U.S. Securities 

and Exchange 

Commission

STRATEGIC PLAN

FISCAL YEARS 2014–2018

Protecting investors, maintaining fair, 

orderly, and efficient markets, 

and facilitating capital formation
This document presents the U.S. Securities 

and Exchange Commission’s Strategic 

Plan prepared in accordance with the 

Government Performance and Results Act 

Modernization Act of 2010. The plan sets 

out the Commission’s mission, vision, 

values, and strategic goals for fiscal years 

2014 through 2018. Furthermore, it 

discusses the SEC’s environment, details 

the strategic objectives the Commission 

seeks to achieve, presents the strategies 

and initiatives that will be undertaken 

to accomplish those objectives, and lists 

the performance goals that will be used 

to gauge the agency’s progress.
STRATEGIC PLAN , FISCAL YEARS 2014–2018 | 1

CONTENTS

Mission, Vision, and Values . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  

Strategic Goals and Strategic Objectives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  

Environmental Perspective and Outlook . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  

Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  

Strategic Goal 1 

Establish and maintain an effective regulatory environment . . . . . . . . . . . . . . . . . . . . 1

Strategic Goal 2

Foster and enforce compliance with the federal securities laws . . . . . . . . . . . . . . . . . 25

Strategic Goal 3

Facilitate access to the information investors need to make informed 

investment decisions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37

Strategic Goal 4

Enhance the Commission’s performance through effective alignment 

and management of human, information, and financial capital . . . . . . . . . . . . . . . . . 45

Program Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 56
The U.S. Securities and Exchange Commission 

is an independent federal agency established 

pursuant to the Securities Exchange Act of 1934 

(Exchange Act). It is headed by a bipartisan 

five-member Commission, comprised of the 

Chair and four Commissioners, who are appointed 

by the President and confirmed by the Senate. 

The Chair is responsible for the executive and 

administrative functions of the Commission. 

The SEC employs over 4,100 people. 
STRATEGIC PLAN , FISCAL YEARS 2014–2018 | 3

MISSION

The mission of the SEC is to protect investors, maintain fair, orderly, and efficient 

markets, and facilitate capital formation

VISION

The SEC strives to promote a securities market that is worthy of the public’s trust 

and characterized by:

■ Transparent disclosure to investors of the risks of particular investments;

■ Oversight of key market participants, including exchanges, brokers and 

dealers, investment advisers, and others;

■ Focus on strengthening market structure and systems;

■ Promotion of disclosure of market-related information;

■ Protection against fraud and abuse; and

■ Evaluation, development and maintenance of appropriate rules and regulations

VALUES

Integrity: As the SEC is the independent federal agency entrusted with regulating 

and conducting enforcement for the U.S. securities markets; each member of th

Commission’s workforce has a responsibility to demonstrate the highest ethical 

standards to inspire confidence and trust

Excellence: The SEC is committed to the highest standards of excellence in pursuit 

of its mission. The investing public and the U.S. securities markets deser

nothing less

Accountability: The SEC embraces the responsibility with which it is charged. In

carrying out its mission, SEC employees hold themselves accountable to the public 

and take responsibility for achieving SEC goals

Effectiveness: The SEC strives to work creatively, proactively, and effectively in 

assessing and addressing risks to the securities markets, the public, and other market 

participants. The staff is committed to finding innovative and flexible approaches to

the SEC’s work and using independent judgment to explore new ways to fulfill the 

SEC’s mission in the most efficient and effective manner possible
4 | U.S. Securities and Exchange Commission

Teamwork: The SEC recognizes that its success depends on a diverse, coordinated 

team committed to the highest standards of trust, hard work, cooperation, and 

communication. The staff is committed to working together and coordinating

effectively with investors, business, governments, and other organizations in the 

U.S. and abro

Fairness: The SEC treats investors, market participants, and others fairly and in 

accordance with the law. As an employer, the SEC seeks to hire and to retain a skilled

and diverse workforce, and to ensure that all decisions affecting employees and 

applicants are fair and ethical
STRATEGIC PLAN , FISCAL YEARS 2014–2018 | 5

STRATEGIC GOALS AND STRATEGIC OBJECTIVES

Strategic Goal 1: Establish and maintain an effective regulatory 

environment

➤ Strategic Objective 1.1

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

➤ Strategic Objective 1.2

The SEC promotes capital markets that operate in a fair, efficient, transparent 

and competitive manner, fostering capital formation and useful innovation

➤ Strategic Objective 1.3

The SEC adopts and administers regulations and rules that are informed by 

robust economic analysis and public comment and that enable market participants to understand clearly their obligations under the securities laws

➤ Strategic Objective 1.4

The SEC engages with a multitude of stakeholders to inform and enhance 

regulatory activities domestically and internationally

Strategic Goal 2: Foster and enforce compliance with the federal 

securities laws

➤ Strategic Objective 2.1

The SEC fosters compliance with the federal securities laws

➤ Strategic Objective 2.2

The SEC promptly detects and deters violations of the federal securities laws

➤ Strategic Objective 2.3

The SEC prosecutes violations of federal securities laws and holds violators 

accountable through appropriate sanctions and remedies
6 | U.S. Securities and Exchange Commission

Strategic Goal 3: Facilitate access to the information investors need 

to make informed investment decisions

➤ Strategic Objective 3.1

The SEC works to ensure that investors have access to high-quality disclosure 

materials that facilitate informed investment decision-making

➤ Strategic Objective 3.2

The SEC works to understand investor needs and educate investors so they are 

better prepared to make informed investment decisions

Strategic Goal 4: Enhance the Commission’s performance through 

effective alignment and management of human, information and 

financial capital

➤ Strategic Objective 4.1

The SEC promotes a results-oriented work environment that attracts, engages, 

and retains a technically proficient and diverse workforce, including leaders who 

provide motivation and strategic direction

➤ Strategic Objective 4.2

The SEC encourages a collaborative environment across divisions and offices 

and leverages technology and data to fulfill its mission more effectively and 

efficiently

➤ Strategic Objective 4.3

The SEC maximizes the use of agency resources by continually improving 

agency operations and bolstering internal controls.
STRATEGIC PLAN , FISCAL YEARS 2014–2018 | 7

ENVIRONMENTAL PERSPECTIVE & OUTLOOK

The SEC’s goals and priorities are influenced by a number of external environmental 

factors, including the demands of fulfilling its mission in an increasingly complex 

and globally interconnected securities market and the statutory structure within 

which the Commission works. In recent years, this environment has changed

dramatically. While this Strategic Plan attempts to anticipate various ways in which

the markets, regulated industries and legislative requirements may evolve over time, 

no plan can anticipate all possible scenarios. The following discussion outlines the

agency’s perspective and outlook on the most significant environmental factors that 

have influenced—and are expected to continue to influence—the SEC’s fulfillment 

of its mission

Increasingly Dispersed and Complex Financial Markets

Driven by competition, technology, regulation and market participants’ innovation, 

today’s financial markets offer more products, services, strategies and opportunities 

than ever before. Investors are confronted by a growing number of increasingly

complex product offerings. Sophisticated technology brings remarkable speed and

efficiency to the financial markets, making both routine trades and complex transactions easier and less expensive to execute. At the same time, this technology brings

new risks of accidental or intentional disruptions which are capable of spreading 

across markets, international borders and institutional firewalls. In addition, market

structure has become highly fragmented as trading volume is dispersed among many 

highly automated trading centers that compete for order flow of securities

New Aspects of the Agency’s Jurisdiction

The SEC’s role has significantly expanded in recent years, as historic legislation like 

the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank 

Act) and the Jumpstart Our Business Startups Act (JOBS Act) have increased the 

Commission’s regulatory responsibility for advisers to hedge funds and other private 

funds, clearing houses, rating agencies, municipal advisers, crowdfunding portals 

and, together with the Commodity Futures Trading Commission (CFTC), the entire 

market structure surrounding swaps

Actions designed to ease the acquisition of new capital by new and smaller

enterprises—chiefly through crowdfunding and general solicitation—will increasingly demand SEC time and resources as well
8 | U.S. Securities and Exchange Commission

The Globally Interconnected Financial Markets

At the same time that domestic responsibilities are expanding, activities the SEC regulates increasingly have international implications. Traders in today’s global financial

market can move billions of dollars thousands of miles away in a fraction of a second; 

issuers can explore a whole world of choices as they decide where to list and raise 

new capital; and investor portfolios are more diverse and global than ever before

Engagement and appropriate coordination with foreign regulators, both bilaterally 

and multilaterally, on everything from enforcement strategies to swaps regulations, 

are necessary for the SEC to oversee today’s markets, to combat fraud and to identify 

global risks that could impact U.S. securities marke

Continuing Risks

Many of the initiatives outlined in this Strategic Plan are designed to address specific 

problems brought to light by the global financial crisis and its aftermath. Despite best

efforts, however, it is impossible to predict and plan for all potential challenges. The

degree of the SEC’s success in achieving its goals and strategic objectives may depend 

upon factors such as those listed below

■ The SEC’s ability to meet its statutory mission and the performance goals and 

strategic objectives outlined in this Strategic Plan are inherently dependent upon 

the SEC obtaining sufficient resources, which the agency needs to keep pace 

with the growing size and complexity of the securities markets and the broad 

oversight and enforcement responsibilities. The SEC submits an annual budget

request which outlines the funding it is seeking and the intended use of such 

funding. The appropriation that the SEC receives is fully offset by securities

transaction fees and, accordingly, the SEC’s funding is not borne by taxpayers

Budgetary constraints will impact the ability of the SEC to fulfill its goals and 

objectives as outlined in this Strategic Plan

■ Legislative and regulatory changes may not be successful in providing 

regulators with a comprehensive understanding of systemic risk or sufficient 

tools to manage that risk more effectively

■ Changes in financial industry regulation may unintentionally hamper 

behavior that would benefit the market and investors

■ Regulations may be perceived as a substitute for care and diligence on the part 

of investors in their own decision-making

■ Over-regulation or under-regulation may undermine the competitiveness of the 

U.S. capital markets in an increasingly competitive global marketpla

■ Over-regulation or under-regulation may chill innovation, entrepreneurship, 

and prudent risk taking
STRATEGIC PLAN , FISCAL YEARS 2014–2018 | 9

RESOURCES

The SEC is an independent federal government agency funded through annual 

appropriations enacted by Congress and the President. Until FY 2012, the agency’s

appropriations were offset by transaction and registration fees collected by the 

agency. The Offsetting Collections and Spending Authority chart below presents

the SEC’s budgetary authority derived from offsetting collections from transaction 

fees collected pursuant to Section 31 of the Exchange Act and registration fees 

collected under Section 6(b) of the Securities Act of 1933, Sections 13(e) and 14(g) of 

the Exchange Act and Section 24(f) of the Investment Company Act of 1940 during 

the period FY 2005 through 2011. Pursuant to the Dodd-Frank Act and beginning in

FY 2012, registration fee collections are no longer offsetting collections, and are now 

either deposited into the Securities and Exchange Commission Reserve Fund or the 

U.S. Treasury General Fund. Thus, the columns for FY 2012 through FY 2013 refle

only Section 31 transaction fee collections

The SEC’s appropriation is deficit-neutral since, under the Dodd-Frank Act, 

the Commission’s appropriation is matched by anticipated collections of Section 31 

securities transaction fees. Thus, each year, Congress and the President can decide

the size of the SEC’s appropriation without diverting resources from other priorities 

or adding to the nation’s debt. Since personnel and technology typically comprise

about 70 percent of the SEC’s appropriation, constraints on the Commission’s budget 

can have a direct and significant impact on the staff and systems the Commission 

has available to enforce and implement the federal securities laws

■	 Spending Authority 

from the General 

Fund, Resulting from 

Lower-Than-Expected 

Offsetting Collections

■ Section 6(b), and 

Sections 13(e) & 14(g)

■	 Section 31

OFFSETTING COLLECTIONS AND SPENDING AUTHORITY (Dollars in Millions)

0

200

400

600

800

1000

1200

1400

1600

1800

2000

2005

actual

2006

actual

2007

actual

2008

actual

2009

actual

2010

actual

2011

actual

2012

actual

2013

actual
10 | U.S. Securities and Exchange Commission

‘‘Effective regulation of the U.S. financial system 

requires us to grapple with a global financial system 

that transcends boundaries. And it demands that 

we match our regulatory and enforcement 

priorities with those of scores of jurisdictions 

around the world.

 ’’CHAIR MARY JO WHITE
STRATEGIC PLAN , FISCAL YEARS 2014–2018 | 11

Establish and Maintain an Effective Regulatory Environment

THE SEC IS RESPONSIBLE FOR ESTABLISHING a regulatory environment in 

which the agency’s mission can be met and sustained. Most securities laws and regulations flow from two central principles. First, all investors should have equal acces

to accurate, complete and timely information about the investments they buy, sell, 

and hold. Second, investors should be able to rely upon self-regulatory organizations

(SRO), exchanges, broker-dealers, investment advisers, investment companies and 

other market participants to conduct investors’ securities transactions efficiently and 

according to the informed choices made by investors

The SEC has broad authority to shape the regulatory framework for the securities 

industry. Rulemaking often is required to remedy abusive practices, to respond to

Congressional mandates, to address changing economic conditions, to address risks 

in advances in technology or novel products or services. In general, rulemaking and

policies are designed to improve disclosure, facilitate the flow of important information 

to investors and the public, improve governance, promote high-quality accounting 

standards and financial reporting, enhance the responsibilities and accountability of 

financial intermediaries and other market participants and strengthen the structure of 

the trading markets, among other goals. When properly crafted, these rules serve to

further the SEC’s mission. In addition, when existing laws are not sufficient to achieve

this mission, the SEC also has a duty to advise Congress about necessary corrective 

measures. The SEC recognizes that regular reviews of Commission regulations and

its rulemaking processes are necessary to confirm that intended results are being 

achieved as well as to identify gaps and redundancies in regulation

In addition to promulgating its rules and regulations, the SEC provides guidance 

when, among other things, it sets forth the views of the Commission or its staff on 

questions of current concern without stating them in the form of legal requirements

The most prevalent form of this guidance is publicly available staff statements on a 

particular legal or accounting issue or on an interpretation of a rule or regulation

The staff also responds to inquiries from individuals and companies about whether 

an activity, undertaken in a specified manner, would violate the securities laws. The

STRATEGIC GOAL 1
12 | U.S. Securities and Exchange Commission

inquiries can take the form of written requests that the staff not recommend enforcement or other action to the Commission if the activity is completed as specified. The

SEC also issues individual orders granting relief from provisions of the securities laws 

when the specific facts indicate that doing so is consistent with the protection of 

investors and the policy and purposes behind the laws. These orders can serve as a

testing ground for useful innovation and may pave the way for rulemaking

STRATEGIC OBJECTIVE 1.1

The SEC establishes and maintains a regulatory environment that promotes 

high-quality disclosure, financial reporting and governance, and prevents 

abusive practices by registrants, financial intermediaries and other market 

participants.

The investments of Americans and their families are dependent upon the maintenance 

of healthy capital markets. The greater availability of and access to investment opportunities can help Americans build their portfolios to create a better life for themselves

and their children. Investment opportunities may include the potential for abuse by

market intermediaries, and other market participants. Such abuses erode the investing

public’s trust and undermine investor confidence in markets as a whole

To protect investors and to promote confidence in the integrity and fairness of the 

markets, the SEC uses its regulatory authority to deter potentially abusive behavior

The federal securities laws entrust the SEC with authority to shape the regulatory framework so that investors are protected through the availability of high-quality disclosure 

about their investments. In addition, the agency develops regulations that promote

and strengthen corporate and fund governance

Initiatives

To accomplish this strategic objective, the SEC plans to implement the following 

initiatives:

■ Improve the quality and usefulness of disclosure: The SEC will continue to 

evaluate and, where necessary, amend its requirements to improve the quality and 

usefulness of registrants’ disclosures to investors, including continuing to modernize the collection and dissemination of timely, machine-readable, structured data 

to investors when appropriate. Areas of focus will include disclosure about registrants’ financial condition, operations, risk management and executive compensation decisions and practices. Additionally, the SEC will continue to pursue dat

standards and methods that permit investors to more efficiently search for information within forms as well as aggregate and compare financial data across filers
STRATEGIC PLAN , FISCAL YEARS 2014–2018 | 13

■ Engage in rulemaking mandated by Congress: The SEC will continue to fulfill 

its obligations under the Dodd-Frank Act and the JOBS Act to develop and promulgate mandated rules and regulations with appropriate notice comment and 

economic analysis

■ Analyze trends in new financial products and instruments, including exchange 

traded products, and market innovations: The SEC will proactively seek out 

information from market experts both inside and outside the SEC to help inform 

the regulatory process, look for new risks, understand the impact of significant 

market events and ensure that rules and registrants’ disclosures take into account 

the latest market environment and practices. When possible, the SEC will directly

collect and analyze relevant market data to identify upcoming trends, patterns, 

or relationships among asset classes, instruments and market participants, and to 

identify areas of regulatory need. One area of focus will be to consider requiring

mutual funds to provide additional information on portfolio holdings and other 

operations

■ Strengthen proxy infrastructure: The SEC will consider issues related to the 

mechanics of proxy voting and shareholder-company communications, including 

the role of proxy advisory firms

■ Modernize beneficial ownership reporting: The SEC will consider how to 

modernize its beneficial ownership reporting requirements to, among other 

things, address the disclosure obligations relating to the use of equity swaps and 

other derivative instruments

■ Analyze regulatory structures for investment advisers and broker-dealers 

providing personalized investment advice: The SEC will continue to analyze 

whether the different regulatory obligations that apply to broker-dealers and 

investment advisers providing personalized investment advice should be changed 

for the protection of investors

■ Modernize the regulatory treatment and valuation of certain portfolio holdings of registered investment companies: The SEC will consider regulatory initiatives and/or guidance needed to update and improve the current regulatory regime 

for the use of derivatives by mutual funds, exchange-traded funds and other 

registered investment companies. A related initiative is consideration of updated

guidance for registered investment companies regarding the valuation of their 

portfolio securities and other assets

■ Promote high-quality accounting standards: The SEC will continue to promote 

the establishment of high-quality accounting standards by independent standard 

setters in order to meet the needs of investors. In overseeing the Financial Accounting Standards Board (FASB), the SEC will strengthen and support the FASB’s

independence and maintain the focus of financial reporting on the needs of 
14 | U.S. Securities and Exchange Commission

investors. Due to the increasingly global nature of the capital markets, the agency

will work to promote higher quality financial reporting worldwide and will 

consider, among other things, whether a single set of high-quality global 

accounting standards is achievable

■ Foster high-quality audits through the oversight of the accounting profession: 

The SEC will continue to oversee the Public Company Accounting Oversight 

Board (PCAOB) and its regulation of independent auditors through the PCAOB’s 

inspection and disciplinary programs. The SEC also will work closely with the

PCAOB on the promulgation and interpretation of auditing standards to address 

current issues in the capital markets

■ Enhance the regulation of broker-dealers, clearing agencies, and other major 

market participants: The SEC will continue to enhance its oversight of brokerdealers, clearing agencies, and other major market participants by, among other 

things, evaluating the current regulatory structure related to financial responsibility, 

customer protection and governance

■ Monitor disclosures related to asset-backed securities: The SEC is considering 

revising its rules and forms to improve registration and disclosure requirements 

for asset-backed securities, and will monitor disclosures and compliance with 

current and any revised rules that have been promulgated by the Commission

The SEC will continue to fulfill its statutory mandate to work with other federal 

regulators in the promulgation of joint rules concerning credit risk retention in 

securitized transactions

■ Strengthen oversight of municipal advisors and consider guidance for private 

fund advisers: The SEC will continue to enhance the program for registration and 

oversight of municipal advisors, with a particular focus on registering municipal 

advisors under the permanent registration rules and reviewing rule filings by the 

Municipal Securities Rulemaking Board (MSRB) to implement the permanent 

municipal advisor registration rules. Another area of focus will be the application

of rules under the Investment Advisers Act to private fund advisers and the need to 

provide guidance regarding the application of those rules
STRATEGIC PLAN , FISCAL YEARS 2014–2018 | 15

INDICATOR DESCRIPTION

Number of investor testing 

research projects

This metric tracks the number of research initiatives used 

to gather feedback from investors on the usefulness of 

disclosures and other input on SEC rulemaking.

STRATEGIC OBJECTIVE 1.2

The SEC promotes capital markets that operate in a fair, efficient, transparent, 

and competitive manner, fostering capital formation and innovation.

Through rulemaking and other initiatives, the Commission works to assure that 

investors have fair access to securities markets; that their orders are handled in an 

efficient and transparent manner throughout the order entry, execution, clearing, 

and settlement process; that securities laws and regulations do not promote regulatory 

arbitrage; and that U.S. securities markets remain vibrant, competitive and resilie

These efforts help to promote markets in which investors have the necessary information to make investment decisions, the price discovery process is fair and free from 

manipulation, and trades can be executed efficiently. The Commission also fosters

capital formation by facilitating market access for novel products and innovative and 

competitive investment company structures when consistent with investor protection

Self-regulation is a fundamental component of the regulation of U.S. securitie

markets and market intermediaries. SROs must balance multiple interests and responsibilities. The SEC oversees SROs to ensure that securities markets operate in a fair

efficient and orderly manner; that they are competitive; and that they promote capital 

formation. The SEC has authority over the rulemaking and other activities of SROs,

which include national securities exchanges, the Financial Industry Regulatory 

Authority (FINRA) and clearing agencies. In approving SRO rules, the SEC must

determine, among other things, that these rules are designed to prevent fraudulent 

and manipulative practices, promote just and equitable principles of trade, and foster 

cooperation in the clearing and settling of trades, and that they do not impose an 

unnecessary or inappropriate burden on competition. At the same time, SROs face

unique challenges balancing their regulatory responsibilities with business and other 

interests. In this respect, the SEC’s oversight over SROs provides it with the ability to

monitor conflicts of interest by, among other things, ensuring that an SRO’s rules, 

Related Indicator

The following indicator is useful for understanding the SEC’s activities, but should not 

be considered a performance metric. As this indicator is not used to assess performance,

it does not require a target or timeframe
16 | U.S. Securities and Exchange Commission

as well as any changes to those rules, assure a fair representation among members and 

participants in the selection of an SRO’s directors and administration of its affairs, and 

also are not designed to permit unfair discrimination between customers and other 

participants. 

Initiatives

To accomplish this strategic objective, the SEC plans to implement the following 

initiatives:

■ Foster a fair and efficient market structure: The SEC will continue to pursue 

initiatives that promote the goals of the national market system in the trading of 

securities, such as enhancing price transparency, facilitating best execution, 

assuring fair access to trading systems and fostering fair competition. These may

include:

➤	 Reviewing the impact of algorithmic and other automated trading on the 

markets, including its potential contribution to market volatility and, if 

warranted, developing an appropriate policy response;

➤	 Strengthening the incentives for investors to display trading interest, and 

thereby contribute to the price discovery process;

➤	 Enhancing the post-trade transparency of alternative trading systems 

(including dark pools) in order to address market fragmentation and facilitate 

best execution;

➤	 Continuing and expanding a comprehensive review of equity market 

structure; and

➤	 Considering a comprehensive review of the structure and operation of the 

listed options markets to promote fair, efficient, transparent, and competitive 

markets

■ Oversee the system of self-regulation: Through its review of SRO proposed rule 

changes, ongoing dialogue with SROs, and rulemaking and other initiatives, the 

SEC will appropriately oversee the system of self-regulation. This is particularly

important in light of conflicts of interests

■ Enhance the technological resilience of securities markets: The SEC is working 

with securities markets, securities firms and other key market participants to 

ensure the development of adequate policies and procedures with regard to their 

automated systems and to guard against technological failures. The SEC recently

proposed rulemaking to require securities markets, clearing agencies, and plan 

processors to assure that their systems have adequate levels of capacity, integrity, 

resiliency, availability and security to maintain their operational capability and 
STRATEGIC PLAN , FISCAL YEARS 2014–2018 | 17

that those markets operate in the manner intended. The SEC anticipates continuing

its work on this rulemaking proposal and continuing its dialogue with securities 

markets to assure a robust and sound U.S. market infrastructu

■ Reduce reliance on credit ratings references in SEC rules: The SEC will continue 

to work to implement the credit rating reference removal provisions required by 

the Dodd-Frank Act and insert appropriate substitutes as required by law

■ Enhance oversight of derivatives: The SEC will continue to implement the 

derivatives provisions of Title VII of the Dodd-Frank Act, including through 

cooperative measures with foreign counterparts. The SEC will work with the

CFTC to seek to harmonize futures and securities laws for economically equivalent 

instruments

■ Help prevent market manipulation: As part of this initiative, the SEC will 

review recent changes to the regulation of short sales to assess their effectiveness 

and determine whether additional modifications are warranted. The agency also

intends to explore ways to enhance the transparency of trading activities to better 

deter and detect manipulation. In addition, the SEC will pursue initiatives to update

and enhance the anti-manipulation rules that address the activities of underwriters, 

issuers, selling security holders and others in connection with securities offerings, 

as well as update and enhance the anti-manipulation rules that address issuer 

repurchases and timely public notice of dividends and other distributions

■ Improve transparency and oversight of small capitalization securities: The 

SEC will pursue initiatives focused on the special characteristics of the market 

for small capitalization securities, in order to enhance the transparency of this 

market and promote vigorous oversight. Goals of these initiatives will include

assuring appropriate investor protections and promoting market efficiency. The

SEC also will review its rule that governs the publication of quotations for 

securities that are not listed on a national securities exchange, to ensure that it 

adequately addresses securities and situations most likely to raise concerns about 

fraud and manipulation

■ Consider implementing further money market fund reforms: The SEC plans 

to consider final amendments to its rule regulating money market funds (MMFs), 

which would be designed to reduce their susceptibility to runs, improve their 

ability to manage the effects of high levels of shareholder redemptions in times of 

stress, increase the transparency of risk in MMF portfolios and preserve, as much as 

possible, the benefits of MMFs for investors and the short-term financing markets

■ Enhance the market structure for fixed income securities: The SEC plans to 

pursue many of the recommendations highlighted in the July 2012 Report on the 

Municipal Securities Market through a combination of SEC, MSRB, and FINRA 

initiatives, in an effort to enhance the market structure for all fixed income securities, 
18 | U.S. Securities and Exchange Commission

including taxable and tax-exempt securities. This effort will include initiatives

aimed at promoting transparency and the development of new mechanisms to 

facilitate the provision of liquidity, as well as initiatives to improve the execution 

quality of investor orders

■ Consider streamlining the process for introducing new exchange-traded 

funds: The SEC will consider whether or not to permit certain exchange-traded 

funds to be introduced to the market without first submitting an application 

under the Investment Company Act of 1940 and receiving an exemptive order 

from the Commission

■ Improve clearance and settlement: The SEC will pursue initiatives to develop 

registration practices that facilitate appropriate access to U.S. financial markets fo

different types of clearing agencies and transfer agents, and supervisory resources 

and practices that allow the SEC to appropriately consider the systemic and other 

risks of registered and exempt clearing agencies and transfer agents performing 

payment, clearance and settlement activity in the U.S. and for U.S. persons.

SEC also will consider whether and how to modify existing rules covering clearing agencies and transfer agents to enhance the safety and efficiency of securities 

clearance and settlement practices and ensure that such practices are harmonized 

with the broader U.S. financial syst

Performance Goal

The SEC intends to use the following performance metric to gauge its progress in 

achieving this strategic objective:

PERFORMANCE GOAL DESCRIPTION

Time to complete SEC review 

of SRO rules that are subject to 

SEC approval

The SEC reviews SRO rule proposals for consistency with 

the Exchange Act standards of investor protection, fair and 

orderly operation of the markets and market structure, as 

well as other statutory requirements. This metric gauges the 

timeliness of those reviews.
STRATEGIC PLAN , FISCAL YEARS 2014–2018 | 19

Related Indicators

The following indicators are useful for understanding the SEC’s activities, but should 

not be considered performance metrics. As these indicators are not used to assess performance, they do not require targets or timeframe

INDICATOR DESCRIPTION

Percentage of SRO rule filings 

submitted for immediate 

effectiveness

This indicator gauges the proportion of SRO rule proposals 

that are submitted for immediate effectiveness. 

Percentage of transaction dollars 

settled on time each year

This indicator measures the efficiency of the U.S. clearance 

and settlement system for equity securities. 

Percentage and number of market 

outages at SROs and electronic 

communications networks (ECNs) 

that are corrected within targeted 

timeframes

Market outages reflect problems in the systems underlying 

the securities markets that could have an adverse effect 

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 indicator 

gauges how quickly outages are resolved, so that market 

activity can resume. 

STRATEGIC OBJECTIVE 1.3

The SEC adopts and administers regulations and rules that are informed 

by robust economic analysis and public comment and that enable market 

participants to understand their obligations under the securities laws.

The process of developing and administering rules and regulations is one of the 

primary functions of the SEC and involves staff from virtually every division and 

office. One of the agency’s primary objectives is to maintain a regulatory framework

that enables market participants to understand their obligations

The success of this strategic objective requires collaboration and coordination among 

staff members who bring a variety of different perspectives, with appropriate tools and 

support. In addition, the agency must continually reevaluate its regulatory framework

so that it provides sufficient protections to investors as new products and services 

enter the market. In addition to drafting its own rules, the SEC often coordinates with

other federal regulators in joint rulemaking to ensure consistency and clarity throughout the market
20 | U.S. Securities and Exchange Commission

The SEC’s economic analysis supports a wide spectrum of activities, including policymaking and rulemaking. The SEC integrates robust economic analysis into the rulemaking process and rule releases, so that its rules and regulations are appropriately

informed by economic reasoning and impacts. The SEC also identifies developing

risks and trends in the financial markets and engages in long-range planning and 

training to address such developments

The SEC plans to continue to encourage investor participation and comments on 

proposed rules, regulations and other issues materially affecting investors through a 

variety of methods, including supporting the work of the Investor Advisory Committee, staffing the Office of the Investor Advocate and working with the Office of Investor Education and Advocacy to highlight issues that may be of particular interest to 

investors

Initiatives

To accomplish this strategic objective, the SEC plans to implement the following 

initiatives:

■ Improve agency-wide coordination of the rulemaking process: The SEC will 

seek additional ways to foster greater and earlier collaboration among divisions 

and offices on rulemaking initiatives. The agency will establish collaboration tools

to more effectively gather and analyze data from across the SEC and manage 

rulemaking activities

■ Enhance the process for no-action, interpretive, and exemptive regulatory 

requests: The SEC will continue reviewing its process for handling written 

requests for no-action, interpretive, and exemptive relief, so that the agency’s 

responses are completed in a timely and efficient manner

■ Respond accurately and promptly to informal guidance requests from market 

participants and others: The SEC will strive to respond to informal requests for 

guidance regarding the laws and rules it administers to provide appropriate 

informal guidance as quickly as possible
STRATEGIC PLAN , FISCAL YEARS 2014–2018 | 21

Performance Goals

The SEC intends to use the following performance metrics to gauge its progress in 

achieving this strategic objective:

PERFORMANCE GOAL DESCRIPTION

Length of time to respond 

to written requests for noaction letters (NAL), exemptive 

applications, and written 

interpretive requests

The SEC staff responds to requests for guidance from individuals 

and market participants about specific provisions of the federal 

securities laws. These queries may seek interpretations of the 

securities laws or regulations, or assurances that no enforcement 

action will be taken if the individual or market participant engages 

in a specified activity. 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 metric gauges the timeliness of initial 

comments issued by the Divisions of Trading and Markets, 

Investment Management, and Corporation Finance.

Timeliness of responses to 

requests for informal guidance 

received by the Devision of 

Trading & Markets dedicated 

hotline or email box

The Division of Trading and Markets maintains a dedicated 

phone line and an email account to provide market participants 

with avenues to request information and informal guidance 

regarding the Exchange Act and rules thereunder. This metric will 

reflect the timeliness of the staff’s responses to these requests. 

INDICATOR DESCRIPTION

Number of amendments to 

national securities exchange 

registrations (Form 1)

This indicator provides information about the volume of 

material filed with the SEC that involves amendments to 

exchange registrations. 

Number of Alternative Trading 

System registrations (Form ATS)

This indicator provides information about the volume of 

material filed with the SEC that involves filings related to ATS 

registrations. 

Number of new investment 

product submissions

This indicator provides information about the volume of 

material filed with the SEC that involves new product 

submissions pursuant to Rule 19b-4(e) of the Exchange Act. 

Number of published economic 

reports

This indicator gauges the number of economic reports that 

staff of the Division of Economic and Risk Analysis publishes 

annually on the SEC’s website. 

Related Indicators

The following indicators are useful for understanding the SEC’s activities, but should 

not be considered performance metrics. As these indicators are not used to assess

performance, they do not require targets or timeframes
22 | U.S. Securities and Exchange Commission

STRATEGIC OBJECTIVE 1.4 

The SEC engages with a multitude of stakeholders to inform and enhance 

regulatory activities domestically and internationally.

In today’s markets, capital can cross jurisdictional boundaries with the click of a 

mouse. It is more important than ever to coordinate with other U.S. and foreign regulatory authorities and stakeholders on the best regulatory responses to the changi

market landscape. Failure to effectively coordinate can significantly hamper the SEC’s

ability to achieve its policy objectives or avoid significant unintended consequences.

Domestically, the Chair of the SEC will continue to participate actively in the Financial Stability Oversight Committee (FSOC) with the heads of others FSOC member 

agencies, such as the Board of Governors of the Federal Reserve, the Department of 

the Treasury and the CFTC

The SEC also will actively participate in international multilateral organizations, 

including the International Organization of Securities Commissions (IOSCO), the 

Financial Stability Board, the Organization for Economic Cooperation and Development, and the Financial Action Task Force. These efforts will be complemented by

direct bilateral consultations with foreign regulatory counterparts on enforcement 

and regulatory cooperation matters. In addition, the SEC continues to promote international coordination and cooperation through its technical assistance programs for

foreign regulators

The SEC will continue to coordinate with domestic stakeholders including investors, 

industry representatives, technical experts and other market participants. The SEC

will also continue to work with the Investor Advisory Committee on a variety of 

regulatory issues

Initiatives

To accomplish this strategic objective, the SEC plans to implement the following 

initiatives:

■ Collaborate with other authorities on enforcement and market oversight 

matters: In order to create a more effective and coordinated regulatory environment, the SEC will partner with U.S. federal and state regulatory authorities t

share data, information, and expertise on regulatory issues as appropriate. The

SEC will similarly utilize arrangements to share appropriate and relevant data, 

information, and expertise with foreign authorities about cross-border issues
STRATEGIC PLAN , FISCAL YEARS 2014–2018 | 23

■ Continue global coordination and assistance: The SEC will continue to work 

closely with its regulatory counterparts abroad, as well as with relevant international organizations, to promote high-quality securities regulation worldwide and 

regulatory convergence where appropriate. The SEC will conduct technical assistance programs that promote emerging and recently-emerged markets’ capacity to

take steps to minimize the likelihood of regulatory arbitrage and promote crossborder enforcement and supervisory assistance

■ Facilitate input from stakeholders in rulemaking initiatives: The SEC will 

continue to seek input from stakeholders to inform its rulemaking initiatives 

through a variety of methods including, as appropriate to the initiative, meeting 

with investors, industry representatives, technical experts and other market 

participants, holding roundtables and issuing concept releases

■ Coordinate closely with the Investor Advisory Committee: The SEC will 

continue to work closely with the Investor Advisory Committee, which was 

established to present the views and experience of a wide variety of investors and 

to advise the Commission on regulatory priorities and practices. The Investor

Advisory Committee is authorized by statute to submit findings and recommendations to the Commission for review and consideration

Performance Goals

The SEC intends to use the following performance metrics to gauge its progress in 

achieving this strategic objective:

PERFORMANCE GOAL DESCRIPTION

Supervisory cooperation requests 

from foreign authorities for SEC 

assistance and SEC requests 

for assistance on supervisory 

cooperation from foreign authorities

The SEC makes requests to foreign authorities for supervisory 

cooperation assistance and responds to such requests from 

foreign regulators both through formal mechanisms, such 

as supervisory memoranda of understanding, and on an ad 

hoc basis.

Number of non-U.S. regulators 

trained

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 promoting cross-border enforcement and supervisory 

assistance.
‘‘The ability to identify and bring timely, high-quality 

enforcement actions when violations of the federal 

securities laws occur is integral to the SEC’s core 

mission. The SEC must enhance its enforcement 

function not only to send strong messages to 

wrongdoers that misconduct will be swiftly and 

aggressively addressed, but also to adapt to the 

highly automated, high-speed markets of today 

and tomorrow.

 ’’CHAIR MARY JO WHITE
STRATEGIC PLAN , FISCAL YEARS 2014–2018 | 25

STRATEGIC GOAL 2

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. Through disclosure reviews and examinations of broker-dealers,

investment advisers, SROs and other market participants, the SEC seeks both to detect 

violations of the securities laws and rules and to foster strong compliance and risk 

management practices within these firms and organizations

When violations do occur, the SEC strives to take prompt action to stop the misconduct, penalize the wrongdoers and, where possible, return funds to harmed investors

These actions span the broad spectrum of the securities laws including, among others, 

matters of financial reporting, disclosure, accounting fraud, securities offerings, 

insider trading and market manipulation. These critical investor protection functions

contribute to investors’ confidence in our capital markets

The SEC will continue to enhance its National Examination and Enforcement 

programs. As discussed further below, these improvements include expanding the

SEC’s training programs, hiring staff with new skill sets, streamlining processes, 

enhancing information-sharing, leveraging the knowledge of third parties, improving 

the processing of the thousands of tips the agency receives annually and improving 

risk assessment techniques. These, and other significant efforts, contribute to the SEC’s

objective of creating an enduring structure for improved protection of investors 

and markets

STRATEGIC OBJECTIVE 2.1

The SEC fosters compliance with the federal securities laws.

While detecting violations of the federal securities laws is an integral aspect of the 

SEC’s programs (see Strategic Objective 2.2), working to prevent future violations can

be even more important to protecting investors and enhancing market integrity. The

SEC’s goal is to encourage regulated entities and reporting companies to do all that 

they reasonably can to identify possible compliance pitfalls and take preventive action 

before a violation occurs
26 | U.S. Securities and Exchange Commission

Initiatives designed to foster greater compliance with securities laws run throughout 

this Strategic Plan. They include efforts designed to provide investors with information

they need so that they can wisely select and monitor their investments and professional 

intermediaries (see Strategic Objective 3.1); to ensure that rules are written in an understandable way, so that those charged with compliance clearly understand their responsibilities (see Strategic Objective 1.3); to create, as appropriate, prophylactic rules tha

prevent abusive trading or marketing practices (see Strategic Objective 1.2); and to

deter regulated entities and reporting companies from engaging in unlawful conduct 

(see Strategic Objective 2.2

The SEC seeks to encourage within organizations of all sizes that participate in the 

securities markets a strong “culture of compliance”—an environment that fosters, 

from top leadership down, ethical behavior and decision-making. This philosophy

should underpin all that the organization does, so that when employees make 

decisions, large and small, they are guided by a culture that reinforces acting in both 

a legal and ethical manner

Initiatives

To accomplish this strategic objective, the SEC plans to implement the following 

initiatives:

■ Expand outreach efforts for promoting compliance practices: The SEC will 

enhance efforts to promote compliance by engaging in more proactive communications with registrants and their personnel, including chief compliance 

officers, senior executives and board members. These efforts will include expanding participation in compliance outreach events; disseminating targeted materials

to firms by means of risk alerts; detailing areas where examiners have identified significant compliance deficiencies, best practices identified by examiners 

or industry groups, and rule changes; and raising registrant awareness of the 

seriousness of certain exam findings by holding post-examination compliance 

conferences
STRATEGIC PLAN , FISCAL YEARS 2014–2018 | 27

Performance Goals

The SEC intends to use the following performance metrics to gauge its progress in 

achieving this strategic objective:

PERFORMANCE GOAL DESCRIPTION

Number of industry outreach and 

education programs targeted to 

areas identified as raising particular 

compliance risks

Targeted communication with industry participants on topics 

shaping the examination program is intended to enhance 

compliance practices and prevent violations before they 

occur. This metric identifies the number of major outreach 

efforts conducted including the SEC’s national and regional 

compliance outreach events, published risk alerts, and other 

educational programs and initiatives. 

Percentage of firms receiving 

deficiency letters that take 

corrective action in response to all 

exam findings

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, including monetary compensation to clients 

and enhancements to disclosures, policies and procedures. 

Most often, registrants respond that they have corrected 

the deficiencies and implemented measures to prevent 

recurrence. 

STRATEGIC OBJECTIVE 2.2

The SEC promptly detects and deters violations of the federal securities laws.

Violations of the securities laws have a tremendous impact on investors. Accordingly,

prompt detection of potential securities law violations is important in limiting the 

harm caused to investors. By identifying violations early, the SEC seeks to punish

wrongdoers promptly, correct violative behavior in the financial markets before it 

proliferates, stop fraud and manipulation before it affects a large number of investors, 

and locate and preserve investors’ assets before they are lost or dissipated.

Detecting violations of the federal securities laws is a difficult but critical function, 

and one in which the agency continuously seeks to enhance its efforts. In the midst

of constantly evolving financial markets, the SEC seeks to strengthen its oversight of 

the large number of registrants by focusing its resources on the areas of greatest risk

This risk-based approach, which the Commission continually seeks to refine, is implemented across agency programs through various methodologies aimed at identifying, 

assessing and managing risks to investors
28 | U.S. Securities and Exchange Commission

In addition, each year the SEC receives thousands of tips and complaints, as well as 

referrals from SROs, that staff analyze to determine matters requiring investigation

The Commission works closely with others—SROs, the Department of Justice and 

other criminal authorities, and state, federal, and foreign regulators—to maximize the 

breadth and depth of its combined efforts. As described below, the SEC will continue

working to improve its detection and deterrence efforts

Initiatives

To accomplish this strategic objective, the SEC plans to implement the following 

initiatives:

■ Enhance surveillance and risk assessment capabilities: The SEC will continue 

to enhance the methods and tools for more effectively identifying and assessing 

risks in the markets and focusing surveillance efforts on entities, persons, and 

practices that pose a high risk to investors and financial markets. As part of this

effort, the SEC will seek to obtain greater access to data and insights from a variety 

of sources including data from registrants, SROs, commercial vendors, and other 

sources. In addition, the SEC will expand the use of analytics to enhance the ability

of examination and enforcement staff to detect potentially violative activity

■ Improve management of tips, complaints, and referrals: The SEC will enhance 

the process for receiving, processing, and acting upon tips, complaints and referrals 

so they can continue to be handled consistently and appropriately, including 

through examinations or enforcement investigations. This effort will also enhance

the SEC’s data on tips, complaints, and referrals, to help the agency spot trends 

and patterns about potential issues or violations that may warrant further Commission action

■ Build upon the establishment and successes of the Office of the Whistleblower: 

The SEC will continue to encourage individuals and entities with timely, credible 

and specific information about potential securities law violations to provide information to the Commission to further investigations and promote more efficient 

use of the Commission’s limited resources. Pursuant to the Dodd-Frank Act, the

SEC is required to compensate eligible whistleblowers with an award of 10 to 30 

percent of amounts collected as a result of original information provided by a 

whistleblower that leads to a successful enforcement action resulting in monetary 

sanctions exceeding $1,000,000

■ Bolster the expertise of SEC staff: The SEC will continue to develop and implement specialized teams focusing on particular market issues that directly affect 

investors and the functioning of the markets, by enhancing the expertise of SEC 

staff through targeted training in critical and emerging areas, and enabling staff to 

obtain additional training resulting in certifications, such as “Certified Fraud 

Examiners” and “Chartered Financial Analysts.
STRATEGIC PLAN , FISCAL YEARS 2014–2018 | 29

■ Build upon Enforcement’s Cooperation Program: The staff will use a variety 

of tools—including cooperation agreements, deferred prosecution agreements 

and non-prosecution agreements—to encourage individuals and companies to 

promptly report violations and provide assistance to the agency

■ Enhance sharing, cooperation, and joint initiatives both within the agency and 

with other regulators: The SEC will focus on improving the sharing of information between divisions and offices of the Commission and with other regulators

This type of communication will help ensure that expertise is shared and that 

areas of mutual interest are addressed in an efficient and effective manner. This

includes continuing the use of joint specialized working groups within the agency 

that are focused on market issues and entities presenting significant risks. This

would also include continuing efforts to collaborate and share information with 

other regulators, such as FINRA, state regulators, the CFTC, international counterparts and many others

Performance Goals

The SEC intends to use the following performance metrics to gauge its progress in 

achieving this strategic objective:

PERFORMANCE GOAL DESCRIPTION

Percentage of investment advisers, 

investment companies, and brokerdealers examined during the year 

This metric indicates the number of registrants examined by 

the SEC or an SRO as a percentage of the total number of 

registrants. This metric includes all types of examinations: 

risk priority examinations, cause inspections to follow up on 

tips and complaints, limited-scope special inspections to probe 

emerging risk areas, oversight examinations of broker-dealers 

to test compliance and the quality of examinations by FINRA.

Percentage of compliance exams 

that are concluded in accordance 

with the Office of Compliance 

Inspections and Examination’s 

(OCIE) statutory deadline

The staff conducts examinations each year of registered 

entities, including investment advisers, investment company 

complexes, transfer agents, and broker-dealers. The staff 

strives to complete its examinations and communicate 

findings in the most efficient and effective manner and within 

its statutory deadline. This metric reflects the percentage of 

examinations concluded within the statutory deadline.

Number of joint exams, information 

sharing agreements, and formal 

meetings with other regulators

The SEC attempts to coordinate and collaborate with other 

regulators on areas of mutual interest. This helps to ensure 

that all regulators are informed of ongoing risks and issues 

related to broad market practices as well as specific entities 

of mutual interest. This cooperation is critical to the exam 

program to ensure that certain higher risk firms and activities 

are addressed in the most efficient and effective manner. This 

metric tracks critical cooperation activities that are occurring 

between the SEC’s exam program and other regulators.
30 | U.S. Securities and Exchange Commission

Related Indicators

The following indicators are useful for understanding the SEC’s activities, but should 

not be considered performance metrics. As these indicators are not used to assess

performance, they do not require targets or timeframes

INDICATOR DESCRIPTION

Percentage of exams that identify 

deficiencies, the percentage that 

result in a “significant finding,” 

and the percentage referred to the 

Division of Enforcement

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 indicator 

identifies the percentage of exams that identified deficiencies, 

that resulted in significant deficiency findings, and that were 

referred to Enforcement. 

Number of cause exams that 

result from tips, complaints and 

referrals

Analysis of a tip can support the request for a cause exam. This 

indicator would identify the number of SEC cause exams that 

result from tips collected through outreach efforts. 

Number of rule-making initiatives 

assisted by the National Exam 

Program 

The examination program interacts with registrants on a regular 

basis and this work provides feedback critical to ensuring 

effective and practical rulemaking and policy efforts. This 

indicator tracks how frequently the examination program assists 

with rulemaking initiatives.

Number of investigations or 

inquiries originating from a tip or 

complaint

Analysis of a tip or complaint can result in the need for an 

enforcement investigation. The indicator identifies the number 

of SEC investigations that result from tips and complaints 

received by the SEC. 

SEC investigations in which 

requests for access to information 

were granted by the SEC to other 

authorities, such as SROs or 

other state, federal, and foreign 

enforcement authorities

The SEC works closely with other regulators and authorities. 

This metric identifies the number of investigations in which 

the SEC granted one or more authorities access to information 

concerning an investigation during the fiscal year. This may 

include requests for access to SEC investigative files 

concerning investigations that the SEC continues to pursue, as 

well as those in which the SEC has completed its investigation. 

Requests from foreign authorities 

for SEC assistance and SEC 

requests for assistance from 

foreign authorities

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 bilateral informationsharing arrangements, as well as the Multilateral Memorandum 

of Understanding, an information-sharing arrangement 

negotiated through IOSCO. 
STRATEGIC PLAN , FISCAL YEARS 2014–2018 | 31

STRATEGIC OBJECTIVE 2.3

The SEC prosecutes violations of federal securities laws and holds violators 

accountable through appropriate sanctions and remedies.

Investors are not truly protected unless those who prey on them are swiftly and 

appropriately sanctioned. The enforcement staff strives to obtain swift and firm

sanctions, while remaining fair and reasonable. The breadth of the enforcement

program’s capabilities in this area derives, in part, from its close cooperation with the 

other SEC divisions that perform regulatory functions and also have deep knowledge 

of the market and its participants

To improve the quality and efficiency of its investigations, the SEC is committed to 

streamlining internal processes wherever possible. In pursuing potential violations of

the securities laws, the SEC regularly works closely with other regulators and law 

enforcement agencies. The enforcement program also has seen a dramatic increase

in its coordination efforts with foreign authorities, including requests for assistance 

to and from foreign regulators under bilateral and multilateral information-sharing 

arrangements. These efforts also include requests to trace proceeds of fraud to foreign

countries, and actions to obtain asset freezes. The SEC is committed to further

expanding its coordination with these entities in order to strengthen the Commission’s 

ability to hold wrongdoers accountable

Initiatives

To accomplish this strategic objective, the SEC plans to implement the following 

initiatives:

■ Continue utilizing specialty groups within the enforcement program: The SEC 

will continue to use specialized groups and task forces to move quickly and to 

centralize expertise on the most critical issues emerging in the markets. As market

conditions and market events dictate, Enforcement will evaluate the need to add, 

eliminate or implement changes to specialized groups and task forces

■ Enhance timeliness of distributions to wronged investors: The SEC will improve 

timeliness and efficiency of its efforts to return money collected in enforcement 

actions to harmed investors

■ Enhance communications among SEC divisions and offices and the enforcement 

program: The SEC will improve communication and sharing of information 

between the enforcement program and other divisions and offices to bring to 

bear the collective expertise of the Commission in a timely and efficient manner, 

such as continuing meetings of the Cross-Border Working Group
32 | U.S. Securities and Exchange Commission

■ Review approach for enforcement penalties: The SEC will continue to assess its 

approach to the use of penalties in connection with enforcement recommendations/

actions so that penalties have the appropriate punitive and deterrent effect, having 

in mind avoiding unnecessary harm to shareholders

■ Broaden the range of enforcement sanctions: The SEC will develop alternative 

approaches to sanctions to gain greater flexibility in bringing actions to conclusions 

that benefit investors

Performance Goals

The SEC intends to use the following performance metrics to gauge its progress in 

achieving this strategic objective:

PERFORMANCE GOAL DESCRIPTION

Percentage of enforcement actions 

in which the Commission obtained 

relief on one or more claims

This metric identifies, as to all parties to enforcement actions 

that were resolved in the fiscal year, the percentage against 

whom the Commission obtained a judgment or order entered 

on consent, a default judgment, a judgment of liability on one 

or more charges, and/or the imposition of monetary or other 

relief. The Division of Enforcement is currently assessing 

this metric, and evaluating how to incorporate qualitative 

considerations of the results of its enforcement actions. 

Percentage of first enforcement 

actions filed within two years of the 

opening of an investigation

This metric concerns the pace of investigations that lead to the 

filing of enforcement actions. Specifically, this metric captures 

the rate at which the first enforcement action arising out of an 

investigation was filed within two years of the opening of the 

investigation. If the investigation was preceded by a matter 

under inquiry, the metric draws on the date of the opening 

of the matter under 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.

Average months between opening 

a matter under inquiry or an 

investigation and commencing an 

enforcement action

This metric captures the average number of months between 

the opening of an investigation and the filing of the first 

enforcement action arising out of that investigation. If the 

investigation was preceded by a matter under inquiry, the 

metric draws on the date of opening of the matter inquiry. 

In conducting investigations, the enforcement program 

continually strives to balance the need for complete, effective, 

and fair investigation with the need to file enforcement actions 

in as timely a manner as possible. While not all investigations 

result in the filing of enforcement actions, this metric provides 

information concerning the pace of investigations that do lead 

to such actions and supplements the previous goal, which 

measures the percentage of first enforcement actions filed 

within two years. 
STRATEGIC PLAN , FISCAL YEARS 2014–2018 | 33

PERFORMANCE GOAL DESCRIPTION

Percentage of debts where either 

a payment has been made or a 

collection activity has been initiated 

within 180 days of the due date of 

the debt

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 SEC or the federal district court, payments 

must be made by a certain date. This metric 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. 

Percentage of Fair Fund and 

disgorgement fund plans that 

have distributed 80 percent of the 

available funds for distribution 

within twenty four (24) months of 

the approval of the distribution plan

In addition to other types of relief, the SEC may seek 

orders requiring parties to disgorge any money obtained 

through wrongdoing. The SEC also is empowered to seek 

civil penalties for violations of the securities laws. Where 

appropriate, the SEC has sought to return disgorged funds 

to harmed investors and, as a result of the Fair Funds 

provisions of the Sarbanes-Oxley Act and the Dodd-Frank 

Act, to combine amounts paid as penalties with disgorged 

funds, or to create a Fair Fund from penalties only, to reduce 

losses to injured parties and to maximize funds available 

for distribution. This metric identifies the percentage of 

distribution plans that reached a critical mass during the 

fiscal year and within twenty four (24) months of the approval 

of the distribution plan. The distribution plan includes the 

timeline and procedures required to return the funds to 

injured investors. This reflects Commission-wide efforts to 

implement plans to return money to investors quickly. Any 

funds not returned to investors are sent to the U.S. Treasury 

or the Investor Protection Fund established pursuant to 

Section 21F(g) of the Securities Exchange Act of 1934. 

Neither disgorgement nor penalties are used for the SEC’s 

own expenses. 
34 | U.S. Securities and Exchange Commission

Related Indicators

The following indicators are useful for understanding the SEC’s activities, but should 

not be considered performance metrics. As these indicators are not used to assess

performance, they do not require targets or timeframes

INDICATOR DESCRIPTION

Percentage of filed enforcement 

actions reflecting characteristics 

that present enhanced risk 

to investors and markets, as 

measured by the nature of the 

investigation, conduct, parties 

and impact.

This indicator assesses the quality of the cases filed by the 

Division of Enforcement. The indicator focuses on cases filed 

by the SEC that involve factors reflecting enhanced risk to 

investors and markets. Such cases may involve: (i) those 

identified through risk analytics and cross-disciplinary initiatives 

to reveal difficult-to-detect or early stage misconduct, thus 

minimizing investor loss and preventing the spread of unlawful 

conduct and practices; (ii) particularly egregious or widespread 

misconduct and investor harm; (iii) vulnerable victims; (iv) a high 

degree of scienter; (v) involvement of individuals occupying 

substantial positions of authority, or having fiduciary obligations 

or other special responsibilities to investors; (vi) involvement 

of recidivists; (vii) high amount of investor loss prevented; 

(viii) misconduct that is difficult to detect due to the complexity 

of products, transactions, and practices; (ix) use of innovative 

investigative or analytical techniques; (x) effective coordination 

with other law enforcement partners; and/or (xi) whether the 

matter involves markets, transactions or practices identified 

as an enforcement priority, or that advances the programmatic 

priorities of other SEC divisions or offices. 

Total amount distributed within 

the fiscal year, and the number 

of Fair Funds from which those 

distributions came

In its enforcement actions, the SEC 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 SEC to combine amounts paid 

as penalties with disgorged funds, or to create a Fair Fund 

from penalties only, to reduce losses to injured parties. This 

reflects the SEC’s efforts to return funds to injured investors. 

This indicator identifies the total amount distributed within the 

fiscal year, and the number of Fair Funds from which those 

distributions came. This indicator may increase or decrease 

in dollar amount and number of distribution funds based on 

the number of SEC enforcement actions brought involving 

distributions, amounts ordered and paid in those actions, 

and other factors. Due to the variation in reporting timelines 

established for each individual distribution, reported amounts 

are based on the agency’s best available information. Reported 

amounts do not include those funds distributed through 

receiverships. Any funds not returned to investors are sent to 

the U.S. Treasury or the Investor Protection Fund established 

pursuant to Section 21F(g) of the Securities Exchange Act 

of 1934. Neither disgorgement nor penalties are used for the 

Commission’s own expenses. 
STRATEGIC PLAN , FISCAL YEARS 2014–2018 | 35

INDICATOR DESCRIPTION

Percent of enforcement actions 

filed that arose out of national 

priority investigations

The Division of Enforcement brings many enforcement actions 

each year that can be characterized as high impact and of national 

priority. High impact or national priority investigations include those 

investigations which are significant for one or more of the following 

reasons: (i) presents an opportunity to send a particularly strong 

and effective message of deterrence, including with respect to 

markets, products and transactions that are newly developing, or 

that are long established but which by their nature present limited 

opportunities to detect wrongdoing and thus to deter misconduct; 

(ii) involves particularly egregious or extensive misconduct; (iii) 

involves potentially widespread and extensive harm to investors; 

(iv) involves misconduct by persons occupying positions of substantial authority or responsibility, or who owe fiduciary or other 

enhanced duties and obligations to a broad group of investors 

or others; (v) involves potential wrongdoing as prohibited under 

newly-enacted legislation or regulatory rules; (vi) concerns potential misconduct that occurred in connection with products, markets, 

transactions or practices that pose particularly significant risks for 

investors or a systemically important sector of the market; (vii) 

involves a substantial number of potential victims and/or particularly vulnerable victims; (viii) involves products, markets, transactions or practices that the Division of Enforcement has identified as 

priority areas (i.e., conduct relating to the financial crisis; fraud in 

connection with mortgage-related securities; financial fraud involving public companies whose stock is widely held; misconduct by 

investment advisers; and matters involving priorities established 

by particular regional offices or the specialized units); and/or 

(ix) provides an opportunity to pursue priority interests shared 

by other law enforcement agencies on a coordinated basis. 

Criminal actions related to 

conduct under investigation 

by the SEC

In some instances, conduct may involve both civil and criminal 

violations and may be investigated by both the SEC and the criminal authorities. This indicator identifies the number of criminal 

actions that are related to conduct under investigation by the SEC. 

Disgorgement and penalties 

ordered and the amounts 

collected

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. In some cases, the SEC will seek to obtain 

large monetary sanctions even in instances where the prospects 

of collecting on a judgment are slight. The rationale for seeking 

monetary relief in these circumstances is that such relief, even 

when likely uncollectible, might become collectible in the future 

based on the defendant’s changed circumstances, and also 

because such relief can serve to deter others from violating 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 or the Investor Protection Fund established pursuant to Section 21F(g) of the Securities Exchange Act 

of 1934. This indicator lists disgorgement and penalties ordered as 

a result of SEC cases and the amounts collected in those actions. 

This indicator could increase or decrease based on various factors. 
‘‘Increasing investor understanding should always 

be one of our primary goals. But it is not enough 

merely to make accurate, timely, and useful 

information available; we also have to make it 

accessible. We have to provide information in the 

ways that investors want to receive it. Investor 

outreach is crucial to success. Finding out what is 

on investors’ minds will improve the overall quality 

of the information we provide.

 CHAIR MARY JO WHITE

’’
STRATEGIC PLAN , FISCAL YEARS 2014–2018 | 37

STRATEGIC GOAL 3

Facilitate Access to the Information Investors Need to Make 

Informed Investment Decisions

THE FEDERAL SECURITIES LAWS require that corporations, investment companies, and other entities provide investors with timely and meaningful information 

about, among other things, their operations and financial condition. Because an

educated and informed investor ultimately provides the best defense against fraud and 

costly mistakes, these laws place great emphasis on providing material information to 

the investing public

The SEC promotes informed investment decisions through two main approaches

The first is to require that investors have accurate, useful, and timely public access 

to disclosure materials that can be easily understood and analyzed. The second is to

implement a variety of investor education initiatives aimed at providing investors with 

a better understanding of the operations of the nation’s securities markets

In administering its disclosure program, the SEC requires reporting entities to disclose 

financial and non-financial information to the investing public, thereby providing a 

common pool of knowledge for all investors to use to judge for themselves whether a 

security is an appropriate investment. Similarly, SEC rules require that investors have

access to certain information about the financial intermediaries they rely upon for 

investment advice and other services. SEC staff reviews the disclosure and other filings

that corporations, investment companies, and other entities submit to assess whether 

the disclosures appear adequate and accurate under the relevant rules and regulations

The goal of the SEC’s investor education program is to give investors the information 

they need to evaluate current and potential investments, while also providing agency 

staff with critical insight about emerging trends and factors shaping investor decisionmaking. The SEC staff aims to collect investor-focused data from a variety of sources

and use it both to track trends in the securities industry and to identify, among other 

things, problematic brokers, investment advisers, firms, and sales practices
38 | U.S. Securities and Exchange Commission

STRATEGIC OBJECTIVE 3.1

The SEC works to ensure that investors have access to high-quality 

disclosure materials that facilitate informed investment decision-making. 

Investors who have access to information and know what questions to ask are more 

likely to invest wisely, and to choose professional intermediaries that will best meet 

their objectives. The SEC understands that not all investors need the same information and that those needs are affected by their backgrounds, resources and goals. Th

SEC seeks to structure disclosure requirements so that investors are armed with timely 

and useful information they need to make informed investment decisions

As technology and the complexity of financial instruments change, so too do the 

needs of modern day investors. Providing investors with information in concise,

easy-to-use formats that are tailored to their needs helps investors to help themselves

On a recurring basis, the Commission examines its filing review program to explore 

whether its disclosure requirements, review criteria, approach to comments, and professional and technology resources provide maximum impact to benefit investors. As

described below, the SEC will engage in a number of initiatives to further enhance its 

programs in this key area

Initiatives

To accomplish this strategic objective, the SEC plans to implement the following 

initiatives:

■ Update disclosure and reporting requirements to reflect the informational 

needs of today’s investors: The SEC will continue its efforts to enhance disclosure 

requirements for the benefit of investors, including a reassessment of current core 

corporate disclosure requirements. In proposing changes for the Commission to

consider, the staff will seek to modernize disclosure requirements and eliminate 

redundant reporting requirements. The staff’s efforts will continue to include a

review of proxy voting and shareholder communications to identify ideas and 

proposals for potential improvement to those rules

■ Evaluate the effectiveness of filing review programs for reporting entities 

so that investors receive material information in a timely manner without 

imposing undue regulatory burdens on filers: The staff will continue to evaluate the Commission’s filing review processes and make changes in response to 

evolving trends or market developments. The staff will also work to ensure that

the SEC has reliable risk management tools to identify material issues in offering 

documents and periodic reports for review, and obtain enhancements in disclosure. This assessment will explore the criteria used to identify filings for review,

the process of issuing comments to reporting entities and new ways for technology 

to help improve the Commission’s programs
STRATEGIC PLAN , FISCAL YEARS 2014–2018 | 39

■ Design and implement new disclosure regimes for specialized categories of 

issuers so that investors in these products have relevant and useful information to make informed investment decisions: The SEC will continue to evaluate 

and improve the disclosure requirements for securitized financial products and 

other complex financial instruments. The SEC plans to consider rules designed

to provide variable annuity investors with more user-friendly disclosure and to 

improve the delivery of information about variable annuities through increased 

use of the internet and other electronic means of delivery. In addition, the SEC

will continue work on proposed amendments to its advertising rules that would 

require target date retirement funds’ marketing materials to provide investors 

enhanced information about those funds

■ Design and implement enhancements to EDGAR and SEC.gov to facilitate 

investor and market participant access to and utilization of disclosure documents and other information: The SEC will continue to modernize its IT systems 

and the dissemination and rendering of electronic disclosure documents to improve 

investor access to relevant information and the ease of interacting with the SEC

The SEC is working on enhancements to data standards and XBRL filing requirements that improve the quality of structured data and reduce burdens on filers

Performance Goals

The SEC intends to use the following performance metrics to gauge its progress in 

achieving this strategic objective:

PERFORMANCE GOAL DESCRIPTION

Percentage of public companies 

and investment companies with 

disclosures reviewed each year

The Sarbanes-Oxley Act requires that the SEC review, at least 

once every three years, the disclosures of all companies and 

investment company portfolios reporting under the Exchange 

Act. These reviews help improve the information available to 

investors and may identify possible violations of the federal 

securities laws. This metric gauges the number of public 

companies and investment companies reviewed each year.

Time to issue initial comments on 

Securities Act filings

The target of 30 days or less has become a de facto industry 

standard for issuers and underwriters’ expectations for the 

maximum time to receive initial comments on Securities 

Act registration statements. This metric will measure the 

Commission’s frequency in meeting this 30-day target.

Percentage of investment company 

disclosure reviews for which initial 

comments are completed within 

timeliness goals

For initial registration statements, the SEC’s goal is for staff 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 for staff comment 

on post-effective amendments within 45 days and preliminary 

proxy statements within 10 days after they are filed. This metric 

will show how often the Commission is meeting this goal. 
40 | U.S. Securities and Exchange Commission

Related Indicator

The following indicator is useful for understanding the SEC’s activities, but should 

not be considered a performance metric. As this indicator is not used to assess performance, it does not require a target or timefram

INDICATOR DESCRIPTION

Total digital audience including 

website, social media and mobile 

media

Digital media has become the dominant channel for investors 

seeking to access information. These statistics will help 

evaluate the extent to which investors are turning to the SEC, 

identify the channels they use, and quantify the amount of 

information they receive.

STRATEGIC OBJECTIVE 3.2

The SEC works to understand investor needs and educate investors 

so they are better prepared to make informed investment decisions. 

Understanding the interests and concerns of investors is critical to carrying out the 

Commission’s investor protection mission. The SEC advances this mission by regularly communicating with investors, responding to their complaints and inquiries, and

providing educational programs and materials

The SEC will obtain more comprehensive information about the views and perspectives of investors. It will seek more robust information regarding the behavioral characteristics of investors and the types of information investors need and use as they

make informed investment decisions. It will compile and provide this information to

the Commission to help in the development of rules and educational programs that 

address investors’ views and concerns

The SEC is exploring ways to encourage investor input by presenting investors with 

clear, easily understandable explanations of Commission rules and rule proposals and 

other activities through a variety of communication channels, including social media

These efforts will complement those of the Investor Advisory Committee, which was 

constituted to present the views and experience of a broad spectrum of investors, and 

which will serve as an additional source of information concerning investors’ priorities and perspectives on the Commission’s regulatory agenda

More comprehensive data about investors also will drive the Commission’s investor 

education efforts. Working in partnership with other federal and state agencies, financial industry associations, consumer groups and educational organizations, the SEC

will develop investor education initiatives that are targeted to specific audiences
STRATEGIC PLAN , FISCAL YEARS 2014–2018 | 41

Initiatives

To accomplish this strategic objective, the SEC plans to implement the following 

initiatives:

■ Use feedback from individual investors to improve investor education resources: 

In addition to responding to investor complaints and inquiries and conducting 

in-person outreach, the SEC will use informational surveys to evaluate whether 

investors are engaging in prudent investing behaviors and to gauge the usefulness 

of its investor education materials and responsiveness of its investor assistance 

program

■ Inform rulemaking with investors’ views: The SEC will use investor testing 

and other outreach efforts, as appropriate, to gather input from investors on rulemaking initiatives and better understand their informational needs

■ Address Investor Advisory Committee input: The SEC will consider information and respond to recommendations from the Investor Advisory Committee 

regarding investors’ perspectives and priorities

■ Expand collaborative partnerships: The SEC will partner with other federal and 

state agencies, securities regulators and non-profit organizations to shape and 

target educational initiatives to maximize their impact on specific communities 

of interest

■ Promote investor awareness: The SEC staff will issue Investor Alerts and other 

educational materials designed to both arm investors to be their own first line of 

defense against fraud and assist them in understanding new products and the role 

of financial intermediaries
42 | U.S. Securities and Exchange Commission

Performance Goals

The SEC intends to use the following performance metrics to gauge its progress in 

achieving this strategic objective:

PERFORMANCE GOAL DESCRIPTION

Number of page views of online 

investor education content, and 

number of in-person events, 

including those with specifically 

targeted communities and 

organizations

The Office of Investor Education and Advocacy (OIEA) 

initiates investor education campaigns on key strategies for 

making informed investment decisions, including publicizing 

online resources for researching investment professionals 

and investments, understanding fees, and identifying fraud. 

OIEA staff also participates in in-person events for investors 

generally and those targeted to specific investors, such as 

seniors, service members, and other affinity groups. This 

metric tracks page views of SEC online investor education 

materials and the number of investor events in which OIEA 

staff participated. 

Timeliness of responses to investor 

contacts

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.

Customer satisfaction rating of 

OIEA’s online investor education 

resources

 This metric gauges the effectiveness, helpfulness, and 

usability of OIEA’s online investor education resources.

Number of new investor education 

materials designed primarily to 

help investors protect themselves 

from fraud

Through OIEA, and often in conjunction with other 

organizations, the staff issues Investor Alerts and other forms 

of educational material that inform investors about different 

permutations of fraud, new investment products, and other 

topical issues. This metric measures the number of new 

investor education materials issued by OIEA. 
STRATEGIC PLAN , FISCAL YEARS 2014–2018 | 43

Related Indicators

The following indicators are useful for understanding the SEC’s activities, but should 

not be considered performance metrics. As these indicators are not used to asses

performance, they do not require targets or timeframes

INDICATOR DESCRIPTION

Number of investor testing 

research projects

This indicator tracks the number of research initiatives used 

to gather feedback from investors on the usefulness of 

disclosures and other input on SEC rulemaking. 

Number of sets of 

recommendations prepared by 

the investor advisory committee

This indicator tracks the recommendations from the Investor 

Advisory Committee regarding investors’ perspectives and 

priorities. 
‘‘The SEC’s hardworking and dedicated staff is the 

core component of the agency’s strength.

 CHAIR MARY JO WHITE

’’
STRATEGIC PLAN , FISCAL YEARS 2014–2018 | 45

STRATEGIC GOAL 4

Enhance the Commission’s Performance Through Effective 

Alignment and Management of Human, Information, and 

Financial Capital

THE PUBLIC AND THE SECURITIES MARKETS are best served by an efficient, 

effective, and agile SEC. Given the immense size of the securities markets the SEC

regulates, the SEC’s success in fulfilling its mission and in achieving the goals and 

objectives outlined in this Plan is highly dependent upon whether it’s adequately 

funded and its ability to continually direct its resources towards the most productive 

uses. The SEC also is extremely mindful of its responsibility to optimize the use of its

resources because it is a government agency entrusted with public funds

The SEC continuously strives to enhance its performance by making sound investments in human capital and new technologies and by employing strong financial 

management and operational risk management practices. With respect to its workforce, the SEC 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

The Commission’s information technology environment must give employees the 

tools they need to view, analyze and act upon the enormous volume of financial data 

and other information relevant to oversight of the securities markets. The SEC must

demonstrate a continued commitment to maintaining strong internal controls to 

support effectiveness and efficiency of Commission operations. Finally, the SEC must

continually direct its financial resources to their highest and best use, always subject 

to strong internal controls
46 | U.S. Securities and Exchange Commission

STRATEGIC OBJECTIVE 4.1

The SEC promotes a results-oriented work environment that attracts, 

engages, and retains a technically proficient and diverse workforce, 

including leaders who provide motivation and strategic direction. 

The SEC is committed to being an employer of choice by consistently attracting, hiring, 

developing, and retaining a high-quality, diverse, and results-oriented workforce. The

SEC is continually refining a series of programs to enhance its human capital, such 

as rewarding high performance, promoting high employee satisfaction and updating 

staff skills

The SEC continues to build and maintain an effective training program to deepen 

expertise and skills, not only in the rapidly evolving nature of the markets, but also in 

areas of new responsibility for the Commission. The training supports development

for employees directly involved in examinations, investigations, fraud detection, 

litigation, and other core mission responsibilities of the SEC. The training consists

of specialized in-depth topics concerning new trends in the securities industry and 

changing market conditions, as well as analytics and forensics. It also allows staff to

obtain certain specialized financial certifications and regulatory credentials, as well 

as the advanced continuing education credits required for maintaining legal and 

financial credentials

The SEC’s success at fulfilling its strategic goals depends upon effective leadership 

at all levels. From branch chiefs to the Commission’s senior leadership, the SEC’s

leaders must not only motivate and manage employees effectively, but also play a 

critical role in identifying the key areas on which staff should focus their attention to 

generate the greatest benefit for investors. Through leadership and employee development programs, the Commission seeks to maintain a diverse cadre of technically

proficient leaders that can conduct their supervisory responsibilities effectively and 

meet the dynamic challenges of market oversight
STRATEGIC PLAN , FISCAL YEARS 2014–2018 | 47

Initiatives

To accomplish this strategic objective, the SEC plans to implement the following 

initiatives:

■ Increase employee engagement and retention: To retain high caliber and diverse 

talent, the SEC will implement programs and initiatives focused on employee 

engagement and retention. In response to employee viewpoint survey results, the

SEC has conducted numerous interviews and focus groups with its workforce at 

every level. The recommendations derived from this information will form the

basis for action plans aimed at improving the Commission’s organizational 

climate and workforce morale. These plans will be implemented and evaluated in

a manner designed to promote continuous improvement. Improvements in

organizational climate and workforce morale should lead to greater employee 

engagement and increased retention, particularly of high-performing employees

■ Enhance employee development program: For the SEC to fulfill its mission 

it must attract and select a diverse cadre of highly talented and accomplished 

people and provide them with opportunities to develop the knowledge and skills 

to achieve high levels of performance and address changes in market conditions, 

securities laws, federal regulations, best practices and technology. The Office

of Human Resources (OHR) will work to identify training and learning needs 

within each division and office and to procure or develop high-quality training 

that will develop employee skills. OHR will utilize, encourage and monitor the use

of individual development plans so that employee-specific needs are met and that 

progress can be tracked

■ Leadership development program: To ensure the SEC has the caliber of leadership commensurate with its mission, the SEC will continue the construction 

and implementation of a comprehensive leadership development program that 

will address the needs of a diverse group of supervisors, managers, and leaders. Specific aspects of the program include improving training for new supervisors, building skills in change management, enhancing cultural awareness and

inclusiveness, increasing the number and scope of developmental opportunities 

for all leaders, and instituting a succession planning program to prepare nonsupervisors to assume supervisory roles and supervisors to assume key executive 

positions
48 | U.S. Securities and Exchange Commission

Performance Goals

The SEC intends to use the following performance metrics to gauge its progress in 

achieving this strategic objective:

PERFORMANCE GOAL DESCRIPTION

Turnover When employee morale and engagement are high, highperforming employees tend to remain in the organization. 

Although turnover can fluctuate based on a variety of factors, 

the SEC aims to keep its turnover rate relatively low, below 

8% per year. 

Expanding staff expertise Internal training and hiring programs are designed to help 

the agency recruit and develop a diverse and qualified staff 

with the key skills, industry knowledge, and expertise to 

support the SEC mission. In particular, there is a need to 

train examiners, attorneys, economists, and other experts 

for subject matter expertise relevant to the marketplace 

and investment and trading practices. This metric tracks 

whether certain areas requiring significant training are being 

addressed. The agency will track the number of SEC staff 

participants in mission-focused training and development 

programs and will report on specific items through the use of 

post-course evaluations to assess the impact and results of 

this training on a five-point scale. 

Number of diversity-related 

partnerships/alliances

Increased numbers of diversity-related partnerships or 

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 and/or alliances with diverse professional 

associations and educational organizations. 

Survey rankings Annual and other rankings, together with other metrics and 

indicators of federal government agencies will be used as 

one kind of metric to determine the SEC’s overall success in 

improving employee morale and employee engagement. 

Bench strength To maintain mission effectiveness, it is essential that attrition 

in the leadership ranks is quickly addressed by having a 

highly qualified and diverse pool of candidates ready to 

assume those critical roles. Success is measured by the 

percentage of key leadership positions for which the SEC has 

identified a pool of qualified candidates. 
STRATEGIC PLAN , FISCAL YEARS 2014–2018 | 49

STRATEGIC OBJECTIVE 4.2 

The SEC encourages a collaborative environment across divisions and 

offices and leverages technology and data to fulfill its mission more 

effectively and efficiently. 

The SEC’s divisions and offices collaborate in a variety of ways, both formal and 

informal, to advance the Commission’s mission. Such coordination is essential for any

organization as large and complex as the SEC to bring together different perspectives, 

decide on the best course of action, and implement that course in the most effective 

way. Given the importance and complexity of the SEC’s mission, it is imperative that

the Commission continuously improve its ability to break down silos, share information and work jointly towards a common purpose

Information technology plays a crucial role in the mission of the SEC and its ability 

to share information and data both internally and externally. The SEC gathers a wide

variety of data and other information from a variety of sources, including corporate 

disclosures, equity exchange feeds, investigations and examinations, tips, complaints, 

and referrals, and commercial vendors. The SEC is working to develop systems that

will allow more of this information to be quickly shared, analyzed, and joined with 

other information about the same entity or individual. These efforts should save staff

time, provide better information about the firms the SEC regulates and enhance the 

ability to uncover hidden risks to investors

The increasing size and complexity of the U.S. markets require that the SEC continu

to leverage technology to improve its productivity, as well as identify and address the 

most significant threats to investors. Information technology is an increasingly vital

function to the SEC in modernizing filing practices, disseminating the vast quantity of 

regulatory filings, managing the large number of internal business processes and work 

products and protecting the Commission’s information assets
50 | U.S. Securities and Exchange Commission

Initiatives

To accomplish this strategic objective, the SEC plans to implement the following 

initiatives:

■ Work smarter to achieve the SEC mission: A multi-year technology transformation plan called “Working Smarter” will ensure the SEC’s business processes 

are streamlined, integrated, and implemented with the best technology to reduce 

costs and increase efficiencies and effectiveness; deliver better services to both 

employees and the public; and provide greater accountability, transparency, and 

security. Leveraging modern, reliable, and innovative technologies and predictive

analytics will transform the way the SEC performs its mission and provide a 

proactive view into how technology impacts capital markets. By ensuring people

“work smarter,” the SEC will derive significant and measurable performance 

improvements in core operations and increase value through the use of automated 

processes

■ Make disclosure information more useful for analysis: Disclosure documents 

are submitted to the Commission electronically and, as appropriate, disseminated 

electronically to the investing public. This initiative will review the current disclosure systems and processes and identify ways to optimize the use of technology

to improve the way disclosure documents are constructed and submitted with 

more emphasis on data collection. A new filing system that is optimized for data

retrieval and analysis will provide features that help users create filings that are 

appropriate to their purpose and that allow computers to extract data from the 

filings for automated analysis. The system will be more flexible, so that, as new

disclosure documents are defined, they can be implemented much more quickly, 

with all of the features of a modern, web-based filing system. Eventually, new

filings structured for automated data retrieval and analysis will replace all 

filings submitted through the EDGAR system

■ Improve SEC’s information management and analysis functions: The SEC 

aims to provide its staff with the access to information and effective analytical 

capabilities needed to perform their duties. To accomplish this outcome, the SEC

will work on several fronts to improve its abilities to acquire, store, manage, and 

deliver data and information in support of its critical business functions. Among

the steps in this effort are standardization of enterprise-wide platforms, knowledge management, seamless integration of structured and unstructured data 

sources, cloud computing, modernization of SEC.gov and EDGAR filer systems,

cataloging the SEC’s data and its interrelationships in an electronic data warehouse (EDW); ensuring data quality; and establishing new methods for capturing 

information, including from SEC staff themselves as they conduct examinations, 

investigations, and other activities
STRATEGIC PLAN , FISCAL YEARS 2014–2018 | 51

■ Enhance workflow and document management: Virtually all business processes 

within the Commission involve the acquisition, creation, review, and editing of 

documents. These processes are conducted informally, without the benefit of

automated tracking, notification and auditing capabilities. Under this initiative,

the SEC will assess its critical business processes and apply document management tools to increase productivity, enhance collaboration and create a shared 

repository of essential documents and data. Among the business areas that would

benefit from this effort are enforcement case management, disgorgement and 

penalties, examination management, management of Commission actions, filing 

of administrative proceedings and rulemaking

■ Enhance the SEC’s electronic discovery program: The SEC must have the technical 

capability to electronically organize and retrieve an extraordinary volume of 

documents obtained in the conduct of investigations. Under this initiative, the

SEC will enhance its current electronic discovery tools and improve its document 

storage, organization, and analytic capabilities. The SEC also will create a repository

of documents and data that is more widely available across cases and with other 

Commission business functions as appropriate

■ Enhance operational resiliency: The SEC will support a reliable computing 

environment that provides high performance, security and cost effectiveness. The

Commission also will enhance the computing infrastructure, including through 

server virtualization and clustering, to eliminate down time if systems at one site 

fail, enhance security, and achieve cost savings

■ Enhance internal communications to staff: Led by the Offices of Public Affairs 

and Chief Operating Officer, the SEC will track and recognize exceptional staff 

achievements, awards and other successful outcomes to promote a sense of pride 

and accomplishment throughout the Commission. Additionally the SEC will

initiate a program leveraging technology and best practices to centralize all 

administrative, technology, financial, procurement, human capital and other 

operational information, news and resources so that staff can easily “self-service” 

and find the tools, forms, guidance and support they need
52 | U.S. Securities and Exchange Commission

Performance Goals

The SEC intends to use the following performance metrics to gauge its progress in 

achieving this strategic objective:

PERFORMANCE GOAL DESCRIPTION

Ensure SEC’s systems and 

applications are available

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 or within 8 hours.

Equip the SEC with an enhanced 

enterprise infrastructure

The SEC aims to promote collaboration and information 

sharing across the enterprise. To improve efficiency and 

knowledge management, the SEC will consolidate and 

centralize its collaborative technologies to a commonly 

used enterprise set by 2020. This metric will measure the 

percentage of the SEC’s offices and divisions that utilize 

centralized enterprise collaboration solutions.

Expand the SEC’s video 

teleconferencing (VTC) capabilities 

to support an increasingly 

geographically dispersed workforce

The SEC seeks to develop a state-of-the-art video teleconference solution that allows users to conduct a video/

teleconference meeting between HQ, regional offices and 

multiple endpoints simultaneously; collaborate and share 

presentation materials; and use VoIP technology to host 

video teleconferences from their offices/workspaces with 

other SEC users or conference rooms. This metric will 

measure the average “uptime” or availability of all VTC 

systems.

Pursue continuous technology cost 

reductions and efficiencies

Recent technology enhancements- e.g., data center 

consolidation, virtualization and maintenance contract 

reductions- are producing technical efficiencies and cost 

savings. This metric will measure the amount of these costs 

savings.

Enhance the SEC’s enterprise 

data warehouse infrastructure and 

performance

The Enterprise Data Warehouse (EDW) infrastructure 

will enable the provisioning of data to Commission staff 

for search and analysis through a virtual data warehouse 

platform. This metric will measure the availability of EDW and 

data sources.
STRATEGIC PLAN , FISCAL YEARS 2014–2018 | 53

STRATEGIC OBJECTIVE 4.3

The SEC maximizes the use of agency resources by continually improving 

agency operations and bolstering internal controls. 

As an agency of the federal government entrusted with public funds, the SEC must 

always strive to enhance the value for investors it creates from every budget dollar

The SEC continually strives to allocate the resources approved by Congress and the 

President towards the highest and best use. The SEC also constantly reevaluates its

operations to identify cost savings and maximize their benefit

The SEC will strive to maintain strong financial management practices and robust 

internal controls. The SEC is placing great emphasis on bolstering its processes and

systems in its budgeting, accounting, and internal control functions over operations

In addition, the SEC continues to focus on delivering complete, concise, and meaningful information about the financial and operating performance of the Commission 

that supports management decision-making

Initiatives

To accomplish this strategic objective, the SEC plans to implement the following 

initiatives:

■ Better integrate data from SEC operational functions into management 

decisions: To accomplish the SEC’s mission it is essential that management 

decisions are based on the best available information from multiple sources. This

requires SEC leaders to consider information from human resources, financial 

management, information technology and support operations functions when 

making management decisions. To improve decision-making and reporting

capabilities, the SEC will examine its data collection, analysis and reporting 

methods to determine areas for improvement

■ Further enhance financial systems to achieve operational efficiency and 

effectiveness: The SEC is in the early stages of building a financial datamart as 

part of a broader Commission-wide EDW initiative. The datamart is expected to

integrate data from various systems to provide more comprehensive management 

and financial reporting on a regular basis, to facilitate better decision-making

The SEC also will participate in the federal government-wide deployment of a 

new travel system, work to replace the system supporting budget execution and 

formulation, and focus on reforming the systems related to filing fees and registrant 

deposits
54 | U.S. Securities and Exchange Commission

■ Continue enhancing internal controls: Although the SEC has made significant 

progress in strengthening internal controls over financial reporting, the Commission is still focused on further optimizing its controls to enhance financial 

accounting, reporting and operations. Many of these areas are interdisciplinary

and involve collaboration between different offices within the SEC. Such areas

include accounting for property and contract obligations, as well as disgorgements, penalties, and filing fees. The SEC also will continue to focus on areas that

are highly manual and therefore more at risk for error, with a view towards 

further automation where possible

■ Further enhance management assurance to achieve operational efficiency and 

effectiveness via an agency-wide operational risk management program: The 

SEC will continue to build its Operational Risk Management program to 

manage internal risks that may impact its ability to successfully fulfill its mission

Risk management processes and procedures will be institutionalized and 

consistently applied within all operating units to ensure that internal operating 

risks are identified, analyzed, and managed at all levels of the organization. The

SEC is in the early stages of formalizing governance structures through the 

Operational Risk Management Oversight Committee (RMOC). The RMOC will

provide oversight of the development and implementation of operational risk 

policies, framework, methodologies, and provide leadership and monitoring of 

Commission-wide operational risks

■ Enhance consideration of diverse sources in SEC’s business activities: For the 

SEC to enhance the diversity of its suppliers to ensure that it is procuring the best 

goods and services to meet its contracting needs, the SEC actively will engage in 

outreach to diverse vendors to evaluate and consider their capabilities, and 

publicize procurement opportunities in diverse sources
STRATEGIC PLAN , FISCAL YEARS 2014–2018 | 55

Performance Goals

The SEC intends to use the following performance metrics to gauge its progress in 

achieving this strategic objective:

PERFORMANCE GOAL DESCRIPTION

Financial audit results Under the Accountability of Taxpayer Dollars Act of 2002, 

the SEC 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 (GAO).

Assurance statement on internal 

control over operations

In accordance with OMB A-123 and Section 961 of the DoddFrank Act, the SEC conducts an annual assessment of the 

effectiveness of internal controls. The SEC will continue 

to develop its Operational Risk program and enhance 

cross-organizational processes to support all division and 

office management assurance statements. Success is 

measured by the quality of risk and control assessments and 

management self-identification and resolution of improvement 

opportunities.

Timely completion of corrective 

action on Office of Inspector 

General (OIG) 

Timely completion of audit recommendations is an important 

SEC priority. This metric measures how well the Commission 

is doing in completing corrective action on OIG audit 

recommendations within established timeframes.
56 | U.S. Securities and Exchange Commission

PROGRAM EVALUATION

The SEC values independent, high-quality assessments of the agency’s performance 

against its goals and desired strategic objectives. Such assessments are critical to the

Commission’s ability to evaluate its work, refine its programs and redirect resources 

accordingly. The more than 150 audits, studies, and evaluations of SEC programs and

securities industry-related issues completed since the release of the agency’s previous 

Strategic Plan have served as an important resource in the development of this Strategic 

Plan. Over the next five years, the SEC will continue to draw on evaluations from a

variety of sources to improve its programs

Annual Performance Report

In February 2013, the SEC published an Annual Performance Report (APR) describing 

the agency’s accomplishments and presenting the results of the agency’s performance 

metrics for FY 2012. The most recent version of the SEC’s APR can be found on the

agency’s website, at http://www.sec.gov/about/secreports.sh

Consultation with Outside Groups

The SEC frequently seeks the input of investors, industry groups, academia, and 

other experts to gain outside perspectives about its programs and various issues in the 

securities industry. These efforts include the SEC’s Investor Advisory Committee;

Commission-sponsored roundtables focused on specific issues; the agency’s 

Annual Government-Business Forum on Capital Formation, focused particularly 

on the needs of new, small, medium-sized, and independent businesses; the SEC’s 

annual conference with the North American Securities Administrators Association; 

and solicitations of public comments on Commission rule proposals

Government Accountability Office

The Government Accountability Office conducts dozens of studies or investigations 

related to the SEC’s programs every year. In FY 2013, GAO’s reports covered internal

supervisory controls, requirements and costs associated with newly developed SEC 

rules, and the criteria for qualifying as an accredited investor, among other areas

In addition, GAO performs an annual audit of the SEC’s financial statements and 

internal controls over financial reporting

Office of the Inspector General

The Office of Inspector General (OIG) is an independent office within the SEC that 

conducts audits of programs and operations of the Commission and investigations 

into allegations of misconduct by staff or contractors. The mission of the OIG is to

detect fraud, waste and abuse, and to promote integrity, economy, efficiency and 

effectiveness in the Commission’s programs and operations

U.S. SECURITIES AND EXCHANGE COMMISSION

100 F STREET NE | WASHINGTON, DC 20549 | WWW.SEC.GOV