEC), our 

Office of the Advocate for Small Business Capital Formation has successfully scaled and 

operationalized over our first two years. Our team continues to champion pragmatic 

solutions so that small businesses—from startups to smaller public companies—and 

their investors can build great companies together using our capital markets.

This strategic plan is a roadmap to guide our Office’s decisions and align actions with 

mission execution. We are making this plan publicly available in furtherance of our core 

values: making our work accessible, fostering inclusivity in how we engage internally 

and externally, crafting pragmatic approaches to addressing capital raising challenges, 

and being efficient with how our team uses time and resources. The plan outlines four 

key goals, with strategies and initiatives underpinning each.

We are committed to this vision for our Office, and I look forward to implementing 

this plan together with the Commission, our SEC colleagues, Congress, our agency 

partners, and—most importantly—those whom we are called to serve: small businesses 

and their investors.

MARTHA LEGG MILLER
2 | OFFICE OF THE ADVOCATE FOR SMALL BUSINESS CAPITAL FORMATION

EXECUTIVE SUMMARY

GOAL 1

Engage with small businesses and their investors to solicit views on 

relevant capital raising issues.

Strategy 1.1: Conduct outreach with diverse audiences.

Strategy 1.2: Host the SEC’s annual Small Business Forum.

GOAL 2

Educate small businesses and their investors about capital raising 

rules to reduce barriers to entry and increase compliance.

Strategy 2.1: Develop accessible educational materials about capital raising.

Strategy 2.2: Optimize content and delivery based upon changes in market 

needs and preferences.

GOAL 3

Collaborate on pragmatic policy solutions to address capital raising 

challenges faced by small businesses and their investors.

Strategy 3.1: Assist small businesses and their investors in resolving issues 

encountered with the SEC or self-regulatory organizations (SRO).

Strategy 3.2: Analyze data on capital raising to identify trends and gaps in 

funding, including for underrepresented and rural founders, and 

in areas affected by natural disasters.

Strategy 3.3: Promote practical policy solutions for Commission or 

Congressional action to address capital raising challenges.

Strategy 3.4: Deliver annual reports to Congress and the Commission that 

advocate for capital raising solutions.

Strategy 3.5: Support the SEC’s Small Business Capital Formation Advisory 

Committee in providing advice to the Commission on capital 

raising policy.

GOAL 4

Empower a mission-driven team to leverage varied perspectives to 

solve the complex problems of an evolving and increasingly diverse 

capital market.

Strategy 4.1: Advance diversity, equity, and inclusion (DE&I) throughout 

 Office operations.

Strategy 4.2: Foster a culture of connectivity, collegiality, and collaboration 

 among Office staff.
STRATEGIC PLAN 2021–2025 | 3

ABOUT THE OFFICE

The Office advocates for solutions to address challenges faced by small businesses 

and their investors raising and deploying capital. “Small business” for the Office spans 

from early-stage start-ups raising seed capital, to later-stage private companies whose 

founders and investors are seeking liquidity in the public markets, all the way to smaller 

public companies. Congress established the Office via the bipartisan SEC Small Business 

Advocate Act of 2016 as an independent office within the U.S. Securities and Exchange 

Commission (SEC) that reports to the entire Commission as well as to multiple 

committees of Congress.

The Office approaches its advocacy mission by:

 Engaging with small businesses and their investors to understand their most 

pressing capital raising issues;

 Identifying unique capital raising challenges faced by minority-owned, womenowned, rural, and natural disaster-affected small businesses and their investors;

 Analyzing the potential impact of policy changes likely to significantly affect 

small businesses and their investors; and

 Advocating to Congress and the Commission for policy changes.

MISSION

We champion pragmatic solutions so that small businesses—from startups to smaller 

public companies—and their investors can build great companies together using our 

capital markets.

CORE VALUES

ACCESSIBILITY — We engage with both small businesses and their investors, as 

well as with the SEC, SROs, Congress, and other agencies on a regular basis through a 

variety of channels.

INCLUSIVITY — We encourage people to speak openly and contribute authentically to 

facilitate greater trust and collaboration.

PRAGMATISM — We approach problems with a solution-oriented mindset to make 

practical recommendations.

EFFICIENCY — We operate like a lean start-up, maximizing resources and focusing 

activities where the Office can have a meaningful impact.
GOALS, STRATEGIES, 

AND INITIATIVES

GOAL 1: ENGAGE

GOAL 4: PEOPLE

GOAL 2: EDUCATE

GOAL 3: POLICY
STRATEGIC PLAN 2021–2025 | 5

ENGAGE WITH SMALL BUSINESSES AND THEIR INVESTORS 

TO SOLICIT VIEWS ON RELEVANT CAPITAL RAISING ISSUES.

STRATEGY 1.1: CONDUCT OUTREACH WITH DIVERSE AUDIENCES.1

 Engage with small businesses, investors, professional advisors, and ecosystem 

builders through a variety of channels, including: roundtables, speaking 

engagements, podcast recordings, webinars, and other relevant platforms.

» Leverage external participants’ networks for broader reach.

» Share recordings after events, as appropriate, to increase accessibility.

 Proactively connect with:2

» Underrepresented demographic groups, including women and minorities;

» Entrepreneurial ecosystems across the United States, including rural 

communities and areas affected by natural disasters; and

» Businesses and investors at different stages of the capital raising lifecycle.

 Collaborate with the Office of Public Affairs (OPA), the Office of Minority and 

Women Inclusion (OMWI), the Office of Legislative and Intergovernmental 

Affairs, and SEC regional offices in the promotion of events to maximize 

accessibility and reach of engagement efforts.

 Involve SEC leadership and relevant policymaking staff to provide direct 

exposure to public feedback.

 Track outreach metrics, including attendee headcount and any expressed 

attendee demographic affiliation and geographic location, as available.

STRATEGY 1.2: HOST THE SEC’S ANNUAL SMALL BUSINESS FORUM.3

 Convene members of the public and private sectors for a yearly forum to 

highlight relevant capital raising issues and suggest policy improvements.4

 Invite speakers who bring diverse backgrounds and perspectives. 

 Incorporate federal agencies, SEC staff, and other stakeholders in planning and 

providing feedback on the event.5

 Prepare a report to Congress with a summary of the event and findings or 

recommendations by participants, along with the Commission’s response.6

1

GOAL
6 | OFFICE OF THE ADVOCATE FOR SMALL BUSINESS CAPITAL FORMATION

EDUCATE SMALL BUSINESSES AND THEIR INVESTORS 

ABOUT CAPITAL RAISING RULES TO REDUCE BARRIERS 

TO ENTRY AND INCREASE COMPLIANCE.

STRATEGY 2.1: DEVELOP ACCESSIBLE EDUCATIONAL MATERIALS 

ABOUT CAPITAL RAISING.7

 Collaborate with rulewriting staff, the Office of the General Counsel (OGC), 

and OPA on content development.

 Design user-centric content tailored to targeted audiences—such as videos, 

Q&A guides, fact sheets, charts, and infographics—that:

» Explain impact of rule changes to affected audiences; and

» Encourage comments to the rulemaking file for rule proposals.

 Create educational toolkits for distribution through external parties’ platforms 

(e.g., educational institutions, trade associations, chambers of commerce, 

accelerators, local bar associations).

 Promote educational materials across channels that meet user needs, including 

SEC.gov, social media, and email.

STRATEGY 2.2: OPTIMIZE CONTENT AND DELIVERY BASED UPON 

CHANGES IN MARKET NEEDS AND PREFERENCES.

 Assess trends in external parties’ capital raising educational content to 

understand user needs and address gaps in Office content.

 Evaluate educational content sufficiency and relevancy to ensure it meets the 

needs of small businesses and their investors.

 Collaborate internally and externally to update content and delivery strategies.

2

GOAL
STRATEGIC PLAN 2021–2025 | 7

COLLABORATE ON PRAGMATIC POLICY SOLUTIONS TO 

ADDRESS CAPITAL RAISING CHALLENGES FACED BY SMALL 

BUSINESSES AND THEIR INVESTORS.

STRATEGY 3.1: ASSIST SMALL BUSINESSES AND THEIR INVESTORS IN 

RESOLVING ISSUES ENCOUNTERED WITH THE SEC OR SELF-REGULATORY 

ORGANIZATIONS (SRO).8

 Maintain accessible channels for communication with the public, including:

» Public-facing website;

» Email inbox; and

» Office phone line.

 Raise relevant matters with SEC leadership, rulewriting teams, and SROs for 

technical assistance, issue flagging, and/or policy resolution.

STRATEGY 3.2: ANALYZE DATA ON CAPITAL RAISING TO IDENTIFY TRENDS 

AND GAPS IN FUNDING, INCLUDING FOR UNDERREPRESENTED AND RURAL 

FOUNDERS, AND IN AREAS AFFECTED BY NATURAL DISASTERS.9

 Monitor research and publications on relevant capital raising topics.

 Engage with academia and thought leaders who study relevant capital raising topics, 

collaborating as appropriate on areas for further research.

 Work with the Division of Economic and Risk Analysis (DERA) on analyses of 

capital raising trends.

 Produce translational research in the Office’s annual report to contextualize capital 

raising policy alongside market trends.

 Conduct or contract for research in accordance with the Office’s statutory mandate.10

STRATEGY 3.3: PROMOTE PRACTICAL POLICY SOLUTIONS FOR 

COMMISSION OR CONGRESSIONAL ACTION TO ADDRESS CAPITAL RAISING 

CHALLENGES.11

 Contribute to Commission capital raising policy initiatives by:

» Supporting SEC staff and leadership during the rulewriting process; 

» Suggesting timely research and public feedback from outreach to be considered 

by the Commission; and

» Providing insights on the potential impact of policy initiatives on small 

businesses and their investors.

 Monitor relevant updates to SRO rules.

 Liaise with Congress and committee staff on relevant capital raising matters.

 Propose other policy solutions by:12

» Identifying practical options directly with SEC leadership;

» Publishing recommended solutions in the Office’s annual report;

» Consulting with other SEC staff and leadership, including the Office of the 

Investor Advocate,13 and OMWI;14

» Conferring with Congress, other federal agencies, policymakers, interest 

3

GOAL
8 | OFFICE OF THE ADVOCATE FOR SMALL BUSINESS CAPITAL FORMATION

groups, and private parties on potential solutions; and

» Working with the Commission as it responds to solutions from the Office.15

STRATEGY 3.4: DELIVER ANNUAL REPORTS TO CONGRESS AND THE 

COMMISSION THAT ADVOCATE FOR CAPITAL RAISING SOLUTIONS.16

 Prepare a compelling and visually engaging report on the Office’s prior fiscal year, 

detailing:

» Highlighted activities of the Office;17

» Data from DERA and external parties quantifying relevant capital 

raising trends;18

» Policy recommendations to address key capital raising issues,19 highlighting 

unique challenges encountered by underrepresented groups;20

» Small Business Capital Formation Advisory Committee activities 

(see Strategy 3.5); and

» Any other information on capital raising matters that are appropriate to 

promote the interests of small businesses and their investors.21

» Ensure independence of the report by limiting pre-publication access to 

design support by OPA and citation clearance by OGC staff.22

 Promote accessibility of the report following publication, including via social 

media and targeted outreach.

STRATEGY 3.5: SUPPORT THE SEC’S SMALL BUSINESS CAPITAL 

FORMATION ADVISORY COMMITTEE IN PROVIDING ADVICE TO THE 

COMMISSION ON CAPITAL RAISING POLICY.23

 Provide administrative support for meetings called by the Committee chair or 

the Commission, including by:24

» Coordinating meeting logistics, travel, and other matters;

» Drafting meeting materials at the direction of the Committee chair;

» Vetting speakers and preparing briefing materials for Committee members; 

and

» Managing the Committee website on SEC.gov in collaboration with OPA.

 Support the Commission’s replacement of Committee members upon resignation, 

removal, or expiration of terms, including by:

» Monitoring end dates of Committee member terms;

» Conferring with OMWI and other SEC leadership on candidate 

identification; and

» Vetting a diverse slate of candidates based upon functional 

membership categories.

 Highlight the Committee’s fiscal year activities in the Office’s annual report.

 Collaborate with rulewriting staff on Commission responses to Committee 

recommendations.25
STRATEGIC PLAN 2021–2025 | 9

EMPOWER A MISSION-DRIVEN TEAM TO LEVERAGE 

VARIED PERSPECTIVES TO SOLVE THE COMPLEX 

PROBLEMS OF AN EVOLVING—AND INCREASINGLY 

DIVERSE—CAPITAL MARKET.

STRATEGY 4.1: ADVANCE DIVERSITY, EQUITY, AND INCLUSION (DE&I) 

THROUGHOUT OFFICE OPERATIONS.26 

 Incorporate best practices with hiring, development, and retention to develop 

a team that is reflective of the multi-faceted needs of small businesses and their 

investors, with attention paid to all facets of diversity.

 Take proactive steps to include diverse voices in decision-making for the Office 

and that team members have equal opportunity to thrive.

 Develop skills and talents of team members through coaching, training, and 

opportunities to hone subject matter expertise.

 Broadly engage both internally and externally on DE&I issues.

STRATEGY 4.2: FOSTER A CULTURE OF CONNECTIVITY, COLLEGIALITY, 

AND COLLABORATION AMONG OFFICE STAFF.

 Reduce barriers and foster connectivity among colleagues through project 

staffing decisions and informal relationship-building opportunities.

 Emphasize transparency in decision-making, a team-based mentality, and 

positivity in approaching challenges.

 Provide regular, concrete feedback to team members to set expectations 

and create clear pathways for growth.

4

GOAL

STRATEGIC PLAN 2021–2025 | 11

END NOTES

1 See 15 U.S.C. § 78d(j)(4)(E), directing the 

Office to “conduct outreach to small businesses and small business investors, including 

through regional roundtables, in order to 

solicit views on relevant capital formation issues.”

2 See 15 U.S.C. § 78d(j)(4)(C), directing the 

Office to “identify problems that small businesses have with securing access to capital, 

including any unique challenges to minorityowned small businesses, women-owned small 

businesses, and small businesses affected by 

hurricanes or other natural disasters.”

3 See 15 U.S.C. § 78d(j)(8), directing the Office 

to “be responsible for planning, organizing, 

and executing the annual Government-Business Forum on Small Business Capital Formation described in section 80c–1 of this title.”

4 See 15 U.S.C. § 80c-1(a), directing the SEC 

through the Office to “conduct an annual 

Government-business forum to review the current status of problems and programs relating 

to small business capital formation.”

5 See 15 U.S.C. § 80c-1(b), directing the Commission to “invite other Federal agencies, such 

as the Department of the Treasury, the Board 

of Governors of the Federal Reserve System, 

the Small Business Administration, organizations representing State securities commissioners, and leading small business and professional organizations concerned with capital 

formation, to participate in the planning for 

such forums.”

6 See 15 U.S.C. § 80c-1(e), directing the 

Commission to “(1) review the findings and 

recommendations of the forum; and (2) each 

time the forum submits a finding or recommendation to the Commission, promptly issue 

a public statement-(A) assessing the finding or 

recommendation of the forum; and (B) disclosing the action, if any, the Commission intends 

to take with respect to the finding or recommendation.”

7 See note 2; through outreach with small 

businesses and their investors, accessibility 

of securities laws has been repeatedly flagged 

as a critical barrier to entry for entrepreneurs 

and investors alike, particularly among communities with fewer financial resources. See 

also SEC FY 2018-2022 Strategic Plan, Initiative 1.2 “Enhance our outreach, education, 

and consultation efforts, including in ways 

that are reflective of the diversity of investors 

and businesses.”

8 See 15 U.S.C. § 78d(j)(4)(A), directing the 

Office to “assist small businesses and small 

business investors in resolving significant problems such businesses and investors may have 

with the Commission or with self-regulatory 

organizations.”See also SEC FY 2018-2022 

Strategic Plan, Initiative 1.1 “Enhance our 

understanding of the channels retail and 

institutional investors use to access our capital 

markets to more effectively tailor our policy 

initiatives.”

9 See 15 U.S.C. § 78d(j)(4)(D)(i), directing the 

Office to “analyze the potential impact on 

small businesses and small business investors 

of proposed regulations of the Commission 

that are likely to have a significant economic 

impact on small businesses and small business 

capital formation.” See also SEC FY 2018-

2022 Strategic Plan, Initiative 2.1 “Expand 

market knowledge and oversight capabilities 

to identify, understand, analyze, and respond 

effectively to market developments and risks.”

10 See note 9.

11 See 15 U.S.C. §§ 78d(j)(4)(B), directing the 

Office to “identify areas in which small businesses and small business investors would 

benefit from changes in the regulations of the 

Commission or the rules of self-regulatory 

organizations.” See also SEC FY 2018-2022 

Strategic Plan, Initiative 2.2 “Identify, and 

take steps to address, existing SEC rules and 

approaches that are outdated.”

12 See 15 U.S.C. § 78d(j)(4)(F), directing the Office to “propose to the Commission changes in 

the regulations or orders of the Commission 

and to Congress any legislative, administrative, 

or personnel changes that may be appropriate to mitigate problems identified under this 

paragraph and to promote the interests of 

small businesses and small business investors.”

13 See 15 U.S.C. § 78d(j)(4)(G), directing the 

Office to “consult with the Investor Advocate 

on proposed recommendations made under 

subparagraph (F).”

14 See also SEC FY 2018-2022 Strategic Plan, 

Initiative 3.5 “Promote collaboration within 

and across SEC offices to ensure we are communicating effectively across the agency, 

including through evaluation of key internal 

processes that require significant collaboration.”

15 See 15 U.S.C. § 78d(j)(7).
12 | OFFICE OF THE ADVOCATE FOR SMALL BUSINESS CAPITAL FORMATION

16 See 15 U.S.C. § 78d(j)(6)(A), directing that 

“[n]ot later than December 31 of each year 

after 2015, the Advocate for Small Business Capital Formation shall submit to the 

Committee on Banking, Housing, and Urban 

Affairs of the Senate and the Committee on 

Financial Services of the House of Representatives a report on the activities of the Advocate 

for Small Business Capital Formation during 

the immediately preceding fiscal year.”

17 See 15 U.S.C. § 78d(j)(6)(B)(ii), directing 

the report to include: “information on steps 

that the Advocate for Small Business Capital 

Formation has taken during the reporting 

period to improve small business services and 

the responsiveness of the Commission and selfregulatory organizations to small business and 

small business investor concerns”

18 See 15 U.S.C. § 78d(j)(6)(B)(i), directing the 

report to include: “appropriate statistical 

information and full and substantive analysis.”

19 See 15 U.S.C. § 78d(j)(6)(B)(v), directing the 

report to include: “recommendations for 

such changes to the regulations, guidance and 

orders of the Commission and such legislative 

actions as may be appropriate to resolve problems with the Commission and self-regulatory 

organizations encountered by small businesses 

and small business investors and to encourage 

small business capital formation.”

20 See 15 U.S.C. § 78d(j)(6)(B)(iii), directing the 

report to include: “a summary of the most 

serious issues encountered by small businesses and small business investors, including 

any unique issues encountered by minorityowned small businesses, women-owned small 

businesses, and small businesses affected by 

hurricanes or other natural disasters and their 

investors, during the reporting period.”

21 See 15 U.S.C. § 78d(j)(6)(B)(iv), directing the 

report to include: “an inventory of the items 

summarized under clause (iii) (including items 

summarized under such clause for any prior 

reporting period on which no action has been 

taken or that have not been resolved to the 

satisfaction of the Advocate for Small Business 

Capital Formation as of the beginning of the 

reporting period covered by the report) that 

includes— 

(I) identification of any action taken by the 

Commission or the self-regulatory organization and the result of such action; 

(II) the length of time that each item has 

remained on such inventory; and 

(III) for items on which no action has been 

taken, the reasons for inaction, and an 

identification of any official who is responsible for such action;”

See also 15 U.S.C. § 78d(j)(6)(B)(vi), directing 

the report to include “any other information, 

as determined appropriate by the Advocate for 

Small Business Capital Formation.”

22 See 15 U.S.C. § 78d(j)(6)(D), directing that 

the report “shall be provided directly to the 

committees of Congress listed in such subparagraph without any prior review or comment 

from the Commission, any commissioner, any 

other officer or employee of the Commission, 

or the Office of Management and Budget.”

23 See 15 U.S.C. § 78qq.

24 See 15 U.S.C. § 78qq(d)(1), (f), directing 

the Commission to “make available to the 

Committee such staff as the chairman of the 

Committee determines are necessary to carry 

out this section.”

25 See 15 U.S.C. § 78qq(g), directing the Commission to “(1) review the findings and 

recommendations of the Committee; and (2) 

each time the Committee submits a finding or 

recommendation to the Commission, promptly 

issue a public statement— (A) assessing the 

finding or recommendation of the Committee; 

and (B) disclosing the action, if any, the Commission intends to take with respect to the 

finding or recommendation.”

26 See SEC Diversity and Inclusion Strategic 

Plan for FY 2020-2022; see also 15 U.S.C. §

78d(j)(3).

OFFICE OF THE 

ADVOCATE FOR SMALL 

BUSINESS CAPITAL 

FORMATION

U.S. Securities and 

Exchange Commission

100 F Street NE

Washington, DC 20549

202.551.5407

www.sec.gov/oasb

smallbusiness@sec.gov