U.S. Securities and 

Exchange Commission

February 2010

FY 2011 Congressional Justification
U.S. Securities and Exchange Commission 

TABLE OF CONTENTS 

Subject Page

Executive Summary 2 

Tables 

FTE and Positions by Program 8 

Obligations by Object Class 9 

Average Salary and Grade 9 

FY 2011 Request by Strategic Goal and Program 10 

Summary of Changes 11 

Fee Collections and Spending Authority 12 

Appropriations Language 13

Request by Strategic Goal 14

Goal 1: Foster and Enforce Compliance with the Federal Securities Laws 17 

Goal 2: Establish an Effective Regulatory Environment 25 

Goal 3: Facilitate Access to the Information Investors Need to Make Informed Decisions 32 

Goal 4: Enhance the Commission’s Performance through Effective Alignment and Management of Human, 

Information, and Financial Capital 37 

Request by Program 

Division of Enforcement 45 

Office of Compliance Inspections and Examinations 46 

Division of Corporation Finance 47 

Division of Trading and Markets 48 

Division of Investment Management 49 

Division of Risk, Strategy and Financial Innovation 50 

Office of the General Counsel 51 

Other Program Offices 52 

Office of Chief Accountant 53 

Office of Investor Education and Advocacy 54 

Office of International Affairs 55 

Office of the Administrative Law Judges 56 

Agency Direction and Administrative Support 57 

Agency Direction 58 

Office of the Executive Director 59 

Office of Information Technology 60 

Office of Equal Employment Opportunity 61 

Office of the Inspector General 62 

Appendix A - Acronyms 63

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EXECUTIVE SUMMARY 

The financial crisis that began in 2008 and continues to resonate through the markets today is, as 

President Obama has stated, the most serious economic and regulatory crisis this country has faced 

since the Great Depression. The damage to investors, to taxpayers, to our economy, and to our nation 

has been real and significant. The crisis has also challenged investor faith in our financial system. 

The response to this crisis has required extraordinary efforts from every federal financial regulator, 

including the U.S. Securities and Exchange Commission (SEC) and its staff. 

But the job of restoring investor confidence and rebuilding trust in financial institutions and markets is 

far from done, and will require a sustained regulatory commitment for years to come. That the federal 

government be successful in these efforts is extremely important. Integral to this success is an SEC 

that is revitalized and refocused on its core mission to protect investors, maintain fair, orderly, and 

efficient markets, and facilitate capital formation. 

Between fiscal years (FY) 2005 and 2007, the SEC experienced three years of flat or declining 

budgets, losing 10 percent of its employees and severely hampering key areas such as the agency’s 

enforcement and examination programs. Even with the funding increases provided by Congress in the 

last two years, under the SEC’s current funding level, the agency’s workforce still falls about one 

percent—or 35 full-time-equivalents (FTE)—short of the FY 2005 level. And yet while the 

workforce at the SEC has shrunk, the job that the SEC has been asked to do has grown even larger. 

Since 2005, the number of investment advisers registered with and overseen by the SEC has grown by 

32 percent, and the number of broker-dealer branch offices has grown by 67 percent. 

The SEC oversees a total of more than 35,000 registrants, including over 10,000 public companies, 

7,800 mutual funds, about 11,500 investment advisers, 5,400 broker-dealers, 600 transfer agents, 12 

securities exchanges, 10 nationally recognized statistical rating organizations (NRSROs), and selfregulatory organizations (SROs) such as the Financial Industry Regulatory Authority, Municipal 

Securities Rulemaking Board, and Public Company Accounting Oversight Board. While other 

financial regulators have close to parity between the number of staff and the number of entities they 

regulate, in recent years SEC staffing and funding simply have not kept pace with industry growth. 

In order to provide sufficient resources to restore the agency as a vigorous and effective regulator of 

the nation’s securities markets, and to implement the Administration’s proposal for financial reform, 

the President has requested $1.258 billion in FY 2011 for the SEC. This represents an increase of 

approximately $139 million over the SEC’s FY 2010 funding level of $1.119 billion, and authority for 

4,720 total positions (or 4,190 FTE), an increase of 380 positions (associated with 119 FTE) over FY 

2010. Within this amount, $24 million in FY 2011 is requested contingent upon the enactment of 

financial reform legislation, to begin implementation of the SEC’s new and enhanced authorities 

under the Administration’s financial reform proposal. 

It is important to note that this proposed increase in SEC spending would be fully offset by increased 

SEC collections of fees on securities transactions and registrations. In FY 2011, pursuant to the 

requirements of the Investor and Capital Markets Fee Relief Act (P.L. 107-123), the SEC will set fees 

at levels sufficient to raise $1.7 billion in collections, an increase of $220 million over FY 2010. 

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Here is a summary of how the SEC plans to use its FY 2011 resources: 

Reinvigorating SEC Enforcement 

Enforcement of the securities laws is the foundation of the SEC’s mission, and swift and vigorous 

prosecution of those who have broken the law is at the heart of the agency’s efforts to restore investor 

trust and confidence in the nation’s securities markets. 

The SEC’s top priority is to reinvigorate its enforcement program, which in recent years has operated 

under a variety of budgetary and procedural constraints. To carry out these efforts, the SEC plans to 

fill 1,478 positions (or 1,368 FTE) in FY 2011, an increase of 70 positions (associated with 26 FTE) 

above FY 2010. At these staff levels, the agency estimates the SEC will be able to commence 75 

additional inquiries, conduct 314 additional formal investigations, and file charges in 70 additional 

civil or administrative cases. Without these resources, the SEC would simply not be able to 

investigate and bring as many cases as projected. These 70 positions will be allocated as follows: 

• 39 new positions (associated with 14 FTE) committed to reinforcing the investigations process. 

This is directly responsive to the findings in the Government Accountability Office’s March 2009 

report on the agency’s enforcement program, which identified an 11 percent decline in 

investigative staffing levels from FY 2004 to FY 2008. A significant number of these new 

positions will be for administrative, support, and paralegal staff—a particular need identified in 

the GAO’s report. 

• 16 positions (seven FTE) to reinforce the proceedings function, including trial lawyers and support 

for bringing enforcement cases in federal court or in administrative proceedings. 

• 15 positions (five FTE) to strengthen the intelligence analysis function, including the newly 

created Office of Market Intelligence. The office’s functions will include managing the riskassessment and strategic planning processes to ensure that the agency’s investigations are 

strategic, swift, smart, and successful. 

Finally, the SEC is also presently engaged in a strategic review and redesign of the systems for 

collecting, reviewing, and acting on complaints, tips, and investigative leads provided by 

whistleblowers or other sources. Over the past ten years, the agency has seen a dramatic increase in 

the number of tips received annually, and the current infrastructure is simply unable to keep pace. 

Having an effective process for reviewing these to identify the most valuable tips can give the agency 

an early jump on detecting and stopping frauds and other violations of securities laws. Staffing for 

this function will be integrated into the Office of Market Intelligence, and funding for development of 

systems improvements is a top priority within the agency’s information technology budget. 

 

Strengthening Examinations and Oversight 

One lesson that has been learned from the recent financial crisis is that strong regulation is essential to 

the fair, orderly, and efficient operation of markets. The SEC’s enforcement program is designed to 

bring to justice those who violate the securities laws and whenever possible provide restitution to 

harmed investors. The SEC’s rulemaking and examination programs serve the equally important roles 

of setting forth the rules of appropriate conduct, and examining for compliance with those rules. 

When these functions are performed well, such as by closing regulatory gaps through the rule-writing 

process or providing early warning to firms about potential weaknesses in compliance programs, they 

reduce the opportunities for wrongdoing. 

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Within the examination function, the SEC plans to fill 1,033 positions (or 912 FTE), an increase of 

100 positions (associated with 30 FTE) from FY 2010. This increase will enable the SEC’s 

examination program to begin to address the growing disparity between the number of exam staff and 

the growing number of registered firms, which include investment advisers, broker-dealers, mutual 

funds, self-regulatory organizations, and nationally recognized statistical rating agencies. As an 

example of the challenges the SEC faces in overseeing a growing number of registrants, the agency 

has approximately 460 examiners and accountants responsible for overseeing roughly 11,500 

investment advisers and 7,800 mutual funds. It is also worth noting that the number of registered 

entities will grow by thousands more if the Administration’s legislation is enacted to require oversight 

of advisers to hedge funds and other private pools of capital. 

Decreasing the huge disparity between the number of exam staff and the number of regulated entities 

will take several years, as the SEC cannot hire and appropriately train an unlimited number of new 

examiners in a single year. Consequently, the examinations program is designed to target resources 

where they will do the most good by focusing on high-risk practices and entities. A key part of the 

agency’s FY 2011 budget is devoted to continuing the development of more robust and sophisticated 

methodology for identifying those high-risk targets. 

The agency estimates that the additional staff will enable the SEC to conduct 50 additional exams of 

investment advisers, 25 additional mutual fund exams, and 75 examinations of newly registered fund 

advisers, assuming legislation is enacted requiring them to register with the Commission. Without 

these additional resources, the scope and coverage of examinations will be limited, despite the 

agency’s efforts aimed at further developing a robust risk-based approach to oversight. 

Additionally, the FY 2011 budget will enable the SEC to carry out a more robust oversight function 

for credit rating agencies. In 2006, the SEC took on a major new responsibility with the enactment of 

the Credit Rating Agency Reform Act, which gave the agency authority to regulate certain internal 

processes of nationally recognized statistical rating organizations, such as record-keeping and policies 

to guard against conflicts of interest. This budget will staff this function and enable the exam staff to 

conduct examinations at half of the registered nationally recognized statistical rating organizations in 

FY 2011. 

The Division of Investment Management is responsible for establishing rules that regulate the $30 

trillion investment management industry in the United States, including mutual funds, exchangetraded funds, and investment advisers. As part of these responsibilities, the division also annually 

reviews disclosures of over 4,000 investment companies. For FY 2011, the agency plans to allocate a 

total of 194 positions (or 174 FTE) for Investment Management, an increase of 20 positions 

(associated with 6 FTE). These additional resources are needed to provide more robust oversight in 

several areas where the recent financial crisis has identified the need for improved regulation. 

Ten of these new positions (or three FTE) will be allocated to regulation of advisers to hedge funds 

and private pools of capital. The President has proposed legislation to require advisers to hedge funds 

and other private pools of capital to register with and report information to the SEC under the 

Investment Advisers Act. The additional staff positions requested will be used to conduct rulemaking 

related to this industry, provide interpretive and other guidance to advisers, and assist with related 

enforcement matters. (In addition, the budget envisions using approximately 35 of the 100 additional 

examinations staff positions to conduct compliance exams of hedge fund advisers and others who 

would be required to register if the President’s proposal should become law.) 

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Another major priority for Investment Management is oversight of money market funds, which hold 

approximately $3 trillion in assets, including about one-fifth of U.S. households’ cash balances. In the 

fall of 2008, as liquidity concerns and vulnerabilities in several funds were exposed, the systemic risk 

implications of this market quickly became clear when investors withdrew $300 billion, or nearly 15 

percent of all assets, during a single week. The SEC has adopted new rules to strengthen the 

operations of money market funds, including requirement for monthly disclosure of portfolio 

holdings, which will, in turn, necessitate additional monitoring and oversight by SEC staff. Another 

priority for Investment Management includes more oversight and strengthened rules relating to 

investment advisers’ custody of client assets to prevent theft and guard against Ponzi schemes and 

similar frauds. 

The Division of Trading and Markets is responsible for establishing rules that regulate the major 

securities market participants, including broker-dealers, SROs, NRSROs, and transfer agents. The 

division also processes and reviews more than 1,000 SRO rules annually. For FY 2011, the agency 

plans to have a total of 279 positions (or 230 FTE) for Trading and Markets, an increase of 40 

positions (associated with 12 FTE) above FY 2010. These additional resources will provide more 

robust oversight in several areas where the recent financial crisis has identified the need for improved 

regulation. 

The new positions within Trading and Markets will be focused on improving supervision of securities 

firms and markets. The new staff will facilitate new rulemaking and guidance with respect to the 

fairness and efficiency of market structure, abusive short selling, modernization of transfer agent 

regulation, and improved disclosure in the municipal securities market. The FY 2011 budget also 

anticipates the enactment of the Administration’s legislation to harmonize the regulatory framework 

for broker-dealers and investment advisers, which will require new regulations and oversight of broker 

sales practices, disclosure obligations, and conflicts of interest. The division also anticipates that an 

additional four to eight securities exchanges will register with the SEC over the next 24 months, and 

this significantly increased workload is taken into account as part of the FY 2011 budget. 

Another priority for the division, which is being executed in collaboration with the Commodity 

Futures Trading Commission and other members of the President’s Working Group on Financial 

Markets, is to provide more oversight of over-the-counter derivatives, including through central 

clearing counterparties. These responsibilities will become even more significant if the Congress 

enacts the Administration’s proposal to grant the SEC authority to regulate securities-based over-thecounter derivatives. 

The Division of Corporation Finance is responsible for overseeing corporate disclosure of important 

information to the investing public. In carrying out these responsibilities, the division annually 

reviews more than 4,500 corporate filings. For FY 2011, the agency plans to have a total of 544 

positions (or 496 FTE) for Corporation Finance, an increase of 30 positions (associated with 9 FTE). 

These additional resources will be used to continue restoring the staffing reductions that the division 

has absorbed in recent years, and to expand oversight in several key areas. The enhanced scope and 

frequency of the division’s reviews of large and financially significant companies will require the 

addition of 25 new positions (9 FTE) in FY 2011 to adequately maintain the division’s review 

presence without compromising the quality and frequency of filing reviews for small and mid-sized 

companies. 

An important priority is executive compensation and proxy voting. The market crisis shook not only 

investor confidence in the financial system, but also shareholder trust in the executives and 

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management at major financial institutions and other public companies. Ensuring the accountability 

of management to boards of directors, and in turn to shareholders, is vital to restoring that trust. 

Corporation Finance’s rules and oversight play a vital role in ensuring the fairness of the proxy voting 

process by which shareholders hold boards accountable. The SEC has adopted rules to require new 

disclosures in the proxy statement with respect to executive compensation and risk management, as a 

direct response to the financial crisis. In addition, the SEC has proposed a major rulemaking to 

facilitate shareholders’ access to the corporate proxy for the purpose of nominating directors, as a way 

of holding boards accountable for their oversight of company management. Both of these new 

rulemakings will require significant new oversight by the division, and the agency’s budget 

anticipates and accounts for these expanded responsibilities. 

Spending Wisely by Setting Priorities Based on Risk 

The SEC recently established a new Division of Risk, Strategy and Financial Innovation to better 

equip the SEC to identify and address emerging risks and long-term issues of critical importance. For 

FY 2011, the agency will allocate 102 positions (or 68 FTE) to support the work of this new division, 

an increase of 30 positions (associated with 9 FTE) over FY 2010. The new division was created by 

merging the staff and operations of the agency’s former Offices of Risk Assessment and Economic 

Analysis. To successfully carry out its mission of integrating considerations pertaining to risk into all 

aspects of agency decision-making, the division will require additional staff with different skill sets to 

perform new functions relating to long-term planning, research, and analysis. 

The new staff positions contained in the agency’s budget request will allow Risk, Strategy and 

Financial Innovation to establish a deeper reservoir of experts who can conduct risk and economic 

analysis, spot emerging trends and practices, and advise on appropriate responses to reduce the 

likelihood that a problem might metastasize into a more potent or systemic risk. The agency 

anticipates hiring professionals with significant knowledge and expertise in financial markets and 

products expertise, including economists, academics, lawyers, and financial market professionals, 

consistent with a recommendation proposed by the GAO in its March 2009 report. In addition, the 

SEC plans a major initiative to develop new risk assessment tools, in an effort over time to restructure 

and combine the agency’s current repositories of data to uncover hidden risks and trends and give 

SEC staff a better picture of a firm’s operations. While the SEC cannot prevent every fraud, the 

Division of Risk, Strategy and Financial Innovation will help the agency to be smarter in utilizing 

resources to have the greatest impact. 

Managing Agency Growth 

Although the budget calls for significant growth in the size of the SEC, the agency is properly 

positioned to implement this spending plan. With respect to hiring, the agency would hire hundreds 

of new staff during the course of FY 2011. To accomplish this, the SEC is streamlining its hiring 

process in FY 2010, consistent with its current authorities, and enhancing its human resources staff. 

In addition, the agency expects to benefit from the significant interest it has been experiencing in 

response to its job postings of the last several months. With these factors aiding the SEC’s hiring 

efforts, the SEC estimates that the 380 additional staff positions in FY 2011 would utilize an estimated 

119 full-time equivalents. 

This agency budget also includes the necessary space rent, information technology, and other noncompensation expenses necessary to outfit the new staff positions requested for FY 2011. The SEC 

has already begun identifying, leasing, and building out additional space needed to accommodate the 

agency’s growth in FY 2010. This request also contemplates an appropriate expansion of the 

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agency’s executive leadership and administrative support functions to ensure that the agency 

continues to manage its resources wisely and efficiently during this period. 

A healthy and strong SEC is critically important to healthy and strong capital markets. By restoring 

investor confidence in the securities markets, the SEC’s success in its mission can provide significant 

benefits to the economy and to the nation as a whole. 

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FTE and Positions by Program 

 FY 2009 FY 2010 FY 2011 

 Actual Enacted Request 

 FTE Positions FTE Positions FTE Positions 

Enforcement 

 Headquarters 431 469 460 534 515 567

 Regions 748 789 777 874 853 911

 Total 1,179 1,258 1,237 1,408 1,368 1,478

Compliance Inspections and Examinations 

 Headquarters 144 160 146 167 152 172

 Regions 676 712 694 766 760 861

 Total 820 872 840 933 912 1,033

Corporation Finance 464 489 470 514 496 544

Trading and Markets 177 209 197 239 230 279

Investment Management 154 162 160 174 174 194

Risk, Strategy and Financial Innovation 35 56 49 72 68 102

General Counsel 

 Headquarters 121 138 125 148 133 153

 Regions 11 11 11 11 11 11

 Total 132 149 136 159 144 164

Other Program Offices 

 Chief Accountant 58 72 60 77 64 82

 Investor Education and Advocacy 67 75 72 81 79 91

 International Affairs 32 33 35 37 40 42

 Administrative Law Judges 11 12 11 12 11 13

 Total 168 192 178 207 194 228

Agency Direction and Administrative Support 

 Executive Staff 37 38 39 40 41 45

 Public Affairs 8 9 9 10 11 12

 Secretary 42 46 42 46 43 49

 Executive Director 11 11 11 11 13 17

 Financial Management 56 67 60 78 70 88

 Human Resources 61 68 66 84 79 99

 Administrative Services 91 97 90 106 98 113

 Information Technology 126 139 133 156 150 171

 Equal Employment Opportunity 8 10 8 10 8 11

 Total 440 485 458 541 513 605

Inspector General 15 16 19 19 19 19

Total FTE and Positions 3,656 3,962 3,816 4,340 4,190 4,720

 Headquarters Total Permanent 2,149 2,376 2,262 2,615 2,494 2,863

 Regional Office Total Permanent 1,435 1,512 1,482 1,651 1,624 1,783

 Temporary 72 74 72 74 72 74

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Obligations by Object Class 

($ in thousands) 

 FY 2009 FY 2010 FY 2011 

 Actual * Enacted * Request 

Personnel Compensation & Benefits 

 Total Personnel Compensation (11.9) $517,434 $581,925 $647,827

Full-time Permanent (11.1) 507,894 561,761 637,126 

Other than Full-time Permanent (11.3) 2,950 3,744 3,883 

Other Personnel Compensation (11.5) 6,590 16,420 6,818 

 Civilian Personnel Benefits (12.1) 141,519 155,404 175,347 

Subtotal Cost of Salaries $658,953 $737,329 $823,174

Other Expenses 

 Benefits for Former Personnel (13.0) 479 2,247 73 

 Travel and Transportation of Persons (21.0) 11,574 14,840 16,716 

 Transportation of Things (22.0) 110 114 115 

 Rent, Communications & Utilities (23.0) 108,102 100,301 129,593 

Rental Payments to Others (23.2) 96,637 88,379 116,628 

Comm., Utilities, and Misc. Charges (23.3) 11,465 11,922 12,965 

 Printing and Reproduction (24.0) 8,127 9,650 9,884 

 Other Contractual Services (25.0) 146,352 182,916 203,035 

Advisory and Assistance Services (25.1) 26,991 31,077 32,345 

Other Services (25.2) 34,893 48,533 54,237 

Purchase of Goods & Services from 

 Government Accounts (25.3) 4,568 9,825 9,932 

Operation & Maintenance of Facilities (25.4) 6,500 9,730 9,837 

Operation & Maintenance of Equipment (25.7) 73,400 83,751 96,684 

 Supplies and Materials (26.0) 2,267 3,079 3,303 

 Equipment (31.0) 20,602 55,473 59,161 

 Building Alterations (32.0) 2,367 12,805 12,946 

 Claims and Indemnities (42.0) 1,256 0 0 

Subtotal Cost of Other Expenses $301,236 $381,425 $434,826

Spending Authority $960,189 $1,118,754 $1,258,000

* FY 2009 includes $2,247 and FY 2010 includes $7,753 from the $10,000 supplemental appropriation the SEC received in July 2009 (P.L. 111-32).

Average Salary and Grade 1/

 FY 2009 FY 2010 FY 2011 

 Actual Enacted Request 

Average SO Salary $228,498 $233,068 $236,331 

Average SK Salary $139,952 $142,751 $147,644 

Average SK Grade 13 13 13 

1/ Average salary as of the last day of the fiscal year.
FY 2011 Request by Strategic Goal and Program 

($ in thousands) 

FY 2011 Request 

Goal 1 Goal 2 Goal 3 Goal 4 

Enforce Effective Facilitate Align & 

FY 2009 FY 2010 Securities Regulatory Access Manage FY 2011 

SEC Program Actual * Enacted * Laws Environ. To Info. Resources Request FY 2009 Actual * $600,349 $89,789 $164,555 $105,496 FY 2010 Enacted * $688,029 $107,024 $191,614 $132,087 Enforcement $324,352 $382,246 $429,499 $0 $0 $0 $429,499 

 Headquarters 135,142 177,668 198,112 0 0 0 198,112  Regions 189,210 204,578 231,387 0 0 0 231,387 

Compliance Inspections

and Examinations 207,601 230,096 256,995 0 0 0 256,995 

Headquarters 37,085 47,132 50,120 0 0 0 50,120 Regions 170,516 182,964 206,875 0 0 0 206,875 

Corporation Finance 120,638 138,468 3,012 19,578 128,013 0 150,603 Trading and Markets 45,370 54,337 11,231 35,675 19,159 0 66,065 Investment Management 47,581 54,656 13,556 28,960 19,100 0 61,616 Risk, Strategy, and 

Financial Innovation 13,850 18,827 8,166 13,172 2,898 2,107 26,343 

General Counsel 36,074 41,470 28,231 7,170 1,792 7,619 44,812 

Headquarters 33,327 38,551 26,341 6,690 1,672 7,109 41,812 Regions 2,747 2,919 1,890 480 120 510 3,000 

Other Program Offices 42,457 50,001 19,106 13,898 20,278 2,712 55,994 Agency Direction and  Administrative Support 117,558 142,600 5,753 5,658 17,297 131,115 159,823 Inspector General 4,708 6,053 0 0 0 6,250 6,250 Total SEC Funding $960,189 $1,118,754 $775,549 $124,111 $208,537 $149,803 $1,258,000 Percent Increase over Prior Year 13% 16% 9% 13% * FY 2009 includes $2,247 and FY 2010 includes $7,753 from the $10,000 supplemental appropriation the SEC received in July 2009 (P.L. 111-32). 
Summary of Changes 

($ in thousands) 

FY 2010 FY 2011 Net 

Actual Request Change

Spending Authority $1,118,754 $1,258,000 +$139,246

Full-time Equivalents 3,816 4,190 +374 

Positions 4,340 4,720 +380 

Explanation of Changes: Positions FTE Amount

One-time Decreases to Base 

Settlement of within-grade increases - - - - - - -$10,000

Voluntary Separation Incentive Pay - - - - - - -2,175

Subtotal, One-time Decreases - - - - - - -12,175

FY 2011 Base Changes 

Annualization of 378 positions received in FY 2010 - - - +255 +46,798

Annualization of FY 2010 2.0 % pay raise - - - - - - +5,042

FY 2011 pay raise, 1.4% effective first full pay 

 period in January 2011 - - - - - - +8,067

Merit pay increases for eligible staff - - - - - - +15,745 

Increases in space rent and utilities - - - - - - +3,571 

Other non-compensation inflation of 1.1% - - - - - - +3,232 

Subtotal, Base Changes - - - +255 +82,455 

FY 2011 Program Increases 

Information Technology Enhancements - - - - - - +12,000 

Training Increases - - - - - - +2,000

Staffing Increases: +54,966

 Enforcement +70 +26 - - -

 Compliance Inspections & Examinations +100 +30 - - -

 Corporation Finance +30 +9 - - -

 Trading and Markets +40 +12 - - -

 Investment Management +20 +6 - - -

 Risk, Strategy and Financial Innovation +30 +9 - - -

 General Counsel +5 +1 - - -

 Other Program Offices +21 +6 - - - 

 Agency Direction & Admin. Support +64 +20 - - -

Subtotal, Program Increases +380 +119 +68,966

Total Change +380 +374 +$139,246

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Fee Collections and Spending Authority 

* Fees collected under Sections 13(e) and 14(g) do not have collection targets specified in statute. Rather, the rates for these fees must equal the rates 

assessed under Section 6(b).

 

FY 2009 FY 2010** FY 2011** 

Actual Estimate Estimate

Source of Fees ($ in thousands) 

Registration of securities: Securities Act of 1933 

(Section 6(b)) $173,522 $334,000 $394,000

Securities transactions under the Securities 

Exchange Act of 1934 (Section 31) 834,938 1,161,000 1,321,000

Merger and Tender Fees under the Securities 

Exchange Act of 1934 (Sections 13(e) and 

14(g)) 7,997 25,000 25,000

Total Collections $1,016,457 $1,520,000 $1,740,000

** FY 2010 and FY 2011 estimates are based on target fee collections under P.L. 107-123 and are not based on expectations relative to economic 

and market conditions. 

 

FY 2009 FY 2010 FY 2011 

Actual Enacted Request

Spending Authority ($ in thousands)

Current Year Appropriated Offsetting Collections $894,356 $1,094,916 $1,258,000

Current Year Direct Appropriation*** 10,000 0 0

Available Balances from Prior Years 65,644 16,084 0

Total Authority $970,000 $1,111,000 $1,258,000

*** Funding for this appropriation came from the two-year emergency supplemental appropriation and not from offsetting collections.

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Appropriations Language 

For necessary expenses for the Securities and Exchange Commission, including services as authorized 

by 5 U.S.C. 3109, the rental of space (to include multiple year leases) in the District of Columbia and 

elsewhere, and not to exceed $3,500 for official reception and representation expenses, 

$1,234,000,000, to remain available until expended; of which not less than $4,800,000 shall be for the 

Office of Inspector General; of which not to exceed $20,000 may be used toward funding a permanent 

secretariat for the International Organization of Securities Commissions; and of which not to exceed 

$100,000 shall be available for expenses for consultations and meetings hosted by the Commission 

with foreign governmental and other regulatory officials, members of their delegations, appropriate 

representatives and staff to exchange views concerning developments relating to securities matters, 

development and implementation of cooperation agreements concerning securities matters and 

provision of technical assistance for the development of foreign securities markets, such expenses to 

include necessary logistic and administrative expenses and the expenses of Commission staff and 

foreign invitees in attendance at such consultations and meetings including: (1) such incidental 

expenses as meals taken in the course of such attendance; (2) any travel and transportation to or from 

such meetings; and (3) any other related lodging or subsistence: Provided, That fees and charges 

authorized by sections 6(b) of the Securities Act of 1933 (15 U.S.C. 77f(b)), and 13(e), 14(g) and 31 

of the Securities Exchange Act of 1934 (15 U.S.C. 78m(e), 78n(g), and 78ee), shall be credited to this 

account as offsetting collections: Provided further, That not to exceed $1,234,000,000 of such 

offsetting collections shall be available until expended for necessary expenses of this account: 

Provided further, That the total amount appropriated under this heading from the general fund for 

fiscal year 2011 shall be reduced as such offsetting fees are received so as to result in a final total 

fiscal year 2011 appropriation from the general fund estimated at not more than $0. 

 _______________________________________ 

Contingent upon the enactment of authorizing legislation of new or enhanced financial regulation 

activities of the Securities and Exchange Commission, $24,000,000, to remain available until 

September 30, 2012: Provided, That of the amounts credited to this account as offsetting collections, 

not to exceed $24,000,000 shall be available until expended for necessary expenses: Provided further, 

That the total amount appropriated under this heading from the general fund for fiscal year 2011 shall 

be reduced as such offsetting collections are received so as to result in a final total fiscal year 2011 

appropriations from the general fund estimated at not more than $0.

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FY 2011 Request by Strategic Goal 

The Securities and Exchange Commission developed its fourth strategic plan in accordance with the 

Government Performance and Results Act of 1993. During FY 2009, managers and staff from across 

the SEC worked to prepare a new strategic plan covering FY 2010 - 2015. The plan which is currently 

still in draft form but will be finalized in the coming months, sets out the Commission’s mission, 

vision, values, and strategic goals for FY 2010 - FY 2015. To gauge the SEC’s progress in 

accomplishing its mission, the proposed strategic plan has 48 performance measures and 15 

indicators, of which a majority are new. 

The number and complexity of registrants and the total assets for which the SEC has oversight 

responsibility have increased significantly in recent years. The events of the past several years have 

shown gaps in regulation of the U.S. financial markets and have brought to light the consequences of 

an understaffed SEC. The SEC is working to issue new rules, as appropriate, and preparing for new 

legislation that will reform the regulatory structure of the United States. The agency also is refocusing 

its efforts on deterring and detecting fraud and reengineering its internal processes to work more 

efficiently and effectively. 

The SEC’s FY 2011 budget request positions the agency to begin to better accomplish these goals. 

The budget request for FY 2011 totals $1.258 billion, a $139 million (12 percent) increase over the 

agency’s FY 2010 funding level of $1.119 billion. The FY 2011 budget funds 4,118 permanent fulltime equivalents (FTE), an increase of 374 FTE (10 percent) from the FY 2010 level and increases the 

number of permanent positions from 4,266 in FY 2010 to 4,646 in FY 2011. Chart 1 depicts how the 

agency plans to allocate its resources in FY 2011 to achieve the goals identified in the agency’s FY 

2010 - 2015 strategic plan. 

Goal 3 

Facilitate access to the information investors 

need to make informed investment decisions 

$208,505 (16%) 

 

Goal 4 

Enhance the Commission’s performance 

through effective alignment and management 

of human, information, and financial capital 

$149,790 (12%)

Goal 2 

 Establish an effective regulatory environment 

$124,094 (10%) 

Chart 1

FY 2011 Request by Strategic Goal

($ in thousands) 

Goal 1 

Foster and enforce compliance with the federal securities laws 

$775,611 (62%) 

- 14 - 
The additional resources for FY 2011 will bolster the SEC’s efforts to achieve each of the four 

strategic goals. Resources directly supporting enforcement of the securities laws will increase about 

13 percent from FY 2010 to FY 2011. Rulemaking efforts to establish an effective regulatory 

environment will receive a 16 percent increase in resources compared to FY 2010. Disclosure review 

and investor education and advocacy activities to promote informed decision making by investors will 

receive an estimated nine percent increase. 

The agency is mindful that significantly increasing staffing in the mission-program areas requires a 

commensurate increase in staff and funding for support offices. The resources attributed to agency 

direction and administrative support will account for approximately 12 percent of the total budget for 

FY 2011 and will increase about 13 percent compared to FY 2010, due in large part to substantial 

investments in information technology (IT) and staff training. The FY 2011 budget request includes a 

program increase of $12 million for IT investments and $2 million for training to better leverage the 

work of the agency’s staff. The additional IT resources will enhance the data management, 

integration, document management, disclosure, and infrastructure support functions, and strengthen 

the agency’s internal controls over financial reporting. The additional training resources will address 

the needs of existing and new staff, particularly concerning detection of fraud, new financial products, 

trading strategies and other issues. 

The SEC’s programs work together to achieve the four strategic goals. Chart 2 specifies how the 

agency plans to allocate its resources to the programs in FY 2011. 

General Counsel

$44,805 (4%) 

144 FTE (4%) 

Agency Direction & Administrative Support

$159,809 (13%) 

513 FTE (13%) 

Enforcement

$429,606 (34%) 

1,368 FTE (33%) 

Compliance Inspections & Examinations

$256,961 (20%) 

912 FTE (22%) 

Investment Management

$61,608 (5%) 

174 FTE (4%) 

Other Program Offices

$55,985 (5%) 

194 FTE (5%) 

Chart 2 

FY 2011 Request by SEC Program

($ in thousands) 

Trading and Markets

$66,056 (5%) 

230 FTE (5%) 

Corporation Finance

$150,579 (12%) 

496 FTE (12%) 

Risk, Strat. & Fin.Innov.

$26,342 (2%) 

68 FTE (2%) 

Inspector General

$6,249 (< 1%) 

19 FTE (< 1%) 

The following chapters comprise the agency’s performance budget for FY 2011, which explains how 

the SEC plans to use the requested resources to achieve each of its four strategic goals. The 

performance budget presents the performance measures and indicators that the agency will use going 

- 15 - 
forward to help determine its success in achieving planned outcomes. In FY 2010, the agency will 

begin collecting the information necessary to determine baseline levels for the 17 performance 

measures with targets yet to be determined. 

To complement the FY 2011 performance budget, the agency also presents its FY 2011 budget by 

program. Each program chapter provides detailed information on program priorities, initiatives, and 

workload figures for the relevant divisions and offices. 

- 16 - 
Goal 1: Foster and Enforce Compliance with the Federal Securities Laws 

Fostering compliance with Federal securities laws is interwoven through all of the Commission’s 

programs and is central to fulfilling its mission of protecting investors; maintaining fair, orderly and 

efficient markets; and facilitating capital formation. The SEC seeks both to foster strong compliance 

and risk management practices and to detect violations of the securities laws. When violations occur, 

the Commission aims to take prompt action to halt the misconduct, sanction wrongdoers effectively, 

and return funds to harmed investors. 

Compliance Inspections & Examinations (37%) 

Enforcement (53%) 

Trading and Markets (1%)

Investment Management (1%)

General Counsel (4%) 

Other Program Offices (3%) 

Trading and Markets (1%)

General Counsel (4%)

Other Program Offices (2%)

Compliance Inspections & Examinations (35%) 

Enforcement (55%) 

FY 2011 Request (Permanent FTE)

2,563 Total FTE 

FY 2011 Request ($ in thousands)

$784,721 Total Cost 

Investment Management (2%)

Risk, Strat. & Fin. Innov. (1%) Risk, Strat. & Fin. Innov. (1%) 

Chart 3

Outcome 1.1: The SEC fosters compliance with federal securities laws. 

 

Compliance Efforts: Preventing future violations of the federal securities laws is extremely important 

to protecting investors and enhancing market integrity. The SEC seeks to promote compliance with 

the securities laws by everyone who participates in the U.S. capital markets. The Commission’s goal 

is to encourage individuals, regulated entities, and reporting companies to do all that they reasonably 

can to identify possible compliance pitfalls and take corrective action before there is a complaint filed, 

a deficiency identified by an SEC examiner, or an enforcement action. 

In FY 2010 and FY 2011, the Office of Compliance Inspections and Examinations (OCIE) and other 

SEC staff will conduct targeted, sweep, and cause examinations on those firms and practices with the 

greatest potential risk of securities violations that can harm investors. The staff’s goal is to identify 

and communicate potential issues to firms within 120 days of the completion of field work for nonsweep examinations to ensure that compliance problems and issues are addressed and corrected 

quickly. An increase in examination staff in FY 2011 is expected to result in more exams being 

conducted, and will assist the office in improving its completion rate within 120 days over FY 2009 

levels. However, the anticipated increase in the numbers of registrants, as well as the types and 

complexities of registrants examined, may not result in the program achieving performance levels 

above 75 percent (Measure 3). 

To further promote compliance with federal securities laws, OCIE works with registrants to ensure 

that corrective action is taken in response to deficiencies identified during an exam. During FY 2011, 

the staff expects registrants to continue taking action with respect to nearly all deficiencies identified 

by the staff (Measure 1). 

 

OCIE will also continue efforts aimed at encouraging stronger industry compliance programs. These 

efforts include OCIE’s CCOutreach program, which provides information and resources for the chief 

compliance officers (CCO) of investment advisory and broker-dealer firms; a disclosure review 

- 17 - 
program; Compliance Alerts; periodic examinations, inspections, and sweeps; advocacy and outreach 

events often coordinated with local law enforcement organizations and regulators; a strong 

enforcement program; and other means. 

 OCIE will continue its efforts to proactively assist registered firms in compliance efforts through a 

variety of compliance-related initiatives including disseminating more expansive and targeted 

materials to firms by means of Compliance Alerts detailing areas where examiners have identified 

significant compliance deficiencies; disseminating best practices identified by examiners or industry 

groups; and raising registrant awareness of the seriousness of certain exam findings by holding postexamination compliance conferences. 

During FY 2010 and FY 2011, the staff expects to continue devoting a significant amount of time to 

the CCOutreach program in order to make it as relevant and beneficial as possible for registered 

entities. The staff will make every effort to ensure that these programs reach as many registrants and 

their personnel as possible and that it continues to be useful in helping registered firms with their 

compliance efforts (Measure 2). 

Goal 1: Measure 1 

Percentage of firms receiving deficiency letters that take corrective action in response to all exam 

findings 

Description: At the conclusion of examinations, the staff communicates identified deficiencies to 

registrants in the form of a deficiency letter. Registrants are then given a chance to respond to staff findings 

and often take action to remedy any problems and potential risks. Most often, registrants respond that they 

have corrected the deficiencies and implemented measures to prevent recurrence. 

Fiscal Year 

FY 

2006 

FY 

 2007 

FY 

 2008 

FY 2009 

Plan 

FY 2009 

Actual 

FY 

2010 

FY 

2011 

Percentage 95% 94% 93% 95% 94% 95% 95% 

Goal 1: Measure 2 

Percentage of attendees at CCOutreach that rated the program as “Useful” or “Extremely Useful” in 

their compliance efforts 

Description: The CCOutreach program is designed to educate, inform, and alert CCOs of pertinent 

information, including about effective compliance controls, that may assist them in administering 

compliance programs within registered firms. Improving compliance programs will reduce violative activity, 

resulting in increased protection for investors. At the conclusion of all CCOutreach events, CCOs are given 

the opportunity to rate the usefulness of the information provided in assisting them in their compliance 

efforts.

Fiscal Year 

FY 

2006 

FY 

 2007 

FY 

 2008 

FY 2009 

Plan 

FY 2009 

Actual 

FY 

2010 

FY 

2011 

Percentage 95% 97% 92% 90% 84% 92% 92% 

- 18 - 
Goal 1: Measure 3 

Percentage of non-sweep exams that are concluded within 120 days 

Description: The staff conducts examinations each year of investment advisers, investment company 

complexes, transfer agents, and broker-dealers. The staff strives to complete its examinations in the most 

efficient and effective manner. When possible, the staff attempts to conclude its examinations within 120 

days of the end of any field work completed. However, some examinations require significantly more time so 

that potential violations are fully reviewed. To ensure that time pressure does not impair quality, the target for 

this benchmark should not be set too high. 

Fiscal Year 

FY 

2006 

FY 

 2007 

FY 

 2008 

FY 2009 

Plan 

FY 2009 

Actual 

FY 

2010 

FY 

2011 

Percentage 83% 79% 79% 80% 65% 75% 75% 

Outcome 1.2: The SEC promptly detects violations of the federal securities laws. 

Examination Program: Prompt detection of potential securities law violations is important in 

correcting violative behavior in the financial markets before it escalates, stopping fraud and 

manipulation before it affects a large number of investors, and locating and preserving investors’ 

assets before they are dissipated. OCIE’s risk-based program is designed to focus the SEC’s 

resources on those firms and practices that have the greatest potential risk of securities law violations 

that can harm investors. The SEC will track the volume of exams resulting from its multi-divisional 

risk-targeting efforts and will monitor the rate of deficiencies deemed “significant” that are identified 

during an examination (Indicator 1). 

In FY 2011, increases in the number of examination staff will allow OCIE to complete an increased 

number of exams over FY 2010 levels; however, because of the expected growth in the number of 

investment advisers and investment companies, the overall percentage of advisers and funds examined 

by the SEC is expected to be lower in FY 2010 and FY 2011 than in prior years (Measure 6). 

The SEC receives a high volume of tips and complaints each year, as well as referrals from SROs, that 

staff analyze to determine matters requiring investigation. The SEC is working to centralize the 

process for receiving, processing, and acting upon tips, complaints and referrals so they can be 

handled consistently and appropriately. The agency will monitor its efforts to improve its systems and 

processes by gauging the number of cause examinations or enforcement investigations that result from 

complaints, tips, or referrals (Indicator 2). 

Goal 1: Measure 4 (new) 

Percentage of exams conducted as a result of risk assessment processes that include multi-divisional 

input 

Description: As SEC staff expands its use of risk-based methods and has more data available for risk 

analysis, staff anticipates that the percentage volume of exams driven by a more robust risk assessment 

process will increase. The agency must further refine its processes for collecting this information before 

establishing targets. 

Fiscal Year 

FY 

2006 

FY 

 2007 

FY 

 2008 

FY 2009 

Plan 

FY 2009 

Actual 

FY 

2010 

FY 

2011 

Investment Advisers Prior-year data not available TBD TBD 

- 19 - 
Goal 1: Measure 5 

Percentage of advisers deemed “high risk” examined during the year 

Description: To conduct oversight of investment advisers, the staff conducts a risk-based program of 

examinations. During each fiscal year, certain advisers are identified as high risk and inspection plans then 

focus on coverage of those registrants. 

Fiscal Year 

FY 

2006 

FY 

 2007 

FY 

 2008 

FY 2009 

Plan 

FY 2009 

Actual 

FY 

2010 

FY 

2011 

Percentage 33% 33% 33% 33% 22% 33% 33% 

Goal 1: Measure 6 

Percentage of investment advisers, investment companies, and broker-dealers examined during the 

year 

Description: This measure indicates the number of registrants examined by the SEC or a SRO as a 

percentage of the total number of registrants. This measure includes all types of examinations: routine 

examinations, cause inspections to follow up on tips and complaints, limited-scope special inspections to 

probe emerging risk areas, and oversight examinations of broker-dealers to test compliance and the quality 

of examinations by the Financial Industry Regulatory Authority (FINRA). 

Fiscal Year 

FY 

2006 

FY 

 2007 

FY 

 2008 

FY 2009 

Plan 

FY 2009 

Actual 

FY 

2010 

FY 

2011 

Investment advisers 14% 13% 14% 9% 10% 9% 9% 

Investment companies 27% 20% 23% 15% 29% 15% 17% 

Broker-Dealers (exams 

by SEC and SROs) 49% 54% 57% 55% 54% 55% 55% 

Goal 1: Indicator 1 (new) 

Percentage of exams that identify deficiencies, and the percentage that result in a “significant 

finding” 

Description: Examiners find a wide range of deficiencies during examinations. Some of the deficiencies 

are more technical in nature, such as failing to include all information that is required to be in a record. 

However, other deficiencies may cause harm to customers or clients of a firm, have a high potential to 

cause harm, or reflect recidivist misconduct. The latter deficiencies are among those categorized as 

“significant.” This measure identifies the percentage of exams by registrant category that identified 

deficiencies, and that resulted in significant deficiency findings. The SEC will report data for new 

indicators no earlier than FY 2010. 

Fiscal Year FY 2006 FY 2007 FY 2008 FY 2009 

Percentage that identify deficiencies Prior-year data not available 

Percentage that result in a “significant finding” Prior-year data not available 

Goal 1: Indicator 2 (new) 

Number of tips that result in a “cause” exam or enforcement investigation 

Description: Analysis of a tip can result in an action plan being established to support the request for a 

cause exam or an enforcement action. This measure would identify the volume of SEC actions that result 

from tips collected through its outreach efforts. The SEC will report data for new indicators no earlier than 

FY 2010. 

Fiscal Year FY 2006 FY 2007 FY 2008 FY 2009 

Number of tips Prior-year data not available 

- 20 - 
Outcome 1.3: The SEC prosecutes violations of federal securities laws and holds violators 

accountable. 

Enforcement Program: Enforcement staff continually strives to balance the need for complete, 

effective, and fair investigations with the need for timely filing of enforcement actions against 

individuals and companies who violate securities laws. The division also moves to close an 

investigation quickly upon determining that no violations occurred. The agency anticipates that the 

percentage of first enforcement cases filed within two years of opening an investigation or inquiry will 

remain at about 60 percent, the same as in FY 2010 (Measure 8). This percentage is dependent on the 

types of cases brought, as well as the time needed for other priorities such as litigating actions already 

filed. The SEC also will monitor the number of investigations referred to other regulators and 

enforcement agencies (Indicator 3). 

The staff also strives to resolve successfully as many cases as possible and expects to maintain the 

percentage successfully resolved in FY 2011 at 90 percent (Measure 7). A continued high success 

ratio depends on numerous factors, including the complexity of cases and the extent to which parties 

contest actions. While achieving this strong track record, the staff will continue to pursue cases that 

are large, difficult, or precedent-setting and that can achieve a deterrent effect. The agency will 

monitor the percentage of its cases deemed “high impact” and also the criminal proceedings related to 

SEC investigations (Indicators 5 and 6). 

Under the Sarbanes-Oxley Act of 2002, the SEC can use Fair Funds to redirect penalties collected 

from securities law violators to the victims of their wrongdoing (Indicator 7). The SEC is committed 

to the timely collection and distribution of penalties and disgorgement monies and is directing 

additional staffing resources to improving its efficiency in this area including adopting a variety of 

new measures for monitoring its progress. In FY 2011, the SEC will seek to obtain payment or 

institute collection activities within six months of the due date of a debt for at least 90 percent of debts 

(Measure 9). The agency also will gauge its timeliness in distributing funds to injured investors by 

monitoring the volume of first payments within 12 months of the approval date of a plan (Measure 

11), and the percentage of final distributions made within 24 months of appointing a fund 

administrator (Measure 10). 

Goal 1: Measure 7 

Percentage of enforcement cases successfully resolved 

Description: A case is considered “successfully resolved” if it results in a favorable outcome for the SEC, 

including through litigation, a settlement, or the issuance of a default judgment. In general, the SEC strives 

to successfully resolve as many cases as possible but, at the same time, aims to file large, difficult, or 

precedent-setting cases when appropriate, even if success is not assured. This measure does not include any 

cases in which the SEC awaits a final outcome. The measure is calculated on a per-defendant basis. Large 

cases may involve several defendants. 

Fiscal Year 

FY 

2006 

FY 

 2007 

FY 

 2008 

FY 2009 

Plan 

FY 2009 

Actual 

FY 

2010 

FY 

2011 

Percentage 94% 92% 92% 90% 92% 90% 90% 

- 21 - 
Goal 1: Measure 8 

Percentage of first enforcement cases filed within two years 

Description: This measure identifies the percentage of first enforcement actions filed within two years of 

opening an investigation or inquiry. In conducting investigations, the enforcement program continually 

strives to balance the need for complete, effective, and fair investigations with the need to file enforcement 

actions in as timely a manner as possible. 

Fiscal Year 

FY 

2006 

FY 

 2007 

FY 

 2008 

FY 2009 

Plan 

FY 2009 

Actual 

FY 

2010 

FY 

2011 

Percentage 64% 54% 62% 60% 70% 60% 60% 

Goal 1: Measure 9 

Percentage of debts where either a payment has been made or a collection activity has been initiated 

within six months of the due date of the debt 

Description: The SEC can seek a wide range of remedies for failure to comply with the securities laws. 

These remedies include civil monetary penalties and disgorgement. When the remedies are imposed by the 

Commission or the federal district court, payments must be made by a certain date. This measure identifies 

the percentage of debts where debtors have made payments or the SEC has initiated a collection activity 

within 180 days of the due date. Such collection activities include, among other things, demand letters, 

negotiation of payment plans, enforcing the payment of the debt through the courts, or other judicial 

remedies. 

Fiscal Year 

FY 

2006 

FY 

 2007 

FY 

 2008 

FY 2009 

Plan 

FY 2009 

Actual 

FY 

2010 

FY 

2011 

Percentage N/A N/A 88% 90% 90% 90% 90% 

Goal 1: Measure 10 (new) 

Percentage of Fair Fund and disgorgement fund plans that distributed the final tranche of funds to 

injured investors within 24 months of the order appointing the fund administrator 

Description: In addition to other types of relief, the Commission may seek orders requiring parties to 

disgorge any money obtained through wrongdoing. The Commission also is empowered to seek civil 

penalties for violations of the securities laws. Where appropriate, the Commission has sought to return 

disgorged funds to harmed investors and, as a result of the Fair Funds provision of the Sarbanes-Oxley Act, to 

combine amounts paid as penalties with disgorged funds to reduce losses to injured parties. After sufficient 

disgorgement and penalties have been collected to form a distribution fund, the Commission appoints, or, in 

civil actions, seeks the appointment of, a fund administrator to develop and subsequently implement an 

approved plan to distribute funds to injured investors. Using the claims-made process, the fund administrator 

identifies injured investors and determines amounts to be disbursed to eligible claimants. The distribution of 

funds to eligible claimants may be made in several tranches to return funds to investors more quickly, while 

efforts continue to locate any remaining investors through the claims-made process. This measure identifies 

the percentage of claims-made distribution plans that distributed the final tranche during the fiscal year and 

within 24 months of the order appointing the fund administrator. This reflects Commission-wide efforts to 

develop, approve, and implement plans to return funds to investors quickly, regardless of the monetary 

amount in the fund. Any funds not returned to investors are sent to the U.S. Treasury; neither disgorgement 

nor penalties are used for the Commission’s own expenses. The agency must further refine its processes for 

collecting this information before establishing targets. 

Fiscal Year 

FY 

2006 

FY 

 2007 

FY 

 2008 

FY 2009 

Plan 

FY 2009 

Actual 

FY 

2010 

FY 

2011 

Percentage Prior-year data not available TBD TBD 

- 22 - 
Goal 1: Measure 11 (new) 

Percentage of Fair Fund and disgorgement fund plans approved by final order within the prior fiscal 

year which had a first tranche of funds distributed under those plans within 12 months of such 

approval date 

Description: In its enforcement cases, the Commission may seek to return funds to harmed investors through 

disgorgement of ill-gotten gains or through the Fair Funds provision of the Sarbanes-Oxley Act. This 

provision permits the Commission to combine amounts paid as penalties with disgorged funds to reduce 

losses to injured parties. This measure identifies the percentage of distribution plans for which a first tranche 

was distributed to injured investors within 12 months of the plans’ approval date. This reflects the 

Commission’s efforts to return funds to investors quickly, regardless of the monetary amount in the fund. Any 

funds not returned to investors are sent to the U.S. Treasury; neither disgorgement nor penalties are used for 

the Commission’s own expenses. The agency must further refine its processes for collecting this information 

before establishing targets. 

Fiscal Year 

FY 

2006 

FY 

 2007 

FY 

 2008 

FY 2009 

Plan 

FY 2009 

Actual 

FY 

2010 

FY 

2011 

Percentage Prior-year data not available TBD TBD 

Goal 1: Indicator 3 (new) 

SEC investigations referred to SROs or other state, federal, and foreign authorities for enforcement 

Description: The SEC works closely with other regulators and authorities so that violators of federal 

securities laws are held accountable. In certain circumstances, a matter may be more appropriately handled by 

another entity or in another venue, and the agency will refer the investigation for further action. This measure 

identifies the number (or percentage of the agency’s total number) of investigations that are referred to others 

for action. The SEC will report data for new indicators no earlier than FY 2010. 

Fiscal Year FY 2006 FY 2007 FY 2008 FY 2009 

Number of investigations Prior-year data not available 

Goal 1: Indicator 4 (new) 

Percent of all enforcement cases deemed “high impact” 

Description: High impact cases can include those that are the first of their kind, those that achieve an 

appropriate deterrent effect, cases that affect selected communities, cases addressing areas that are of 

particular interest to market participants, or cases of significant public interest. The goal is to increase the 

number or percentage of high impact cases the agency brings while balancing that emphasis with a 

distribution of cases across a variety of topics and sizes. The SEC will report data for new indicators no 

earlier than FY 2010. 

Fiscal Year FY 2006 FY 2007 FY 2008 FY 2009 

Percentage Prior-year data not available

Goal 1: Indicator 5 (new) 

Percent of cases that come from internally-generated referrals or prospects 

Description: Through enhanced risk assessment practices, the agency aims to improve its ability to identify 

internally-generated tips or prospects for cases. Internal prospects could include issues identified during the 

course of SEC examinations, analysis of data, disclosure reviews, or other activities. The SEC will report data 

for new indicators no earlier than FY 2010. 

Fiscal Year FY 2006 FY 2007 FY 2008 FY 2009 

Percentage Prior-year data not available

- 23 - 
Goal 1: Indicator 6 (new) 

Criminal proceedings relating to SEC investigations 

Description: In some instances, investigations may reveal that both civil and criminal violations have 

occurred. This measure identifies the number of SEC-related criminal cases, where prosecutors have filed 

indictments, information or contempts in the current fiscal year. The SEC will report data for new indicators 

no earlier than FY 2010. 

Fiscal Year FY 2006 FY 2007 FY 2008 FY 2009 

Number of investigations Prior-year data not available

Percentage Prior-year data not available

Goal 1: Indicator 7 (new) 

Disgorgement and Penalties Ordered and the Amounts Collected by the SEC 

Description: In addition to other types of relief, the SEC may seek orders requiring parties to disgorge any 

money obtained through wrongdoing. The SEC is also empowered to seek civil penalties for violations of the 

securities laws. Where appropriate, the SEC has sought to return disgorged funds to harmed investors. Funds 

not returned to investors are sent to the Treasury. This indicator lists disgorgement and penalties ordered as a 

result of SEC cases and the amounts collected by the SEC. This indicator could increase or decrease based on 

various factors. The SEC will report data for new indicators no earlier than FY 2010. 

Fiscal Year FY 2006 FY 2007 FY 2008 FY 2009 

Ordered amounts (in 

millions) Prior-year data not available

Collected amounts (in 

millions) Prior-year data not available

Goal 1: Indicator 8 

Requests from foreign authorities for SEC assistance and SEC requests for assistance from foreign 

authorities 

Description: Each year, the SEC makes hundreds of requests for enforcement assistance to foreign 

regulators, while responding to hundreds of such requests from other nations. To facilitate this type of 

assistance, and encourage other countries to enact laws necessary to allow regulators to cooperate with their 

foreign counterparts, the SEC has entered into the Multilateral Memorandum of Understanding, an 

information-sharing arrangement negotiated through the International Organization of Securities 

Commissions (IOSCO). 

Fiscal Year FY 2006 FY 2007 FY 2008 FY 2009 

Number of Requests from 

foreign authorities 353 371 389 408 

Number of SEC Requests 561 460 483 774 

- 24 - 
Goal 2: Establish an Effective Regulatory Environment

The Commission seeks to establish an effective and fair regulatory environment that will protect 

investors and facilitate capital formation, innovation, and competition to ensure that the U.S. economy 

can grow and create jobs. The Commission believes that its rules and regulations should be drafted to 

enable market participants to understand clearly their obligations under the federal securities laws and 

to conduct their activities in compliance with law. In FY 2011, the agency will consider regulatory 

proposals that address securities firm supervision; investment adviser, money market and mutual fund 

oversight, and corporate governance and disclosure. The agency plans to devote approximately $124 

million and 393 permanent FTE to achieve this goal. 

Trading and Markets 

(32%) 

Investment 

Management (23%) 

Trading and 

Markets (29%) Investment Management 

 (21%) 

Other Program 

Offices (12%) 

Agency Direction & Administrative Support (4%) 

Corporation Finance 

 (16%)

Other Program 

Offices (11%) 

General 

Counsel (6%) 

Corporation Finance 

(16%) 

General 

Counsel (6%) 

Risk, Strat. & Fin. 

Innov. (9%) 

Risk, Strat. & 

Fin. Innov. 11%) 

Agency Direction & Administrative Support (4%) 

FY 2011 Request (Permanent FTE)

393 Total FTE 

FY 2011 Request ($ in thousands)

$124,094 Total Cost 

Chart 4

Outcome 2.1: The SEC establishes and maintains a regulatory environment that promotes 

high-quality disclosure, financial reporting, and governance, and that prevents abusive practices 

by registrants, financial intermediaries, and other market participants. 

Promote high-quality disclosure financial reporting and governance: The Commission uses its 

authority to shape the regulatory framework so that investors are protected through the availability of 

high-quality disclosure. The SEC will continue to evaluate and, where necessary, amend its rules and 

regulations to improve the quality and usefulness of registrants’ disclosures to investors. The SEC is 

in the process of evaluating potential survey instruments and methodologies, to elicit feedback on the 

quality of disclosures and the Commission’s disclosure requirements (Measure 1). 

Additionally in FY 2010 and FY 2011, the agency plans to develop regulations that promote and 

strengthen corporate and fund governance, strengthen proxy voting and shareholder-company 

communications, harmonize regulatory structures for investment advisers and broker-dealers, and 

promote high-quality accounting standards. 

Enhance global coordination and assistance with securities regulation: The SEC’s FY 2010-2015 

Strategic Plan outlines initiatives aimed at increasing global transparency and disclosure. In FY 2011, 

Office of International Affairs (OIA) will continue working with the International Organization of 

Securities Commissions (IOSCO) and foreign regulatory counterparts to promote international 

cooperation and assistance on international enforcement matters. The office also will work 

cooperatively within IOSCO and the Financial Stability Board (FSB) to enhance cross-border 

supervisory cooperation. OIA also will advise the agency on other regulatory policy initiatives, 

- 25 - 
including those identified by the Group of 20 (G-20) leaders. Specific areas to be addressed include 

hedge funds, cross-border oversight of credit rating agencies, and progress towards a single set of high 

quality global accounting standards (Measure 2 and Measure 3). 

Goal 2: Measure 1 (new) 

Survey on quality of disclosure 

Description: Under this metric, the SEC plans to conduct a survey to elicit feedback on the quality of 

disclosures and the Commission’s disclosure requirements. The SEC would track whether the percentage of 

respondents answering positively improves from year to year. The agency must further refine its processes for 

collecting this information before establishing targets. 

Fiscal Year 

FY 

2006 

FY 

 2007 

FY 

 2008 

FY 2009 

Plan 

FY 2009 

Actual 

FY 

2010 

FY 

2011 

Percentage of positive 

response Prior-year data not available TBD TBD 

Goal 2: Measure 2 (new) 

Number of consultations; joint events, reports, or initiatives; and joint examinations and other mutual 

supervisory efforts with SROs and other federal, state, and non-U.S. regulators 

Description: This metric gauges how much the SEC is coordinating with other financial regulatory agencies 

within a given fiscal year. Also, as securities markets around the world become increasingly integrated and 

globalized, it is essential that the SEC work frequently and effectively with its partner regulators both in the 

U.S. and abroad. The agency must further refine its processes for collecting this information before 

establishing targets. 

Fiscal Year 

FY 

2006 

FY 

 2007 

FY 

 2008 

FY 2009 

Plan 

FY 2009 

Actual 

FY 

2010 

FY 

2011 

Number Prior-year data not available TBD TBD 

Goal 2: Measure 3 (new) 

Number of non-U.S. regulators trained 

Description: This metric shows the reach of the SEC’s technical assistance programs for regulators around 

the world. The SEC conducts these training sessions to assist countries in developing and maintaining robust 

protections for investors and promote cross-border enforcement and supervisory assistance. 

Fiscal Year 

FY 

2006 

FY 

 2007 

FY 

 2008 

FY 2009 

Plan 

FY 2009 

Actual 

FY 

2010 

FY 

2011 

Number of non-U.S. 

regulators Prior-year data not available 1,905 1,925 

Goal 2: Indicator 1 (new) 

Average cost of capital in U.S. relative to the rest of the world 

Description: Countries’ cost of capital can vary according to their protections for investors, the strength of 

their disclosure regimes, and the presence of fair, orderly, and efficient markets, among other factors. 

Therefore, although this metric is affected by other economic factors, it can provide some indication of the 

quality of securities regulation in a given country. The SEC will report data for new indicators no earlier than 

FY 2010. 

Fiscal Year FY 2006 FY 2007 FY 2008 FY 2009 

Average cost of capital Prior-year data not available 

- 26 - 
Outcome 2.2: The U.S. capital markets operate in a fair, efficient, transparent, and competitive 

manner, fostering capital formation and useful innovation.

Securities Firm and Market Supervision: The Division of Trading and Markets (TM) supervises the 

major participants in the U.S. securities markets. While the number of market participants supervised 

by the division has been relatively steady over the past several years, a significant increase in the 

number of registered securities exchanges is expected in FY 2010 and FY 2011. The additional 40 

positions (12 FTE) requested in FY 2011 will be dedicated to keeping pace with the expected increase 

in the number of registered exchanges and addressing increased globalization of the securities 

markets. They also will be dedicated to pursuing initiatives that promote enhanced price transparency, 

best execution, fair access to trading systems, and fair competition. 

The SEC plays a key role in protecting the stability and ensuring the resilience of the U.S. financial 

system, thereby promoting investor confidence. In FY 2010 and FY 2011, TM will continue to 

perform inspections of the automated trading and clearing processes of markets and clearing 

organizations, monitor for systems outages and changes, and monitor the compliance of markets and 

clearing agencies with applicable continuity planning standards. In FY 2011, 99 percent of 

transaction dollars are expected to be settled on time (Measure 4), and TM expects 96 percent of all 

market outages to be corrected in less than 24 hours (Measure 6). 

Goal 2: Measure 4 

Percentage of transaction dollars settled on time each year 

Description: This metric measures the efficiency of the U.S. clearance and settlement system for equity 

securities. 

Fiscal Year 

FY 

2006 

FY 

 2007 

FY 

 2008 

FY 2009 

Plan 

FY 2009 

Actual 

FY 

2010 

FY 

2011 

Percentage 98% N/A 99% 98% 99% 99% 99% 

Goal 2: Measure 5 (new) 

Average institutional transaction costs for exchange listed stocks on a monthly basis 

Description: This performance metric captures the actual cost of trading in large (institutional size) 

transactions. The agency must further refine its processes for collecting this information before establishing 

targets. 

Fiscal Year 

FY 

2006 

FY 

 2007 

FY 

 2008 

FY 2009 

Plan 

FY 2009 

Actual 

FY 

2010 

FY 

2011 

Average Transaction costs Prior-year data not available TBD TBD 

- 27 - 
Goal 2: Measure 6 

Percentage of market outages at SROs and electronic communications networks (ECNs) that are 

corrected within targeted timeframes 

Description: Market outages reflect problems in the systems underlying the securities markets that could 

have an adverse affect on the markets’ ability to function as required. The SEC assesses the reliability and 

resiliency of these systems to minimize the number and duration of outages. This metric gauges how quickly 

outages are resolved, so that market activity can resume. 

Fiscal Year 

FY 

2006 

FY 

 2007 

FY 

 2008 

FY 2009 

Plan 

FY 2009 

Actual 

FY 

2010 

FY 

2011 

Within 2 hours N/A 81% 84% 60% 87% 60% 60% 

Within 4 hours N/A 91% 96% 75% 98% 75% 75% 

Within 24 hours N/A 100% 100% 96% 98% 96% 96% 

Goal 2: Indicator 2 (new) 

Average quoted spread for exchange listed stocks on a monthly basis 

Description: This indicator gauges the hypothetical cost of trading in small amounts at the quoted markets, 

based solely on published quotations. The SEC will report data for new indicators no earlier than FY 2010. 

Fiscal Year FY 2006 FY 2007 FY 2008 FY 2009 

Average quoted spread Prior-year data not available 

Goal 2: Indicator 3 (new) 

Average effective spread for exchange listed stocks on a monthly basis 

Description: This indicator captures the cost of trading in small amounts based on actual trade prices and the 

quotes at the times of those trades. The SEC will report data for new indicators no earlier than FY 2010. 

Fiscal Year FY 2006 FY 2007 FY 2008 FY 2009 

Average effective spread Prior-year data not available 

Goal 2: Indicator 4 (new) 

Speed of Execution 

Description: This indicator gauges how quickly transactions are executed in the U.S. securities markets. The 

SEC will report data for new indicators no earlier than FY 2010. 

Fiscal Year FY 2006 FY 2007 FY 2008 FY 2009 

Speed of execution Prior-year data not available 

Goal 2: Indicator 5 (new) 

Average quoted size of exchange listed stocks on a monthly basis 

Description: This indicator measures the amount of liquidity visible to the market at the displayed quotes. 

The SEC will report data for new indicators no earlier than FY 2010. 

Fiscal Year FY 2006 FY 2007 FY 2008 FY 2009 

Average quoted size Prior-year data not available 

- 28 - 
Goal 2: Indicator 6 (new) 

Average daily volatility of exchange listed stocks on a monthly basis 

Description: This statistic gauges short term price changes, which are an indicator of the risk of holding 

stock. The SEC will report data for new indicators no earlier than FY 2010. 

Fiscal Year FY 2006 FY 2007 FY 2008 FY 2009 

Average daily volatility Prior-year data not available 

Outcome 2.3: The SEC adopts and administers rules and regulations that enable market 

participants to understand clearly their obligations under the securities laws. 

Securities Firm and Market Supervision: The process of developing and administering rules and 

regulations is one of the primary functions of the SEC and involves staff from nearly every division 

and office. The SEC must continually reevaluate its regulatory framework to ensure that market 

participants understand clearly the rules and regulations. The SEC intends to survey market 

participants, such as broker-dealers and investment advisers, to determine whether they believe the 

Commission’s regulatory requirements are clear (Measure 8). 

TM, IM, and CF devote a significant share of their resources responding to no-action letters, 

interpretive and other requests from regulated entities. Although each division has separate processes 

and benchmarks for their responses (Measure 7), the agency is committed to responding to such 

requests in a timely way. 

In FY 2011, TM plans to respond to 75 percent of all requests within 60 days. This is an 

improvement over performance levels in previous years, primarily due to the additional FTE dedicated 

to responding to these requests. Although IM issued initial comments on all no-action letters and 

interpretive requests within three weeks of receipt in FY 2009, the division plans to maintain its target 

at 75 percent for FY 2010 and FY 2011. IM also expects to meet its future goals for timely review of 

exemptive application requests (Measure 7). 

In FY 2009, CF completed 85 percent of initial comments on shareholder proposals by the company’s 

planned proxy mailing date which is a significant improvement from the previous year’s performance 

level of 66 percent. CF plans to assign additional staff to this function and improve work processes in 

order to complete 90 percent of initial comments within the targeted timeframe in FY 2010 and FY 

2011. 

In FY 2010 and FY 2011, the SEC will continue to explore ways to streamline the SRO rule filing 

process. TM expects to deploy additional staff to review higher numbers of SRO rule filings, with a 

target of completing 40 percent of filings within 35 days from the date of publication and 80 percent 

of filings within 45 days (Measure 9). 

- 29 - 
Goal 2: Measure 7 

Length of time to respond to written requests for no-action letters, exemptive applications, and written 

interpretive requests 

Description: The SEC staff responds to requests for guidance from individuals and companies about specific 

provisions of the federal securities laws. These queries can ask for proper interpretations of the securities laws 

or regulations, or for assurances that no enforcement action will be taken in certain circumstances. The staff 

also reviews applications for exemptions from the securities laws. Written responses to such requests for 

guidance, when provided, generally are publicly available, as are applications and related notices and orders, 

when issued. This measure gauges whether the Divisions of Trading and Markets, Investment Management, 

and Corporation Finance are issuing initial comments on these requests on a timely basis. 

Fiscal Year 

FY 

2006 

FY 

 2007 

FY 

 2008 

FY 2009 

Plan 

FY 2009 

Actual 

FY 

2010 

FY 

2011 

Trading and Markets: No-action letters, exemptive applications, and written interpretive requests (combined 

figure) 

Percentage 86% 91% 63% 70% 70% 85% 85% 

Investment Management 

No-action letters and 

interpretive requests 76% 91% 98% 75% 100% 75% 75% 

Exemptive applications N/A N/A 81% 80% 95% 80% 80% 

Corporation Finance 

No-action letters and 

interpretive requests (1) 65% 66% 66% 90% 85% 90% 90% 

Shareholder proposals (2) 100% 100% 100% 100% 100% 100% 100% 

Goal 2: Measure 8 (new) 

Survey on whether SEC rules and regulations are clearly understandable 

Description: The SEC aims to promote a regulatory environment in which market participants clearly 

understand their obligations. Through this metric, the SEC intends to survey market participants to determine 

whether they believe the Commission’s regulatory requirements are clear. The agency must further refine its 

processes for collecting this information before establishing targets. 

Fiscal Year 

FY 

2006 

FY 

 2007 

FY 

 2008 

FY 2009 

Plan 

FY 2009 

Actual 

FY 

2010 

FY 

2011 

Percentage Prior-year data not available TBD TBD 

Goal 2: Measure 9 (new) 

Time to complete SEC review of SRO rules that are subject to SEC approval 

Description: The SEC reviews SRO rule proposals for consistency with the Exchange Act and the investor 

protection, market operation and structure, and other rules. This metric gauges how quickly the SEC 

completes these reviews after a proposed rule change requiring Commission approval has been filed. 

Fiscal Year 

FY 

2006 

FY 

 2007 

FY 

 2008 

FY 2009 

Plan 

FY 2009 

Actual 

FY 

2010 

FY 

2011 

Within 35 days Prior-year data not available 40% 40% 

Within 45 days Prior-year data not available 80% 80% 

- 30 - 
Goal 2: Indicator 7 (new) 

Percentage of SRO rule filings that are submitted for immediate effectiveness 

Description: This metric gauges the proportion of SRO rule proposals that can be submitted for immediate 

effectiveness, without Commission approval. The SEC will report data for new indicators no earlier than FY 

2010. 

Fiscal Year FY 2006 FY 2007 FY 2008 FY 2009 

Percentage Prior-year data not available 

- 31 - 
Goal 3: Facilitate Access to the Information Investors Need to Make Informed 

Decisions 

The financial markets operate best when investors are fully informed, and an educated investing 

public ultimately provides the best defense against fraud and costly mistakes. The agency works to 

promote informed investment decisions through two main approaches. The first is reviewing 

disclosures of companies and mutual funds to enhance the clarity, completeness, and accuracy of the 

information that is available to investors. The second is developing programs to equip individual 

investors with tools to understand and analyze the market information they receive. In FY 2011, the 

agency plans to devote approximately $209 million and 683 permanent FTE to achieve this goal. 

Investment 

Management (9%) 

Other Program 

Offices (10%) Agency Direction & 

Administrative Support 

General Counsel (8%) (1%)

Risk Strat. & Fin. 

Innov. (1%) 

Corporation 

Finance (62%) Trading and 

Markets (9%) 

Corporation 

Finance (62%)

Other Program 

Offices (10%) 

Agency Direction 

& Administrative Support 

 (8%) 

General 

Counsel (1%) 

Trading and 

Markets (10%) 

Investment 

Management (8%) 

Risk Strat. & Fin. 

Innov. (1%) 

FY 2011 Request (Permanent FTE)

683 Total FTE 

FY 2011 Request ($ in thousands)

$208,505 Total Cost 

Chart 5

Outcome 3.1: Investors have access to high quality disclosure materials that are useful to 

investment decision making.

Disclosure Review: As part of its disclosure program, the agency requires issuers to disclose material 

financial and other information to the public. These disclosures form a common pool of knowledge 

that all investors can use to judge for themselves if a security is an appropriate investment, based on 

each investors unique objectives. The Divisions of CF and IM continued to meet the requirements of 

the Sarbanes-Oxley Act in FY 2009, and CF continued its trend of reviewing an increased percentage 

of filings over the past few years. These disclosure reviews encourage transparency about a company 

or fund’s governance and financial condition; deter fraud in public securities transactions; and help 

ensure that investors receive relevant information about emerging and novel issues. 

In FY 2011, CF plans to concentrate its review resources on critical disclosures that appear to conflict 

significantly with Commission rules, GAAP, or that appear to be materially deficient in explanation or 

clarity. The enhanced scope and frequency of CF’s reviews of large and financially significant 

companies will require the addition of 25 new positions (9 FTE) in FY 2011 to adequately maintain 

the division’s review presence without compromising the quality and frequency of filing reviews for 

small and mid-sized companies. 

In addition to reviewing the filings of reporting companies, CF expects to continue to issue initial 

comments on 1933 and 1934 Act registration statements within its target of 30 days of filing (Measure 

2). While the average time to issue initial comments has decreased over the past few years and CF 

- 32 - 
expects this trend to continue in FY 2010 and FY 2011, the thirty day target has become an industry 

standard for planning purposes and as a result, the agency will continue to maintain its target at that 

level. IM aims to provide comments within timeliness goals for at least 85 percent of initial 

registration statements, 90 percent of post-effective amendments, and 99 percent of preliminary proxy 

statements in FY 2010 and FY 2011 (Measure 3). These targets are consistent with past years’ 

targets, though IM exceeded the planned levels in FY 2009. 

Disclosure and Reporting Requirements: The SEC seeks to structure disclosure requirements so that 

investors are armed with the timely and meaningful information they need to make appropriate 

investment decisions. The SEC will use Measures 4, 5, and 6 to gauge investor demand for financial 

and other disclosure information that will allow investors to easily analyze and compare data. 

Furthermore, agency staff will examine its filing review program to explore whether its disclosure 

requirements, review criteria, and approach to comments provide maximum impact to benefit 

investors (Measure 7). 

Goal 3: Measure 1 

Percentage of public companies and investment companies with disclosures reviewed each year 

Description: The Sarbanes-Oxley Act requires that the SEC review the disclosures of all companies and 

investment company portfolios reporting under the Exchange Act at least once every three years. These 

reviews help improve the information available to investors and may uncover possible violations of the 

securities laws. 

Fiscal Year 

FY 

2006 

FY 

 2007 

FY 

 2008 

FY 2009 

Plan 

FY 2009 

Actual 

FY 

2010 

FY 

2011 

Corporations 33% 36% 39% 33% 40% 34% 34% 

Investment Company 

Portfolios 36% 38% 36% 33% 35% 33% 33% 

Goal 3: Measure 2 

Time to issue initial comments on Securities Act filings 

Description: The target of 30 days or less has become a de facto industry standard for the maximum time to 

receive initial comments. 

Fiscal Year 

FY 

2006 

FY 

 2007 

FY 

 2008 

FY 2009 

Plan 

FY 2009 

Actual 

FY 

2010 

FY 

2011 

Days 26.2 days 25.5 days 25.2 days <30 days 25.3 days <30 days <30 days

Goal 3: Measure 3 

Percentage of investment company disclosure reviews for which initial comments are completed within 

timeliness goals 

Description: For initial registration statements, the SEC’s goal is to issue initial comments within 30 days 

after they are filed (60 days for registration statements of insurance product separate accounts and related 

mutual funds). The SEC also aims to comment on post-effective amendments within 45 days and preliminary 

proxy statements within 10 days after they are filed. 

Fiscal Year 

FY 

2006 

FY 

 2007 

FY 

 2008 

FY 2009 

Plan 

FY 2009 

Actual 

FY 

2010 

FY 

2011 

Initial Registration 

Statements 88% 87% 95% 85% 95% 85% 85% 

Post-Effective Amendments 96% 95% 97% 90% 97% 90% 90% 

Preliminary Proxy 

Statements 99% 99% 99% 99% 99% 99% 99% 

- 33 - 
Goal 3: Measure 4 (new) 

Point of Sale “click-through rate” 

Description: The point of sale initiative relies on a layered approach that combines point of sale disclosure 

and Internet-based disclosure. This measure would determine how often investors click on broker-dealers’ 

web sites to obtain information about broker-dealer compensation and related conflicts of interest. The 

agency must further refine its processes for collecting this information before establishing targets. 

Fiscal Year 

FY 

2006 

FY 

 2007 

FY 

 2008 

FY 2009 

Plan 

FY 2009 

Actual 

FY 

2010 

FY 

2011 

“click-through rate” Prior-year data not available TBD TBD 

Goal 3: Measure 5 (new) 

Access to broker-dealer and investment adviser background checks 

Description: Greater availability of professional background information on broker-dealers and their 

employees through the BrokerCheck system will provide investors with the ability to make better-informed 

decisions. Investors also have the ability to check the backgrounds of investment advisory firms through the 

SEC’s Investment Adviser Public Disclosure (IAPD) system. This measure gauges the demand for disclosure 

information about broker-dealers and their employees through the BrokerCheck website and about investment 

advisers through the IAPD. The agency must further refine its processes for collecting this information before 

establishing targets. 

Fiscal Year 

FY 

2006 

FY 

 2007 

FY 

 2008 

FY 2009 

Plan 

FY 2009 

Actual 

FY 

2010 

FY 

2011 

BrokerCheck System Prior-year data not available TBD TBD 

IAPD System Prior-year data not available TBD TBD 

Goal 3: Measure 6 (new) 

Investor demand for disclosures on municipal securities 

Description: Greater availability of market-sensitive information through the Municipal Securities 

Rulemaking Board’s Electronic Municipal Market Access (EMMA) website will provide investors with the 

ability to make better-informed investment decisions and assist market participants in fulfilling their 

disclosure obligations. This measure gauges the demand for disclosure information about municipal securities 

through the EMMA website. The agency must further refine its processes for collecting this information 

before establishing targets. 

Fiscal Year 

FY 

2006 

FY 

 2007 

FY 

 2008 

FY 2009 

Plan 

FY 2009 

Actual 

FY 

2010 

FY 

2011 

Web Site Hits Prior-year data not available TBD TBD 

Goal 3: Measure 7 (new) 

Satisfaction index for disclosure process 

Description: The agency will conduct survey research or focus groups to identify the level of satisfaction 

with disclosure requirements. The agency must further refine its processes for collecting this information 

before establishing targets. 

Fiscal Year 

FY 

2006 

FY 

 2007 

FY 

 2008 

FY 2009 

Plan 

FY 2009 

Actual 

FY 

2010 

FY 

2011 

Satisfaction Index Prior-year data not available TBD TBD 

- 34 - 
Outcome 3.2: Agency rulemaking and investor education programs are informed by an 

understanding of the wide range of investor needs. 

Investor Education and Outreach: In FY 2011, with an additional 10 positions (three FTE), the Office 

of Investor Education and Advocacy (OIEA) plans to increase outreach by expanding social media 

initiatives, offering more publications for Spanish-speaking investors, and updating resources targeted 

to specific investor audiences. OIEA estimates over 17 million investors will be reached directly by 

the SEC through various communication channels, including Web pages and printed publications 

(Measure 8). This level of outreach is expected to drive the development of educational programs, and 

the agency will use focus groups and surveys to assess the usefulness of educational material provided 

to investors (Measure 12). 

In FY 2011, OIEA will continue to actively represent the agency at investor and community events, 

and plans to conduct research to better understand investor reaction to current market conditions that 

affect their investment strategies. The SEC’s Investor Advisory Committee, created in January 2009, 

will continue to hear from a wide range of investors on a variety of financial products and provide 

input to the Commission and agency offices and divisions. Additionally, the agency, in partnership 

with other federal and state agencies, financial industry associations, consumer groups and educational 

organizations, plans to develop and produce 10 investor education initiatives in FY 2011 (Measure 9). 

Investor Advocacy: OIEA serves tens of thousands of investors who contact the SEC each year with 

investment-related complaints and questions. The staff strives to close all inquiries and complaints in 

a timely manner, often working with other SEC offices and divisions, as well as other regulators and 

firms, to resolve matters. In FY 2011, the staff plans to close 80 percent of investor complaints and 

inquiries within seven days and 90 percent within thirty days (Measure 10). In FY 2010 and FY 2011, 

OIEA will continue to refine internal processes, increase staff training, and complete the 

implementation of a new software solution to handle investor complaints and inquiries. With these 

improvements, OIEA plans to significantly increase the percentage of investor complaints and 

inquiries closed within seven days over prior year targets. Data reported in FY 2008 and FY 2009 

excludes public information requests from the count of complaints and inquiries, resulting in lower 

percentages for these years than previously planned. Out year targets for FY 2010 and 2011 also 

exclude public information requests. 

Goal 3: Measure 8 (new) 

Number of investors reached, and number of “in-person” events with specifically targeted 

communities and organizations 

Description: The agency has developed an extensive collection of free information to help investors 

understand the basics of investing; the risks and rewards of various products and strategies; the importance of 

diversification; and ways to find information about brokers, advisers, and companies. Much of this 

information is posted on the SEC’s Investor Information Web page, a key tool for informing and educating 

the investing public. In addition, the Office of Investor Education and Advocacy (OIEA) publishes hard-copy 

educational brochures and conducts in-person events. This measure seeks to determine the total number of 

investors reached by the SEC, and assess the effectiveness of outreach efforts conducted by OIEA and the 

regional offices targeted to specific investor groups (for example, seniors, military, or other affinity groups). 

The measure also assesses the use of various channels to reach investors, such as the SEC webpage, 

investor.gov, social networking sites, outreach programs, or public appearances. 

Fiscal Year 

FY 

2006 

FY 

 2007 

FY 

 2008

FY 2009 

Plan 

FY 2009 

Actual 

FY 

2010 

FY 

2011 

Number of Investors Reached (millions) Prior-year data not available 17.3 17.4 

Number of “In-Person” Events Prior-year data not available 25 30 

- 35 - 
Goal 3: Measure 9 (new) 

Number of investor educational initiatives organized and produced 

Description: In partnership with other organizations, the agency will develop a number of educational 

campaigns intended to customize content and maximize its reach to various investor communities. Through 

the use of primary and secondary research including tracking emerging investor concerns and complaints, the 

agency will compile information on how to best target its efforts to the investing public. This measure 

identifies the number of major investor initiatives undertaken. 

Fiscal Year 

FY 

2006 

FY 

 2007 

FY 

 2008 

FY 2009 

Plan 

FY 2009 

Actual 

FY 

2010 

FY 

2011 

Number of Initiatives Prior-year data not available 8 10 

Goal 3: Measure 10 

Timeliness of responses to investor contacts 

Description: OIEA serves the tens of thousands of investors each year who contact the SEC with 

investment-related complaints and questions. The staff aims to close out as many new investor assistance 

matters as possible within seven and thirty business days. 

Fiscal Year 

FY 

2006 

FY 

 2007 

FY 

 2008 

FY 2009 

Plan 

FY 2009 

Actual 

FY 

2010 

FY 

2011 

Closed within 7 days 

Total 81% 82% 78% 85% 70% 80% 80% 

Closed within 30 days 

Total 94% 94% 88% 97% 90% 90% 90% 

Goal 3: Measure 11 (new) 

Percentage of rules impacting investors that are presented in alternate user-friendly formats 

Description: The agency intends to publish explanations of Commission actions in easily understandable 

language, to encourage investor participation and comments on issues materially affecting them. The agency 

also will track emerging concerns and trends and then transmit the information to the rulemaking divisions 

and other offices for consideration of possible regulatory responses. The SEC also may use surveys or 

questionnaires to collect input from investors to assist in assessing their views on Commission actions. 

Fiscal Year 

FY 

2006 

FY 

 2007 

FY 

 2008 

FY 2009 

Plan 

FY 2009 

Actual 

FY 

2010 

FY 

2011 

Percentage Prior-year data not available 100% 100% 

Goal 3: Measure 12 (new) 

Customer satisfaction with usefulness of investor educational programs and materials 

Description: Through the use of focus groups and surveys, the agency will assess the usefulness of 

educational material provided to investors across a variety of channels based upon ease of use, 

appropriateness, and other factors. The agency must further refine its processes for collecting this information 

before establishing targets. 

Fiscal Year 

FY 

2006 

FY 

 2007 

FY 

 2008 

FY 2009 

Plan 

FY 2009 

Actual 

FY 

2010 

FY 

2011 

Satisfaction index Prior-year data not available TBD TBD 

- 36 - 
Goal 4: Enhance the Commission’s Performance through Effective Alignment 

and Management of Human, Information, and Financial Capital 

The investing public and the securities markets are best served by an efficient, well-managed, and 

proactive SEC. The agency strives to improve its organizational effectiveness by making sound 

investments in human capital and new technologies and by enhancing internal controls. In FY 2011, 

the SEC plans to devote approximately $150 million and 478 permanent FTE to achieve Goal 4. 

Agency Direction & Administrative Support (88%) 

General 

Counsel (5%) 

Agency Direction & Administrative Support (88%) 

General 

Counsel (5%) 

Other Program 

Other Program Offices (2%) 

Offices (2%) 

Risk Strat. & 

Fin.Innov. (1%) Risk Strat. & 

Fin Innov. (1%) 

Inspector 

General (4%) 

Inspector 

General (4%) 

FY 2011 Request ($ in thousands)

$149,790 Total Cost 

FY 2011 Request (Permanent FTE)

478 Total FTE 

Chart 6

Outcome 4.1: The SEC maintains a work environment that attracts, engages, and retains a 

technically proficient and diverse workforce that can excel and meet the dynamic challenges of 

market oversight. 

Staff Recruitment, Retention, and Training: The SEC’s employees are its most vital strategic 

resource, and the agency works hard to attract and retain a high-quality, diverse, and results-oriented 

workforce. The Office of Human Resources (OHR) supports the agency’s efforts by providing 

organizational leadership for the strategic management of human capital, and is working to integrate 

human capital systems for candidate selection, personnel performance management, and employee 

development. In FY 2011, OHR will continue to implement a pay-for-performance system for all 

agency staff. The agency will continue to implement policies and services to improve the SEC’s total 

compensation program to achieve comparability with other federal financial regulatory agencies. 

The agency is committed to being an employer of choice by consistently attracting, hiring, 

developing, and retaining a high-quality, diverse, and results-oriented workforce. OHR will continue 

to refine a series of programs to enhance the agency’s human capital, such as by rewarding high 

performance, promoting high employee satisfaction, and updating staff skills for the effective 

oversight of the securities markets. OHR’s programs are expected to help the agency produce a high 

level of employee engagement and help maintain the agency’s turnover rate below eight percent in FY 

2010 and FY 2011 (Measures 1 and 3). Economic conditions contributed to a low turnover rate in FY 

2009, as fewer employees are likely to choose to retire or to leave the SEC for the private sector. The 

agency anticipates these programs will help regain the agency’s top five ranking as one of the best 

places to work in the federal government (Measure 2). 

With respect to its workforce, the agency must be able to attract and retain high-performing staff, 

continually update their skills so they are abreast of the latest developments in the industry, and create 

organizational structures and work processes that are efficient and effective. OHR will encourage and 

monitor the use of individual development plans so that employee-specific needs are met. This 

- 37 - 
initiative will be further enhanced by the implementation of a learning management system to 

automatically track learning programs, certifications, and competency gaps (Measure 4 and Measure 

5). 

To promote the highest level of personal and organizational performance, the SEC must have a 

performance management program that is robust, credible, fair, and transparent. In FY 2009, the SEC 

implemented a new performance management system among its managers and supervisors. In FY 

2010, the SEC will implement a similar system among all Senior Officers and non-supervisory staff. 

The SEC will invest in an extensive training program for managers and other employees, evaluate the 

effectiveness and acceptability of the system, make improvements based on results of the evaluation, 

and support the program with technology and experienced consultants (Measure 7). 

In FY 2010 and FY 2011, the Office of Equal Employment Opportunity (EEO) will develop and 

implement strategies and programs focused on creating a diverse talent pipeline to meet the SEC’s 

current and future workforce needs. The SEC will develop and expand strategic partnerships and 

alliances with diverse educational institutions, professional associations, and community-based 

organizations. These partnerships and business alliances will provide the SEC opportunities to recruit 

mid-level to high-level career professionals from diverse backgrounds (Measure 6). 

Goal 4: Measure 1 (new) 

Survey of employee engagement 

Description: The SEC strives to maintain a culture in which employees demonstrate a strong personal, 

positive connection with the organization and its mission and strategic goals. This connection, which can be 

called “employee engagement,” can result in higher-quality work, willingness to lead or participate in special 

projects, sharing job knowledge with others, mentoring other staff, or other positive contributions to the 

agency and its work. This index will be drawn from annual survey results and will track the agency’s success 

in improving employee engagement. 

Fiscal Year 

FY 

2006 

FY 

 2007 

FY 

 2008 

FY 2009 

Plan 

FY 2009 

Actual 

FY 

2010 

FY 

2011 

Biennial Index score Prior-year data not available 65% 65% 

Goal 4: Measure 2 

Best Places to Work ranking 

Description: This biennial ranking of federal government agencies will be used to determine the SEC’s 

overall success in improving our organizational climate. 

Fiscal Year 

FY 2005/ 

FY2006 

Actual 

FY 2007/ 

FY2008 

Actual 

FY 2009/ 

FY 2010 

Plan 

FY 2009/ 

FY 2010 

Actual 

FY 2011/ 

FY 2012 

Plan 

Ranking Number Ranked #5 Ranked #3 

Top Five 

Ranking 11 5 

- 38 - 
Goal 4: Measure 3 

Turnover 

Description: The SEC strives to maintain an organizational climate in which high-performing employees 

wish to remain. Although turnover can fluctuate based on a variety of factors, including the health of the 

economy and the number of outside job opportunities available for SEC staff, the agency aims to keep its 

turnover rate relatively low, below 8% per year. 

Fiscal Year 

FY 

2006 

FY 

 2007 

FY 

 2008 

FY 2009 

Plan 

FY 2009 

Actual 

FY 

2010 

FY 

2011 

Percent Turnover 8.9% 8.8% 6.2% <8% 3.7% <8% <8% 

Goal 4: Measure 4 (new) 

Expanding staff expertise 

Description: Internal training and hiring programs are designed to help the agency recruit and develop its 

staff so that key skills, industry knowledge, and expertise are maintained. In particular, there is a need to hire 

more economists, trading specialists, and other experts with knowledge of the marketplace and investment 

and trading practices. As the industry evolves, requisite staff skills and competencies are adjusted to stay 

current. Annual agency training goals and hiring practices are focused on ensuring staff have the necessary 

capabilities to address trends in the industry. This measure tracks whether certain areas requiring significant 

training are being addressed. For example, the agency will monitor the percentage of staff that has received or 

maintained significant relevant training in fraud detection as measured by achieving the status of a Certified 

Fraud Examiner, Certified Financial Analyst, Series 7, or other relevant industry designations. The agency 

must further refine its processes for collecting this information before establishing targets. 

Fiscal Year 

FY 

2006 

FY 

 2007 

FY 

 2008 

FY 2009 

Plan 

FY 2009 

Actual 

FY 

2010 

FY 

2011 

Percent of staff with 

industry designations Prior-year data not available TBD TBD 

Goal 4: Measure 5 (new) 

Size of competency gaps 

Description: Key competencies will be rated as part of our Performance Management process. Once the SEC 

has implemented a technology system to support the performance management program, the agency will 

assess its baseline competency gaps annually and work to bring them down over time. 

Fiscal Year 

FY 

2006 

FY 

 2007 

FY 

 2008 

FY 2009 

Plan 

FY 2009 

Actual 

FY 

2010 

FY 

2011 

Percentage reduction for the 

size of competency gaps Prior-year data not available 10% 10% 

- 39 - 
Goal 4: Measure 6 (new) 

Number of diversity-related partnerships/alliances 

Description: Increased numbers of diversity-related partnerships and alliances with professional associations 

and educational organizations provide opportunities to educate students about the SEC’s work and to recruit 

career professionals from all segments of society. The SEC will track the number of partnerships or alliances 

and monitor the number and quality of hires stemming from these partnerships and alliances. 

Fiscal Year 

FY 

2006 

FY 

 2007 

FY 

 2008 

FY 2009 

Plan 

FY 2009 

Actual 

FY 

2010 

FY 

2011 

Number of 

partnerships/alliances Prior-year data not available 1 2 

Goal 4: Measure 7 (new) 

Survey feedback on the quality of the SEC’s performance management program 

Description: The SEC will construct an index from survey results to determine the extent to which managers 

and other employees find the performance management program valuable, credible, transparent, and fair. 

Fiscal Year 

FY 

2006 

FY 

 2007 

FY 

 2008 

FY 2009 

Plan 

FY 2009 

Actual 

FY 

2010 

FY 

2011 

Percentage of positive 

survey responses Prior-year data not available 65% 65% 

Outcome 4.2: The SEC retains a diverse team of world-class leaders who provide motivation 

and strategic direction to the SEC workforce. 

Leadership and Staff: To make certain the SEC has the caliber of leadership commensurate with its 

mission, OHR will continue the construction and implementation of a comprehensive leadership 

development program. Specific aspects of the program include improving training for new and 

existing supervisors, building skills in change management, increasing the number and scope of 

developmental opportunities for all leaders, and instituting a program to prepare non-supervisors to 

assume supervisory roles. In addition, OHR will gradually institute a 360-degree feedback program 

for all Senior Officers and supervisors and a new-hire assessment program. These programs will 

include targeted feedback, tailored developmental opportunities, and coaching to ensure a high quality 

of leadership and staff hires (Measures 8, 9, and 10). 

Goal 4: Measure 8 (new) 

Quality of Hire 

Description: Data related to each new hire will be gathered from either the immediate supervisor or the 

selecting official, as appropriate. Data will be gathered three months after entry on board. This early 

assessment will not only inform the agency’s selection system, but will provide an opportunity to address 

quickly any developmental needs or performance issues. 

Fiscal Year 

FY 

2006 

FY 

 2007 

FY 

 2008 

FY 2009 

Plan 

FY 2009 

Actual 

FY 

2010 

FY 

2011 

Percentage of hires rated at 

least 4 on a five-point scale Prior-year data not available 75% 75% 

- 40 - 
Goal 4: Measure 9 (new) 

Leadership Competency Gaps 

Description: A 360-degree feedback survey will be conducted across all leadership ranks. This will provide 

an SEC-wide score on each competency measured in the survey. The gap will be determined by subtracting 

the obtained scores from expected proficiency levels on key competencies. Progress will be determined by 

comparing this baseline to scores obtained from subsequent administrations of the survey. 

Fiscal Year 

FY 

2006 

FY 

 2007 

FY 

 2008 

FY 2009 

Plan 

FY 2009 

Actual 

FY 

2010 

FY 

2011 

Average percentage of gaps 

reduced in each survey Prior-year data not available 10% 10% 

Goal 4: Measure 10 (new) 

Satisfaction with Leadership Development Program 

Description: After each major developmental event participants will complete a survey of items related to 

key training outcomes. Responses to these items will be compiled to create a composite score. 

Fiscal Year 

FY 

2006 

FY 

 2007 

FY 

 2008 

FY 2009 

Plan 

FY 2009 

Actual 

FY 

2010 

FY 

2011 

Average score on a 5-point 

scale Prior-year data not available 4 4 

Outcome 4.3: Information within and available to the SEC becomes a Commission-wide shared 

resource, appropriately protected, that enables a collaborative and knowledge-based working 

environment. 

Information Technology: The Office of Information Technology (OIT) supports the agency’s use of 

technology to modernize agency-wide mission performance. As a result of the increasing size and 

complexity of the U.S. securities markets as well as the expected increase in SEC staff, the agency is 

expecting an increased demand for the technical capability to electronically access, retrieve, organize, 

and analyze relevant information in FY 2010 and FY 2011. Therefore, in FY 2011, OIT plans to 

dedicate 5 positions (1 FTE) to support upgrading the IT infrastructure, ensuring compliance with 

federal IT regulations and standards, and other project and program management functions. 

In FY 2010 and FY 2011, OIT will assist in developing a data integration and management program, 

modernize enforcement and examinations systems, and redesign the Electronic Data Gathering, 

Analysis and Retrieval (EDGAR) system. OIT will work with the new Division of Risk, Strategy, and 

Financial Innovation to identify needed technology capabilities around risk analytics, financial market 

intelligence, and enterprise risk management. OIT also will work with the new division, Enforcement, 

and OCIE to improve data management and workflow systems, which are critical in identifying and 

assessing risk. Measure 11 and Measure 12 will allow the SEC to evaluate its progress in supporting 

data management and integration, and document management. 

Additionally, beginning in FY 2010, OIT will support Enforcement in developing more sophisticated 

tools for storing, analyzing, and organizing investigative evidentiary and work product documents 

(Measure 13). This will enable Enforcement staff to investigate and litigate more efficiently, 

proactively, and intelligently. 

Since the EDGAR system received its last major overhaul more than ten years ago, the volume of 

filings received as well as the amount of forms and submissions to be filed, has significantly 

increased. The data and information contained in filings made available on the agency’s website has 

become a vital resource for both SEC staff and the public. Beginning in FY 2010, the SEC will 

- 41 - 
initiate a multi-year effort to redesign the EDGAR system to allow staff to more effectively address 

new and expanding disclosure requirements for entities. 

As demonstrated in Measure 14, OIT will continue to maintain a high level of systems availability. In 

order to ensure few system outages and keep pace with systems and applications monitoring, in FY 

2010 and FY 2011, OIT will re-design and upgrade the storage management system, continuity of 

operations plans, and systems monitoring capabilities of the IT infrastructure. OIT also will continue 

to ensure compliance with federal IT regulations and standards. 

Goal 4: Measure 11 (new) 

Percentage of SEC data sources accessible through a virtual data warehouse, and milestones achieved 

towards the creation of a robust information management program 

Description: The SEC intends to reform its information management processes, so that data can be more 

easily accessed, shared, and analyzed across the organization. This metric will display the percentage of SEC 

data sources accessible for search and analysis through a virtual data warehouse. In addition, the SEC will 

track its success in achieving relevant milestones over the course of this multi-year effort. These milestones 

include establishing a formal information management program in 2010, completing an information catalog 

by 2011, providing capabilities to support analysis of information by 2012, and developing a capability that 

allows integration of business operations data for management, reporting and analysis by 2013. The agency 

must further refine its processes for collecting this information before establishing targets. 

Fiscal Year 

FY 

2006 

FY 

 2007 

FY 

 2008

FY 2009 

Plan 

FY 2009 

Actual 

FY 

2010 

FY 

2011 

Percentage Prior-year data not available TBD TBD 

Milestone Achieved Prior-year data not available 

Information Mgmt 

Program Established 

Information 

Catalog 

Complete 

Goal 4: Measure 12 (new) 

Deployment of document management and workflow tools 

Description: This metric will present the SEC’s success in applying document management and workflow 

tools to the Commission’s mission critical business functions. Over time, the SEC aims to deploy these tools 

for enforcement case management, the agency’s processes for handling disgorgement and penalties, 

examination management, management of Commission actions, and rulemaking. 

Fiscal Year 

FY 

2006 

FY 

 2007

FY 

 2008

FY 2009 

Plan 

FY 2009 

Actual 

FY 

2010 

FY 

2011 

Business Functions 

Served Prior-year data not available 

Enforcement & 

Examination 

Office of 

Secretary 

Goal 4: Measure 13 (new) 

Time to process evidentiary material for enforcement investigations 

Description: The SEC aims to improve its ability to process evidentiary material gathered during the course 

of its enforcement investigations, and enhance the agency’s document storage, organization, and analytical 

capabilities. This metric will gauge whether these efforts succeed in reducing the time required to process 

evidentiary material, so it can be analyzed by enforcement staff. The agency must further refine its processes 

for collecting this information before establishing targets. 

Fiscal Year 

FY 

2006 

FY 

 2007 

FY 

 2008 

FY 2009 

Plan 

FY 2009 

Actual 

FY 

2010 

FY 

2011 

Number of Days Prior-year data not available TBD TBD 

- 42 - 
Goal 4: Measure 14 (new) 

System Availability 

Description: The SEC aims to enhance its computing infrastructure to eliminate down time if systems at one 

site fail, among other objectives. This metric will capture the percentage of systems and applications that can 

fail over within 4 hours. In addition, the SEC will track the percentage of its systems that have been 

virtualized, further reducing down time and increasing their accessibility from alternative locations. The 

agency must further refine its processes for collecting this information before establishing targets. 

Fiscal Year 

FY 

2006 

FY 

 2007 

FY 

 2008 

FY 2009 

Plan 

FY 2009 

Actual 

FY 

2010 

FY 

2011 

Systems Availability Prior-year data not available 99% 99% 

Percentage Fail Over 

Within 4 Hours Prior-year data not available 100% 100% 

Systems Virtualized Prior-year data not available TBD TBD 

Outcome 4.4: Resource decisions and operations reflect sound financial and risk management 

principles. 

Data Integration: In FY 2010 and FY 2011, OIT plans to dedicate additional resources to fully 

establish a data management program to provide integrated enterprise data management and improved 

reporting and analysis capabilities to SEC staff (Measure 15). OIT will work with the agency’s 

administrative offices and program offices to develop technologies that support data integration and 

data management while ensuring data quality. 

Audited Financial Statements and Budget/ Performance Integration: Given the SEC’s statutory role in 

overseeing the disclosures of public companies and investment funds, taxpayers and investors should 

expect that the agency will maintain strong financial management practices and robust internal control 

over its own systems and operations. As a result, the agency places great emphasis on vigorously 

bolstering its processes and systems that support its budgeting, accounting, and internal control 

functions. In FY 2010 and FY 2011, the Office of Financial Management (OFM) plans to fully 

integrate the agency’s financial management systems and plan for transition to a next generation of 

financial, budget, and performance measurement applications (Measure 16). 

OFM will continue to focus on strengthening internal controls, developing complete and accurate 

financial statements, and increasing transparency of financial and operational information in FY 2011 

(Measure 17). In FY 2009, the SEC received an unqualified audit opinion; however, six significant 

deficiencies were identified which in the aggregate represent a material weakness in SEC’s internal 

control over financial reporting. In FY 2010 and FY 2011, the agency will implement corrective 

action plans to remediate these significant deficiencies and material weakness. 

- 43 - 
Goal 4: Measure 15 (new) 

Milestones achieved towards establishment of a robust data management program 

Description: A business process improvement effort will be initiated to identify enhancements needed to 

create a robust data management program over the next five years. This metric will gauge the agency’s 

success in establishing an integrated enterprise data management, reporting, and analysis capability for 

mission and back office data. 

Fiscal 

Year 

FY 

200

6 

FY 

 2007 

FY 

 2008 

FY 

2009 

Plan 

FY 

2009 

Actual 

FY 

2010 

FY 

2011 

Milestone 

Achieved Prior-year data not available 

Administrative data and 

reporting requirements 

identified 

Mission program data 

and reporting 

requirements identified 

Goal 4: Measure 16 (new) 

Financial systems integration 

Description: As part of the SEC’s effort to integrate its financial systems, the agency will measure the 

percentage of secondary systems that are fully interfaced with the core financial system, in compliance with 

applicable standards. 

Fiscal Year 

FY 

2006 

FY 

 2007 

FY 

 2008 

FY 2009 

Plan 

FY 2009 

Actual 

FY 

2010 

FY 

2011 

Percentage Prior-year data not available 17% 50% 

Goal 4: Measure 17 

Financial audit results 

Description: Under the Accountability of Tax Dollars Act of 2002, the agency is required to meet all 

proprietary and budgetary accounting guidelines for federal agencies and to undergo annual audits. The 

SEC’s audits are conducted by the Government Accountability Office. 

Fiscal Year 

FY 

2006 

FY 

 2007 

FY 

 2008 

FY 2009 

Plan 

FY 2009 

Actual 

FY 

2010 

FY 

2011 

Unqualified Opinion Yes Yes Yes Yes Yes Yes Yes 

Material Weaknesses 0 1 0 0 1 0 0 

Significant Deficiency 3 3 3 0 6 0 0 

- 44 - 
Division of Enforcement 

Executive Summary 

 FY 2009 FY 2010 FY 2011 

 Actual Enacted Request

 

FTE: Headquarters 431 460 515

 Regions 748 777 853

 Total 1,179 1,237 1,368

 

Cost: Salaries and Benefits ($000) $219,087 $245,720 $276,327 

 Non-Personnel Expenses ($000) 105,265 136,526 153,172 

Total Costs ($000) $324,352 $382,246 $429,499 

FY 2011 FTE by SEC Strategic Goal 

Goal 1 Goal 2 Goal 3 Goal 4 

Foster and Enforce Establish an 

Compliance Effective Facilitate Access Align and 

with Federal Regulatory To Information Manage 

Securities Laws Environment Investors Need Resources 

1,368 

A strong Division of Enforcement is critical to the investing public’s confidence in the integrity of the 

markets. The division investigates and brings civil charges in federal district court or in 

administrative proceedings based on violations of the federal securities laws. An integral part of the 

division’s proceedings is to seek penalties and the disgorgement of ill-gotten gains in order to return 

funds to harmed investors. 

To maintain an effective deterrent presence, the enforcement program needs to be adequately staffed 

to address increasingly complex financial products and transactions and the enormous size of the 

markets, and to take prompt action to halt violations and try to recover funds. The SEC’s top priority 

is to reinvigorate the enforcement program, and to this end the program is receiving 150 additional 

positions in FY 2010, and is requesting an additional 70 positions (26 FTE) in FY 2011. These 

positions will complement the enforcement program’s current reorganization efforts by: 

• expanding and focusing the investigations function, so Enforcement can strengthen its efforts 

to identify areas appropriate for enhanced investigative efforts; 

• staffing the newly created Office of Market Intelligence which will conduct risk assessment 

and prioritize the hundreds of thousands of tips, complaints, and referrals expected each year; 

• strengthening the litigation function in order to succeed in an increased number of trials; 

• increasing staffing in the Office of Collections and Distributions, which is responsible for 

collecting penalties and disgorgements and returning funds to harmed investors whenever 

possible; 

• expanding staff in the division’s information technology (IT) group. 

- 45 - 
 

Office of Compliance Inspections and Examinations 

Executive Summary 

 FY 2009 FY 2010 FY 2011 

 Actual Enacted Request

 

FTE: Headquarters 144 146 152

 Regions 676 694 760

 Total 820 840 912

 

Cost: Salaries and Benefits ($000) $150,011 $165,281 $182,616 

 Non-Personnel Expenses ($000) 57,590 64,815 74,379 

Total Costs ($000) $207,601 $230,096 $256,995 

FY 2011 FTE by SEC Strategic Goal 

Goal 1 Goal 2 Goal 3 Goal 4 

Foster and Enforce Establish an 

Compliance Effective Facilitate Access Align and 

with Federal Regulatory To Information Manage 

Securities Laws Environment Investors Need Resources 

912 

The Office of Compliance Inspections and Examinations (OCIE) conducts the SEC’s examinations of 

investment advisers, investment companies, broker-dealers, self-regulatory organizations, credit rating 

agencies, transfer agents, and clearing agencies. Examinations have three broad goals: to detect fraud 

and other violations of the federal securities laws; to foster compliance with the securities laws; and to 

provide the SEC with information regarding developments and areas of potential risk in the securities 

industry. 

In FY 2011, OCIE plans to significantly expand and enhance its oversight of registered advisers. 

Currently, OCIE is only able to inspect approximately 10 percent of all registered investment advisers 

each year. To better protect investors, to provide them with the oversight that is expected, this 

percentage must be dramatically increased. This additional staff would begin to improve this annual 

coverage. OCIE will continue to devote significant resources to conducting cause examinations 

arising out of tips and complaints alleging fraud or other abuse, as well as risk targeted and sweep 

examinations. The staff also will continue to target critical securities market participants for 

examinations, including credit rating agencies and new clearing agencies for credit default swaps. 

The office requests 100 positions (30 FTE) to accomplish these goals. 

OCIE also will enhance training and expertise of examiners in fraud detection, new products, trading 

strategies and other issues, and will continue ongoing efforts to improve its risk assessment and 

surveillance methodologies. Additionally in FY 2011, OCIE will continue to promote industry 

compliance efforts through the CCOutreach program. 

- 46 - 
Division of Corporation Finance 

Executive Summary 

 FY 2009 FY 2010 FY 2011 

 Actual Enacted Request

 

FTE: Headquarters 464 470 496

 

Cost: Salaries and Benefits ($000) $82,087 $90,887 $97,690 

 Non-Personnel Expenses ($000) 38,551 47,581 52,913 

Total Costs ($000) $120,638 $138,468 $150,603 

FY 2011 FTE by SEC Strategic Goal 

Goal 1 Goal 2 Goal 3 Goal 4 

Foster and Enforce Establish an 

Compliance Effective Facilitate Access Align and 

with Federal Regulatory To Information Manage 

Securities Laws Environment Investors Need Resources 

10 64 422 

The Division of Corporation Finance (CF) has two primary missions: to see that investors are 

provided with materially complete and accurate information and to deter fraud and misrepresentation 

in the public offering, trading, voting, and tendering of securities. The division’s primary authority is 

derived from three statutes: the Securities Act of 1933 (1933 Act), the Securities Exchange Act of 

1934 (1934 Act), and the Sarbanes-Oxley Act of 2002. 

In response to current economic and business conditions, in FY 2011 the division plans to focus more, 

and with greater frequency, on disclosures made by large and financially significant companies. The 

division also plans to prepare proposals to update the general disclosure requirements applicable to 

public companies, prepare proposals to update beneficial ownership reporting rules in light of market 

developments such as equity swaps and other derivatives, and continue rulemaking efforts to adopt 

new disclosure requirements for complex financial instruments such as asset-backed securities. The 

staff will undertake information technology (IT) projects to modernize disclosure forms and the 

Electronic Data Gathering, Analysis and Retrieval (EDGAR) system. In FY 2011, the division plans 

to continue to meet the review cycle requirements of the Sarbanes-Oxley Act, monitor the amount of 

time attributed to staff review, and process in a timely manner all requests for confidential treatment 

associated with these filings. The division requests 30 additional positions (nine FTE) in FY 2011 to 

meet its goals. 

 

- 47 - 
 Division of Trading and Markets 

Executive Summary 

 FY 2009 FY 2010 FY 2011 

 Actual Enacted Request

 

FTE: Headquarters 177 197 230

 

Cost: Salaries and Benefits ($000) $32,722 $37,915 $45,168 

 Non-Personnel Expenses ($000) 12,648 16,422 20,897 

Total Costs ($000) $45,370 $54,337 $66,065 

FY 2011 FTE by SEC Strategic Goal 

Goal 1 Goal 2 Goal 3 Goal 4 

Foster and Enforce Establish an 

Compliance Effective Facilitate Access Align and 

with Federal Regulatory To Information Manage 

Securities Laws Environment Investors Need Resources 

39 125 66 

The mission of the Division of Trading and Markets (TM) is to establish and maintain standards for 

fair, orderly and efficient markets, while fostering investor protection and confidence in the markets. 

As envisioned by the Securities Exchange Act of 1934 (1934 Act), the SEC relies on the selfregulation of the securities industry as the primary method of ensuring fair dealing and investor 

protection, but directly regulates market participants where Commission rulemaking is more effective 

than self-regulation. 

Securities Firm Supervision: In FY 2011, TM will continue rulemaking efforts related to short sales 

of securities, manipulation, privacy, broker-dealer registration, and financial responsibility. The staff 

will address issues relating to foreign and domestic transfer agents. The staff will also continue to 

work with the Financial Industry Regulatory Authority (FINRA) to consolidate and revise selfregulatory organization (SRO) rules governing securities firms. 

Market Supervision: Due to the anticipated legislative changes, including reform of the regulatory 

structure of the U.S. financial markets, regulation of credit default swaps, the registration of as many 

as eight new exchanges, and the increased globalization of the securities markets, the division will 

face significant new challenges in FY 2011 regarding the regulation and supervision of the U.S. 

securities markets. These challenges include analyzing the implications of consolidations among U.S. 

exchanges and other markets, as well as affiliations or other alliances between U.S. and non-U.S. 

markets. In FY 2011, the staff plans to examine appropriate ways to facilitate the globalization of the 

securities markets and to streamline the SEC rule filing process for U.S. exchanges and other SROs. 

The division is requesting 40 additional positions (12 FTE) in FY 2011. These additional resources 

will allow the division to begin to meet the challenges posed by an anticipated increase in regulated 

entities and new program initiatives related to supervision of securities firms and the markets. 

- 48 - 
 Division of Investment Management 

Executive Summary 

 FY 2009 FY 2010 FY 2011 

 Actual Enacted Request

 

FTE: Headquarters 154 160 174

 

Cost: Salaries and Benefits ($000) $29,843 $32,958 $36,432 

 Non-Personnel Expenses ($000) 17,738 21,698 25,184 

Total Costs ($000) $47,581 $54,656 $61,616 

FY 2011 FTE by SEC Strategic Goal 

Goal 1 Goal 2 Goal 3 Goal 4 

Foster and Enforce Establish an 

Compliance Effective Facilitate Access Align and 

with Federal Regulatory To Information Manage 

Securities Laws Environment Investors Need Resources 

38 82 54 

The mission of the investment management program is to minimize the financial risks to investors 

from fraud, mismanagement, self-dealing, and misleading or incomplete disclosure in the investment 

company and investment adviser segments of the financial services industry, without imposing 

unnecessary costs and burdens on regulated entities. 

In FY 2011, the Division of Investment Management (IM) plans to monitor results of rules (if adopted 

in FY 2010) designed to reduce the credit and liquidity risk profiles of money market funds, make 

them less susceptible and better able to respond to runs, and improve the Commission’s ability to 

monitor those funds. IM also will consider recommendations for the proposal and adoption of 

additional rules to further improve the regulatory regime for money market funds and enhance the 

protections afforded to money market fund investors. 

The division plans to recommend the Commission propose and adopt rules to implement legislation 

(if passed) that would require advisers of hedge funds and other private pools to register with the 

Commission under the Investment Advisers Act of 1940 and require them to report information on the 

funds they manage that is sufficient to assess whether any fund poses a threat to financial stability. 

The division will monitor the results of the new requirements. Additionally, IM plans to work with 

the Division of Trading and Markets to implement legislation (if passed) that would establish 

consistent standards of fiduciary conduct regarding investment advice for broker-dealers and 

investment advisers. IM requests 20 additional positions (six FTE) in FY 2011 to accomplish these 

goals. 

- 49 - 
Division of Risk, Strategy and Financial Innovation 

Executive Summary 

 FY 2009 FY 2010 FY 2011 

 Estimate Estimate Request

 

FTE: Headquarters 35 49 68

 

Cost: Salaries and Benefits ($000) $7,975 $10,784 $14,918 

 Non-Personnel Expenses ($000) 5,875 8,043 11,425 

Total Costs ($000) $13,850 $18,827 $26,343 

FY 2011 FTE by SEC Strategic Goal 

Goal 1 Goal 2 Goal 3 Goal 4 

Foster and Enforce Establish an 

Compliance Effective Facilitate Access Align and 

with Federal Regulatory To Information Manage 

Securities Laws Environment Investors Need Resources 

21 34 8 5 

The Division of Risk, Strategy, and Financial Innovation (RiskFin) was formed in the fall of 2009 by 

combining the Office of Economic Analysis (OEA) with the Office of Risk Assessment (ORA) and 

extending the mission of the overall group. RiskFin supports a multi-disciplinary approach to finance 

that blends the expertise of professional economists, lawyers, and financial practitioners to help tackle 

many of the issues facing the SEC today. RiskFin’s responsibilities cover three broad areas: risk and 

strategic analysis, strategic research, and financial innovation. Its activities relate to policymaking, 

rulemaking, and enforcement matters agency-wide. 

The division requests an additional 30 positions (nine FTE) in FY 2011, an increase of 42 percent 

from FY 2010. As a result, RiskFin will have a staff of 102, including a number of visiting academics 

and industry experts. RiskFin’s operations will support the areas of analytics, financial markets 

intelligence, and risk management. The division will monitor market developments, conduct outreach 

to market participants, and enhance risk-based methods for maximizing resources throughout the 

SEC. RiskFin will support the Office of Compliance Inspections and Examinations (OCIE) in its 

efforts to improve systems for surveillance, risk-based targeting of examinations, and data analysis 

capabilities. In FY 2011, the division expects to continue providing analyses for a number of issues 

being considered for legislative action, as well as analyses of the impact of existing legislation on 

investors and regulated entities. RiskFin plans to focus on issues related to the regulation of brokerdealers and certain other persons. RiskFin also will support efforts related to the development of 

policies and analytics associated with over-the-counter (OTC) derivatives, OTC derivative markets 

and participants, and clearance and settlement. 

- 50 - 
 Office of the General Counsel 

Executive Summary 

 FY 2009 FY 2010 FY 2011 

 Actual Enacted Request

 

FTE: Headquarters 121 125 133

 Regions 11 11 11

 Total 132 136 144

 

Cost: Salaries and Benefits ($000) $26,491 $29,084 $31,432 

 Non-Personnel Expenses ($000) 9,583 12,386 13,380 

Total Costs ($000) $36,074 $41,470 $44,812 

FY 2011 FTE by SEC Strategic Goal 

Goal 1 Goal 2 Goal 3 Goal 4 

Foster and Enforce Establish an 

Compliance Effective Facilitate Access Align and 

with Federal Regulatory To Information Manage 

Securities Laws Environment Investors Need Resources 

91 23 6 24 

The General Counsel serves as the chief legal officer of the Commission and provides independent 

legal analysis and advice to the Chairman, Commissioners, and operating divisions on all aspects of 

the Commission’s activities. The General Counsel also defends the Commission in federal district 

courts, represents the Commission in all appellate matters and amicus curiae filings, and oversees the 

SEC’s bankruptcy program. 

In FY 2011, the Office of the General Counsel (OGC) anticipates working on legislative initiatives to 

reform the existing regulatory structure for the securities markets and the financial services industry. 

OGC also expects to provide technical assistance to Congress and other financial regulatory agencies 

on numerous legislative initiatives and other matters. The requested increase in the size of the 

enforcement staff is expected to lead to an increase in the number of enforcement matters that will 

reach adjudication as appeals, as well as an increase in the number and time sensitivity of the 

enforcement actions analyzed by OGC staff. 

Ethics counseling matters are expected to rise, in large part due to the overall increase in SEC staff. 

The Ethics Office has recently assumed responsibility for all agency financial disclosure requirements, 

including review of the staff’s security transactions. The office implemented a new electronic ethics 

and compliance system in early FY 2010 and will establish a compliance branch by the end of 

FY 2010. 

The office is requesting five additional positions (one FTE) in FY 2011 to address expanding 

requirements and the additional workload generated by increasing staffing levels across the agency. 

- 51 - 
Other Program Offices 

 FY 2009 FY 2010 FY 2011 

 Actual Enacted Request

 

FTE: Headquarters 

 Office of Chief Accountant 58 60 64

 Office of Investor Education and Advocacy 67 72 79

 Office of International Affairs 32 35 40

 Office of Administrative Law Judges 11 11 11

 Total 168 178 194

 

Cost: Salaries and Benefits ($000) $29,383 $33,028 $36,497 

 Non-Personnel Expenses ($000) 13,074 16,973 19,497 

Total Costs ($000) $42,457 $50,001 $55,994 

This section of the SEC’s request includes chapters that describe the responsibilities and activities of 

the agency’s smaller program offices, including: 

Office of Chief Accountant: Establishes accounting and auditing policy and works to improve the 

professional performance of public company auditors to ensure that financial statements used for 

investment decisions are presented fairly and have credibility. 

Office of Investor Education and Advocacy: Serves investors who complain to the SEC about 

investment fraud or the mishandling of their investments by securities professionals. The SEC has 

significantly expanded the office’s responsibilities to ensure the views of retail investors inform the 

Commission’s regulatory policies and disclosure programs and to improve investors’ financial 

literacy. 

Office of International Affairs: Advances international regulatory and enforcement cooperation, 

promotes converged high regulatory standards worldwide, and facilitates technical assistance 

programs in foreign countries. 

Office of Administrative Law Judges: Adjudicates allegations of securities law violations. 

- 52 - 
Office of Chief Accountant 

Executive Summary 

 FY 2009 FY 2010 FY 2011 

 Actual Enacted Request

 

FTE: Headquarters 58 60 64

 

FY 2011 FTE by SEC Strategic Goal 

Goal 1 Goal 2 Goal 3 Goal 4 

Foster and Enforce Establish an 

Compliance Effective Facilitate Access Align and 

with Federal Regulatory To Information Manage 

Securities Laws Environment Investors Need Resources 

22 24 13 5 

The Office of the Chief Accountant (OCA) is responsible for establishing and interpreting accounting 

policy to enhance the transparency and relevancy of financial reporting for investors. OCA works to 

improve the professional performance of public company auditors to ensure that financial statements 

used for investment decisions are presented fairly and have credibility. OCA leads the SEC’s efforts 

to oversee accounting-standard setting by the Financial Accounting Standards Board (FASB) and 

auditor oversight and regulation by the Public Company Accounting Oversight Board (PCAOB). 

Rigorous accounting standards are critical to resolve global and U.S. economic issues. During the 

April 2009 Group of 20 (G-20) meeting, the heads of state of the world’s largest economies called on 

accounting standard setters to improve upon the existing guidance for valuing financial instruments 

and endorsed the adoption of a single set of global accounting standards. The Administration’s 

proposed framework for reforming federal financial regulation expands on the G-20 declarations, 

requiring the evaluation of fair value accounting and loan loss provisioning. 

OCA requires additional resources to foster progress towards global convergence of accounting 

standards and to oversee the FASB and PCAOB. During FY 2011, OCA projects increased workload 

related to FASB oversight and support, including the implementation of recommendations to improve 

financial reporting usefulness to investors. OCA will continue overseeing the PCAOB, including 

monitoring its progress in inspecting firms outside of U.S. jurisdictions. 

- 53 - 
 Office of Investor Education and Advocacy 

Executive Summary 

 FY 2009 FY 2010 FY 2011 

 Actual Enacted Request

 

FTE: Headquarters 67 72 79

 

FY 2011 FTE by SEC Strategic Goal 

Goal 1 Goal 2 Goal 3 Goal 4 

Foster and Enforce Establish an 

Compliance Effective Facilitate Access Align and 

with Federal Regulatory To Information Manage 

Securities Laws Environment Investors Need Resources 

8 8 59 4 

Understanding the needs and concerns of investors is critical to carrying out the SEC’s investor 

protection mission. The Office of Investor Education and Advocacy (OIEA) advances this mission by 

communicating daily with investors, responding to their complaints and inquiries, and providing 

educational programs and materials. 

In FY 2011, OIEA plans to expand its research on various categories of investors and investment 

decision-making behavior. This research will drive the development of educational programs and 

materials and help inform the Commission’s rulemaking agenda. OIEA also will address the SEC’s 

Investor Advisory Committee’s input regarding investors’ perspectives and priorities. OIEA plans to 

shorten response times for investor contacts and improve quality assurance. The office estimates it 

will manage approximately 2,000 more investor assistance activities compared to FY 2010. 

Additionally, OIEA plans to continue to update its publications, expand its offering of Spanish 

language publications and explore new channels for communicating with investors. To implement 

new initiatives and address increasing workload, OIEA requests 10 additional positions (three FTE) in 

FY 2011. 

- 54 - 
 Office of International Affairs 

Executive Summary 

 FY 2009 FY 2010 FY 2011 

 Actual Enacted Request

 

FTE: Headquarters 32 35 40

 

FY 2011 FTE by SEC Strategic Goal 

Goal 1 Goal 2 Goal 3 Goal 4 

Foster and Enforce Establish an 

Compliance Effective Facilitate Access Align and 

with Federal Regulatory To Information Manage 

Securities Laws Environment Investors Need Resources 

24 13 3 

The Office of International Affairs (OIA) assists the Commission in meeting its mandate by 

advancing cross-border supervisory and enforcement cooperation, advising the agency on developing 

and modernizing regulatory policy to reflect the increasingly international nature of securities activity, 

and providing technical assistance to emerging markets. A core function of OIA is to assist the 

enforcement program with respect to cross-border investigations and to foster investor protection in a 

global environment. 

Enforcement cases with important international aspects have grown at a rapid pace, and the cases are 

projected to be more complex as fraudsters try to use new methods to hide ill-gotten gains. OIA 

expects respond to about 855 inquiries seeking the assistance of foreign authorities, almost 45 percent 

more than the 594 handled in FY 2008 and requests five additional positions (two FTE) primarily to 

support the enforcement program. 

In FY 2011, OIA will continue working with the International Organization of Securities 

Commissions (IOSCO) and foreign regulatory counterparts to promote international cooperation and 

assistance on international enforcement matters. The office also will work cooperatively within 

IOSCO and the Financial Stability Board (FSB) to enhance cross-border supervisory cooperation. 

Further, OIA will advise other SEC divisions and offices on regulatory policy initiatives, including 

those identified by the Group of 20 (G-20) leaders. Specific areas to be addressed include hedge 

funds, cross-border oversight of credit rating agencies, and progress towards a single set of high 

quality global accounting standards. 

- 55 - 
 

Office of the Administrative Law Judges 

Executive Summary 

 FY 2009 FY 2010 FY 2011 

 Actual Enacted Request

 

FTE: Headquarters 11 11 11

 

FY 2011 FTE by SEC Strategic Goal 

Goal 1 Goal 2 Goal 3 Goal 4 

Foster and Enforce Establish an 

Compliance Effective Facilitate Access Align and 

with Federal Regulatory To Information Manage 

Securities Laws Environment Investors Need Resources 

11 

Pursuant to the Administrative Procedure Act and federal securities laws, administrative law judges 

preside at evidentiary hearings where the Commission has determined that public hearings are 

appropriate, in the public interest, and for protection of investors. The hearings are conducted in a 

manner similar to non-jury trials in federal court. 

In FY 2011, the Office of Administrative Law Judges (OALJ) plans to dispose of roughly 140 

proceedings. For these proceedings, the OALJ expects to issue approximately 25 initial decisions. 

The office requests one additional position (less than one FTE) in FY 2011, commensurate with the 

substantial increase in the enforcement program in FY 2010 and FY 2011. 

- 56 - 
 Agency Direction and Administrative Support 

 FY 2009 FY 2010 FY 2011 

 Actual Enacted Request

 

FTE: Headquarters 

 Agency Direction 

 Office of Executive Staff 37 39 41

 Office of Public Affairs 8 9 11

 Office of the Secretary 42 42 43

 Subtotal 87 90 95

 

 Administrative Support 

 Office of the Executive Director 11 11 13

 Office of Financial Management 56 60 70

 Office of Human Resources 61 66 79

 Office of Administrative Services 91 90 98

 Office of Information Technology 126 133 150

 Office of Equal Emp. Opportunity 8 8 8

 Subtotal 353 368 418

 Total 440 458 513

 

Cost: Salaries and Benefits ($000) $78,393 $88,117 $98,465 

 Non-Personnel Expenses ($000) 39,165 54,483 61,358 

Total Costs ($000) $117,558 $142,600 $159,823 

This section of the FY 2011 request details the SEC’s agency-wide executive activities, operations, 

and administrative functions and covers the following areas: 

Agency Direction: Includes the Chairman’s and Commissioners’ offices, Office of Legislative and 

Intergovernmental Affairs (OLIA), Office of Public Affairs (OPA), and Office of the Secretary. 

Office of the Executive Director: Develops and executes agency management policies. The office 

oversees the allocation and utilization of agency resources, promotes management controls and 

financial integrity, and manages administrative support functions. 

Office of Information Technology: Manages the Commission’s IT program including application 

development, user support, capital planning, security, and enterprise architecture. 

Office of Equal Employment Opportunity: Ensures that employees and applicants for employment 

have equal opportunity in employment. 

- 57 - 
Agency Direction 

Executive Summary 

 FY 2009 FY 2010 FY 2011 

 Actual Enacted Request

 

FTE: Headquarters 

 Office of Executive Staff 37 39 41

 Office of Public Affairs 8 9 11

 Office of the Secretary 42 42 43

 Total 87 90 95

FY 2011 FTE by SEC Strategic Goal 

Goal 1 Goal 2 Goal 3 Goal 4 

Foster and Enforce Establish an 

Compliance Effective Facilitate Access Align and 

with Federal Regulatory To Information Manage 

Securities Laws Environment Investors Need Resources 

17 17 60 1 

Agency Direction is comprised of the Commissioners and their staff, as well as the Office of the 

Secretary (OS), the Office of Legislative and Intergovernmental Affairs (OLIA), and the Office of 

Public Affairs (OPA). The Chairman’s Office oversees all aspects of agency operations, as well as the 

review and approval of enforcement cases and formal orders of investigation and the development, 

consideration, and execution of the agency’s substantive policy and rulemaking agenda. Matters such 

as the proposal or adoption of new rules or the consideration of enforcement cases or formal orders of 

investigations also involve the agency’s four other Commissioners and their staffs. 

OLIA works with Members of Congress and their staff on issues that affect the SEC and its mission, 

including the consideration of the agency’s funding and legislation that might affect the securities 

laws or other aspects of agency operations. OLIA also coordinates testimony of SEC officials and 

oversees correspondence sent between the Chairman and Members of Congress. OPA coordinates the 

SEC’s communications with the media, the general public, and foreign visitors. OS reviews all 

documents issued by the Commission, schedules Commission meetings, prepares and maintains 

records of Commission actions, advises the Commission and staff about practice and procedure, and 

maintains the library and related databases and content. 

In FY 2010 and FY 2011, the Commission will work to strengthen the administration of the federal 

securities laws, protect investors, and respond to the challenges identified by the recent financial 

crisis. OPA plans to increase the agency’s use of new technologies and social media to further 

support the goal of open and transparent government. OS plans to better manage administrative 

proceedings by establishing a new electronic filing system in FY 2011. Together, these two offices 

also intend to redesign the SEC’s external and internal Web sites to improve accessibility of 

information for investors, market participants, and SEC staff. 

In total, these offices are requesting ten new positions (three FTE) in FY 2011. 

- 58 - 
 Office of the Executive Director 

Executive Summary 

 FY 2009 FY 2010 FY 2011 

 Actual Enacted Request

FTE: Headquarters 

 Office of the Executive Director 11 11 13

 Office of Financial Management 56 60 70

 Office of Human Resources 61 66 79

 Office of Administrative Services 91 90 98

 Total 219 227 260

FY 2011 FTE by SEC Strategic Goal 

Goal 1 Goal 2 Goal 3 Goal 4 

Foster and Enforce Establish an 

Compliance Effective Facilitate Access Align and 

with Federal Regulatory To Information Manage 

Securities Laws Environment Investors Need Resources 

2 1 257 

The Office of the Executive Director (OED) aims to maximize the use of SEC resources by 

overseeing the strategic planning, financial management, human resources, and administrative 

functions of the agency. The Office of Financial Management (OFM) is responsible for the SEC’s 

accounting, budgetary, and financial operations, as well as financial, performance, and other 

managerial analysis and reporting. The Office of Human Resources (OHR) provides organizational 

leadership for strategic management of all aspects of the agency’s human capital program. The Office 

of Administrative Services (OAS) manages the agency’s physical infrastructure and provides a wide 

range of support services. 

Under the FY 2011 request, the SEC’s budget and workforce would grow significantly. OED and its 

subordinate offices will play a central role in supervising this growth, ensuring that the additional 

resources entrusted to the SEC are used wisely and efficiently. Towards this end, the offices will 

oversee efforts to hire and train new staff as well as secure additional facilities to accommodate them. 

In addition, OED would help the Office of Information Technology (OIT) manage the increased 

resources dedicated to technology, to successfully modernize the suite of systems supporting the 

SEC’s programs. Altogether, the offices are requesting 38 additional positions (12 FTE) to support 

the mission programs’ expansion and effectively manage the agency’s resources and internal control 

processes. 

- 59 - 
 Office of Information Technology 

Executive Summary 

 FY 2009 FY 2010 FY 2011 

 Actual Enacted Request

 

FTE: Headquarters 126 133 150

 

FY 2011 FTE by SEC Strategic Goal 

Goal 1 Goal 2 Goal 3 Goal 4 

Foster and Enforce Establish an 

Compliance Effective Facilitate Access Align and 

with Federal Regulatory To Information Manage 

Securities Laws Environment Investors Need Resources 

 150 

Information technology plays a critical role in the mission of the SEC. The increasing size and 

complexity of the U.S. markets require that the SEC leverage technology to continuously improve its 

productivity, as well as identify and address the most significant threats to investors. 

 

The SEC’s staffing proposal for FY 2011 will have a significant impact on the Office of Information 

Technology (OIT). To meet the resulting increase in demand for new technologies and support, OIT 

is requesting 15 additional positions (5 FTE) and an additional $12 million for FY 2011 to support its 

data management and integration, document management, disclosure, internal accounting and 

financial reporting, and infrastructure support functions. OIT plans to use the additional resources to 

fully establish a data management program to provide integrated enterprise data management and 

improved reporting and analysis capabilities to SEC staff. OIT plans to work with the new Division 

of Risk, Strategy and Financial Innovation to identify and implement technologies supporting risk 

analytics, financial market intelligence, and enterprise risk management. 

The office plans to dedicate additional staff to address the increased demand for document 

management and workflow systems anticipated in FY 2011 following completion of the enforcement 

case management and tracking system and the examination management system. Additionally, OIT 

will continue a multi-year effort initiated in FY 2010 to modernize the Electronic Data Gathering, 

Analysis and Retrieval (EDGAR) filing platform. This will significantly improve the timeliness of 

system modifications to accommodate rulemaking, enable staff to target their reviews more 

effectively, and lower contracting costs to support the system. 

- 60 - 
 Office of Equal Employment Opportunity 

Executive Summary 

 FY 2009 FY 2010 FY 2011 

 Actual Enacted Request

 

FTE: Headquarters 8 8 8

 

FY 2011 FTE by SEC Strategic Goal 

Goal 1 Goal 2 Goal 3 Goal 4 

Foster and Enforce Establish an 

Compliance Effective Facilitate Access Align and 

with Federal Regulatory To Information Manage 

Securities Laws Environment Investors Need Resources 

 8 

The Office of Equal Employment Opportunity (EEO) ensures that the SEC is an equal opportunity 

employer in full compliance with all federal EEO laws. These laws prohibit employment 

discrimination based on age, color, disability status, gender, national origin, race, religion, protected 

genetic information, sexual orientation, and discriminatory retaliation against individuals for 

participating in the EEO process or opposing discrimination. The EEO Office also is responsible for 

promoting a diverse and inclusive working environment. 

In FY 2011, in connection with the agency’s requested expansion of its staff, the EEO Office will 

increase its efforts to develop additional sources of diverse job applicants. The office plans to provide 

training, instructional, and inquiry support for the SEC workforce; continue supporting the 

Memorandum of Understanding (MOU) between the SEC and the National Treasury Employees 

Union (NTEU); support the SEC’s strategic plan; promote compliance with three new EEO-related 

statutes; and comply with EEO and Diversity-related components of financial regulatory reform. 

- 61 - 
 Office of the Inspector General 

Executive Summary 

 FY 2009 FY 2010 FY 2011 

 Actual Enacted Request

 

FTE: Headquarters 15 19 19

 

Cost: Salaries and Benefits ($000) $2,960 $3,552 $3,628 

 Non-Personnel Expenses ($000) 1,748 2,501 2,622 

Total Costs ($000) $4,708 $6,053 $6,250 

FY 2011 FTE by SEC Strategic Goal 

Goal 1 Goal 2 Goal 3 Goal 4 

Foster and Enforce Establish an 

Compliance Effective Facilitate Access Align and 

with Federal Regulatory To Information Manage 

Securities Laws Environment Investors Need Resources 

 19 

The Office of the Inspector General (OIG) is an independent office that conducts audits of programs 

and operations of the SEC and investigations into allegations of misconduct by staff or contractors. 

The mission of OIG is to detect fraud, waste, and abuse and to promote integrity, economy, efficiency, 

and effectiveness in the SEC’s programs and operations. The rapid pace of significant internal and 

external changes that affect the work of the SEC drives the work of OIG. 

In FY 2011, OIG will continue its focus on improving agency operations through audits, inspections, 

and evaluations. It also will enhance staff and agency integrity by investigating allegations of 

employee and contractor misconduct. By conducting audits, evaluations, inspections, and 

investigations, OIG supports the efforts of Congress and the SEC to fulfill their responsibilities and 

achieve their goals and objectives with respect to oversight of the securities industry and investor 

protection. 

OIG’s investigative workload has increased dramatically due to a variety of factors, including events 

pertaining to the recent financial crisis and increased Congressional focus on the SEC. This trend is 

expected to continue through FY 2011. 

The FY 2011 budget request is being submitted in conformance with the requirements of the Inspector 

General Reform Act of 2008 (Pub. L. 110-409). The aggregate amount of funds requested for the 

direct costs of operating the OIG in FY 2011 is $4,834,800. The estimated training costs for OIG for 

FY 2011 are $26,250, and OIG’s estimated contribution to the Council of the Inspectors General on 

Integrity and Efficiency (CIGIE) is $11,600. 

- 62 - 
Appendix A - Acronyms 

ARP Automation Review Program 

ASCII American Standard Code for Information Interchange 

ATS Alternative Trading Systems 

CCO Chief Compliance Officers 

CDS Credit Default Swap 

CF Division of Corporation Finance 

CIGIE Council of the Inspectors General on Integrity and Efficiency 

ECN Electronic Communications Network 

EDGAR Electronic Data Gathering, Analysis and Retrieval System 

EEO Equal Employment Opportunity 

EIS Electronic Information Systems 

EMMA Electronic Municipal Market Access 

ENF Division of Enforcement 

ETF Exchange-traded Fund 

FASB Financial Accounting Standards Board 

FINRA Financial Industry Regulatory Authority 

FOIA Freedom of Information Act 

FSB Financial Stability Board 

FTE Full-Time Equivalent 

FY Fiscal Year 

G-20 Group of 20 

GAAP U.S. Generally Accepted Accounting Principles 

GAO Government Accountability Office 

HTML Hyper Text Markup Language 

IAPD Investment Adviser Public Disclosure 

IASB International Accounting Standards Board 

IASCF International Accounting Standards Committee Foundation 

IFRS International Financial Reporting Standards 

IM Division of Investment Management 

IOSCO International Organization of Securities Commissions 

IPO Initial Public Offering 

IT Information Technology 

IWMS Integrated Workplace Management System 

MMOU Multilateral Memorandum of Understanding 

MOU Memorandum of Understanding 

MSD Municipal Securities Dealer 

MSRB Municipal Securities Rulemaking Board 

MUI Matters Under Inquiry 

NRSRO Nationally Recognized Statistical Rating Organization 

- 63 - 
- 64 - 

NTEU National Treasury Employees Union 

OALJ Office of Administrative Law Judges 

OAS Office of Administrative Services 

OCA Office of the Chief Accountant 

OCIE Office of Compliance Inspections and Examinations 

OED Office of the Executive Director 

OFM Office of Financial Management 

OGC Office of the General Counsel 

OHR Office of Human Resources 

OIA Office of International Affairs 

OIEA Office of Investor Education and Advocacy 

OIG Office of the Inspector General 

OIT Office of Information Technology 

OLIA Office of Legislative and Intergovernmental Affairs 

OMB Office of Management and Budget 

OPA Office of Public Affairs 

OPM Office of Personnel Management 

OS Office of the Secretary 

OTC Over-the-Counter 

PCAOB Public Company Accounting Oversight Board 

PDF Portable Document Format 

PL Public Law 

RiskFin Division of Risk, Strategy and Financial Innovation 

SIPC Securities Investor Protection Corporation 

SRO Self-Regulatory Organization 

SRTS SRO Rule Tracking System 

TARP Troubled Asset Relief Program 

TBD To Be Determined 

TM Division of Trading and Markets 

UIT Unit Investment Trust 

VERA Voluntary Early Retirement Authority 

VSIP Voluntary Separation Incentive Program 

XBRL eXtensible Business Reporting Language 

XML Extensible Markup Language