U.S. SECURITIES AND EXCHANGE COMMISSION

FISCAL YEAR 2023

Congressional Budget 

Justification

Annual Performance Plan

PROTECT INVESTORS

MAINTAIN MARKETS

FACILITATE CAPITAL FORMATION

FISCAL YEAR 2021

Annual Performance

Report

Contents

Agency and Mission Information............................................................................................................................ 1

Executive Summary .......................................................................................................................................... 2

Mission, Vision, Values, and Goals .............................................................................................................9

History and Purpose........................................................................................................................................ 12

Organizational Structure and Resources.............................................................................................. 13

FY 2023 Budget Request Tables...........................................................................................................................15

Positions and Full-Time Equivalents (FTE) by Program................................................................16

Obligations by Object Class........................................................................................................................ 17

Strategic Goal and Program........................................................................................................................18

Request Summary of Changes .................................................................................................................19

FY 2023 Appropriations Language......................................................................................................................21

FY 2023 Budget Request by Program..............................................................................................................23

Other Information ...........................................................................................................................................................97

Risks, Internal Controls, and Management Challenges...............................................................98

Cross-Agency Collaboration....................................................................................................................103

Evidence Building..........................................................................................................................................109

Links to Additional Information and Resources ..............................................................................112

FY 2021 Annual Performance Report (APR) and 

FY 2023 Annual Performance Plan (APP)..................................................................................................... 113

A Reader’s Guide to SEC Performance Information .....................................................................114

FY 2021 APR and FY 2023 APP Summary...........................................................................................114

Performance Summary by Strategic Goal....................................................................................................115

Appendices....................................................................................................................................................................... 131

Appendix A: Verification and Validation of Performance Data ............................................... 132

Appendix B: SEC’s Responses to Government Accountability Office Reports.............. 133

Appendix C: SEC’S Good Accounting Obligation in Government Act 

(GAO-IG Act) Report ..................................................................................................................................... 136
ABOUT THIS REPORT 

The Congressional Budget Justification (CBJ) is the annual presentation to Congress that justifies 

the U.S. Securities and Exchange Commission’s (SEC) budget request. This report also includes 

the Annual Performance Plan (APP) for fiscal year (FY) 2023 and the Annual Performance Report 

(APR) for FY 2021, focusing on the agency’s strategic goals and performance results. This report 

provides information that satisfies requirements contained in the following laws and regulations 

listed below:

• Federal Information Technology Acquisition Reform Act 

• Good Accounting Obligation in Government Act

• Government Management Reform Act of 1994 

• GPRA Modernization Act of 2010

• Inspector General Act of 1978, as amended

• Office of Management and Budget (OMB) Circular A-11, Preparation, Submission, and 

Execution of the Budget

• OMB Circular A-136, Financial Reporting Requirements

• Reports Consolidation Act of 2000

This report is compliant with Section 508 of the Rehabilitation Act (29 U.S.C. § 794 (d)). For a 

machine readable format of the tables found on pages 16-19, download the report and open the 

Attachments panel in Adobe Acrobat. 

An electronic version of this document and its components is available at SEC.gov/cj. 

To comment on the SEC’s FY 2023 CBJ and APP and FY 2021 APR, email

OFM_budget_formulation@sec.gov. 
Executive Summary.........................................................................................................................................................2

Mission, Vision, Values, and Goals..........................................................................................................................9

History and Purpose......................................................................................................................................................12

Organizational Structure and Resources........................................................................................................13

Agency and 

Mission Information
2 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

EXECUTIVE SUMMARY

On behalf of the U.S. Securities and Exchange Commission (SEC), I am pleased to submit the 

fiscal year (FY) 2023 budget request. The SEC requests $2.149 billion in support of 5,261 

positions and 4,808 full-time equivalents. The SEC’s funding is deficit-neutral, with any amount 

appropriated to the agency offset by transaction fees. These funds are necessary to enable the 

SEC to effectively carry out its core mission—protecting investors, maintaining fair, orderly, and 

efficient markets, and facilitating capital formation—and meet the challenges of today’s global, 

interconnected, and technologically sophisticated markets. 

As our capital markets have grown, though, the SEC has not grown in parallel. At the end of 

FY 2016, the SEC had 4,650 people on board. Five years later, that number had decreased by 

about three percent. The FY 2023 request seeks to close this gap by providing the additional 

resources needed to bring in new personnel with skills and expertise to address critical needs, 

including the wave of traditional initial public offerings (IPOs) and an unprecedented surge in 

non-traditional IPOs by special purpose acquisition companies (SPACs); the growing size and 

number of private funds, particularly private equity and venture capital funds; the significant 

growth in crypto-assets; the rise of financial technology and predictive data analytics; and 

increased regulation of security-based swaps. As more Americans are accessing the capital 

markets, we need to be sure that the Commission has the resources to protect them.

The SEC is charged with overseeing approximately $118 trillion in annual securities trading 

on U.S. equity markets and the activities of more than 29,000 registered entities. The agency 

also oversees 24 national securities exchanges, 95 alternative trading systems, 9 credit 

rating agencies, and 7 active registered clearing agencies, as well as the Public Company 

Accounting Oversight Board (PCAOB), the Financial Industry Regulatory Authority (FINRA), 

the Municipal Securities Rulemaking Board (MSRB), the Securities Investor Protection 

Corporation (SIPC), and the Financial Accounting Standards Board (FASB). In addition, the 

SEC is responsible for reviewing the disclosures and financial statements of more than 7,900 

reporting companies, of which approximately two-thirds are exchange-listed. The SEC also 

engages and interacts with the investing public on a daily basis through a number of activities 

ranging from our investor education programs to alerts on SEC.gov. In addition, we provide 

critical market information through the agency’s information technology (IT) systems such as 

the Electronic Data Gathering, Analysis, and Retrieval (EDGAR) system.
AGENCY AND MISSION INFORMATION | 3

The capital markets affect nearly every American. The $52 trillion debt markets are how 

local governments raise funds, how corporations borrow money, or how construction of the 

hospital down the street gets financed. They also fund our mortgages and auto loans. Our 

$51 trillion public equity markets, which get most of the attention, connect Americans 

looking to invest with public companies seeking to grow, innovate, and hire employees. 

Our $18 trillion of gross assets in the private funds area also play a significant role.

These markets also have experienced significant growth in recent years. A record 68 million 

U.S. families held direct and indirect stock holdings in 2019, up 15 percent from 2010.1 Total 

net assets invested in registered investment companies have grown by more than 80 percent 

since 2015.2

The FY 2023 request would allow the SEC to address several key priority areas that will affect 

its resource needs going forward.

Initial Public Offerings and Special Purpose Acquisition Companies

The wave in traditional IPOs, along with the unprecedented surge in SPACs, has placed 

increasing demands on the SEC’s resources. Further, the staff has been devoting significant 

resources to addressing emerging issues in a variety of areas, including climate-related risk 

disclosures, supply chain and other pandemic-related issues, and legal and accounting issues 

presented by registrants engaged in crypto-asset businesses. For example, the Division of 

Corporation Finance has seen a surge in transactional work related to IPOs and SPACs, 

including the offerings presenting novel legal and accounting issues. The staff have observed 

IPO activity increase from over 700 IPOs in FY 2020 to over 2,000 IPOs in FY 2021, a 177 

percent increase.3

 Many of these IPOs involved SPACs, so it is reasonable to expect a high 

volume of de-SPAC transactions for review in the coming years, and as many as 500 SPACs 

are currently searching for a target. 

Private Funds

There has been significant growth in the number of private funds managed by SEC-registered 

investment advisers, in particular private equity and venture capital funds. There are 

approximately 19,000 private equity funds, an increase of more than 60 percent in the last 

five years. In addition, the number of venture capital funds grew to more than 2,000, an 

increase of approximately 151 percent. The size of these funds has also grown, with reported 

gross fund assets increasing by 122 percent in private equity funds and 200 percent in venture 

capital funds over that period. 

1 Data drawn from the public version of triennial Survey of Consumer Finances (SCF): https://www.federalreserve.gov/econres/scfindex.

htm. The SCF is sponsored by the Board of Governors of the Federal Reserve System with the cooperation of the U.S. Department of the 

Treasury. The 2019 SCF is the most recent survey. 

2 See Investment Company Institute, “2021 Investment Company Fact Book,” available at https://www.ici.org/system/files/2021-05/2021_

factbook.pdf, and the statistics, available at https://www.ici.org/statistics. 

3 The data are based on the IPOs filed with the SEC during the fiscal year.
4 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

As these figures grow, the agency’s workload to review disclosures of investment risks and conflicts of interest, fees and expenses, liquidity, valuation of assets, and controls around material 

non-public information grows commensurately. The SEC also will need additional enforcement and examination staff to identify and address violative conduct across a larger industry.

Crypto-Assets

The crypto token asset class has grown significantly in scale and valuations over the last five 

years. There are many challenges for investor protection in these markets. As of February 

2022, this asset class purportedly was worth about $2 trillion, with 87 tokens worth at least 

$1 billion each and 1,784 with at least a $1 million market capitalization.4 This asset class 

is prone to fraud, scams, and abuse in certain applications, and in many cases, investors are 

unable to get the complete information they deserve. Many tokens may be securities, and they 

are sometimes offered or sold without required registration, disclosures, or market oversight. 

This leaves prices open to manipulation and investors vulnerable. Such products are subject 

to the securities laws and must comply with the SEC’s securities regime. Our staff continue to 

protect investors in the case of unregistered or fraudulent sales of securities. 

Furthermore, the world of crypto finance now has platforms where people can trade tokens 

and other venues where people can lend tokens. These platforms may also implicate the 

securities laws. The American public is buying, selling, and lending crypto on these so-called 

decentralized finance (DeFi) platforms, and they present significant challenges for investor 

protection and market integrity. 

Financial Technology

While financial technology (fintech) start-ups enable greater access and growth to our capital 

markets, they also bring new competitors into the markets. At the same time, they can put 

additional demands on SEC resources—not only in examinations and enforcement matters, 

but also in new rulemakings and policy areas. These new business models and technologies 

raise a variety of policy questions around gamification, behavioral prompts, the use of 

predictive data analytics and differential marketing, and more.

4 Numbers as of Feb. 6, 2022. See CoinMarketCap, available at www.coinmarketcap.com. Crypto-asset figures are not audited or reported 

to regulatory authorities.
AGENCY AND MISSION INFORMATION | 5

Agency Use of Data Analytics

As the markets continue to change, the Commission needs to adjust by re-evaluating how we 

assess data and incorporating machine learning and deep learning into our examination and 

enforcement functions. Part of the FY 2023 request would be used to enhance the agency’s 

ability to pursue complex investigations of large financial institutions, which require significant 

resources given the billions of dollars at issue, the size and scale of the institutions, and the 

millions of investors, clients, and others affected. Further, our economy’s reliance on the 

rapidly changing field of data analytics is growing. 

We are starting to see artificial intelligence-based funds, high-frequency traders, and asset 

management platforms, along with predictive tools and sentiment analysis, that require us to 

similarly use data to enhance the self-regulatory organizations’ (SRO) and SEC’s capabilities. 

Further related to data analysis, the Consolidated Audit Trail (CAT) can play a key part in the 

SEC’s response to these trends. The SEC has required national securities exchanges and FINRA 

to track all activity throughout the U.S. markets in National Market System (NMS) securities. 

The data that CAT will provide when implementation is complete, in conjunction with other 

data analytic tools, will significantly enhance the SROs’ and SEC’s capabilities to identify potentially violative conduct and develop data-driven policies. Finally, this request helps to address 

the increased workload of economic impact analyses of proposed rules.

Enhance IT and Cybersecurity

Efficient, effective, and responsible use of data and IT is a crucial focus of the SEC. The SEC 

already is making progress in key areas such as cybersecurity, secure cloud infrastructure, 

and data management. In addition to advancing data analytics as described above, this 

budget request would enable the SEC to implement high-priority initiatives, including: (1) the 

modernization of key legacy systems; (2) the migration of applications to the cloud; (3) the 

improvement of information security and identity management practices, including to comply 

with new cybersecurity requirements; and (4) the enhancement of the resiliency of the SEC 

network and infrastructure. 

For FY 2023, the request seeks an additional $20 million for these IT initiatives and 

includes new technology staff positions in the Office of Information Technology (OIT) to 

provide expertise in cloud computing. The request also would allow OIT to hire personnel 

to strengthen security controls, policies, and procedures, and comply with requirements 

mandated in the recent Executive Order to move the agency toward a “zero trust” approach 

to cybersecurity. In addition, the request would enable divisions to hire product owners to 

support agile development of key agency systems, helping make sure our IT investments are 

yielding the promised value and benefits for agency programs. Our FY 2023 request also 

assumes full use of the Reserve Fund for technology modernization and enhancements. The 

Reserve Fund allows the SEC to commit to important, long-term technology initiatives that 

otherwise would be more difficult to sustain.
6 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

Details of Staffing Request 

For FY 2023, we are seeking to increase our workforce by 400 positions to address the 

priorities laid out above. 

Division of Enforcement (ENF) requests 125 positions. The additional positions would allow 

the following: 44 positions for increased capacity to investigate misconduct and accelerate 

enforcement actions; 34 positions to strengthen our litigation support; 33 positions to bolster 

the capabilities of our Cyber Unit; and 14 positions to provide additional accounting and 

operational support. 

Division of Examinations (EXAMS) requests 90 positions. These will consist primarily of 

examiners who will help EXAMS keep pace with continued industry growth. Specifically, 

the request includes 84 positions for dedicated oversight/exam activities of the following: 

investment advisers (34), broker-dealers with a focus on Regulation Best Interest (25), new 

registrants in swap markets (20), and cybersecurity and market infrastructure (5). Additionally, 

the request includes six positions to support FINRA and MSRB oversight, data analytics, 

outreach, and industry education. 

Division of Corporation Finance (CF) requests 65 positions. Of these, 58 positions would bolster the Disclosure Review Program to assist with review of the significant increase of IPO and 

SPAC filings, provide more robust review of registration statements, and provide prompt and 

thorough responses to registrants. Furthermore, seven positions would support key rulemaking initiatives that the Commission has identified as priorities to strengthen capital markets, 

increase transparency, and safeguard American investors. 

Division of Trading and Markets (TM) requests 20 positions in support of rulemaking and 

enhanced market oversight. Of these, 15 positions would work on implementation of the 

Dodd-Frank Wall Street Reform and Consumer Protection Act Title VII rules, processing of 

inquiries from the public, NMS initiatives and their implementation, oversight of securitybased swaps, and analysis of CAT data, while five positions would support TM oversight 

and rulemaking for non-equity market structure.

Division of Investment Management (IM) requests 13 positions. The request includes four 

positions to support priority agency rulemakings and conduct more frequent Form ADV 

reviews. Additionally, three positions are requested to meet increased industry demand for 

consultation and informal staff guidance on regulatory requirements, while three positions 

would enhance IM’s capacity to perform rapid, detailed analysis of market and regulatory 

data to inform the Commission and inter-regulatory bodies. Finally, three positions would 

be dedicated to the Disclosure Review Office to respond to an increase in workload, 

stemming from increased filings, deeper involvement in rulemakings, and substantially 

more complex products. 
AGENCY AND MISSION INFORMATION | 7

Division of Economic and Risk Analysis (DERA) requests 25 positions, of which 21 would 

be financial economists and research associates to increase capacity for supporting economic 

analyses of policy matters, rulemakings, and enforcement activities. In addition, the request 

would fund two data scientists to provide complex analytical solutions to clients around the 

SEC through the use of artificial intelligence and two data engineers to manage the data in 

DERA’s systems. 

Office of the General Counsel (OGC) requests 17 positions. Of the new positions, 14 would 

address current and planned increases in OGC’s workload, including advising on the Commission’s regulatory initiatives, advising on enforcement and whistleblower matters, defending the 

Commission’s enforcement and regulatory actions, and addressing inquiries on staff’s compliance with professional responsibility obligations. Additionally, three positions are needed 

to respond to the significant increase of workload in the Adjudication group as a result of an 

increasing volume of cases and appeals. 

Other Program Offices collectively request 14 additional positions. Of these, three positions 

would permit the Office of the Chief Accountant to assist with new and complex accounting 

matters, both domestically and internationally, and to assist ENF with accounting-related 

litigation matters. The Office of International Affairs requests six positions to advance the 

Commission’s policy objectives on international regulatory policy matters and support the 

Commission’s leadership role in the International Organization of Securities Commissions. 

Two positions would allow the Office of Investor Education and Advocacy to support 

investor outreach to underserved communities and the Office of the Investor Advocate to 

handle the growing number of investor inquiries for the Ombudsman. Finally, the SEC 

requests two positions for the Office of Credit Ratings to provide staff guidance to nationally 

recognized statistical rating organizations (NRSRO) on Commission rules and conduct annual 

examinations of NRSROs and one position for the Office of Municipal Securities to advise on 

municipal securities matters and conduct outreach with municipal market participants. 

Agency Direction and Administrative Support requests 28 positions. Of these, 11 positions 

would permit OIT to advance the transformation to a cloud-based environment and assess 

the security of division/office systems. Additionally, three positions would enable the EDGAR 

Business Office to enhance outreach to filers and manage data structuring initiatives, and one 

position would assist the Office of the Ethics Counsel with managing its key systems. The 

agency also would dedicate two positions for the Office of Acquisitions to support expanded 

diversity, equity, and inclusion efforts and overall workload increases and two positions for the 

Office of Minority and Women Inclusion and the Office of Equal Employment Opportunity 

to advise divisions and offices on advancing equity. The Office of Public Affairs requests two 

positions to enhance the agency’s external outreach to key stakeholder groups. Finally, the 

Office of the Chief Operating Officer requests seven positions for its component offices to 

support climate-related disclosure and reporting, handle increased human resources needs—

including the new paid internship program described below—and support budget analysis 

and internal controls. 
8 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

Office of Inspector General (OIG) requests three positions, which will significantly enhance 

the quality of the OIG’s reviews of the SEC’s programs and operations and investigations of 

alleged fraud, waste, and abuse therein.

SEC Student Intern and Honors Programs 

The FY 2023 request would fund paid internship and honors programs under SEC Scholars, 

SEC Honors, and the Pathways program. Far too often, those with financial obligations 

cannot afford to work unpaid. Through these programs, we hope to foster a more diverse 

and inclusive federal workforce and provide opportunities for those who want to serve. 

Real Property Leasing 

Finally, the FY 2023 request would support the SEC’s ongoing efforts, in partnership with the 

General Services Administration, to manage the new construction project and move for the 

successor lease for the agency’s Washington, DC, headquarters office. As requested in the past, 

the SEC proposes to offset these costs with fee collections and return any unused amounts to 

fee payers after project completion. 

GARY GENSLER

Chair

March 28, 2022
AGENCY AND MISSION INFORMATION | 9

Our Mission 

To protect investors, maintain fair, orderly, and efficient markets, and facilitate 

capital formation.

Our Vision 

To promote capital markets that inspire public confidence and provide a diverse 

array of financial opportunities to retail and institutional investors, entrepreneurs, 

public companies and other market participants.

Our Values

INTEGRITY

We inspire public confidence and trust by adhering to the highest ethical standards.

EXCELLENCE

We are committed to excellence in pursuit of our mission on behalf of the 

American public.

ACCOUNTABILITY

We embrace our responsibilities and hold ourselves accountable to the 

American public.

TEAMWORK

We recognize that success depends on a skilled, diverse, coordinated 

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

and communication.

FAIRNESS

We treat investors, market participants, and others fairly and in accordance 

with the law.

EFFECTIVENESS

We strive for innovative, flexible, and pragmatic regulatory approaches that 

achieve our goals and recognize the ever-changing nature of our capital markets. 

MISSION, VISION, VALUES, AND GOALS
10 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

Strategic Goals and Strategic Initiatives

INVESTORS

STRATEGIC GOAL 1

Focus on the long-term interests of our Main Street investors. 

Strategic Initiative 1.1: Enhance our understanding of the channels retail and institutional 

investors use to access our capital markets to more effectively tailor our policy initiatives.

Strategic Initiative 1.2: Enhance our outreach, education, and consultation efforts, including in 

ways that are reflective of the diversity of investors and businesses. 

Strategic Initiative 1.3: Pursue enforcement and examination initiatives focused on identifying 

and addressing misconduct that impacts retail investors.

Strategic Initiative 1.4: Modernize design, delivery, and content of disclosure so investors, 

including in particular retail investors, can access readable, useful, and timely information to 

make informed investment decisions.

Strategic Initiative 1.5: Identify ways to increase the number and range of long-term, 

cost-effective investment options available to retail investors, including by expanding the 

number of companies that are SEC-registered and exchange-listed. 

INNOVATION

STRATEGIC GOAL 2

Recognize significant developments and trends in our evolving capital 

markets and adjust our efforts to ensure we are effectively allocating 

our resources. 

Strategic Initiative 2.1: Expand market knowledge and oversight capabilities to identify, 

understand, analyze, and respond effectively to market developments and risks.

Strategic Initiative 2.2: Identify, and take steps to address, existing SEC rules and approaches 

that are outdated.

Strategic Initiative 2.3: Examine strategies to address cyber and other system and infrastructure 

risks faced by our capital markets and our market participants.

Strategic Initiative 2.4: Promote agency preparedness and emergency response capabilities.
AGENCY AND MISSION INFORMATION | 11

PERFORMANCE STRATEGIC GOAL 3

Elevate the SEC’s performance by enhancing our analytical 

capabilities and human capital development. 

Strategic Initiative 3.1: Focus on the SEC’s workforce to increase our capabilities, leverage our 

shared commitment to investors, and promote diversity, inclusion, and equality of opportunity 

among the agency’s staff.

Strategic Initiative 3.2: Expand the use of risk and data analytics to inform how we set 

regulatory priorities and focus staff resources, including developing a data management 

program that treats data as an SEC-wide resource with appropriate data protections, 

enabling rigorous analysis at reduced cost.

Strategic Initiative 3.3: Enhance our analytics of market and industry data to prevent, detect, 

and prosecute improper behavior.

Strategic Initiative 3.4: Enhance the agency’s internal control and risk management capabilities, 

including developing a robust and resilient program for dealing with threats to the security, 

integrity, and availability of the SEC’s systems and sensitive data.

Strategic Initiative 3.5: Promote collaboration within and across SEC offices to ensure we are 

communicating effectively across the agency, including through evaluation of key internal 

processes that require significant collaboration.
12 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

HISTORY AND PURPOSE

1 More information about the Securities Act of 1933 can be found at SEC.gov/about/laws/sa33.pdf

2 More information about the Securities Exchange Act of 1934 can be found at SEC.gov/about/laws/sea34.pdf

3 More information about the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 can be found at SEC.gov/about/laws/

wallstreetreform-cpa.pdf

History

During the peak of the Great Depression, Congress passed the Securities Act of 19331 (Securities Act) and the Securities Exchange Act of 19342

 (Securities Exchange Act), which established 

the SEC. These laws were designed to regulate the financial markets and restore investor 

confidence in U.S. capital markets by providing investors and the markets with reliable information and clear rules to ensure honest dealings. The main purpose of these laws was to ensure 

the following:

• Companies that publicly offer securities for investment dollars are forthcoming and transparent about their businesses, the securities they are selling, and the risks involved with 

investing; and

• People who sell and trade securities—brokers, dealers, and exchanges—treat investors fairly 

and honestly.

Purpose

The SEC is responsible for overseeing the nation’s securities markets and certain primary 

participants, including broker-dealers, investment companies, investment advisers, clearing 

agencies, transfer agents, credit rating agencies, and securities exchanges, as well as 

organizations such as FINRA, MSRB, and PCAOB. Under the Dodd-Frank Wall Street 

Reform and Consumer Protection Act of 20103 (Dodd-Frank Act), the agency’s jurisdiction 

was expanded to include certain participants in the derivatives markets, private fund advisers, 

and municipal advisors.

Each year, the SEC brings hundreds of civil enforcement actions against individuals and 

companies for violation of securities laws. Examples of infractions are insider trading, 

accounting fraud, market manipulation, and providing false or misleading information 

about securities and/or the issuing companies.

To help investors stay informed, the SEC offers the public a wealth of educational information 

on its website at Investor.gov, as well as through an online database of disclosure documents 

that public companies and other market participants are required to file with the SEC. These 

can be found at: SEC.gov/edgar/searchedgar/companysearch.html.
AGENCY AND MISSION INFORMATION | 13

ORGANIZATIONAL STRUCTURE 

AND RESOURCES

The SEC is an independent federal agency, established pursuant to the Securities Exchange 

Act of 1934, headed by a bipartisan, five-member Commission. The Commissioners are 

appointed by the President and confirmed by the Senate. The President designates one of the 

Commissioners as the Chair. The five Commission members act jointly to set and enforce 

the rules that govern the securities markets and its participants. The Chair is responsible for 

overseeing the executive and administrative functions of the agency and its more than 4,500 

staff members. 

Office Locations 

The SEC’s headquarters are in Washington, DC, and the agency has 11 regional offices 

located throughout the country. The regional offices are responsible for investigating and 

litigating potential violations of the securities laws. The regional offices also have enforcement 

and examination staff to inspect regulated entities such as investment advisers, investment 

companies, and broker-dealers. The following graphic illustrates the locations of, and specific 

areas within, each of the regional offices.

Los Angeles 

Regional Office

Southern California,* Arizona, 

Guam, Hawaii, Nevada

SEC Headquarters San Francisco 

Regional Office

Northern California,* 

Alaska, Idaho, Montana, 

Oregon, Washington 

Salt Lake 

Regional Office

Utah

Denver 

Regional Office

Colorado, Kansas 

(Exam Program), 

Nebraska, New Mexico, 

North Dakota, South 

Dakota, Wyoming

Fort Worth 

Regional Office

Texas, Arkansas, 

Kansas, Oklahoma

Chicago 

Regional Office

Illinois, Indiana, Iowa, 

Kentucky, Michigan, 

Minnesota, Missouri, 

Ohio, Wisconsin

Boston Regional Office

Massachusetts, Connecticut, 

Maine, New Hampshire, 

Rhode Island, Vermont 

Atlanta Regional Office

Georgia, Alabama, North Carolina, 

South Carolina, Tennessee

Miami Regional Office

Florida, Louisiana, Mississippi, 

Puerto Rico, U.S. Virgin Islands 

New York 

Regional Office

New York, New Jersey

Philadelphia 

Regional Office

Pennsylvania, Delaware, 

District of Columbia, Maryland, 

Virginia, West Virginia

* Northern California includes ZIP codes 93600 and above, and 93200–93299

 Southern California includes ZIP codes 93599 and below, except 93200–93299
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Positions and Full-Time Equivalents (FTE) by Program....................................................................... 16

Obligations by Object Class.....................................................................................................................................17

Strategic Goal and Program.................................................................................................................................... 18

Request Summary of Changes............................................................................................................................. 19

FY 2023 Budget 

Request Tables
16 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

POSITIONS AND FULL-TIME 

EQUIVALENTS (FTE) BY PROGRAM

FY 2021 Actual

FY 2022 

Continuing Resolution 

(Annualized) FY 2023 Request

Positions FTE Positions FTE Positions FTE

Enforcement 1,366 1,315 1,366 1,302 1,499 1,365

Examinations 1,113 1,061 1,113 1,060 1,212 1,100

Corporation Finance 423 388 423 398 500 438

Trading and Markets 284 256 284 263 314 290

Investment Management 220 200 221 208 239 222

Economic and Risk Analysis 159 140 163 147 190 174

General Counsel 156 138 157 144 175 161

Other Program Offices

Chief Accountant 48 43 48 44 51 46

Investor Education and 

Advocacy 44 44 44 43 45 43

International Affairs 53 48 53 49 59 51

Administrative Law Judges 12 10 12 9 12 11

Investor Advocate 15 12 15 13 17 15

Credit Ratings 46 43 46 43 48 44

Municipal Securities 10 9 10 9 11 10

Advocate for Small Business 

Capital Formation 11 9 11 9 12 12

Strategic Hub for Innovation

and Financial Technology 8 4 8 7 8 8

Subtotal 247 222 247 226 263 240

Agency Direction and Administrative Support

Executive Staff 34 21 34 28 34 30

Public Affairs 24 20 24 23 26 25

Secretary 26 21 26 23 26 25

Chief Operating Officer 37 30 39 35 40 38

Financial Management 90 88 90 85 92 87

Information Technology 216 189 217 206 228 220

Human Resources 118 107 119 110 123 113

Acquisitions 57 55 57 55 59 55

Support Operations 94 87 94 88 95 91

EDGAR Business Office 34 31 34 33 37 34

Ethics Counsel 19 19 19 19 20 19

Minority and Women Inclusion 12 9 12 12 14 13

Equal Employment Opportunity 13 12 13 11 14 13

Subtotal 774 689 778 728 808 763

Inspector General 55 50 55 52 61 55

Total Positions and FTE 4,797 4,459 4,807 4,528 5,261 4,808
FY 2023 BUDGET REQUEST TABLES | 17

OBLIGATIONS BY OBJECT CLASS

1 Obligations reported here differ from those shown in the President’s Budget Appendix because they include activity only in the stated 

fiscal year.

2 The FY 2022 Continuing Resolution (Annualized) column includes the FY 2021 request for funds to support headquarters move-related 

costs and potential build-out costs associated with San Francisco Regional Office lease replacement, but does not include the amount 

requested in the FY 2022 Congressional Justification for Fort Worth Regional Office potential move-related costs.

(DOLLARS IN THOUSANDS) FY 2021 Actual 1

FY 2022 

Continuing Resolution

(Annualized)2 FY 2023 Request

Personnel Compensation and Benefits

Personnel Compensation (11.0) $ 941,755 $ 956,867 $ 1,092,015

Personnel Benefits (12.0) 342,694 351,243 410,468

Subtotal, Cost of Compensation 

and Benefits $ 1,284,449 $ 1,308,110 $ 1,502,483

Other Expenses

Benefits for Former Personnel (13.0) 3,223 50 51

Travel and Transportation of Persons (21.0) 344 2,078 12,100

Transportation of Things (22.0) 108 251 257

Rent, Communications, and Utilities (23.0) 130,094 114,768 126,984

Printing and Reproduction (24.0) 8,016 3,028 9,067

Other Contractual Services (25.0) 490,492 441,163 460,148

Supplies and Materials (26.0) 1,049 1,090 1,205

Equipment (31.0) 33,451 56,214 60,143

Land and Structures (32.0) 348 125 641

Insurance Claims and Indemnities (42.0) 137 901 921

Subtotal, Cost of Other Expenses 667,261 619,668 671,517

Subtotal, Obligations $ 1,951,710 $ 1,927,778 $ 2,174,000

Budget Authority Used to Liquidate 

Prior Obligations for Deficient Leases, 

per an October 3, 2011, Report from 

the Comptroller General 2,296

Total Budget Authority $ 1,954,006 $ 1,927,778 $ 2,174,000

Less: Anticipated Carryover of Prior 

Year Unobligated Balances (7,943)

Less: Anticipated Recoveries of Prior 

Year Obligations (25,000) (25,000)

Request for SEC Operations $ 1,954,006 $ 1,894,835 $ 2,149,000

Headquarters Move-Related Costs 18,650 57,405

Potential Build-out Costs Associated with San 

Francisco Regional Office Lease Replacement 12,677
18 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

STRATEGIC GOAL AND PROGRAM

1 Obligations reported here differ from those shown in the President’s Budget Appendix because they include activity only in the stated 

fiscal year.

2 The FY 2022 Continuing Resolution (Annualized) column includes the FY 2021 request for funds to support headquarters move-related 

costs and potential build-out costs associated with San Francisco Regional Office lease replacement, but does not include the amount 

requested in the FY 2022 Congressional Justification for Fort Worth Regional Office potential move-related costs.

(DOLLARS IN THOUSANDS) FY 2023 Request

SEC Program

FY 2021

Actual1

FY 2022

Continuing 

Resolution 

(Annualized)2

Goal 1 

Investors

Goal 2

Innovation

Goal 3

Performance

FY 2023

Request

Enforcement $ 627,556 $ 613,013 $ 632,737 $ 20,411 $ 27,215 $ 680,363 

Examinations 447,801 437,874 438,321 24,351 24,351 487,023

Corporation Finance 172,329 166,102 133,374 40,012 17,148 190,534

Trading and Markets 110,810 109,754 12,671 88,694 25,341 126,706

Investment Management 84,682 85,301 52,894 25,004 18,273 96,171

Economic and Risk Analysis 69,696 69,717 49,738 19,066 14,093 82,897

General Counsel 60,570 60,158 33,557 15,380 20,973 69,910

Other Program Offices 99,351 99,411 65,184 32,918 14,825 112,927

Agency Direction and 

Administrative Support 258,085 264,890 18,413 19,332 265,086 302,832

Inspector General 20,829 21,559 7,391 7,391 9,855 24,638

Subtotal, Obligations $ 1,951,710 $ 1,927,778 $ 1,444,280 $ 292,560 $ 437,159 $ 2,174,000 

Budget Authority Used to 

Liquidate Prior Obligations 

for Deficient Leases, 

per an October 3, 

2011, Report from the 

Comptroller General 2,296

Total Budget Authority $ 1,954,006 $ 1,927,778 $ 2,174,000 

Less: Anticipated Carryover 

of Prior Year Unobligated 

Balances (7,943)

Less: Anticipated Recoveries 

of Prior Year Obligations (25,000) (25,000)

Request for SEC 

Operations $ 1,894,835 $ 2,149,000

Headquarters Move-Related 

Costs 18,650 57,405

Potential Build-out Costs 

Associated with San 

Francisco Regional Office 

Lease Replacement 12,677
FY 2023 BUDGET REQUEST TABLES | 19

REQUEST SUMMARY OF CHANGES

 (DOLLARS IN THOUSANDS) Positions FTE Amount

FY 2022 Continuing Resolution (Annualized) 4,807 4,528 $ 1,927,778 

FY 2023 Base Changes 

Annualization of Prior Year Staffing Actions 54 157 44,541

Other Compensation Adjustments 108,993 

Net Changes in Non-Compensation Costs 30,549 

Subtotal, Base Changes 54 157 $ 184,083 

FY 2023 Current Services Level 4,861 4,685 $ 2,111,861 

FY 2023 Program Increases

Addition of 400 Positions (123 FTE):

 Enforcement 125 38 

 Examinations 90 32 

 Corporation Finance 65 21 

 Trading and Markets 20 5 

 Investment Management 13 4 

 Economic and Risk Analysis 25 5 

 General Counsel 17 4 

 Other Program Offices 14 4 

 Agency Direction and Administrative Support 28 9 

 Inspector General 3 1 

Subtotal, Staffing Increases 400 123 $ 42,139 

 Increase for Technology $ 20,000 

Subtotal, Program Increases 400 123 $ 62,139

FY 2023 Operational Budget Request 5,261 4,808 $ 2,174,000 

Less: Anticipated Carryover of Prior Year Unobligated Balances 

Less: Anticipated Recoveries of Prior Year Obligations (25,000)

FY 2023 Request for SEC Operations 5,261 4,808 $ 2,149,000 

Headquarters Move-Related Costs 57,405 
This page intentionally left blank
APPROPRIATIONS LANGUAGE | 21

FY 2023 Appropriations 

Language

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

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

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

expenses, $2,149,000,000, to remain available until expended; of which not less than 

$18,979,000 shall be for the Office of Inspector General; of which not to exceed $275,000 

shall be available for a permanent secretariat for the International Organization of Securities 

Commissions; and of which not to exceed $100,000 shall be available for expenses for 

consultations and meetings hosted by the Commission with foreign governmental and other 

regulatory officials, members of their delegations and staffs to exchange views concerning 

securities matters, such expenses to include necessary logistic and administrative expenses and 

the expenses of Commission staff and foreign invitees in attendance including: (1) incidental 

expenses such as meals; (2) travel and transportation; and (3) related lodging or subsistence.

In addition to the foregoing appropriation, for move, replication, and related costs associated 

with a replacement lease for the Commission’s District of Columbia headquarters facilities, not 

to exceed $57,405,000, to remain available until expended.

For purposes of calculating the fee rate under section 31(j) of the Securities Exchange Act of 

1934 (15 U.S.C. 78ee(j)) for fiscal year 2023, all amounts appropriated under this heading 

shall be deemed to be the regular appropriation to the Commission for fiscal year 2023: 

Provided, That fees and charges authorized by section 31 of the Securities Exchange Act of 

1934 (15 U.S.C. 78ee) shall be credited to this account as offsetting collections: Provided 

further, That not to exceed $2,149,000,000 of such offsetting collections shall be available 

until expended for necessary expenses of this account and not to exceed $57,405,000 of 

such offsetting collections shall be available until expended for move, replication, and related 

costs under this heading associated with a replacement lease for the Commission’s District of 
22 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

Columbia headquarters facilities: Provided further, That the total amount appropriated under 

this heading from the general fund for fiscal year 2023 shall be reduced as such offsetting fees 

are received so as to result in a final total fiscal year 2023 appropriation from the general fund 

estimated at not more than $0: Provided further, That if any amount of the appropriation for 

move, replication, and related costs associated with a replacement lease for the Commission’s 

District of Columbia headquarters facilities is subsequently de-obligated by the Commission, 

such amount that was derived from the general fund shall be returned to the general fund, and 

such amounts that were derived from fees or assessments collected for such purpose shall be 

paid to each national securities exchange and national securities association, respectively, in 

proportion to any fees or assessments paid by such national securities exchange or national 

securities association under section 31 of the Securities Exchange Act of 1934 (15 U.S.C. 78ee) 

in fiscal year 2023.
Division of Enforcement.............................................................................................................................................24

Division of Examinations............................................................................................................................................26

Division of Corporation Finance ...........................................................................................................................29

Division of Trading and Markets ............................................................................................................................31

Division of Investment Management................................................................................................................36

Division of Economic and Risk Analysis..........................................................................................................40

Office of the General Counsel................................................................................................................................43

Other Program Offices.................................................................................................................................................46

Office of the Chief Accountant ..................................................................................................................47

Office of Investor Education and Advocacy....................................................................................... 50

Office of International Affairs ......................................................................................................................51

Office of Administrative Law Judges......................................................................................................54

Office of the Investor Advocate.................................................................................................................55

Office of Credit Ratings................................................................................................................................. 58

Office of Municipal Securities....................................................................................................................60

Office of the Advocate for Small Business Capital Formation.................................................. 62

Strategic Hub for Innovation and Financial Technology..............................................................64

Agency Direction and Administrative Support.........................................................................................66

Executive Staff.................................................................................................................................................. 67

Office of Public Affairs...................................................................................................................................68

Office of the Secretary.................................................................................................................................. 70

Office of the Chief Operating Officer......................................................................................................71

Office of the Ethics Counsel....................................................................................................................... 87

Office of Minority and Women Inclusion.............................................................................................89

Office of Equal Employment Opportunity ...........................................................................................91

Office of Inspector General......................................................................................................................................93

FY 2023 Budget 

Request by Program
24 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

DIVISION OF ENFORCEMENT

The Division of Enforcement (ENF) is critical to the Commission’s ability to fulfill its threepart mission: protect investors, maintain fair, orderly, and efficient markets, and facilitate 

capital formation. ENF’s efforts to uncover misconduct and deter and punish securities 

law violators are critical to safeguarding millions of investors and instilling confidence 

in the integrity of the U.S. markets. Each year, on the basis of ENF investigations and 

recommendations, the Commission brings hundreds of civil and administrative enforcement 

actions against individuals and entities for fraud, financial and accounting irregularities and 

misstatements, misconduct by investment professionals and regulated entities, and other 

violations. The Commission also pursues enforcement actions against wrongdoers in new and 

emerging areas, including crypto-asset markets, cyber-related risks, the environmental, social, 

and governance space, and special purpose acquisition companies. The meaningful remedies 

that the Commission obtains through enforcement actions deter future wrongdoing and, when 

possible, deprive violators of the fruits of their misconduct. When the Commission obtains 

disgorgement of ill-gotten gains, it is often able to return such funds to harmed investors. 

ENF also seeks bars and suspensions that prevent wrongdoers from working in the securities 

industry or being officers and directors of public companies.

ENF brings meaningful cases that cover the entire securities waterfront, protect investors 

in new and emerging areas, hold wrongdoers accountable with meaningful remedies, and 

bolster the public’s trust in financial markets. ENF is guided by five core principles: (1) focus 

on protecting investors; (2) focus on individual accountability, including gatekeepers; (3) keep 

pace with technological change; (4) impose remedies that most effectively further enforcement 

goals; and (5) constantly assess the allocation of SEC resources. These principles drive ENF 

to address misconduct targeting investors; risks posed by cyber-related misconduct; issues 

raised by the activities of investment advisers, broker-dealers, and other registrants; financial 

reporting and disclosure issues involving public companies, their executives, and their auditors; 

misconduct by gatekeepers; and insider trading and market abuse. These areas are priorities 

for ENF, and the division will continue to pursue cases and advance efforts to protect investors 

and the integrity of the market.
FY 2023 BUDGET REQUEST BY PROGRAM | 25

FY 2023 Request

ENF requests 125 additional positions to enhance the division’s ability to timely pursue the 

wide variety of misconduct within the SEC’s remit. They will also strengthen ENF’s capabilities 

to investigate new and emerging issues, including crypto-asset markets, cyber-related risks, 

and the environmental, social, and governance space. Finally, it is expected that the number 

of litigated cases will continue to rise as ENF increasingly holds wrongdoers accountable for 

their misconduct with more meaningful and, in some instances, escalating sanctions. ENF 

requires additional resources to ensure that it has an adequate number of attorneys to staff the 

increasing number of litigated cases.

(DOLLARS IN THOUSANDS)

FY 2021

Actual

FY 2022 

Annualized CR

FY 2023

Request

Full-Time Equivalents 1,315 1,302 1,365 

Cost:

Salaries and Benefits $ 390,289 $ 389,692 $ 439,215

Non-Personnel Expenses 237,267 223,321 241,148

Total Costs $ 627,556 $ 613,013 $ 680,363

Totals may not appear to sum from detail lines due to rounding of actual values

Workload Data

Activity

FY 2021

Actual

FY 2022

Estimate

FY 2023

Request

Intelligence Analysis

Investor Tips and Complaints 46,000 46,000 40,000

Matters Under Inquiry Opened 726 750 760

Investigations

Opened 867 895 910

Ongoing at End of Year 1,452 1,495 1,525

Proceedings

Administrative

Opened 471 485 495

Pending at End of Year 1,204 1,240 1,265

Civil Litigation

Opened 226 235 240

Pending at End of Year 1,944 2,000 2,040
26 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

DIVISION OF EXAMINATIONS

The Division of Examinations (EXAMS) maintains a critical presence among market 

participants by annually conducting thousands of exams that provide timely, accurate, and 

reliable information that assists the SEC in fulfilling its mission to protect investors, maintain 

fair, orderly, and efficient markets, and facilitate capital formation. The results of the division’s 

examinations are used by the SEC to inform rulemaking initiatives, identify and monitor risks, 

improve industry practices, and pursue misconduct.

The division’s risk-based program is designed to focus its resources on those firms, market 

participants, and practices that pose the greatest potential risk of securities laws violations that 

can harm investors and the markets. During FY 2023, EXAMS will continue to emphasize the 

protection of working families, particularly seniors and individuals saving for retirement. The 

division will focus on key issues including cyber and information security and compliance with 

recently adopted rules related to standards of care (including Regulation Best Interest), as well 

as additional practices that represent significant risks to retail investors such as deceptive sales 

practices, conflicts of interest, and elder abuse. 

At the beginning of FY 2023, EXAMS anticipates that roughly 1,000 exam staff will be 

responsible for overseeing:

• more than 15,000 investment advisers with approximately $125 trillion in assets 

under management; 

• over 750 investment company complexes managing nearly 15,000 investment 

company portfolios; 

• over 3,500 broker-dealers with more than 150,000 branch offices; 

• approximately 520 municipal advisors; and

• roughly 400 transfer agents. 

EXAMS will also oversee 24 national securities exchanges and at least 9 entities that provide 

clearing agency functions—including 4 that have been deemed systemically important—as well 

as funding portals, the Public Company Accounting Oversight Board (PCAOB), the Municipal 

Securities Rulemaking Board (MSRB), the Securities Investor Protection Corporation (SIPC), and 

the Financial Industry Regulatory Authority (FINRA). Finally, several new registrant categories, 

including security-based swap dealers, security-based swap data repositories, and security-based 

swap execution facilities, will be subject to examinations and will require resources. 
FY 2023 BUDGET REQUEST BY PROGRAM | 27

FY 2023 Request

EXAMS requests 90 positions to focus on critical division priorities. The division remains 

significantly impacted by a rapidly evolving and growing industry. 

Additional resources are critical and necessary to help EXAMS address the ongoing disparity 

between the number of exam staff and the size of the SEC-regulated community. Most 

importantly, these additional resources will augment efforts to: (1) protect working families 

and retail investors; (2) examine new categories of regulated entities; (3) address critical risks 

such as the resiliency of clearing agencies, information security, and anti-money laundering; 

and (4) further address the growing number, size, and complexity of SEC-registered firms. 

More specifically, a majority of the requested resources will focus on examinations of 

investment advisers and broker-dealers, as these entities are critical market participants 

interacting with a rapidly growing retail sector. In fact, the largest increase in registered 

entities over the last five years has occurred in the investment management industry, with the 

population of investment advisers growing by over 2,500 and the assets managed by these 

entities increasing by nearly $50 trillion. The industry is also evolving as investment advisers, 

including more than 5,000 advisers to private funds, are developing more sophisticated trading 

and investment strategies. In the broker-dealer industry, market volatility events in the past 

year highlighted the sharp increase in retail investor trading. Industry development—including 

zero commissions, fractional shares trading, and technological features offered through digital 

engagement practice—had a significant impact on retail trading practices. The requested 

resources will help the SEC keep pace with this growth and focus on critical risk areas 

impacting retail investors.

Additionally, the request will focus on helping the program address new regulatory 

responsibilities in the security-based swap market. As a result of recent legislation and related 

rulemaking, EXAMS will have examination and monitoring responsibilities in FY 2023 for 

several new categories of registrants, including security-based swap dealers, security-based 

swap data repositories, and security-based swap execution facilities. These new registrants 

and responsibilities will require staffing resources with specialized knowledge and expertise. 
28 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

(DOLLARS IN THOUSANDS)

FY 2021

Actual

FY 2022 

Annualized CR

FY 2023

Request

Full-Time Equivalents 1,061 1,060 1,100 

Cost:

Salaries and Benefits $ 300,896 $ 301,832 $ 338,193

Non-Personnel Expenses 146,905 136,041 148,830

Total Costs $ 447,801 $ 437,874 $ 487,023

Totals may not appear to sum from detail lines due to rounding of actual values

Workload Data

Activity

FY 2021

Actual

FY 2022

Estimate

FY 2023

Request

Investment Adviser Examinations 2,251 2,283 2,428

Investment Company Examinations 

(includes administrators) 129 125 126

Broker-Dealer Examinations 333 320 360

Transfer Agent Examinations 51 47 48

Municipal Advisor Examinations 69 48 48

Market Oversight Inspections1 182 193 192

Clearing Agency Examinations 22 23 19

Funding Portal Examinations 3 3 4

Security-Based Swap Entity Examinations — 8 24

1 Market Oversight Inspections primarily include examinations and inspections of FINRA and national securities exchanges.
FY 2023 BUDGET REQUEST BY PROGRAM | 29

DIVISION OF CORPORATION FINANCE

In support of the Commission’s mission to protect investors, maintain fair, orderly, and 

efficient markets, and facilitate capital formation, the Division of Corporation Finance 

(CF) seeks to ensure that investors have access to material information in order to make 

informed investment decisions when a company offers its securities to the public and on an 

ongoing basis as companies continue to provide information to the marketplace. Through 

its selective review program, CF reviews company filings and provides comments to address 

possible material noncompliance with disclosure and accounting requirements under the 

federal securities laws and to enhance investor protection. CF also makes recommendations 

to the Commission for new or revised rules and the elimination of duplicative or outdated 

rules relating to the disclosure requirements for reporting companies and exemptions from 

registration and provides interpretive advice to companies on SEC rules and forms.

Disclosure Review Program

Through the division’s filing review process, CF reviews filings made under the Securities Act 

of 1933 and Securities Exchange Act of 1934 to both monitor and enhance compliance with 

disclosure and accounting requirements. CF focuses its review resources on disclosures that 

appear to be inconsistent with Commission rules or applicable accounting standards, or that 

appear to be materially deficient in their rationale or in clarity.

The division conducts its primary review responsibilities through seven specialized industry 

offices: Energy & Transportation; Finance; Life Sciences; Manufacturing; Real Estate & 

Construction; Technology; and Trade & Services.

Rulemaking and Interpretive Advice

CF continues to assist the Commission with implementing any rules to further investor 

protection, facilitate capital formation, and promote the fair and efficient function of the 

securities markets. As part of this effort, CF is proposing amendments to update disclosure 

requirements and continue the division’s efforts to enhance efficient capital formation. 

The division conducts its rulemaking and interpretative advice through the following policy 

offices: Office of Chief Accountant, Office of Chief Counsel, Office of Rulemaking, and 

Specialized Policy and Disclosure.
30 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

FY 2023 Request

CF requests 65 positions, as listed below.

• Fifty-eight attorney and accountant positions to support the surge of transactional work in 

both traditional and special purpose acquisition company (SPAC) initial public offerings 

(IPO) and backfill losses sustained over the last three years. The 58 new positions will 

allow the division to reinvest in its core disclosure review functions; focus on modernizing 

disclosure requirements while monitoring and enhancing compliance with reporting 

requirements; and improve the management of staff and operations.

• Seven attorney positions to meet its goals and enhance its ongoing efforts to protect 

investors and facilitate capital formation. The new positions will allow CF to better support 

the anticipated 20 rulemakings being considered for recommendation including climate, 

human capital, and executive compensation. The additional positions will increase the 

number of CF staff members solely dedicated to rulemaking. 

(DOLLARS IN THOUSANDS)

FY 2021

Actual

FY 2022 

Annualized CR

FY 2023

Request

Full-Time Equivalents 388 398 438 

Cost:

Salaries and Benefits $ 117,205 $ 118,049 $ 138,650

Non-Personnel Expenses 55,124 48,053 51,884

Total Costs $ 172,329 $ 166,102 $ 190,534

Totals may not appear to sum from detail lines due to rounding of actual values

Workload Data

Activity

FY 2021

Actual

FY 2022

Estimate

FY 2023

Request

Review

Reporting Company Reviews1 2,900 3,000 3,000

Number of New Issuer Reviews

IPO 1933 Act 1,820 1,820 1,820

New 1934 Act 140 140 140

Total Reviews 4,860 4,960 4,960

Rulemaking and Interpretive 

General Advice and Coordination

No-Action Letters/Interpretive Requests 75 75 75

No-Action Letters (Shareholder Proposals) 285 285 285

2

1 The number of active reporting companies has been declining in recent years; however, the trend may be reversing due to the increase 

in IPOs and SPAC merger transactions. CF will continue to fulfill the Sarbanes-Oxley Act review mandate to review the filings of all public 

reporting companies at least once every three years.
FY 2023 BUDGET REQUEST BY PROGRAM | 31

DIVISION OF TRADING AND MARKETS

The Division of Trading and Markets (TM) fulfills the SEC’s mission by establishing and 

maintaining standards for fair, orderly, and efficient markets while fostering investor 

protection and confidence in the markets. To meet the mission requirements, TM is divided 

into different offices which have specific functions and are focused on specific parts of the 

markets. These include: (1) Broker-Dealer Finance/Risk; (2) Chief Counsel; (3) Clearance 

and Settlement; (4) Derivatives Policy and Trading Practices; and (5) Market Supervision. In 

addition, TM has two groups that serve in supporting functions: the Office of Analytics and 

Research and the Office of the Managing Executive.

TM supervises self-regulatory organizations (SRO) and other major market participants in 

the U.S. securities markets, which, as of September 2021, included 24 national securities 

exchanges, 34 National Market System (NMS) stock alternative trading systems (ATS), 

61 non-NMS stock ATSs, over 3,500 broker-dealers, 7 registered clearing agencies, roughly 

404 transfer agents, the Financial Industry Regulatory Authority (FINRA), and various 

securities information processors.

FY 2023 Request

TM requests 20 positions to: (1) help advance the Commission’s rulemaking agenda; 

(2) process interpretive inquiries; (3) address implementation of Title VII rules and provide 

oversight of security-based swaps; (4) address NMS initiatives and their implementation; 

(5) continue in-depth analysis of Consolidated Audit Trail (CAT) data and other market 

monitoring functions; (6) analyze policy and rulemaking related to non-equity market 

structure; and (7) support and facilitate data access and internal sharing requirements, in 

addition to IT transformation initiatives.

TM will dedicate significant resources to Treasury market policy reforms, including 

reconsidering the Commission’s 2020 proposal to bring certain trading platforms into the 

Commission’s regulatory regime. In the equity markets, the division will facilitate greater 

competition and efficiency, considering whether shrinking tick sizes, reevaluating what is 

included in the National Best Bid and Offer, enhancing disclosure, or leveling competition 

between trading venues and wholesalers could increase transparency and competition.
32 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

To enhance market resiliency and market stability, TM will:

• develop a proposal for shortening the settlement cycle; 

• further analyze the need for rulemaking related to conflicts of interest and digital 

engagement practices;

• work toward completing other unfinished Dodd-Frank Act mandates with respect to short 

selling and securities lending; and 

• consider potential rules around aggregate positions, authorized under Exchange Act 

Section 10B, and address anti-manipulation in security-based swaps under Exchange 

Act Section 9j. 

TM staff will also have a role in assessing various data related to security-based swap entities 

and swap data repositories to facilitate regulatory oversight and assist relevant authorities in 

monitoring the security-based swap market and its participants.

The SEC actively engages with counterparts at the U.S. Commodity Futures Trading 

Commission (CFTC) to harmonize the agencies’ respective rules, where appropriate, 

to increase effectiveness and reduce complexity and costs. The SEC’s commitment to 

coordination includes developing recommendations on how to finalize mandates to stand 

up a security-based swap execution facility regime consistent with the CFTC’s regime. 

TM staff is also responsible for implementing recent efforts to address issues in the 

dissemination of market data and access to market data, including enhancing transparency, 

infrastructure, and governance concerning market data distribution and market access.

(DOLLARS IN THOUSANDS)

FY 2021

Actual

FY 2022 

Annualized CR

FY 2023

Request

Full-Time Equivalents 256 263 290 

Cost:

Salaries and Benefits $ 75,046 $ 76,248 $ 90,328

Non-Personnel Expenses 35,764 33,506 36,378

Total Costs $ 110,810 $ 109,754 $ 126,706

Totals may not appear to sum from detail lines due to rounding of actual values
FY 2023 BUDGET REQUEST BY PROGRAM | 33

Workload Data

Activity

FY 2021

Actual

FY 2022

Estimate

FY 2023

Request

Securities Firm Supervision

SRO Proposed Rule Changes Reviewed 186 178 158

SEC Rulemaking, Exemptive Orders, and Interpretive and 

Other Actions 7 10 10

Interpretive, Exemptive, and No-Action Request Letters Closed 11 10 10

Reviews of Potential Enforcement Actions 1,142 1,100 1,100

Notices Filed by SROs Relating to Applications for Admission or 

Continuance as or with an SRO Member Notwithstanding a 

Statutory Disqualification 23 25 25

Provision of Interpretation and Guidance and Responding to 

General Questions 20,376 18,000 17,500

Tips, Complaints, and Referrals (TCR) 289 275 250

Risk Assessment of Broker-Dealers Filing Form 17-H

Firms Assessed 235 235 235

Filings Reviewed 235 235 235

Number of Form 17-H Filings Received 1,175 1,175 1,175

Risk Supervision of Alternative Net Capital Broker-Dealers

Firms Assessed 7 8 8

Filings Reviewed 84 96 96

Risk Supervision of Over-the-Counter Derivatives 

Dealers and Security-Based Swap Dealers

Firms Assessed 7 42 42

Filings Reviewed 84 224 224

Applications Reviewed 2 2 —

Broker-Dealers

Registrants 3,527 3,588 3,827

Registration Applications Filed 213 230 243

Registration Amendments Filed 10,009 10,250 10,300

Registrations Withdrawn or Cancelled 236 263 289

Financial Reports Filed 4,406 4,475 4,614

Security-Based Swap Dealers

Registrants — 50 52

Registration Applications Filed — 50 2

Major Security-Based Swap Participants

Registrants — 2 2

Registration Applications Filed — 2 —

Funding Portals 69 80 95

continued on next page
34 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

Workload Data (continued)

Activity

FY 2021

Actual

FY 2022

Estimate

FY 2023

Request

Security-Based Swap Entities

Substituted Compliance Orders — Proposed 7 8 2

Substituted Compliance Orders — Final 3 8 2

Substituted Compliance — Memorandums of Understanding 1 5 —

Securities Market and Infrastructure Supervision

SRO Proposed Rule Changes and Advance Notices Reviewed 2,092 2,041 1,817

National Market System (NMS) and SRO Plan Amendments 

Filed 12 20 20

SEC Rulemaking, Exemptive Orders, and Interpretive and 

Other Actions 15 15 15

Interpretive, Exemptive, and No-Action Request Letters Closed 17 15 15

Securities Exchanges

Registrants 24 24 25

Registration Applications Filed 1 1 —

Registration Amendments Filed 277 267 278

Registrations Withdrawn or Cancelled — — —

Alternative Trading Systems (ATSs)

ATSs 61 66 71

Initial Operations Reports 21 10 10

Initial Operations Report Amendments 99 104 109

Cessations 3 3 3

Quarterly Reports 225 252 272

NMS Stock ATSs

NMS Stock ATSs 34 36 38

Initial Form ATS-N 8 5 5

Form ATS-N Amendments Filed 226 236 246

Notice of Cessations Filed 4 3 3

Form ATS-R Quarterly Reports 135 143 151

Security-Based Swap Execution Facilities

Registrants — — 5

Registration Applications Filed — — 5

Proposed Rule Changes Filed — — 30

Clearing Agencies (Active)

Registrants 7 10 10

Registration Applications Filed 1 2 2

continued on next page
FY 2023 BUDGET REQUEST BY PROGRAM | 35

Workload Data (continued)

Activity

FY 2021

Actual

FY 2022

Estimate

FY 2023

Request

Security-Based Swap Data Repositories

Registrants 2 3 3

Registration Applications Filed 2 3 3

Transfer Agents

Registrants 328 303 323

Registration Applications Filed 27 35 35

Registration Amendments Filed 167 170 170

Registrations Withdrawn or Cancelled 18 60 15

Annual Reports Filed 273 303 323

Large Traders

Registrants 10,147 10,886 11,580

Registration Applications Filed 1,714 945 900

Registration Amendments Filed 3,089 3,189 3,289

Terminated or Inactive 258 258 258

Annual Reports Filed 4,396 10,147 10,886
36 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

DIVISION OF INVESTMENT 

MANAGEMENT

The Division of Investment Management (IM) works to fulfill the SEC’s mission by 

administering the Investment Company Act of 1940 and the Investment Advisers Act of 

1940 and by developing regulatory policy for open-end management investment companies 

(commonly known as mutual funds), exchange-traded funds (ETF), closed-end funds, variable 

insurance products, other investment companies, and investment advisers. As of October 1, 

2021, over 14,000 SEC-registered funds held approximately $33 trillion in assets. The SEC 

also oversaw more than 14,500 SEC-registered investment advisers reporting more than $110 

trillion in regulatory assets under management. In addition, the SEC receives reports from 

nearly 5,000 SEC-exempt reporting advisers, who report advising over 23,000 private funds 

with over $5 trillion in assets. 

An important part of IM’s mandate is to protect working families investing for their future. 

In FY 2023, IM will continue this work by recommending new rules and amendments to the 

Commission that modernize regulation and ensure investor protection. 

The division is considering the following reforms: 

• Augmented requirements for funds and investment advisers related to environmental, social, 

and governance factors as these investment strategies rapidly increase

• Enhanced reporting and disclosure about private funds or other possible reforms

• Tailored fund shareholder reports to highlight information that is particularly important for 

retail investors to assess and monitor their fund investments 

IM will also continue to review existing rules to make sure they are providing appropriate 

protections in light of trends in the capital markets. For example, IM will consider potential 

reforms for asset managers to address their use of technology and for money market funds 

following events during the COVID-19 market disruption. In addition, the division will 

monitor implementation of recently adopted regulatory changes, including the enhanced 

frameworks for investment adviser marketing, fund valuation practices, and funds’ use 

of derivatives.
FY 2023 BUDGET REQUEST BY PROGRAM | 37

In FY 2023, IM will continue to review and comment on the thousands of prospectuses, proxy 

statements, and other disclosure documents filed by registered investment companies and 

business development companies each year, with an emphasis on filings by new funds, novel 

and complex funds, and principal strategy and risk disclosures. In particular, the focus will be 

on ensuring appropriate protections when reviewing new investment products such as nontransparent ETFs and funds seeking investments in a limited set of crypto-assets. 

The division will also continue to: (1) provide legal guidance to other parts of the agency, 

other regulators, and market participants; (2) consider requests for exemptions from certain 

regulatory requirements; and (3) engage with international regulators on issues important to 

the U.S. asset management industry.

IM is a small division regulating a $110 trillion industry and is committed to increasing 

the efficiency and effectiveness of its programs. In FY 2023, IM expects to do this by: 

(1) increasing analytical capacities to enable more timely analysis of industry data, trends, 

and risks; (2) augmenting outreach capabilities to respond in real-time to market events; 

and (3) enhancing investment adviser policy to reflect growth in the private funds industry 

through targeted Form ADV reviews and Form PF data analysis.

FY 2023 Request 

IM requests 13 new positions for the division, as listed below. 

• Four positions to support priority agency rulemakings and conduct more frequent reviews of 

filings by investment advisers that describe their operations, fees, and investment strategies 

• Three positions to meet increased demand for consultation and informal staff guidance on 

regulatory requirements 

• Three positions to enhance capacity to perform rapid, detailed analysis of market and 

regulatory data to inform the Commission and inter-regulatory bodies 

• Three positions to respond to increased workload in the Disclosure Review Office 

stemming from increased filings, deeper involvement in rulemakings, and substantially 

more complex products 
38 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

(DOLLARS IN THOUSANDS)

FY 2021

Actual

FY 2022 

Annualized CR

FY 2023

Request

Full-Time Equivalents 200 208 222 

Cost:

Salaries and Benefits $ 58,048 $ 59,935 $ 68,978

Non-Personnel Expenses 26,634 25,366 27,193

Total Costs $ 84,682 $ 85,301 $ 96,171

Totals may not appear to sum from detail lines due to rounding of actual values

Workload Data

Activity

FY 2021

Actual

FY 2022

Estimate

FY 2023

Request

Investment Companies1

Number of Investment Companies 3,934 3,968 3,900

Portfolios and Insurance Contracts 18,336 18,328 18,200

Complexes 747 784 775

Assets (dollars in trillions) $ 27.2 $ 32.9 $ 34.7

Investment Advisers1

Number of Investment Advisers 13,810 14,718 15,300

Assets Under Management (dollars in trillions) $ 97.0 $ 112.7 $ 125.0

Disclosure and Accounting Reviews

New Portfolios and Insurance Contracts Filed on 

Registration Statements 2,927 2,650 2,650

New Portfolios and Insurance Contracts Reviewed 2,098 1,825 1,825

Existing Portfolios and Insurance Contracts Filed on 

Post-Effective Amendments2 18,572 18,806 18,806

Existing Portfolios and Insurance Contracts Reviewed3 2,837 3,050 3,050

Portfolios and Insurance Contracts Filed on Proxy Statements 907 850 850

Portfolios and Insurance Contracts Filed on Proxy 

Statements Reviewed 907 850 850

Annual and Periodic Reports Filed 13,407 13,310 13,310

continued on next page

1 Investment company and investment adviser data are reported as of the beginning of the fiscal year. All other data are reported as of the 

end of the fiscal year.

2 Included in post-effective amendments are open-end, closed-end, and unit investment trust (UIT) portfolios.

3 With respect to post-effective amendments, historically over 90 percent of open-end and closed-end portfolios that contain material 

changes in disclosure or in fund operations are reviewed. Amendments to UIT portfolios, because of their repetitive nature, generally are 

not reviewed.
FY 2023 BUDGET REQUEST BY PROGRAM | 39

Workload Data (continued)

Activity

FY 2021 

Actual

FY 2022

Estimate

FY 2023

Request

Annual and Periodic Reports Reviewed 4,002 4,185 5,123

Total Portfolios and Insurance Contracts Reviewed 9,844 9,910 10,848

Disclosure and Accounting Guidance 22 22 22

Targeted Reviews, Sweeps, and Monitoring 27 27 27

Internal Accounting Review Guides 8 8 8

Informal Requests for Accounting Guidance 165 165 165

Interpretive Guidance 

Informal Requests for Guidance 738 1,000 1,000

No-Action Letters Issued 2 2 2

Total Applications Concluded 206 210 210

Exemptive Applications Concluded 103 105 105

Deregistration Matters Reviewed 103 105 105

Tips, Complaints, and Referrals (TCR) 40 45 45

Meetings/Calls/Reviews Related to International Issues 350 350 350

Supervision and Monitoring

EXAMS- and ENF-Related Matters Reviewed 892 1,100 1,300

Analytics Office Outreach 244 175 175

Analytics Office Reports 758 700 700

Data Analysis Requests 252 315 315

Rulemaking

Rulemaking Actions 13 20 20

Business Solutions

Filer and Staff Correspondence Disseminated4 11,388 11,325 11,325

EDGAR Filer Support Requests Processed 1,472 1,464 1,464

Investment Adviser Regulation Depository Filer Support Requests 

Processed 557 554 554

4 Includes correspondence disseminated for IM and the Division of Corporation Finance.
40 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

DIVISION OF ECONOMIC AND 

RISK ANALYSIS

The Division of Economic and Risk Analysis (DERA) advances the Commission’s statutory 

mission to protect investors, maintain fair, orderly, and efficient markets, and facilitate capital 

formation through sound economic analysis and rigorous data analytics.

DERA engages across the entire range of the Commission’s functions, including rulemaking, 

examination, and enforcement. Its multi-disciplinary analyses are informed by research 

insights, and they rely on the knowledge of institutions and practices when examining 

regulatory and risk-related matters. DERA assists the Commission in its efforts to identify, 

analyze, and respond to economic and market issues, including those related to new financial 

products, investment and trading strategies, systemic risk, and fraud. DERA’s data analytics 

work develops a variety of financial and market data analysis tools, supplies economic 

statistics, and promotes data standards.

Organizationally, DERA has four mission areas staffed with experts in economics, data 

science, statistics, accounting, and risk analysis.

• Policy Support. DERA conducts quantitative and qualitative economic analyses informed 

by research insights in support of the SEC’s rulemaking agenda.

• Risk Analysis. DERA performs domestic and international risk analyses of the 

capital markets.

• Examination and Enforcement Support. DERA provides economic and data expertise in 

support of the Commission’s investigations and enforcement-related activities.

• Data Analysis and Management. DERA develops analytic tools and manages economic data 

in support of the entire Commission.

Looking ahead to FY 2023, DERA is positioned to continue: (1) providing high-quality 

economic analyses of Commission rules; (2) analyzing risks facing the capital markets; 

(3) producing up-to-the-minute analyses of the impact of market-wide events; (4) collaborating 

with the Division of Enforcement, focusing on penalties and distributions; and (5) producing 

technological solutions that increase staff productivity.
FY 2023 BUDGET REQUEST BY PROGRAM | 41

FY 2023 Request

DERA requests 25 new positions, of which 21 will be financial economists to increase capacity 

to produce high-quality economic analyses of policy matters, rulemakings, and enforcement 

activities across the agency. Such rules address cybersecurity risk; market structure modernization; short sale disclosure; security-based swaps ownership; the stock loan market; and 

investment funds. Further driving a need for additional resources are projects related to 

security-based swaps, conflicts of interest in securitizations, and special purpose acquisition 

companies, for which DERA’s expertise is crucial. Additional staff will allow the division to 

meet agency demand for its expertise, keep pace with rapidly changing markets, and analyze 

unusual market events and other risks.

As the markets become increasingly automated and reliant on computers and data-based 

analysis, demand for the Commission’s data scientists and engineers has increased. The 

industry and the public are demanding high-quality data and data analytics. Such information 

allows investors to make better informed and timelier decisions. Further, Congress mandated 

that certain information be provided in open machine-readable formats in the Open, Public, 

Electronic, and Necessary Government Data Act. The request includes two data scientists and 

two engineers to help fulfill Congress’ mandate and meet the public’s need for high-quality 

data by working on standardized disclosure taxonomies, data sets, and machine-readable 

access points. This will give the public more timely access to immediately reusable and better 

information about the markets. Further, the data scientists and engineers will work on tools 

and applications used by Commission staff to more efficiently and effectively gather and 

analyze information in support of the Commission’s mission.
42 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

(DOLLARS IN THOUSANDS)

FY 2021

Actual

FY 2022 

Annualized CR

FY 2023

Request

Full-Time Equivalents 140 147 174 

Cost:

Salaries and Benefits $ 39,506 $ 42,827 $ 54,062

Non-Personnel Expenses 30,190 26,890 28,835

Total Costs $ 69,696 $ 69,717 $ 82,897

Totals may not appear to sum from detail lines due to rounding of actual values

Workload Data

(DOLLARS IN THOUSANDS)

FY 2021

Actual

FY 2022

Estimate

FY 2023

Request

Reviews of Commission Rules 102 114 114

Reviews of Self-Regulatory Organization (SRO) Rules 

and Public Company Accounting Oversight Board 

(PCAOB) Filings 61 64 64

Advice on Regulatory, Enforcement, and 

Risk Assessment Issues 3,948 3,980 3,990

Interactive Data Compliance Monitoring 9,061 9,128 9,196

Interactive Data Programs Supported 14 16 17
FY 2023 BUDGET REQUEST BY PROGRAM | 43

OFFICE OF THE GENERAL COUNSEL

The General Counsel serves as the chief legal officer of the Commission and heads the Office 

of the General Counsel (OGC). OGC provides independent legal analysis and advice to the 

Chair, Commissioners, and operating divisions and offices on all aspects of the Commission’s 

activities. OGC also defends the Commission in federal district courts, represents the Commission in appellate matters and amicus curiae filings, and oversees the SEC’s bankruptcy 

program. In addition, OGC represents the Commission and its members and employees at the 

trial and appellate levels when they are parties or witnesses in civil or administrative litigation 

arising from the performance of official functions. OGC also performs a wide variety of other 

legal functions in support of the Commission’s operations.

In FY 2023, OGC anticipates continued work on legislative initiatives to reform the existing 

regulatory structure for the securities markets and the financial services industry. The staff 

of experienced attorneys will handle complex agency and securities law issues, provide legal 

advice on rulemakings and other regulatory initiatives, address legal challenges to rulemakings, 

advise on novel operational issues presented by COVID-19, respond to emerging crypto-asset 

issues, and work to protect the Commission’s identity against cyber-impersonation and other 

deceptive practices. OGC also expects to provide technical assistance to Congress and other 

financial regulatory agencies on numerous legislative initiatives and other matters. OGC will 

continue to manage the agency’s appellate litigation, including appeals related to complex 

enforcement cases and challenges to new rulemakings. OGC will also continue to assist the 

Commission in resolving litigated administrative proceedings set before the Commission, 

appeals from initial decisions issued by the SEC’s administrative law judges, and petitions 

seeking review of actions taken by self-regulatory organizations (SRO). The staff will also 

continue to provide assistance and advice in responding to Congressional requests for information and documents, as well as providing the Commission and operating divisions and 

offices with independent analysis and advice on all enforcement activities, rulemaking releases, 

and whistleblower claim adjudications. 
44 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

FY 2023 Request

OGC requests 17 additional positions. Fourteen positions will address current and planned 

increases in workload, including advising on the Commission’s regulatory initiatives; advising 

on enforcement and whistleblower matters; defending the Commission’s enforcement and 

regulatory actions; and addressing inquiries on staff’s compliance with their professional 

responsibility obligations. The remaining three positions will help OGC respond to the 

significant increase of workload in the Adjudication group as a result of an increasing volume 

of administrative cases and appeals from actions taken by SROs.

More specifically, these additional staff members will enhance OGC’s ability to provide legal 

advice to the Commission and its operating divisions on a regulatory agenda that includes 

complex issues such as climate-related disclosures and digital engagement practices for 

investment advisers, broker-dealers, and advisers to private funds. 

(DOLLARS IN THOUSANDS)

FY 2021

Actual

FY 2022 

Annualized CR

FY 2023

Request

Full-Time Equivalents 138 144 161 

Cost:

Salaries and Benefits $ 41,058 $ 43,263 $ 51,691

Non-Personnel Expenses 19,512 16,894 18,218

Total Costs $ 60,570 $ 60,158 $ 69,910

Totals may not appear to sum from detail lines due to rounding of actual values
FY 2023 BUDGET REQUEST BY PROGRAM | 45

Workload Data

Activity

FY 2021

Actual

FY 2022

Estimate

FY 2023

Request

Appellate Cases 

Open Matters 172 177 182

Adjudicatory Matters

Pending Beginning of Year 343 260 235

Received 182 200 200

Completed 265 225 225

Pending End of Year 260 235 210

Legislation

Testimony 4 10 10

Correspondence with Congress and Others 177 180 180

Legislative Analysis and Technical Assistance 220 250 250

Other 105 110 110

Advisory Services

SEC Statutes 

Analysis of Enforcement Memoranda 2,326 2,200 2,200

Review of Rulemaking and Other Projects 409 400 450

Review of Articles and Speeches 285 300 300

Non-SEC Statutes 

Freedom of Information Act (FOIA)— 

Internal Appeals 645 650 650

Personnel Matters 245 250 254

Procurement Matters 844 875 897

Labor Matters 20 20 20

Attorney Misconduct Investigations 515 530 550

Corporate Reorganization

Petitions Involving Public Investor Interest 30 35 35

Chapter 11 Cases: Appearances 

Filed 21 23 23

Closed 7 20 20

Chapter 11 Cases: Monitored 

Filed 9 12 12

Closed 5 10 10

Disclosure Statement Reviews 130 130 130

Disclosure Statements Commented On 70 70 70

1
46 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

OTHER PROGRAM OFFICES

This section describes the responsibilities and activities of the agency’s smaller program offices:

• Office of the Chief Accountant

• Office of Investor Education and Advocacy

• Office of International Affairs

• Office of Administrative Law Judges

• Office of the Investor Advocate

• Office of Credit Ratings

• Office of Municipal Securities

• Office of the Advocate for Small Business Capital Formation

• Strategic Hub for Innovation and Financial Technology
FY 2023 BUDGET REQUEST BY PROGRAM | 47

OFFICE OF THE CHIEF ACCOUNTANT

The Office of the Chief Accountant (OCA) is responsible for establishing and interpreting 

accounting and auditing policy to enhance the transparency and relevancy of financial 

reporting for investors. The Chief Accountant serves as the principal advisor to the Commission on accounting and auditing matters. OCA works to improve the performance of public 

company financial statement preparers, auditors, and audit committees to ensure that financial 

reporting is decision-useful, relevant, and transparent for the benefit of investors. High-quality 

financial statements are the bedrock of the financial reporting system, establishing a consistent 

and enforceable framework that protects investors; contributing to the fair and efficient 

operation of markets; and promoting capital formation. 

OCA works to assist the SEC’s efforts to oversee accounting standard-setting by the Financial 

Accounting Standards Board (FASB) and help administer the SEC’s statutory obligations to 

provide oversight with respect to the Public Company Accounting Oversight Board (PCAOB), 

including administering the Commission’s selection and appointment of PCAOB Board 

members and administering the Commission’s approval of the PCAOB annual budget and 

accounting support fee. OCA also provides oversight of the Commission’s approval for any 

PCAOB standard-setting or rulemaking. OCA also monitors international standard-setting 

by the International Accounting Standards Board, International Sustainability Standards 

Board, the International Auditing and Assurance Standards Board, and the International 

Ethics Standards Board for Accountants, through participation in the Monitoring Board 

and Monitoring Group, respectively. The office also participates in the activities of the 

International Organization of Securities Commissions (IOSCO) through its leadership role 

on the Committee on Issuer Accounting, Auditing, and Disclosure.

OCA achieves its mission in the following ways.

The Accounting Group (AG) oversees accounting standard-setting by the FASB, addresses 

emerging accounting issues through consultations and stakeholder engagement, and supports 

rulemaking. The FASB has a robust agenda-setting process and post-implementation review 

process. In the past several years, the FASB has issued significant new accounting standards on 

leases, financial instruments, and revenue recognition that significantly impact most registrants. 

The AG is focused on working with the FASB through its consultation process to ensure these 

standards are implemented by registrants in an effective and timely manner. The AG also 

advises the Commission on accounting and auditing matters in SEC rulemaking including, 

most recently, on climate; executive compensation clawbacks; special purpose acquisition 

companies; and on private funds. 
48 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

The Professional Practice Group (PPG) provides expert advice related to auditing, 

independence, and internal controls over financial reporting. The PPG provides this advice 

in rulemaking support by overseeing the PCAOB and through consultations on auditor 

independence and internal control over financial reporting. 

The International Group (IG) leads OCA’s efforts to engage and promote high-quality financial 

reporting and auditing globally, which is a significant Commission priority. The Chief 

Accountant serves as Co-Chair of IOSCO’s Monitoring Group, which works to advance the 

public interest in international audit-related standard-setting and implement the Monitoring 

Group’s reform recommendations. 

The Office of the Chief Counsel (OCC) provides legal counsel to OCA related to legal policy 

with respect to Commission rulemaking and OCA’s oversight activities related to standardsetting and rulemaking by the PCAOB. OCC also provides OCA with legal advice relating

to administrative responsibilities, principally with respect to budget, accounting support 

fees, and appointments at the FASB and the PCAOB. In addition, OCC leads OCA’s process 

of advising the Commission on enforcement matters related to accounting, auditing, and 

auditor independence, including administering the Commission’s Rule 102(e) program 

for accountants. 

FY 2023 Request

OCA requests three additional positions to address an increased workload in several areas. 

In particular, additional resources are needed to support financial reporting related to climate 

rulemaking and international climate and sustainability standard-setting. These positions will 

assist the Chief Accountant in a critical period of navigating challenging market conditions 

to continue to support the agency’s mission and to facilitate continued leadership and 

collaboration with other national securities regulators, domestic and international standardsetters, other international organizations, other divisions and offices of the Commission, and 

other domestic regulators.

(DOLLARS IN THOUSANDS)

FY 2021

Actual

FY 2022 

Annualized CR

FY 2023

Request

Full-Time Equivalents 43 44 46 

Cost:

Salaries and Benefits $ 14,714 $ 14,378 $ 16,009

Non-Personnel Expenses 6,004 5,651 6,178

Total Costs $ 20,718 $ 20,029 $ 22,187

Totals may not appear to sum from detail lines due to rounding of actual values
FY 2023 BUDGET REQUEST BY PROGRAM | 49

Workload Data

Activity

FY 2021

Actual

FY 2022

Estimate

FY 2023

Request

Development of Commission Accounting and Auditing Rules, etc.

Rule Amendments, Proposed Amendments, and Commission 

Guidance Developed by OCA 3 2 2

OCA SEC Staff Announcements, Bulletins, and Statements 4 2 2

Consultation Arising from the Work of Other SEC Divisions and Offices 9 9 9

IOSCO Documents Related to Issuer Accounting, Audit, and Disclosure 3 3 3

Monitoring and Oversight of Standard-Setters

SEC Designated U.S. Accounting Standard-Setter Trustee and 

Board Appointments 7 5 6

U.S. Auditing Regulator (PCAOB) Board Appointments 1 5 1

U.S. Auditing Regulator Budget and Accounting Support Fee Approval 1 1 1

Monitoring and Oversight of Standard-Setting and Other 

Technical Work

U.S. Accounting Standard-Setting Projects 19 20 21

Rules Adopted by the U.S. Auditing Regulator and 

Approved by the SEC 2 2 3

Interpretation of Accounting and Auditing Standards, 

Policies, and Positions

Resolution of Accounting Issues of SEC Registrants 86 88 90

Engagement on Accounting Issues with Non-U.S. Regulators 97 100 103

Engagement on Auditing Issues with Non-U.S. Regulators 61 63 65

External Speaking Engagements 42 60 60

Recommendations and Questions Relating to the 

Qualification of Accountants

Auditor Independence Consultations 164 155 155

Activities In Support of the Enforcement of the Securities Laws

Consultation on Enforcement Investigations of SEC Registrants 76 85 88

Rule 102(e) Accountant Reinstatement Applications 4 9 9
50 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

OFFICE OF INVESTOR EDUCATION 

AND ADVOCACY

The Office of Investor Education and Advocacy (OIEA) seeks to provide individual investors 

with the information they need to make sound investment decisions. 

OIEA promotes this mission through two primary functions: assisting investors with 

complaints and questions about the securities markets and market participants, and 

conducting educational outreach to individual investors. OIEA also helps to inform 

Commission policy by advising the Commission and Commission staff on various issues 

from the perspective of individual investors, including with respect to rulemakings, Investor 

Advisory Committee recommendations, and through the International Organization of 

Securities Commissions’ Committee on Retail Investors.

FY 2023 Request

OIEA requests one additional position to support investor education outreach to underserved communities as it expands efforts to help more individuals protect themselves from 

investment fraud. 

(DOLLARS IN THOUSANDS)

FY 2021

Actual

FY 2022 

Annualized CR

FY 2023

Request

Full-Time Equivalents 44 43 43 

Cost:

Salaries and Benefits $ 12,488 $ 12,656 $ 13,685

Non-Personnel Expenses 7,378 7,031 7,533

Total Costs $ 19,866 $ 19,688 $ 21,219

Totals may not appear to sum from detail lines due to rounding of actual values

Workload Data

Activity

FY 2021

Actual

FY 2022

Estimate

FY 2023

Request

Investor Assistance 

Total Investor Assistance Matters Closed 31,373 31,000 31,000

Percentage of Investor Assistance Matters Closed Within: 

7 Days 45% 45% 45%

30 Days 84% 85% 85%

Investor Education 

Page Views on OIEA Web Pages 25,500,000 27,500,000 30,000,000

In-Person Investor Events 162 160 160

Number of Investor Alerts and Bulletins Issued 36 36 36

Number of Active Partnerships Focused on 

Underserved Communities 4 4 8
FY 2023 BUDGET REQUEST BY PROGRAM | 51

OFFICE OF INTERNATIONAL AFFAIRS

The Office of International Affairs (OIA) advances the SEC’s mission by promoting international enforcement and supervisory cooperation, developing and implementing strategies to 

further SEC policy interests in the regulation and oversight of cross-border securities activities, 

managing and executing the SEC’s participation in international regulatory bodies, engaging 

in regulatory dialogues with international counterparts, and providing technical assistance to 

strengthen partnerships with foreign authorities. OIA will continue to serve as the primary 

coordinator for the SEC on significant international initiatives and developments.

The Regulatory Policy and Supervisory Cooperation (RP/SC) Group will advise the 

Chair, Commissioners, and staff on strategies for advancing the Commission’s objectives in 

international organizations, including the Financial Stability Board and the International 

Organization of Securities Commissions, as well as coordinate the Commission’s participation 

in these bodies. In addition, the RP/SC Group will support the Commission’s engagement in 

work streams on sustainable finance, asset management, outsourcing, financial technology 

(fintech) and crypto-assets, and data consolidation. Also, the RP/SC Group will advance the 

Commission’s bilateral relationships with other jurisdictions and collaborate with foreign 

authorities to address cross-border policy issues that may have an impact on U.S. market 

participants (i.e., crypto-asset and other fintech issues, sustainable finance, cybersecurity, 

cross-border audit oversight inspections, substituted compliance, and data privacy). The 

RP/SC Group will also continue to collaborate with other divisions and offices to develop 

and operationalize SEC rulemakings or other policy initiatives with cross-border aspects, 

in particular rules on climate, money market funds, and open-end funds. 

Further, the RP/SC Group will assist SEC exam staff in the Division of Examinations and 

Office of Credit Ratings on cross-border supervisory issues, and assist foreign regulators 

with supervisory matters involving globally active regulated entities. This work will include 

facilitating cooperation between SEC staff and staff from foreign authorities under the recently 

completed substituted compliance Memoranda of Understanding (MOU). The RP/SC Group 

will also develop and implement additional information-sharing MOUs and other supervisory 

cooperation arrangements with foreign regulatory authorities, including arrangements related 

to data protection. 

The Enforcement Cooperation and Technical Assistance (ENF/TA) Group will assist 

the Division of Enforcement (ENF) in conducting investigations and enforcement proceedings 

with international aspects, including where perpetrators, evidence or the proceeds of fraud 

are located abroad. Similarly, the ENF/TA Group also assists and advises foreign authorities 

with their investigations and litigation. The ENF/TA Group will continue to advance the 
52 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

Commission’s policy objectives for international cooperation, including promoting best 

practices and overcoming obstacles with respect to cross-border enforcement-related 

information sharing. Consistent with the agency’s enforcement priorities, which include 

a focus on investor protection and keeping pace with technological change, the ENF/TA 

Group will continue to advance initiatives to address frauds that affect retail investors, 

such as cross-border pump-and-dump frauds. Further, the ENF/TA Group will assist ENF 

to combat cyber-enabled misconduct. 

In addition, the ENF/TA Group will continue to build capacity and strong relationships 

with the foreign counterparts the SEC relies on for assistance in SEC enforcement cases and 

overseas examinations. In response to increased requests from foreign securities authorities, the 

ENF/TA Group will provide technical advice and virtual training; review regulatory oversight 

regimes and suggest improvements; and consult with foreign securities authorities on draft 

legislation and regulations and operational processes.

FY 2023 Request

OIA requests six additional positions to support the ENF/TA Group and the RP/SC Group. 

Three of these positions include two attorney advisors to advance the Commission’s policy 

objectives for international cooperation and one program support position for the ENF/TA 

Group to advance the Commission’s policy objectives for international cooperation. These 

positions will support its ability to meet the significantly increased demands and complexities 

of cross-border enforcement cases, including managing operational programs that provide 

valuable assistance to ENF. 

The remaining three requested positions are attorney advisors who will serve as experts 

on international regulatory policy matters and ensure appropriate internal procedures are 

followed for evaluating and coordinating international policy engagements. They will support 

OIA’s RP/SC management of the Commission’s bilateral and multilateral engagement with 

foreign authorities as discussed above. The RP/SC Group has seen a dramatic increase both 

in the number of international engagements, as well as in the complexity of the international 

issues confronting the Commission, including addressing financial stability issues related to 

climate change, cybersecurity, data consolidation, and outsourcing. 
FY 2023 BUDGET REQUEST BY PROGRAM | 53

(DOLLARS IN THOUSANDS)

FY 2021

Actual

FY 2022 

Annualized CR

FY 2023

Request

Full-Time Equivalents 48 49 51 

Cost:

Salaries and Benefits $ 13,966 $ 14,017 $ 15,896

Non-Personnel Expenses 6,184 5,445 6,208

Total Costs $ 20,150 $ 19,461 $ 22,105

Totals may not appear to sum from detail lines due to rounding of actual values 

Workload Data

Activity

FY 2021

Actual

FY 2022

Estimate

FY 2023

Request

ENF Requests to SEC OIA for International Assistance 1,597 1,699 1,811

Responses to Foreign Requests for SEC 

Enforcement Assistance 567 588 582

Number of International Regulatory and 

Law Enforcement Officials Trained 1,639 1,500 1,575

SEC Requests for Supervisory Cooperation Assistance 333 235 247

Responses to Foreign Requests for SEC Supervisory 

Cooperation Assistance 200 210 216

International Regulatory Initiatives 846 600 630
54 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

OFFICE OF ADMINISTRATIVE 

LAW JUDGES

1 In FY 2021, one initial decision closed two cases that were consolidated: Crest Radius, Inc., 3-20021, and Loyal Source Market Services, 

Inc., 3-20022.

The Office of Administrative Law Judges supports the SEC’s mission by conducting hearings, 

issuing initial decisions, and adjudicating ancillary matters in administrative proceedings. 

When the Commission orders that a proceeding be heard by an administrative law judge, the 

judge serves as an independent adjudicator who determines whether the allegations against 

one or more respondents are true. The judges conduct public hearings at locations throughout 

the United States, in a manner similar to federal bench trials. Among other actions, they 

issue subpoenas, hold conferences with parties, and rule on motions and the admissibility 

of evidence. Following the hearing, the judge prepares an initial decision setting forth his or 

her factual findings and legal conclusions and determining whether sanctions are warranted. 

Certain proceedings may be resolved without an in-person hearing, such as when the judge 

decides that summary disposition is appropriate or finds a respondent in default.

(DOLLARS IN THOUSANDS)

FY 2021

Actual

FY 2022 

Annualized CR

FY 2023

Request

Full-Time Equivalents 10 9 11 

Cost:

Salaries and Benefits $ 2,172 $ 2,050 $ 2,853

Non-Personnel Expenses 1,104 834 920

Total Costs $ 3,276 $ 2,884 $ 3,774

Totals may not appear to sum from detail lines due to rounding of actual values

Workload Data

Activity

FY 2021

Actual

FY 2022

Estimate

FY 2023

Request

Proceedings Inventory 

Pending Disposition Beginning of Year 16 7 5

Ordered for Hearing 5 5 5

Disposed 14 7 7

Canceled Before Hearing 5 2 2

Canceled After Hearing — — —

Initial Decision Issued1 9 5 5

Pending Disposition End of Year 7 5 3
FY 2023 BUDGET REQUEST BY PROGRAM | 55

OFFICE OF THE INVESTOR ADVOCATE

The mission of the Office of the Investor Advocate (OIAD) is to ensure that the concerns 

of investors are appropriately considered as decisions are being made and policies are being 

adopted at the Commission, at self-regulatory organizations (SRO), and in Congress. As 

required by statute, OIAD analyzes the potential impact on investors from proposed rules 

and regulations, identifies areas in which investors would benefit from changes in rules and 

regulations, and proposes policies to resolve problems that investors have with financial service 

providers and investment products.

The office has four core functions: (1) provide a voice for investors; (2) assist retail investors; 

(3) study investor behavior; and (4) support the SEC’s Investor Advisory Committee. OIAD 

carries out these functions in the ways listed below.

Investor Advocacy

Consistent with the requirements of Section 4(g), OIAD is responsible for identifying 

problems that investors have with financial service providers and investment products; 

analyzing the potential impact on investors of proposed regulations and rules; identifying 

areas in which investors would benefit from changes in SEC regulations or SRO rules; and 

proposing changes in regulations, legislation, or administration of programs that may 

mitigate problems identified. 

Reports to Congress

OIAD is responsible for submitting two reports to Congress per year. 

1. A Report on Objectives is due no later than June 30 of each year, and its purpose is to set

forth the objectives of the Investor Advocate for the following fiscal year. 

2. A Report on Activities is due no later than December 31 of each year, and it describes

the activities of the Investor Advocate during the immediately preceding fiscal year. 

Among other things, the Report on Activities must summarize the most serious problems 

encountered by investors during the reporting period, identify any Commission or SRO 

action that was taken to address those problems, and recommend, as appropriate, any 

administrative and legislative actions to resolve problems encountered by investors.
56 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

Ombudsman

The Investor Advocate is required to appoint an Ombudsman to act as a liaison between 

the SEC and any retail investor in resolving problems that retail investors may have with 

the SEC or SROs. The Ombudsman must also review policies and procedures and make 

recommendations to encourage the investing public and other interested persons to submit 

questions to the Investor Advocate regarding compliance with the securities laws, and establish 

safeguards to maintain the confidentiality of communications between the investing public and 

the Ombudsman. The Ombudsman must also evaluate the effectiveness of this program and 

submit semiannual reports to the Investor Advocate for inclusion in the reports to Congress. 

Investor Testing

The Investor Advocate is required to examine the potential impact on investors of SEC and 

SRO rulemakings, advise the Commission and SROs on potential changes to existing rules, 

identify problematic products and practices that harm investors, and generate related reports 

with substantive statistical analysis. To accomplish these objectives, OIAD utilizes investor 

testing and other research efforts, as appropriate, to gather input from investors on rulemaking 

initiatives and better understand their informational needs. The office anticipates that additional research projects will develop in FY 2023 related to the Commission’s Strategic Plan 

by providing data that gives the Commission insight into the needs of investors. 

Investor Advisory Committee

The Investor Advocate serves as a member of the Investor Advisory Committee, which is 

authorized by Section 39 of the Exchange Act. This committee advises and consults with 

the SEC on regulatory priorities and protection of investors. OIAD provides support and 

assistance to this advisory committee to assist it with fulfilling its statutory mission.

FY 2023 Request

In FY 2023, OIAD will continue to engage with divisions and offices on several major 

Commission rulemakings and the impact of these rulemakings on investors. The Office of the 

Chief Counsel will also continue reviewing SRO filings that flow through the Commission and 

provide expert analysis and advice to the Investor Advocate in specialized policy areas. The 

POSITIER Team will continue conducting investor testing and additional research projects 

to support the SEC’s rulemaking agenda and build a basic library of investor-related research 

such as the demographics of the investor population, investor sentiment over time, and 

investor behavior under specified conditions. The Ombudsman will continue to assist investors 

in resolving complaints regarding the operations and the policies of the SEC and SROs. In 

addition, the Ombudsman will be leading and strengthening the agency’s nationwide outreach 

to investor advocacy clinics. 
FY 2023 BUDGET REQUEST BY PROGRAM | 57

To assist the Ombudsman with the increased workload and to ensure that investor matters 

and communications are addressed, OIAD requests one attorney advisor position. This 

position will handle the majority of investor contacts, assist the Ombudsman with complex 

investor matters, and assist with the research and drafting of the required semiannual 

Ombudsman Reports submitted to the Investor Advocate and Congress.

(DOLLARS IN THOUSANDS)

FY 2021

Actual

FY 2022 

Annualized CR

FY 2023

Request

Full-Time Equivalents 12 13 15 

Cost:

Salaries and Benefits $ 3,739 $ 4,251 $ 5,321

Non-Personnel Expenses 2,440 2,670 2,892

Total Costs $ 6,179 $ 6,921 $ 8,212

Totals may not appear to sum from detail lines due to rounding of actual values

Workload Data

Activity

FY 2021

Actual

FY 2022

Estimate

FY 2023

Request

Ombudsman 

Investor Matters 2,404 2,500 2,600

Investor Contacts 3,231 3,400 3,500

Outreach Events/Speeches 12 20 20

Investor Advocacy

SEC Rulemakings Reviewed 20 38 31

SRO Rulemakings Reviewed 175 185 195

Policy Recommendations to SEC, SROs, 

or Congress 4 2 2

Outreach Events/Speeches 72 25 50

Investor Advisory Committee Support 

Committee Meetings 4 4 4
58 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

OFFICE OF CREDIT RATINGS

The Office of Credit Ratings (OCR) is charged with administering Commission rules with 

respect to the practices of nationally recognized statistical rating organizations (NRSRO). These 

rules are aimed toward promoting accuracy in credit ratings issued by NRSROs, ensuring that 

credit ratings are not unduly influenced by conflicts of interest, and helping to ensure that firms 

provide greater disclosure to investors. In support of this mission, OCR conducts examinations 

of NRSROs to assess and promote compliance with statutory and Commission requirements, 

monitors the activities of NRSROs, develops and administers rules affecting NRSROs, and 

provides guidance generally with respect to the Commission’s regulatory initiatives related 

to NRSROs.

During FY 2023, the majority of OCR’s staff will continue to be dedicated to conducting 

examinations of NRSROs for compliance with the federal securities laws and Commission 

rules. OCR is required by statute to conduct an examination of each NRSRO at least annually, 

covering eight specific review areas. Additionally, OCR uses a risk-based approach to determine 

additional areas of inquiry for each NRSRO examination and for monitoring NRSRO activities 

and industry developments. OCR will continue to provide legal support for examinations and 

any referrals to the Division of Enforcement, providing interpretive guidance, and developing 

rule recommendations for the Commission’s consideration. OCR also reviews requests for 

Commission exemptive relief or staff “no-action” relief from existing rule requirements and 

formulates staff guidance and other interpretive positions related to NRSRO regulations. 

Additionally, OCR reviews initial applications for NRSRO registration and applications from 

existing NRSROs for registration in additional ratings classes.

FY 2023 Request

OCR requests two attorney advisors to provide advice and guidance on complex legal issues 

to strengthen OCR’s legal and policy capabilities in support of a number of key program 

areas, including the analysis and development of rules, exemptive orders, and interpretive 

and other actions involving NRSROs. The attorney advisors will also enhance OCR’s ability 

to support exams and monitoring; review and respond to tips, complaints, and referrals; and 

conduct analyses on potential enforcement actions involving NRSROs or related individuals. 

Additionally, these positions will contribute to the development and issuance of the statutorily 

mandated annual NRSRO reporting, as well as any other published reports or studies by OCR. 
FY 2023 BUDGET REQUEST BY PROGRAM | 59

(DOLLARS IN THOUSANDS)

FY 2021

Actual

FY 2022 

Annualized CR

FY 2023

Request

Full-Time Equivalents 43 43 44 

Cost:

Salaries and Benefits $ 12,497 $ 12,815 $ 14,260

Non-Personnel Expenses 6,927 7,504 8,313

Total Costs $ 19,424 $ 20,320 $ 22,573

Totals may not appear to sum from detail lines due to rounding of actual values

Workload Data

Activity

FY 2021

Actual

FY 2022

Estimate

FY 2023

Request

Examinations 9 11 11

Rulemaking, Exemptive Orders, and Interpretative and 

Other Actions 4 5 5

Reports and Studies 3 3 3

Reviews of Potential Enforcement Actions 11 15 15

Tips, Complaints, and Referrals (TCR) 11 15 15

NRSRO Registrations — Filed Applications, 

Amendments, Withdrawals, and Cancellations 54 56 58
60 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

OFFICE OF MUNICIPAL SECURITIES

The Office of Municipal Securities (OMS) coordinates the Commission’s activities relating to 

the $4 trillion municipal securities market and administers the Commission’s rules pertaining to 

municipal securities brokers and dealers, municipal advisors, investors in municipal securities, 

and municipal issuers. OMS advises the Commission on policy matters and current market 

issues relating to the municipal securities market and is responsible for policy development, 

coordination, and implementation of Commission initiatives to improve the municipal securities 

market, including working with other divisions on cross-fixed income market issues. OMS is 

also responsible for reviewing and processing proposed rule changes filed by the Municipal 

Securities Rulemaking Board (MSRB) with the Commission. OMS provides technical assistance 

to other SEC divisions and offices, including the Division of Enforcement (ENF) and the 

Division of Examinations (EXAMS). OMS’ responsibilities include three primary areas: 

municipal advisor regulation, municipal securities market structure initiatives, and municipal 

securities disclosure initiatives. 

OMS monitors current issues in the municipal securities market and reports developments to 

the Commission. In addition, OMS coordinates with MSRB on rulemaking and enforcement 

actions and reviews all MSRB proposed rule changes on behalf of the Commission. OMS also 

develops recommendations to improve transparency and efficiency in the municipal securities 

market. OMS organizes outreach events such as a municipal securities market conference and 

municipal advisor outreach event with EXAMS, MSRB, and the Financial Industry Regulatory 

Authority (FINRA) to educate market participants about the federal securities laws applicable 

to the municipal securities market.

FY 2023 Request

OMS requests one position to serve as counsel to the director. Specifically, the position 

will focus on: (1) coordinating and consulting with other divisions and offices and with 

Commissioners’ counsels on municipal securities matters; (2) participating in outreach events 

for municipal market participants on behalf of OMS; and (3) assisting in coordinating and 

implementing Commission initiatives to improve the municipal securities market.
FY 2023 BUDGET REQUEST BY PROGRAM | 61

(DOLLARS IN THOUSANDS)

FY 2021

Actual

FY 2022 

Annualized CR

FY 2023

Request

Full-Time Equivalents 9 9 10 

Cost:

Salaries and Benefits $ 2,609 $ 2,250 $ 3,066

Non-Personnel Expenses 985 991 1,114

Total Costs $ 3,595 $ 3,241 $ 4,180

Totals may not appear to sum from detail lines due to rounding of actual values

Workload Data

Activity

FY 2021

Actual

FY 2022

Estimate

FY 2023

Request

SRO Proposed Rule Changes Reviewed1 8 12 12

SEC Rulemaking and Exemptive and Interpretive 

Actions 2 7 6 6

Interpretive, Exemptive, No-Action, and Confidential 

Treatment Request Letters Closed — 1 1

Reviews of Potential ENF Actions and EXAMS 

Examinations 35 40 40

Congressional, Governmental, Industry, and 

Public Correspondence and Inquiries 190 200 200

Public Awareness and Market Outreach 17 25 25

Municipal Advisors (MA)

Registrants 3 526 520 520

Registration Applications Filed 19 25 25

Registration Amendments Filed4 658 780 780

Registrations Withdrawn or Canceled5 21 35 35

1 This data includes filings, pre-filings, and amendments reviewed.

2 For some of these activities in FY 2021, OMS served in a supporting role to another SEC division or office. OMS expects to serve in a 

supporting role to other SEC divisions and offices on SEC rulemakings and exemptive and interpretive actions in FY 2022 and FY 2023.

3 These figures reflect all active MA registrations as of September 30, 2021.

4 Estimate and request figures assume approximately 1.5 amendment filings per registrant per year.

5 These figures reflect the number of registration withdrawals or cancellations effective as of September 30, 2021.
62 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

OFFICE OF THE ADVOCATE FOR 

SMALL BUSINESS CAPITAL FORMATION

The Office of the Advocate for Small Business Capital Formation (OASB) was established 

pursuant to the SEC Small Business Advocate Act (P.L. 114-284) as an independent office 

dedicated to advancing the interests of small businesses and their investors at the SEC and in 

the capital markets. OASB reports to the entire Commission as well as to multiple committees 

of Congress. OASB advocates for solutions to address challenges faced by small businesses 

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

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

investors are seeking liquidity in the public markets, all the way to smaller public companies. 

In FY 2023, the office will focus on four key goals in accordance with its FY 2021 – 2025 

Strategic Plan. 

1. Engage with small businesses and their investors to solicit views on relevant capital 

raising issues.

• Conduct outreach with diverse audiences

• Host the SEC’s annual Small Business Forum

2. Educate small businesses and their investors about capital raising rules to reduce barriers 

to entry and increase compliance.

• Develop accessible educational materials about capital raising

• Optimize content and delivery based upon changes in market needs and preferences

3. Collaborate on pragmatic policy solutions to address capital raising challenges faced 

by small businesses and their investors.

• Assist small businesses and their investors in resolving issues encountered with the SEC 

or self-regulatory organizations

• Analyze data on capital raising to identify trends and gaps in funding, including for 

underrepresented and rural founders, and in areas affected by natural disasters

• Promote practical policy solutions for Commission or Congressional action to address 

capital raising challenges

• Deliver annual reports to Congress and the Commission that advocate for capital 

raising solutions

• Support the SEC’s Small Business Capital Formation Advisory Committee in providing 

advice to the Commission on capital raising policy
FY 2023 BUDGET REQUEST BY PROGRAM | 63

4. Empower a mission-driven team to leverage varied perspectives to solve the complex 

problems of an evolving and increasingly diverse capital market.

• Advance diversity, equity, and inclusion throughout office operations

• Foster a culture of connectivity, collegiality, and collaboration among office staff

(DOLLARS IN THOUSANDS)

FY 2021

Actual

FY 2022 

Annualized CR

FY 2023

Request

Full-Time Equivalents 9 9 12 

Cost:

Salaries and Benefits $ 2,599 $ 2,755 $ 3,956

Non-Personnel Expenses 2,119 1,437 1,597

Total Costs $ 4,718 $ 4,193 $ 5,554

Totals may not appear to sum from detail lines due to rounding of actual values

Workload Data

Activity

FY 2021

Actual

FY 2022

Estimate

FY 2023

Request

Assistance with Small Business Capital 

Formation Inquiries1,2 252 175 175

Outreach Events and Speeches 32 30 30

Government-Business Forum on Small Business 

Capital Formation 1 1 1

Reports on Small Business Forum and OASB Activities 2 2 2

Small Business Capital Formation Advisory 

Committee Meetings2 4 4 4

3

1 Inquiries include solicitation of support from OASB by marketplace participants with compliance obligations, access to capital formation 

resources, or policy recommendations. It is not intended to capture the totality of touchpoints with the public through outreach and other 

events but instead substantive issue resolution or resource navigation directly with affected parties.

2 In FY 2021, OASB experienced an increase of small business capital formation inquiries due to COVID-19.
64 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

STRATEGIC HUB FOR INNOVATION 

AND FINANCIAL TECHNOLOGY

The Strategic Hub for Innovation and Financial Technology (FinHub) supports the SEC’s 

mission to protect investors, maintain fair, orderly, and efficient markets, and facilitate capital 

formation by serving as the central hub for issues and initiatives related to developments 

in technology in financial services. FinHub helps coordinate the agency’s oversight of, and 

responses to, emerging financial technologies, including in the areas of distributed ledger 

technology (for example, crypto-asset markets), automated investment advice, digital 

marketplace financing, and artificial intelligence/machine learning. FinHub is the central point 

of contact for internal and external engagement with market participants, thereby helping to 

shape the agency’s approach to, and understanding of, technological changes in the financial 

industry. FinHub staff works with a wide range of market participants, policymakers, 

regulators, and organizations to advance the SEC’s mission.

FinHub became an independent office in 2020. Since then, FinHub has served as an internal 

and external resource for developing financial technologies, most notably distributed ledger 

technology. FinHub staff regularly engages with domestic and foreign governmental partners 

on a bilateral and multilateral basis to actively monitor and understand emerging issues, 

including U.S. federal and state financial regulators, the Financial Stability Oversight Council, 

the International Organization of Securities Commissions, the Financial Stability Board, and 

other federal and state authorities. FinHub also serves as an internal resource within the 

Commission, engaging with staff in other divisions and offices on new issues as 

they arise, and helping staff integrate financial industry innovations into their work.

Looking forward to FY 2023, FinHub anticipates that financial technology will continue to 

evolve at an incredibly rapid pace and grow increasingly more complex. New products and 

services, such as those offered in the decentralized finance space, are being introduced on 

a compressed timeframe and having an immediate impact on the financial industry. These 

developments and innovations will continue to present challenges to the Commission, as they 

tend to raise new or heightened regulatory concerns. FinHub is uniquely positioned to help 

the Commission and its staff understand and assimilate these advancements and the challenges 

that they present. 
FY 2023 BUDGET REQUEST BY PROGRAM | 65

(DOLLARS IN THOUSANDS)

FY 2021

Actual

FY 2022 

Annualized CR

FY 2023

Request

Full-Time Equivalents 4 7 8 

Cost:

Salaries and Benefits $ 1,426 $ 2,122 $ 2,446

Non-Personnel Expenses 1 553 678

Total Costs $ 1,427 $ 2,674 $ 3,124

Totals may not appear to sum from detail lines due to rounding of actual values

Workload Data

Activity

FY 2021

Actual

FY 2022

Estimate

FY 2023

Request

External Inquiries 277 277 277

International Regulatory Initiatives 16 16 16

No-Action Requests/Interpretative Requests 15 15 15

Outreach Events/Speeches 26 26 26

SRO Rulemakings Reviewed 14 14 14

1
66 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

AGENCY DIRECTION AND 

ADMINISTRATIVE SUPPORT

This section details the SEC’s agency-wide executive activities, operations, and administrative 

functions.

Agency Direction includes:

• Executive Staff, which is comprised of the Chair’s and Commissioners’ Offices 

and the Office of Legislative and Intergovernmental Affairs

• Office of Public Affairs

• Office of the Secretary

Administrative Support includes:

• Office of the Chief Operating Officer and its component offices

• Office of the Ethics Counsel

• Office of Minority and Women Inclusion

• Office of Equal Employment Opportunity
FY 2023 BUDGET REQUEST BY PROGRAM | 67

EXECUTIVE STAFF

The Executive Staff is comprised of the Chair, the Commissioners, their staff, and the Office of 

Legislative and Intergovernmental Affairs (OLIA). 

The Chair serves as the agency’s senior responsible executive, overseeing all aspects of agency 

operations and setting the agency’s substantive policy and rulemaking agenda. In addition, 

the Chair and Commissioners are jointly responsible for interpreting and enforcing the federal 

securities laws; issuing new rules and amending existing rules; overseeing the inspection 

of securities firms and other regulated entities; and coordinating U.S. securities regulation 

with federal, state, and foreign authorities. The staff in the Chair’s Office and in each 

Commissioner’s Office assist with these functions. 

OLIA serves as the liaison between the SEC and Congress, and is responsible for responding 

to requests from Congress for information related to agency programs and legislation affecting 

the SEC or its mission. Specifically, OLIA coordinates testimony and witness preparation 

for SEC officials appearing at Congressional hearings; responds to requests by members of 

Congress and their staff for meetings, briefings, and technical assistance on legislation and 

other matters affecting the SEC or its mission; responds to requests from members of Congress 

and their staff for information concerning the operations and activities of the SEC; and assists 

in responding to Congressional correspondence. OLIA also serves as the agency’s official 

liaison to other federal government agencies, such as the U.S. Department of the Treasury, U.S. 

Commodity Futures Trading Commission, and other federal financial regulatory agencies.

(DOLLARS IN THOUSANDS)

FY 2021

Actual

FY 2022 

Annualized CR

FY 2023

Request

Full-Time Equivalents 21 28 30 

Cost:

Salaries and Benefits $ 12,232 $ 12,187 $ 13,909

Non-Personnel Expenses 5,247 4,744 5,110

Total Costs $ 17,480 $ 16,931 $ 19,020

Totals may not appear to sum from detail lines due to rounding of actual values

Workload Data

Activity

FY 2021

Actual

FY 2022

Estimate

FY 2023

Request

Commission Meetings 72 80 84

Calendar Items 562 576 590

Seriatim Actions 926 550 578

Congressional Testimonies 5 5 5
68 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

OFFICE OF PUBLIC AFFAIRS

The Office of Public Affairs (OPA) assists the Commission in making the work of the 

SEC open to the public, understandable to investors, and accountable to taxpayers. OPA 

communicates the agency’s work and delivers the agency’s data and other digital information 

to the public, market participants, and other stakeholders. OPA manages external 

communications strategy, media relations, internal communications, public engagement, 

digital engagement, speechwriting, and SEC.gov.

OPA leverages technology and multimedia to deliver news, data, and other information to 

inform investors and facilitate internal and external audiences’ interactions with the SEC. The 

office maintains the SEC’s digital platforms, including The Exchange—the agency’s intranet—

and SEC.gov, which received more than one billion page views in FY 2021. OPA will continue 

to expand and improve its digital efforts to meet increasing demand. For example, OPA will 

enhance the search engine, webcast media, content management workflows, caching strategies 

for page loading improvements, and automation of certain functions to SEC.gov and The 

Exchange. Planned improvements will also include content enhancement to make relevant 

information more consumable. The office will also continue to respond to media inquiries, 

write and edit news releases and other materials, and facilitate media interactions with agency 

officials to promote understanding of the SEC’s work in an increasingly dynamic marketplace.

OPA will continue these and other activities in FY 2023, with a heightened emphasis on 

innovative digital and visual communication capabilities that support the emerging needs 

of an increasingly mobile workforce and enable the SEC to convey its work in a compelling 

and relevant manner. The challenge, however, is making sure that the office is deploying its 

resources effectively given the proliferation of digital channels and diverse audiences. 

FY 2023 Request

OPA requests two positions to facilitate its FY 2023 goals: (1) a public engagement program 

manager who will effectively manage external stakeholder relationships and ensure that the 

agency communicates directly with members of the public; and (2) a management program 

analyst who will support OPA managers and staff by performing a variety of administrative 

tasks that require a higher level of analysis and analytical skills so that staff can focus on 

strategic execution of their duties. 
FY 2023 BUDGET REQUEST BY PROGRAM | 69

(DOLLARS IN THOUSANDS)

FY 2021

Actual

FY 2022 

Annualized CR

FY 2023

Request

Full-Time Equivalents 20 23 25 

Cost:

Salaries and Benefits $ 5,054 $ 5,787 $ 6,874

Non-Personnel Expenses 2,127 1,960 2,112

Total Costs $ 7,181 $ 7,747 $ 8,985

Totals may not appear to sum from detail lines due to rounding of actual values

Workload Data

Activity

FY 2021

Actual

FY 2022

Estimate

FY 2023

Request

News Releases and Chair Speeches and Statements 337 400 400

Email and Mobile Bulletins 5,548 5,000 5,000

Social Media Posts 1,099 1,100 1,100

Number of SharePoint Top-Level Sites or Applications 

Created and/or Administered1 11 12 12

Number of Internal Communications Artifacts, including 

Articles, Reminders, and Daily Emails Distributed 2,902 3,200 3,200

SEC.gov Website Content Updates 19,675 20,000 20,000

The Exchange Intranet Content Updates 2,554 2,500 2,500

Number of Digital Signage Slides, Posters, Kiosk, 

and Social Media Graphics 384 610 610

Reports and Publications Production 21 21 21

Video and Other Media Productions 66 100 100

Public Engagements/Event Production 173 400 400

1 2 3

1 Number only represents the top-level (i.e., first level/parent) sites. Nearly 500 subsites, pages, document libraries, and/or workflows 

comprise these sites.
70 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

OFFICE OF THE SECRETARY

The Office of the Secretary (OS) is critical in ensuring the effective processing of all Commission business. OS reviews for legal and factual sufficiency orders and releases issued by 

the Commission; schedules and coordinates Commission meetings; prepares and maintains 

records of Commission actions; receives and tracks filings in administrative proceedings; and 

advises the Commission and staff about practice and procedure. OS is responsible for the 

public dissemination of Commission documents such as notices, orders, and rulemakings and 

oversees the comment letter intake process.

Because all Commission enforcement and regulatory actions flow through OS, the agency’s 

rulemaking agenda and enforcement program will continue to have a significant impact on 

OS workload in FY 2023. In recent years, OS has generally experienced significantly increased 

workload levels. The higher workload OS has taken on is consistent with the agency’s 

increased enforcement actions and rulemaking activity. In addition, OS will continue to 

improve business operations and further enhance its current IT systems. OS intends to focus 

resources on enhancing its internal and outward-facing processes to allow for expedited and 

efficient access by all customers, including the public.

(DOLLARS IN THOUSANDS)

FY 2021

Actual

FY 2022 

Annualized CR

FY 2023

Request

Full-Time Equivalents 21 23 25 

Cost:

Salaries and Benefits $ 5,319 $ 5,910 $ 6,821

Non-Personnel Expenses 2,266 2,063 2,222

Total Costs $ 7,585 $ 7,973 $ 9,043

Totals may not appear to sum from detail lines due to rounding of actual values

Workload Data

Activity

FY 2021

Actual

FY 2022

Estimate

FY 2023

Request

Releases and Orders Processed

Enforcement 1,274 2,492 2,616

Regulatory 1,932 2,251 2,364

Other 106 111 117

Federal Register Submissions

Self-Regulatory 1,526 1,680 1,764

Rulemaking/Other 557 320 336

Public Comment Letters Processed 24,215 25,000 25,000

Documents Posted on SEC.gov 5,022 5,300 5,300

Administrative Proceedings Items Processed 1,724 3,385 3,453

Service of Process — Administrative Proceedings 3,314 2,172 2,215
FY 2023 BUDGET REQUEST BY PROGRAM | 71

OFFICE OF THE 

CHIEF OPERATING OFFICER

The Office of the Chief Operating Officer (OCOO) provides strategic leadership and 

operational oversight of the SEC’s core mission-support activities and compliance with 

administrative requirements from Congress and the Executive Branch.

There are seven offices within OCOO: 

• Office of the Chief Operating Officer’s Front Office

• Office of Financial Management 

• Office of Information Technology 

• Office of Human Resources

• Office of Acquisitions

• Office of Support Operations 

• EDGAR Business Office
72 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

OFFICE OF THE CHIEF OPERATING 

OFFICER (FRONT OFFICE)

The front office of the Office of the Chief Operating Officer (OCOO) oversees and coordinates 

the activities of the six other component offices. In addition, the front office manages several 

key functions, as detailed below.

Chief Data Officer 

The Office of the Chief Data Officer (OCDO) is committed to enabling the secure, effective, 

and efficient use of data in service of the agency’s mission. As required by the Foundations 

for Evidence-Based Policymaking Act of 2018 and the Federal Data Strategy, OCDO will 

coordinate the ongoing refinement and execution of the SEC Data Strategy; lead the design 

and collaborate on the implementation of the Commission’s data architecture, including 

supporting the areas of identity and access management and zero trust; develop and deploy 

enterprise data standards governing data definition, ingestion, and migration; lead additional 

agency initiatives related to data (e.g., Controlled Unclassified Information program); 

categorize and maintain its inventory of data assets, including metadata, via continued 

development of the SEC Data Catalog; develop, implement, and monitor compliance with 

organization-wide data policies and standards governing access, use, and sharing, as well 

as licensing and terms of use; and coordinate implementation of open data requirements 

governing rulemaking and information dissemination, as required by the OPEN Government 

Data Act. OCDO will also continue to promote effective management of the agency’s library 

and third-party research and data resources via the Library and Information Services function.

Chief Risk Officer 

The Office of the Chief Risk Officer (OCRO) strives to provide reliable, timely, and current 

information on agency risks, to enable SEC leadership to make risk-informed decisions on 

strategy, as well as mission and operational objectives. OCRO will continue to strengthen 

the SEC’s Enterprise Risk Management (ERM) governance and procedures to better capture 

and analyze risk information. OCRO will also broaden ERM engagement within the SEC to 

improve information flows and collaboration among divisions and offices. Finally, OCRO will 

strengthen operational capabilities of its tracking tool and better leverage it to improve SEC’s 

risk management processes, internal controls, and audit management.

Managing Executive Support for Small Offices

The Office of the Managing Executive for Small Offices (MESO) provides vital business 

operations planning and management services to support 13 small offices throughout the 

agency. In particular, MESO works collaboratively with small offices’ senior leadership to 

manage their offices’ financial and human resources and IT initiatives to achieve organizational 

goals and objectives. MESO is committed to expanding IT technical support and project 

liaison services to ensure the technological capabilities available to the small offices effectively 

support their operations.
FY 2023 BUDGET REQUEST BY PROGRAM | 73

Strategic Planning and Program Management

The Office of Strategic Planning and Program Management (SPPM) promotes effective 

program and project management throughout the agency, and supports strategic initiatives 

to improve agency operations. Specifically, SPPM focuses on these distinct cross-agency 

areas: (1) enterprise program and project management; (2) business process improvement; 

(3) management of agency performance metrics; (4) enterprise knowledge management; 

(5) strategic projects and programs; and (6) cross-agency processes such as supporting 

crisis management, tracking agency requirements under new laws and regulations, and 

coordinating personnel exits.

(DOLLARS IN THOUSANDS)

FY 2021

Actual

FY 2022 

Annualized CR

FY 2023

Request

Full-Time Equivalents 30 35 38 

Cost:

Salaries and Benefits $ 7,656 $ 9,436 $ 11,189

Non-Personnel Expenses 2,149 2,979 3,209

Total Costs $ 9,804 $ 12,415 $ 14,398

Totals may not appear to sum from detail lines due to rounding of actual values

Workload Data

Activity

FY 2021

Actual

FY 2022

Estimate

FY 2023

Request

Auditor Engagements Facilitated 56 55 55

New Laws and Regulations Tracked by OCOO 31 45 55

SEC Policies Created or Revised 27 32 35

Projects to Improve Agency Business Processes 27 28 30

Small Offices Supported 13 13 13

OCDO Data Management

Data-Related System Development 

Sprints Completed 52 69 72

Data Insights/Visualizations Developed 

and Deployed 23 28 30

Information Services

Library Subscription Management — Account 

Actions Taken 7,391 6,500 6,500

Library Acquisitions — Contracts Managed 118 120 120

Library Acquisitions — Invoices Reviewed/Paid 697 650 650

Library Reference — In-Depth Research Requests 380 350 350

Library Reference — Quick Reference Requests 1,495 1,500 1,500
74 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

OFFICE OF FINANCIAL MANAGEMENT

The Office of Financial Management (OFM) administers the financial management and budget 

functions of the SEC. The office assists the Chief Operating Officer in formulating budget and 

authorization requests; monitors the utilization of agency resources; and develops, oversees, 

and maintains SEC financial systems, statements, and reports. These activities include cash 

management, accounting, fee collections, travel policy development, and oversight of budget 

justification and execution.

OFM is focused on strengthening financial management within the agency through a 

coordinated effort involving the modernization and integration of financial systems, the 

improvement of financial reporting and accountability, and the enhancement of efficient and 

effective internal controls. Specific initiatives will seek to generate efficiencies with financial 

data, automate key reports, and evaluate current processes to reduce costs and strengthen 

the integrity of SEC financial systems and processes. Additionally, OFM supports ongoing 

efforts to further automate and streamline registration fee data. Finally, OFM will take steps 

to implement the recently enacted budget transparency reporting requirements.

FY 2023 Request

OFM requests two additional positions in FY 2023. One position is for budget formulation 

and will bolster capabilities in the areas of planning and ongoing analysis. This position 

will also assist with implementation of the recently enacted budget transparency reporting 

requirements. The second position is for internal controls over financial reporting to enhance 

the testing function of system controls within the financial management office.

(DOLLARS IN THOUSANDS)

FY 2021

Actual

FY 2022 

Annualized CR

FY 2023

Request

Full-Time Equivalents 88 85 87 

Cost:

Salaries and Benefits $ 22,346 $ 21,922 $ 24,404

Non-Personnel Expenses 9,529 8,667 9,336

Total Costs $ 31,875 $ 30,589 $ 33,740

Totals may not appear to sum from detail lines due to rounding of actual values
FY 2023 BUDGET REQUEST BY PROGRAM | 75

Workload Data

Activity

FY 2021

Actual

FY 2022

Estimate

FY 2023

Request

Accounting and Finance

Quarterly/Annual Financial Statements Issued 36 36 36

Financial Transactions Analyzed 7,694,699 7,900,000 8,100,000

Analysis and Reconciliation Reports Prepared 6,988 7,058 7,129

Planning and Budget

Number of Conference Requests Submitted in the 

Automated Event Request System 13 57 85

Percentage of Reserve Fund Letters Delivered to 

Congress On Time 100% 100% 100%

1
76 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

OFFICE OF INFORMATION TECHNOLOGY

IT plays a critical role in the mission of the SEC and its ability to digitally receive data from 

registrants, analyze and derive insights, and share data with its government partners and the 

public while also maintaining the security of the agency’s systems and the privacy of sensitive 

information entrusted to the Commission. The increasing size and complexity of U.S. markets 

requires that the SEC continue leveraging technology to keep pace with the increases in data 

volumes and variety it receives, processes, analyzes, and makes available to the investing public. 

The Office of Information Technology (OIT) is focused on enhancing and modernizing technology 

systems, migrating applications to the cloud, continuing to strengthen the cybersecurity of SEC 

systems, and accelerating the deployment of data analytics tools across the Commission.

OIT supports the Commission and staff of the SEC in all aspects of IT. The office has overall 

management responsibility for the Commission’s IT program including application development, 

data engineering and management, infrastructure operations and engineering, user support, 

IT program management, capital planning, security, privacy, and enterprise architecture. OIT 

operates the Electronic Data Gathering, Analysis, and Retrieval (EDGAR) system, which 

electronically receives, processes, and disseminates more than 500,000 financial statements 

every year. The office also maintains a dynamic and robust website that contains a wealth of 

information about the Commission and the securities industry, and hosts the EDGAR database 

for free public access.

Efficient, effective, and responsible use of data and IT is a crucial focus of the SEC. The agency 

continues to make progress in key areas such as cybersecurity, secure cloud infrastructure, and 

data management. 

FY 2023 Request

OIT requests an additional $20 million above the FY 2022 request and 11 new technology staff 

positions to provide expertise in cloud computing, data engineering, and enabling data analysis 

and management. This budget request will enable the SEC to continue implementing highpriority initiatives, including: (1) the modernization of key legacy systems; (2) the migration of 

applications to the cloud; (3) the improvement of information security and identity management 

practices, including to comply with new cybersecurity requirements; and (4) the enhancement 

of the resiliency of the SEC network and infrastructure. Of the 11 new positions, 6 will design 

and support mission-critical cloud architectures, evaluate cloud technology improvements, and 

monitor cloud privacy requirements and standards. Three positions will be dedicated to data 

engineering and two positions will support agile development of key agency systems, helping 

make sure IT investments yield promised value and benefits for agency programs. 
FY 2023 BUDGET REQUEST BY PROGRAM | 77

Furthermore, with the additional resources, OIT will strengthen security controls, policies, 

and procedures, as well as comply with requirements mandated in the recent Cybersecurity 

Executive Order 14028, Improving the Nation’s Cybersecurity (May 12, 2021) and associated 

Office of Management and Budget Memorandums. 

Reserve Fund 

In FY 2023, the SEC intends to continue using its Reserve Fund to fund mission-critical 

technology modernization and enhancement projects that enhance the agency’s security 

posture, expand the use of risk and data analytics, and reduce cost by migrating legacy 

applications to modern enterprise solutions. This funding supports long-term IT initiatives 

that would otherwise be more difficult to sustain due to year-over-year budget challenges.

The SEC plans to use the Reserve Fund for the following programs: 

• Cybersecurity

• Data Analytics

• EDGAR Security Uplift and Modernization 

• Enforcement Investigation and Litigation Support

• Examination Management

• Business Process Improvements

These key priorities will enhance the SEC’s ability to improve service to registrants and 

the public, integrate and analyze large amounts of data, and improve SEC business and 

operational processes. 

The multi-year effort of modernizing EDGAR will continue, aimed towards, among other 

things, modernizing the core technologies underlying the EDGAR system, making it easier for 

registrants to file through the system, improving system security, and enhancing the usability of 

EDGAR data by the public through SEC.gov.

The Consolidated Audit Trail (CAT) continues to roll out functionality as the phased launch of 

broker-dealer reporting and regulator functionality progresses. Reporting of transactional data 

is expected to be completed in FY 2022, and the full implementation of CAT National Market 

System (NMS) Plan Requirements is scheduled for FY 2023. The SEC is working to establish 

an environment and applications to use CAT data as it becomes available while maintaining 

the appropriate security controls.

In addition, building foundational capabilities in the SEC’s cloud environment will unlock 

future opportunities for cost optimization, technology stability and resiliency, application 

consolidation, and security enhancements. The Commission will continue to set and maintain 

technology standards for development and operations in the cloud, and will continue investing 
78 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

in automation to implement inherited security controls and improve delivery time. It will 

also establish disaster recovery and continuity of operations capabilities in the agency’s cloud 

environment to support the migration of mission-critical applications. These efforts will allow 

the SEC to retire outdated legacy applications that are more expensive to secure and maintain.

(DOLLARS IN THOUSANDS)

FY 2021

Actual

FY 2022 

Annualized CR

FY 2023

Request

Full-Time Equivalents 189 206 220 

Cost:

Salaries and Benefits $ 52,162 $ 57,664 $ 66,353

Non-Personnel Expenses 21,726 20,235 21,798

Total Costs $ 73,888 $ 77,899 $ 88,151

Totals may not appear to sum from detail lines due to rounding of actual values

Workload Data

Activity

FY 2021

Actual

FY 2022

Estimate

FY 2023

Request

Internal Process Improvements and Employee Productivity 

User Requests for Helpdesk Assistance1 98,000 140,000 147,000

Amount of Network-Based Storage (terabytes) 23,160 24,000 24,000

Network Users 6,696 6,700 6,700

Information Security and Disaster Recovery 

Percentage of Major Systems Certified 

and Accredited 100% 100% 100%

1 The anticipated increase for FY 2022 Estimate is due to the expected return to the building in 2022.
FY 2023 BUDGET REQUEST BY PROGRAM | 79

OFFICE OF HUMAN RESOURCES

The Office of Human Resources (OHR) is responsible for the strategic management of 

the SEC’s human capital. OHR consults with management, establishes and administers 

human capital programs and policies, and ensures compliance with federal regulations 

and negotiated agreements. 

Programs and policies under OHR’s purview include those listed below.

• Recruitment, Staffing, and Retention

• Position Management and Classification

• Compensation Administration

• Benefits Counseling and Processing

• Leave Programs

• Leadership and Employee Development

• Performance Management and Awards

• Labor Relations

• Disability Program

• Work-Life Programs

• Telework

• Employee Records Processing and Maintenance

FY 2023 Request

OHR requests four additional positions for FY 2023 to support increased demand for staffing 

services; create and administer a new paid internship program and other recruitment and 

hiring initiatives (consistent with the requirements of Executive Order 14035, Diversity, 

Equity, Inclusion, and Accessibility in the Federal Workforce); and further the strategic 

management of the SEC’s human capital through programs that support the development, 

engagement, and retention of a diverse and talented workforce with the right mix of skills 

and expertise.

(DOLLARS IN THOUSANDS)

FY 2021

Actual

FY 2022 

Annualized CR

FY 2023

Request

Full-Time Equivalents 107 110 113 

Cost:

Salaries and Benefits $ 25,914 $ 26,725 $ 35,754

Non-Personnel Expenses 10,815 10,053 10,829

Total Costs $ 36,729 $ 36,778 $ 46,583

Totals may not appear to sum from detail lines due to rounding of actual values
80 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

Workload Data 

Activity

FY 2021

Actual

FY 2022

Estimate

FY 2023

Request

AskHR Inquiries1 20,143 21,000 21,000

Personnel Actions Processed 18,146 19,486 19,676

Recruitment Actions 520 1,174 1,364

Training Sessions Held 1,646 1,450 1,450

Training Session Attendees 32,704 30,000 30,000

Studies, Reviews, and Policies Issued 702 830 837

Classification Assessments and Federal Staffing 

Policy Reviews 2 48 50 52

Applications Processed for Students and 

Special Programs 3 5,586 2,746 2,746

On-Boards for Students and Special Programs 4 625 660 660

1234

1 Actual figures will be highly dependent on the appropriations enacted by Congress. They also account for personnel actions’ processing for 

regular and recurring actions associated with current employees, e.g., career ladder promotions, career tenure changes, and awards.

2 This metric captures workload related to classification studies, desk audits, office re-organizations, and the review and update of SEC 

Administrative Regulations and Operating Procedures related to federal staffing.

3 This metric captures the number of applications submitted and processed by OHR for the Student Honors Program, Upward Mobility 

Program, and Chair’s Attorney Honors Program. The Student Honors Program will be replaced by the SEC Scholars Program in FY 2022.

4 This metric captures the number of applications that are further evaluated and result in a selection and on-board for the Student Honors 

Program, Upward Mobility Program, and Chair’s Attorney Honors Program. This metric also includes on-boarding for the Intergovernmental 

Personnel Act Mobility Program and intra-agency details. The Student Honors Program will be replaced by the SEC Scholars Program in 

FY 2022.
FY 2023 BUDGET REQUEST BY PROGRAM | 81

OFFICE OF ACQUISITIONS

The Office of Acquisitions (OA) develops and executes programs for the SEC’s acquisitions 

policy; procurement and contract administration; acquisitions workforce training and 

certification; and government purchase cards (GPC). 

OA is responsible for procuring all goods and services—except real property—for the 

SEC. OA provides oversight of the GPC program and certification programs for OA 

staff, Contracting Officer’s Representatives (COR), and program/project managers. OA is 

responsible for maintaining the on-site/off-site contractor database; managing contracts 

and contractors; ensuring performance is monitored; adjusting contracts as needed; closing 

out contracts; and implementing and enforcing specific Congressional legislation, executive 

mandates, and other directives relating to procurement.

OA reports detailed information on expenditures and assures contract-related data is properly 

reported to federal systems and SEC financial systems. OA tracks and reports a broad range 

of information, in addition to financial data, required by the SEC for its financial reporting. 

Examples include Buy American Act information; awards by Congressional district, state, 

vendor, business type, and competition information; and small business and other data 

necessary to ensure transparency and accountability for federal programs.

Procurement budgets increased to their highest levels in FY 2021 and are anticipated to 

continue growing over time. OA has committed to improvements in contract management 

affecting not only OA but also the hundreds of CORs located throughout the SEC. OA 

will continue to develop and improve upon its mechanisms for contract oversight and 

vendor risk management. OA will also continue to support diversity in the SEC’s business 

contracting activities, collaborating with the SEC’s Office of Minority and Women Inclusion 

to review equity barriers in FY 2022 and continuing to promote access to contracting and 

subcontracting opportunities through outreach activities.

FY 2023 Request

OA requests two additional positions to support operational workload increases and meet 

a growing obligation while also focusing attention on contract management risks. Specific 

areas of risk include cyber and IT security, supply chain management, vendor management, 

and oversight/compliance to improve quality and management. This request will also provide 

support for workload increases to review and expand diversity, equity, and inclusion efforts in 

contracting opportunities. 
82 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

(DOLLARS IN THOUSANDS)

FY 2021

Actual

FY 2022 

Annualized CR

FY 2023

Request

Full-Time Equivalents 55 55 55 

Cost:

Salaries and Benefits $ 13,017 $ 13,301 $ 14,516

Non-Personnel Expenses 5,462 5,049 5,439

Total Costs $ 18,479 $ 18,350 $ 19,955

Totals may not appear to sum from detail lines due to rounding of actual values

Workload Data

Activity

FY 2021

Actual

FY 2022

Estimate

FY 2023

Request

Procurement Actions 

(contracts and purchase orders) 1,517 1,487 1,473

Total Dollars Obligated of Contracts with 

Business Funded by SEC $ 580,100,000 $ 614,906,000 $ 651,800,360

Additional Value of Interagency Agreements 

Obligated (in dollars) $ 23,862,387 $ 24,339,634 $ 24,826,426

GPC Cardholder Statements Audited 108 111 112

Closeout Actions Processed1 227 215 205

Dollars Recovered for Reuse (closeouts and 

unliquidated obligation de-obligations) $ 30,200,000 $ 25,000,000 $ 25,000,000

CORs in Acquisition Workforce 457 462 467

Small Business Actions Processed 988 969 950

Dollars Spent with Small Business $ 299,270,844 $ 317,227,095 $ 336,260,721

Percentage of Small Business Dollars 

(23% federal-wide minimum goal) 54% 53% 53%

Multi-Agency Collaborative Actions 322 320 320

Multi-Agency Contract Value Awarded (in dollars) $ 86,192,979 $ 81,883,331 $ 77,789,165

1 Transaction count does not include $0 closeout actions executed with no contract modification.
FY 2023 BUDGET REQUEST BY PROGRAM | 83

OFFICE OF SUPPORT OPERATIONS

The Office of Support Operations (OSO) implements a variety of programs to manage the 

agency’s facilities and assets. OSO is responsible for processing requests made under the 

Freedom of Information Act (FOIA) and Privacy Act (PA), the management of all agency 

records in accordance with the Federal Records Act, maintaining the security and safety of 

SEC facilities, and managing property, equipment, and overall building operations.

Office of FOIA Services (OFS) is responsible for receiving and responding to requests for nonpublic records under FOIA (5 U.S.C. § 552) and PA (5 U.S.C. § 552a). The office’s primary 

objective is to foster openness and transparency in government. FOIA is constantly growing, 

as Congressional interest in the Commission’s mission and activities remains high and public 

demand for SEC records continues to increase. Therefore, OFS estimates that the number of 

FOIA requests received will steadily increase each of the next two fiscal years.

Office of Records Management Services (ORMS) maintains SEC records schedules 

and develops policies and procedures under the Federal Records Act and other records 

requirements. The office also coordinates the retrieval of non-active records from records 

storage facilities and handles requests for certified copies of agency records. The Office of 

Management and Budget’s Transition to Electronic Records Directive (M-19-21) drives 

the increased demands on the program. ORMS employed the Capstone methodology 

to implement electronic management of both permanent and temporary email records. 

ORMS is leading the agency’s modernization of records management business practices, 

by automating the processes by which electronic information is maintained, managed, 

and safeguarded.

Office of Security Services (OSS) is responsible for physical and personnel security, 

emergency management, and safety of SEC personnel and facilities. OSS develops policies 

and procedures to implement federal security-related statutes and regulations. OSS also 

manages the Homeland Security Presidential Directive (HSPD)-12 and National Security 

programs for the SEC in accordance with federal mandates. OSS oversees the SEC Insider 

Threat Program and operates the Sensitive Compartmented Information Facility with secure 

communication capabilities.

Office of Building Operations (OBO) provides a wide range of services. The office supports 

the SEC’s headquarters and 11 regional office locations, and oversees property and facilities 

management, office lease acquisitions and administration, space renovation, transportation, 

and printing and mail operations.
84 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

Business Management Office (BMO) is responsible for the oversight and management of 

all business functions of the OSO organization, ensuring that the most efficient and effective 

business practices are followed. BMO serves as the conduit for OSO offices to plan, manage, 

and execute mission requirements, and also provides essential organizational management 

support. BMO serves the SEC by providing Continuity of Operations Planning (COOP). 

The COOP Branch manages an extensive range of programs directly related to ensuring the 

continuity of SEC’s operations and essential functions across a spectrum of emergencies. 

FY 2023 Request

OSO requests one position to oversee and develop the SEC’s climate-related reporting and 

disclosures, including creating new reporting metrics and formulating recommendations that 

help develop and improve a climate reporting program. This position will also serve as the 

subject matter expert and liaison between management, technical users, and system architects 

for sustainability-related projects. 

(DOLLARS IN THOUSANDS)

FY 2021

Actual

FY 2022 

Annualized CR

FY 2023

Request

Full-Time Equivalents 87 88 91 

Cost:

Salaries and Benefits $ 19,713 $ 20,270 $ 22,878

Non-Personnel Expenses 8,498 7,645 8,235

Total Costs $ 28,211 $ 27,915 $ 31,113

Totals may not appear to sum from detail lines due to rounding of actual values

Workload Data

Activity

FY 2021

Actual

FY 2022

Estimate

FY 2023

Request

FOIA

FOIA Requests Carried Forward from Prior FYs 833 1,025 1,125

New FOIA/PA Requests Received 12,363 12,750 13,000

FOIA/PA Requests Completed 12,171 12,650 12,950

Records Management

Official Certificates 3,611 3,700 3,700

Document Requests 261 280 280

Security Services

Interim Suitability Determinations Made 2,730 2,900 3,100

HSPD-12 Credentials Issued 613 6,000 2,500

HSPD-12 Credential Certificates Updated 396 1,500 750

Building Operations

Print Production (millions of pages) 0.49 1.13 1.77
FY 2023 BUDGET REQUEST BY PROGRAM | 85

EDGAR BUSINESS OFFICE 

The EDGAR Business Office (EBO) provides central and effective management of all aspects 

of the Electronic Data Gathering, Analysis, and Retrieval (EDGAR) system. Among other 

things, EBO governs strategic improvements to EDGAR; oversees EDGAR development 

for SEC rulemakings and other matters; provides Filer Support; maintains responsibility for 

rulemaking related to the administration of EDGAR; and communicates with the public and 

SEC staff about EDGAR matters.

EBO will continue to manage development in EDGAR, including ensuring agency rulemaking 

is implemented effectively in EDGAR, to allow regulated entities and individuals to meet 

agency filing and disclosure obligations. In addition, EBO plans to expand the use of its 

EDGAR Beta environment to allow filers to test planned regulatory filing requirements before 

compliance dates. 

The office will also continue to enhance the security of EDGAR. EBO anticipates that the 

Commission may consider EDGAR Next improvements to EDGAR filer access and account 

management in FY 2023. EDGAR Next potentially would:

• add individual user accounts and multi-factor authentication to the access process;

• enhance the ability of filers to securely maintain access to their EDGAR accounts; 

• facilitate responsible filer management of EDGAR credentials; and 

• simplify procedures for accessing EDGAR.

Furthermore, EBO will seek to add more Application Programming Interfaces to EDGAR. 

EBO strives to improve and simplify the filer experience to facilitate the ability of companies 

and individuals to meet filing and disclosure requirements while also empowering investors 

with accurate, consolidated, and user-friendly data and information to make informed 

investment decisions.

FY 2023 Request

EBO requests three new positions that will focus on: (1) addressing EBO’s expanding 

legal demands to review and provide legal advice on filer issues; (2) executing EBO’s 

communications strategies and coordinating communications related to EDGAR; and 

(3) supporting the agency’s need for structured data expertise in the areas of XML, JSON, 

XBRL, and iXBRL.
86 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

(DOLLARS IN THOUSANDS)

FY 2021

Actual

FY 2022 

Annualized CR

FY 2023

Request

Full-Time Equivalents 31 33 34 

Cost:

Salaries and Benefits $ 7,636 $ 8,299 $ 9,322

Non-Personnel Expenses 3,462 2,960 3,188

Total Costs $ 11,099 $ 11,259 $ 12,510

Totals may not appear to sum from detail lines due to rounding of actual values

Workload Data

Activity

FY 2021

Actual

FY 2022

Estimate

FY 2023

Request

EDGAR Filings, Disclosure, and Review

Online Searches for EDGAR Filings (in millions) 40,258 41,466 42,710

Number of Electronic Filings Received (in millions) 2.38 2.45 2.52

EDGAR Development

EDGAR Agile Development Releases 12 12 12

Division/Office Rulemaking Implementation 

to EDGAR 12 12 12

EBO Rulemaking Activities 6 5 5

EDGAR Filer Support

Filer Support — Internet and Email Inquiries 3,390 3,729 4,102

Assistance, Escalations, and Technical Support —

Telephone Inquiries 102,121 112,333 123,566

EDGAR Form IDs Processed 109,357 125,761 144,625

EDGAR Internal System Access Requests Processed 1,783 1,961 2,157

Rule 15 Actions Processed1 105 158 163

1 This number reflects data from February 2021 to the end of FY 2021 because new Rule 15 under Regulation S-T, adopted in December 

2020, became effective in February 2021.
FY 2023 BUDGET REQUEST BY PROGRAM | 87

OFFICE OF THE ETHICS COUNSEL

The Office of the Ethics Counsel (OEC) is responsible for administering the Commission’s 

Ethics Program and for interpreting the SEC’s Supplemental Ethics Rules as well as federal 

government-wide ethics laws, rules and regulations. OEC provides independent legal analysis 

and advice to the Chair, Commissioners, and divisions and offices on ethics issues. In addition, 

the OEC Compliance team manages personal trading requests for staff Commission-wide in 

compliance with the SEC’s Supplemental Ethics Rules and provides training and counseling on 

personal trading questions. OEC is also the SEC’s liaison with the U.S. Office of Government 

Ethics. OEC expects its workload and responsibilities to increase as the overall workforce 

of the SEC increases, as the office manages the development and implementation of multiple 

significant IT systems, and as the number of enforcement matters increases in FY 2023.

In FY 2023, OEC will continue to advise and counsel all Commission employees and members 

on personal and financial conflicts of interest; post-employment restrictions; securities holdings 

and transactions of Commission employees and their immediate families; gifts; seeking and 

negotiating other employment; outside activities; and financial disclosure. Additionally, OEC 

will continue to review Commission memoranda for potential conflicts of employees with 

financial holdings. Further, the office will continue to develop and enhance IT systems for 

employee trading and financial disclosure. 

FY 2023 Request

OEC requests one additional position for FY 2023 to support the compliance program. 

This position will support the numerous new and overlapping IT developments and critical 

program enhancements.

(DOLLARS IN THOUSANDS)

FY 2021

Actual

FY 2022 

Annualized CR

FY 2023

Request

Full-Time Equivalents 19 19 19 

Cost:

Salaries and Benefits $ 4,950 $ 5,152 $ 5,587

Non-Personnel Expenses 2,077 1,920 2,069

Total Costs $ 7,027 $ 7,073 $ 7,656

Totals may not appear to sum from detail lines due to rounding of actual values
88 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

Workload Data

Activity

FY 2021

Actual

FY 2022

Estimate

FY 2023

Request

Ethics Counseling Inquiries 10,000 10,000 10,000

Review of Public Financial Disclosure Forms 392 404 416

Commission Memoranda Review 1,013 1,043 1,074

Review of Confidential Financial Disclosure Forms 4,129 4,253 4,381

Clearance of 8B Requests 136 140 144

Pre-clearance of Requests for Trading 61,936 63,794 65,707

Employees Trained in Ethics 4,596 4,734 4,876

Review of SEC Forms 682 Financial Disclosure Forms 333 343 353

Testing of Employee Compliance Data 400 400 400
FY 2023 BUDGET REQUEST BY PROGRAM | 89

OFFICE OF MINORITY AND 

WOMEN INCLUSION

The Office of Minority and Women Inclusion (OMWI) provides leadership and guidance 

for the SEC’s efforts to leverage diversity and inclusion throughout the agency to enhance 

mission performance and impact. OMWI’s efforts include building and maintaining a diverse 

workforce and cultivating an inclusive work environment; promoting business diversity with 

the SEC’s regulated entities and stakeholders; and fostering diversity in the agency’s network 

of suppliers, including promoting diversity and inclusion with those suppliers.

OMWI actively supports the SEC’s Diversity and Inclusion Strategic Plan (2020 – 2022), 

which includes developing and implementing initiatives that support the goals set forth 

within it. Accordingly, OMWI continues to guide and assist the SEC in its focus on attracting, 

hiring, developing, and retaining highly quality, diverse talent for all levels of the workforce. 

Under OMWI’s guidance and leadership, the SEC pursues several programs and initiatives to 

promote workforce diversity and foster workplace inclusion.

OMWI will continue its outreach activities with women and other minority-serving high 

schools, colleges, and universities through career fairs, networking events, and recruiting 

opportunities. OMWI’s workforce activity will be increasingly geared toward building 

sustainable and impactful relationships with such educational institutions through strategic 

interactions with these institutions’ leadership; engagement with multicultural and career 

services offices; and financial literacy programs.

OMWI will be increasingly focused on fully integrating diversity and inclusion in the strategic 

decision-making of the agency and promoting business diversity with the SEC’s regulated 

entities and stakeholders. This will include a variety of external initiatives designed to further 

the principles of diversity and inclusion in the financial services industry and U.S. markets, 

including in the areas of asset management, access to capital, and investor access. OMWI’s 

SEC mission-related activities will focus on working with SEC advisory committees for mission 

effectiveness by promoting diverse participation, expanding partnerships with professional 

organizations with minority constituencies, and promoting diversity and inclusion efforts with 

the SEC’s regulated entities.

Internally, in addition to providing diversity and inclusion training and professional 

development programs, OMWI’s efforts will focus on providing customized consultations to 

individual SEC divisions and offices and share recommendations and guidance on enhancing 

diversity, equity, inclusion, and accessibility. OMWI will increase focus on building new 

opportunities for diverse candidates to join the SEC through early-career programs, including 

paid internship opportunities.
90 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

To support diversity in the SEC’s business activities, OMWI works to introduce minorityowned and women-owned businesses (MWOB) to opportunities at the SEC and will continue 

to collaborate with the Office of Acquisitions to promote access to contracting and subcontracting opportunities through extensive outreach activities. In particular, OMWI expects 

to promote awareness of, and access to, contract vehicles focused on the SEC’s IT needs. 

OMWI will continue to present at business conferences focused on MWOBs and meet 

one-on-one with potential contractors at Vendor Outreach Days.

FY 2023 Request

OMWI requests one additional position to support the SEC’s staff and internal operations 

while helping the agency more effectively engage with the diverse public it serves.

(DOLLARS IN THOUSANDS)

FY 2021

Actual

FY 2022 

Annualized CR

FY 2023

Request

Full-Time Equivalents 9 12 13 

Cost:

Salaries and Benefits $ 2,478 $ 4,230 $ 4,893

Non-Personnel Expenses 996 962 1,036

Total Costs $ 3,474 $ 5,192 $ 5,928

Totals may not appear to sum from detail lines due to rounding of actual values

Workload Data

Activity

FY 2021

Actual

FY 2022

Estimate

FY 2023

Request

Workplace Diversity and Inclusion

Diversity and Inclusion Trainings, Events, 

and Initiatives 57 60 63

Diversity, Equity, Inclusion, and Accessibility 

Consultations 4 12 20

Diversity and Inclusion Outreach

Mission-Related Activities and Targeted Outreach 35 37 40

Targeted Employment Advertisements 175 184 200

Supplier Diversity and Business Engagement

Good Faith Effort Contract Reviews 53 55 55

Vendor Matchmaking and Outreach Events 93 98 103

Diversity (Biennial) Assessment of Regulated Entities — 90 — 1
FY 2023 BUDGET REQUEST BY PROGRAM | 91

OFFICE OF EQUAL EMPLOYMENT 

OPPORTUNITY

The Office of Equal Employment Opportunity (OEEO) strives to apply best practices 

to achieve equal employment opportunity (EEO) and to support compliance with antidiscrimination laws so that the SEC serves as an employer-of-choice, fostering an equitable 

workplace dedicated to the SEC’s mission. SEC employees are entitled to a workplace where 

employment decisions are made without regard to race, color, sex (including pregnancy, 

gender identity, sexual orientation, and transgender status), age, religion, national origin, 

genetic information, parental status, marital status, political affiliation, uniformed service, 

union activities, and protected EEO activity. Like these demographic groups, the law protects 

individuals with disabilities from discrimination and also allows them to lawfully receive 

affirmative action. To maintain the impartiality necessary to fulfill its responsibilities under 

29 C.F.R. Part 1614 and related guidance, OEEO is independent of other SEC offices that 

may have different institutional interests, with the OEEO Director reporting directly to the 

SEC Chair.

OEEO is organized in two main analytical functions: Compliance and Resolutions, and 

Barrier Analysis. These functions support the overall success of the SEC by cultivating a 

workplace that is free of unlawful discrimination, resolves conflict early, and incorporates 

best practices into the SEC’s everyday business, thus advancing productivity and efficiency 

of the SEC’s work. 

The Compliance and Resolutions function applies legal principles to the processing and 

adjudication of complaints of discrimination under applicable anti-discrimination laws and 

Executive Orders (EO). This function also provides opportunities to quickly resolve through 

an alternative dispute resolution program. 

The Barrier Analysis function collects and analyzes quantitative and qualitative data to 

determine whether a policy, practice, or procedure impedes equal access to employment 

opportunities for members of a protected demographic group. When an impediment is 

identified, OEEO collaborates with stakeholders to identify concrete action opportunities 

to eliminate the potential barrier in the employment lifecycle, starting with recruitment and 

ending with separation.

OEEO also supports the SEC’s harassment prevention efforts through intake and education, 

offers mandatory training, files required annual reports with external stakeholders, and 

shares information on SEC EEO-related trends, areas of opportunity, best practices, and 

promising practices. OEEO engages frequently with internal and external stakeholders to 

perform these functions. 
92 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

FY 2023 Request

OEEO requests one additional position to support the legal and regulatory mandates, and 

to ensure the agency’s strategic goals are met. OEEO will continue to assess operations during 

its ongoing period of internal change, and seek new or different resources as necessary in 

subsequent requests.

(DOLLARS IN THOUSANDS)

FY 2021

Actual

FY 2022 

Annualized CR

FY 2023

Request

Full-Time Equivalents 12 11 13 

Cost:

Salaries and Benefits $ 3,655 $ 3,351 $ 4,222

Non-Personnel Expenses 1,598 1,417 1,527

Total Costs $ 5,253 $ 4,769 $ 5,749

Totals may not appear to sum from detail lines due to rounding of actual values

Workload Data

Activity

FY 2021

Actual

FY 2022

Estimate

FY 2023

Request

Equal Employment Complaint Program 

(29 CFR 1614)

Contacts to Office 41 47 54

Informal Complaints 22 25 29

Formal Complaints 15 17 21

Final Agency Decisions/Final Agency Orders 12 14 18

Harassment Prevention Program

Inquiries and Program Contacts 42 82 94

Affirmative Employment Program

Affirmative Employment/Barrier Research Studies — 3 5

Research Studies 6 8 12

Formal Consultation on Programs, Policies, 

and Practices 4 6 10

Analytic Briefings 6 6 12

Workforce Training, Outreach, and Education

Harassment Prevention 5 10 15

New Employee Orientation 26 26 26

Supervisory Outreach and Coaching Services 26 50 140

Workforce Events and Educational Outreach — 8 12

Web-Based Training 1 1 2

Mandatory External Reporting 

No FEAR Act (Quarterly + Annual) 5 5 5

Management Directive 715 Benchmark Assessment 1 1 1

Agency Statistical Report on Complaint Activity 

(Form 462) 1 1 1
FY 2023 BUDGET REQUEST BY PROGRAM | 93

OFFICE OF INSPECTOR GENERAL

The Office of Inspector General (OIG) is an independent office that conducts audits of 

programs and operations of the SEC and investigations into allegations of misconduct 

involving the SEC’s programs and operations. The mission of the OIG is to detect fraud, 

waste, and abuse and to promote integrity, economy, efficiency, and effectiveness in the 

SEC’s programs and operations. The rapid pace of significant internal and external changes 

impacting the work of the SEC drives the work of the OIG. The OIG supports the efforts of 

Congress and the SEC to fulfill their responsibilities and achieve their goals and objectives 

with respect to oversight of the securities industry and investor protection.

In FY 2023, the OIG will continue to focus on improving agency programs and operations 

through audits, evaluations, and reviews. The OIG will conduct audits and evaluations 

pursuant to the audit plan it will develop for FY 2023. The OIG will also enhance staff and 

agency integrity by investigating allegations of employee and contractor misconduct, as well 

as allegations of fraud, waste, and abuse in agency programs and operations. The OIG’s audit 

and investigative workload remains high because of a variety of factors, including continued 

Congressional oversight of the SEC and the number of tips and complaints received by the 

OIG. The office expects workload levels to remain high through FY 2023.

The OIG will continue the oversight responsibilities established by the Dodd-Frank Wall Street 

Reform and Consumer Protection Act (Dodd-Frank Act), which was enacted on July 21, 

2010. In particular, Section 966 of the Dodd-Frank Act required the OIG to establish an OIG 

SEC Employee Suggestion Program (ESP). Under that program, SEC employees may submit to 

the OIG suggestions for improving the SEC’s work efficiency, effectiveness, and productivity, 

as well as the SEC’s use of its resources. SEC employees may also submit through the ESP 

allegations of waste, abuse, misconduct, or mismanagement within the Commission. During 

FY 2023, the OIG will continue to monitor, track, and analyze information received through 

the ESP and will increase efforts to promote the program to solicit suggestions that will 

improve the SEC’s effectiveness in overseeing the securities markets and protecting investors. 

The OIG will also produce the required annual report to Congress on the ESP. In addition, 

the OIG will operate a program for recognizing employees who make suggestions, through 

the ESP, that increase the work efficiency, effectiveness, or productivity of the SEC, or reduce 

waste, abuse, misconduct, or mismanagement, as provided for by the Dodd-Frank Act.
94 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

In addition, there has been an increase in the coordination of IG activities to strengthen the 

oversight of the federal financial regulatory structure. For example, the SEC IG currently serves 

on the Council of Inspectors General on Financial Oversight (CIGFO), which was established 

by Section 989E of the Dodd-Frank Act. The OIG’s participation on CIGFO requires additional resources to provide effective oversight. In particular, the OIG will be required to prepare a section of CIGFO’s annual report to Congress in FY 2023. That section of the report 

will highlight the concerns and recommendations in the OIG’s ongoing and completed work, 

focusing on issues that might apply to the broader financial sector. CIGFO may also task the 

SEC OIG to conduct other audit or review activities on CIGFO’s behalf.

Increased coordination and initiatives undertaken by the Council of the Inspectors General 

on Integrity and Efficiency (CIGIE) has increased demands on OIG resources. To implement 

measures included in legislation to promote coordination of and transparency into the 

work of OIGs, the OIG has had to devote added resources to these initiatives such as the IG 

Enhancement Act and the Whistleblower Protection Coordination Act. Similar legislation has 

been proposed that would increase OIG coordination and reporting with OIGs throughout 

the federal government. Additionally, the emphasis on cybersecurity enhancements and 

investigations as the government increasingly moves to IT-based services and solutions 

increases the need for technical solutions and skills in providing oversight. The increase 

in IG activities will result in the need for more OIG resources.

FY 2023 Request

OIG requests 3 additional positions, bringing the total OIG authorized positions to 61. The 

requested positions consist of an auditor, a special agent, and an IT specialist. The additional 

auditor will help the OIG’s Office of Audits to respond to mandatory requirements, including 

external peer reviews and statutorily mandated engagements, as well as working on oversight 

and review matters. The additional special agent will aid the OIG’s Office of Investigations’ 

efforts to conduct complex criminal, civil, and administrative investigations. Adding an IT 

specialist will enhance the OIG’s Office of Operations and Management’s ability to conduct 

innovative research and analysis for data analytics support for OIG investigations and 

audits. The addition of these audit, special agent, and IT specialist positions are requested 

to accomplish the core mission of the OIG.
FY 2023 BUDGET REQUEST BY PROGRAM | 95

Regulatory Requirement

The Inspector General Act of 1978 (as amended) requires that each Inspector General (IG) 

submit a budget estimate and request each fiscal year to the head of the agency to which the 

IG reports. The Act requires that the request include:

• The aggregate amount of funds requested for the operations of the Office of Inspector 

General (OIG);

• The portion of that amount requested for OIG training, including a certification from the 

IG that the amount requested satisfies all OIG training requirements for that fiscal year; and

• The portion of that amount necessary to support the Council of the Inspectors General on 

Integrity and Efficiency (CIGIE).

As required by the Act, the IG of the U.S. Securities and Exchange Commission (SEC) 

submits the following information for the OIG’s budget estimate and request for FY 2023.

• The aggregate budget request for the operations of the OIG is $18,978,165.96.

• The OIG budget request incorporates a sufficient aggregate amount of funds for the 

operations of the OIG. The OIG training needs have traditionally been partially funded 

out of the agency’s training budget (i.e., approximately $1,000 per full-time equivalent 

for general training needs). The estimate for OIG specialized training costs for FY 2023 

is $122,000. The IG certifies that the aggregate amount of the request satisfies all training 

requirements for the OIG for FY 2023 and also any assessment required to support CIGIE. 

• The estimated amount of the SEC OIG’s contribution to CIGIE is 0.33 percent of the budget 

request, or $62,422.

(DOLLARS IN THOUSANDS)

FY 2021

Actual

FY 2022 

Annualized CR

FY 2023

Request

Full-Time Equivalents 50 52 55 

Cost:

Salaries and Benefits $ 14,059 $ 14,734 $ 17,151

Non-Personnel Expenses 6,770 6,825 7,487

Total Costs $ 20,829 $ 21,559 $ 24,638

Totals may not appear to sum from detail lines due to rounding of actual values

Workload Data

Activity

FY 2021

Actual

FY 2022

Estimate

FY 2023

Request

Audits/Evaluations

Pending Beginning of Year 5 6 5

Opened 10 12 12

Completed 9 13 12

Pending End of Year 6 5 5
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Risks, Internal Controls, and Management Challenges.......................................................................98

Cross-Agency Collaboration ............................................................................................................................... 103

Evidence Building........................................................................................................................................................109

Links to Additional Information and Resources ...................................................................................... 112

Other Information
98 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

RISKS, INTERNAL CONTROLS, AND 

MANAGEMENT CHALLENGES

The SEC’s mission is to protect investors, maintain fair, orderly, and efficient markets, and 

facilitate capital formation. The increasingly complex ecosystem of capital markets, public 

companies, and investors makes accomplishing that mission continually more challenging. 

To maximize the impact of the resources provided to the SEC to accomplish its mission, the 

agency continually evaluates its operations to identify emerging risks and ensure its resources 

are deployed in a manner that efficiently and effectively meets agency priorities. 

Enterprise Risk Management 

The SEC’s Office of the Chief Risk Officer (OCRO), within the Office of the Chief Operating 

Officer, is responsible for leading the agency’s enterprise risk management (ERM) program and 

functions, as required under the Office of Management and Budget (OMB) Circular A-123, 

Management’s Responsibility of Enterprise Risk Management and Internal Control. The ERM 

program assists the agency in achieving its strategic and operational objectives by providing 

an enterprise-wide approach for managing risk. With input from the Office of the Chair, the 

Risk Management Oversight Committee (RMOC), and other SEC committees, the ERM 

program coordinates the development and implementation of risk management frameworks 

and methodologies, and produces and maintains the agency’s risk profile. With oversight and 

input from the RMOC, the program collaborates with risk owners to help ensure risks are 

sufficiently and consistently managed, and senior management is supported in making riskinformed decisions.

Management Assessments of Internal Control 

The SEC remains committed to maintaining a strong system of internal control, which is 

integral to effective agency management and obtaining reasonable assurance that the SEC’s 

operational, reporting, and compliance objectives will be achieved. The Federal Managers’ 

Financial Integrity Act of 1982 (FMFIA), along with its implementing guidance in OMB 

Circular A-123, establishes management’s responsibility to establish, maintain, assess, and 

report on internal accounting and administrative controls. Such controls include program, 

operational, and administrative areas as well as accounting and financial management. The 

FMFIA also requires agencies to annually assess whether financial management systems 

conform to related requirements. Finally, the FMFIA requires that the head of each Executive 

Agency annually submit to the President and Congress: (1) a statement on whether there is 

reasonable assurance that the agency’s controls are achieving their intended objectives; and 

(2) a report on material weaknesses in the agency’s controls.
OTHER INFORMATION | 99

In support of this statement by the Chair, OCRO executes the SEC’s Management Assurance 

program to gain insights on the state of the SEC’s internal controls. This program is executed 

at multiple levels within the SEC and includes: 

• An entity-level control evaluation; 

• Internal management reviews, self-assessments, and tests of internal controls; 

• Assurance statements from each division director and office head on the effectiveness 

of their controls; 

• Management’s personal knowledge gained from daily operations; 

• Review and analysis of reports and recommendations from the Government Accountability 

Office (GAO) and the Office of Inspector General (OIG);

• Reviews of financial management systems under OMB Circular A-123 Appendix D, 

Compliance with the Federal Financial Management Improvement Act of 1996; 

• Reports pursuant to the Federal Information Security Management Act (FISMA) and 

OMB Circular A-130, Management of Federal Information Resources; 

• Reviews on improper payments;

• Reviews that support compliance with the Digital Accountability and Transparency Act 

of 2014; and 

• Reports and other information from Congress or agencies such as OMB, the Office of 

Personnel Management (OPM), or the General Services Administration reflecting the 

adequacy of internal controls. 

The SEC’s annual assessment of internal controls and assurance statements based on these 

sources and assessments is discussed in the SEC’s Agency Financial Report (AFR), which can 

be found at SEC.gov.

Management Challenges Identified by the Office of Inspector General 

The SEC’s FY 2021 AFR provides a summary of the most significant management and 

performance challenges facing the SEC, as identified by the OIG, in the Other Information

section. The AFR also details the actions being taken to address these challenges. The table 

on the next page describes how the resources requested for FY 2023 will help address the 

challenges identified by the Inspector General.
100 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

Management Challenge 

Identified by the 

Inspector General

How the FY 2023 Budget Addresses the Challenge

Meeting Regulatory 

Oversight 

Responsibilities

The SEC must continue to find ways to use its limited resources to keep pace 

with the changes in the size and complexity of the securities markets, products, 

and the market participants regulated by the SEC. For example, the population 

of registered investment advisers has grown over 20 percent in the last five 

years, with a more than 65 percent increase in assets managed by these firms. 

Also, in FY 2021, the agency received over 80 percent more tips, complaints, 

and referrals (TCR) than in FY 2020. 

Given this challenge and others identified by the OIG, the Division of Examinations’ (EXAMS) and Division of Enforcement’s (ENF) budget requests for 

FY 2023 included requests for a significant number of new positions. EXAMS 

will use these positions to: (1) address the challenges identified with overseeing 

and examining newly-registered swap market participants; (2) increase oversight and examinations of broker-dealers with a focus on the implementation 

of Regulation Best Interest and other risks such as those associated with the 

rise of financial technology and information security; (3) increase oversight and 

examinations of entities responsible for critical market infrastructure with a focus 

on examining entities for compliance with Regulation SCI and cybersecurity 

preparedness; and (4) increase the capacity of the program to examine and 

keep pace with the growing number of registered investment advisers, including 

those that advise private equity funds.

For ENF, these new positions will allow the division to: (1) increase its capacity 

to investigate misconduct and accelerate enforcement actions; (2) bolster the 

capabilities of its Cyber Unit; (3) strengthen litigation and operational support; 

and (4) improve data management.

In addition, the FY 2023 request will provide the resources necessary for the 

SEC to continue its efforts to, among other things, further leverage technology 

and data analytics to refine the risk-based examination approach; develop tools 

and data to more efficiently and effectively handle the significant increase in 

TCR volume; and further increase the Consolidated Audit Trail functionality to 

enhance regulatory oversight. The SEC will also continue its efforts to improve 

the Enterprise Architecture program to better support SEC mission activities 

and efficiently utilize information technology resources. Finally, the SEC will 

continue its efforts to meet this challenge by improving its investor assistance 

and education efforts and formalizing communication and collaboration efforts 

between SEC divisions and offices.

continued on next page
OTHER INFORMATION | 101

Management Challenge 

Identified by the 

Inspector General

How the FY 2023 Budget Addresses the Challenge

Protecting Systems 

and Data 

Protecting information systems and data is a top priority effort that must meet 

the challenges introduced by new technology, new threats, and new business 

drivers. SEC management remains mindful that governmental agencies, financial 

market participants, and private sector entities must remain vigilant because they 

are subject to frequent attempts by unauthorized actors to disrupt public-facing 

systems, access data, or otherwise damage technology infrastructure.

In FY 2021, the Office of Information Technology (OIT) worked to make 

enhancements in a number of areas and continues to make it a priority 

to address and mitigate the cybersecurity risks identified by the OIG and 

GAO. During FY 2021, the OIG closed 26 information technology-related 

audit recommendations, and GAO closed 5 cybersecurity-related audit 

recommendations. In FY 2022, OIT will continue to allocate significant 

resources to addressing outstanding OIG recommendations. 

OIT is also focused on implementing new guidance from Executive Order 14028, 

Improving the Nation’s Cybersecurity (May 12, 2021). With its FY 2023 budget 

request, OIT will increase its efforts to:

• support the implementation of security services within agency-selected 

cloud capabilities; 

• enhance identity, access, and privilege management protocols and operations 

across platforms; 

• modernize security operations capabilities focusing on automation, integration 

of shared services and experts through managed services, and proactive 

capabilities to identify threats; and 

• continue the implementation of a secure application development structure 

across all agency development teams and projects.

Improving Contract 

Management 

The SEC relies substantially on contractor support to accomplish its mission, 

and the management and oversight of this support remains a priority for 

management. As noted in the OIG’s statement, although the SEC’s Office of 

Acquisitions (OA) is responsible for procuring all goods and services—except 

real property—for the agency, the management and oversight of these contracts 

is an agency-wide effort, with staff from nearly all SEC offices and divisions 

playing key roles. The budget request for FY 2023 will allow OA to continue the 

Contract Management Excellence Initiative to further promote effective contract 

management throughout the agency. Continuation of this initiative will further 

improve contract management by: (1) maturing coordination efforts between OA 

and the Commission’s Contracting Officer’s Representatives to ensure effective 

administration of SEC contracts and proper vendor oversight; (2) continuing 

OA’s compliance and oversight functions in reviewing contract actions and files; 

and (3) bolstering reporting and automation capabilities for improved tracking 

and transparency of workload, and documentation and workflow of procurement 

actions. 

continued on next page
102 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

Management Challenge 

Identified by the 

Inspector General

How the FY 2023 Budget Addresses the Challenge

Ensuring Effective 

Human Capital 

Management 

The success of the SEC depends on an effective, highly-skilled workforce. 

As noted in the OIG’s statement, the SEC continued to take actions to gain 

insights about the effectiveness of its two-tier rating performance management 

program for SK employees. This included engaging with OPM to administer a 

survey and conduct focus groups to gather employee feedback regarding their 

experiences with the performance management program. This feedback will help 

the SEC validate and inform possible improvements to the overall performance 

management program and help ensure that the agency is effectively addressing 

overall employee concerns consistent with GAO’s recommendation.

In addition to further maturing its two-tier rating performance management 

program, the FY 2023 budget request will allow the SEC and its Office of Human 

Resources to continue to address the challenge of ensuring effective human capital 

management. This includes efforts to increase its focus on attracting and retaining 

a diverse and talented workforce that is representative of all segments of American 

society with the right mix of skills and expertise, as well as administering programs 

to enhance employee engagement, performance management, and leadership 

development.
OTHER INFORMATION | 103

CROSS-AGENCY COLLABORATION

The SEC values its many partnerships with other federal agencies, financial regulators, and 

foreign governments. Collaborating across regulatory boundaries, market segments, and national 

borders furthers the SEC’s ability to achieve its mission. The securities markets are large and 

dynamic, and the SEC understands that cooperation is essential to meet its strategic goals. Some 

examples of cross-agency collaboration efforts during FY 2021 – FY 2023 are highlighted below.

Strategic Goal 1 

Focus on the long-term interests of our Main Street investors.

The SEC frequently works with other entities to facilitate access to the information investors 

need to make informed investment decisions. Led by the Office of Investor Education and 

Advocacy (OIEA), the SEC participates in numerous collaboration activities with other 

regulators, federal agencies, and committees to make information accessible to investors. 

For example, OIEA issues joint investor alerts on recent investment frauds and scams with 

the Commodity Futures Trading Commission (CFTC), the Financial Industry Regulatory 

Authority (FINRA), and the North American Securities Administrators Association (NASAA). 

The SEC’s Division of Enforcement (ENF) continues to prioritize effective coordination with 

criminal authorities in bringing parallel enforcement actions seeking to hold wrongdoers 

accountable and remove bad actors from our markets. In more than 425 SEC enforcement 

investigations in FY 2021, other regulators and law enforcement offices requested and 

obtained access to materials contained in the SEC’s investigative files. In many of these cases, 

the SEC and its criminal law enforcement counterparts employed complementary tools to 

further a shared goal of investor protection. Frequently, this entailed collaboration with 

overseas regulatory and law enforcement counterparts.

The SEC’s Division of Examinations (EXAMS) frequently collaborates with other regulators, 

both domestically and abroad, to ensure that critical issues and risks impacting investors are 

addressed in an efficient and effective manner. These cooperation efforts include coordinated 

examinations, information sharing, periodic meetings, and other strategic efforts with domestic 

regulators such as FINRA, CFTC, the National Futures Association, the Financial Crimes 

Enforcement Network (FinCEN), the U.S. Department of Labor, and the Federal Reserve. 

Further, given the increasingly global marketplace, EXAMS continues to work with the SEC’s 

Office of International Affairs (OIA) to protect investors through frequent discussions and 

collaboration with foreign financial regulatory authorities from around the globe. These efforts 

have proven to be an effective method of overseeing entities and issues that impact retail 

investors and cross jurisdictional lines.
104 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

The SEC and CFTC work closely and collaboratively on a wide range of crypto-asset related 

issues. Both agencies have dedicated offices responsible for staying abreast of developments in 

the crypto-asset space, and our respective staff communicate frequently about developments in 

crypto-asset markets.

The SEC also collaborates with external partners to protect the financial well-being of 

American seniors. The SEC works closely with the Elder Justice Interagency Working Group 

(EJWG) and the Elder Justice Coordinating Council (EJCC) to safeguard their interests. The 

EJWG is responsible for carrying out elder justice activities, including elder abuse prevention; 

research, grant, and program funding; and prosecution. The EJCC is a federal entity charged 

with identifying and proposing solutions to the problems surrounding elder abuse, neglect, and 

financial exploitation. Among other roles, OIEA helps inform these working groups about the 

SEC’s initiatives to protect older Americans from investment fraud and abusive sales practices.

OIEA also represents the SEC on the Financial Literacy and Education Commission (FLEC), 

which was established under the Fair and Accurate Credit Transactions Act of 2003. FLEC is 

chaired by the Secretary of the Treasury and made-up of the heads of more than 20 additional 

federal agencies. The Commission was tasked with developing a national financial education 

website (MyMoney.gov) and a national strategy on financial education. In addition, OIEA is a 

national partner of Jump$tart and OIEA’s director, Lori Schock, serves on Jump$tart’s board 

of directors (ex officio). Jump$tart is a coalition of diverse education stakeholders, including 

federal agencies, non-profits, and financial firms, that work together to educate and prepare 

young Americans for life-long financial success. 

Strategic Goal 2 

Recognize significant developments and trends in our evolving capital markets 

and adjust our efforts to ensure we are effectively allocating our resources.

The SEC is a member of the Financial Stability Board (FSB), which promotes international 

financial stability by coordinating national financial authorities and international standardsetting bodies as they work toward developing strong regulatory, supervisory, and other financial 

sector policies. FSB fosters a level playing field by encouraging coherent implementation of these 

policies across sectors and jurisdictions. In addition to its monitoring functions, the Division 

of Trading and Markets (TM) assists the Commission with its work in various domestic and 

international regulatory groups, including FSB, the Financial Stability Oversight Council (FSOC), 

the International Organization of Securities Commissions (IOSCO), and the Senior Supervisors 

Group, by providing technical expertise on market and risk management developments and 
OTHER INFORMATION | 105

emerging financial issues. TM cooperates and collaborates with CFTC, the Federal Reserve 

Board (FRB), the Office of the Comptroller of the Currency (OCC), the Federal Deposit 

Insurance Corporation (FDIC), Federal Reserve Banks, the Bank of England, the Financial 

Conduct Authority, the Japanese Financial Services Agency, Canadian securities regulators, 

and other regulators. This collaboration spans several areas including operations and risk 

management practices of financial market infrastructures, and the capital, liquidity, internal 

controls, funding sources, and financial condition of firms and their holding companies that 

are supervised by the SEC. It also includes regulatory and supervisory areas of mutual interest. 

In addition, SEC staff continued to work with other U.S. and foreign regulators on significant 

issues related to the cessation of LIBOR (London Interbank Offered Rate) at the end of 2021.

The Division of Investment Management (IM) participates in various work streams related to 

FSOC, including monthly meetings of the FSOC Systemic Risk Committee. On occasion IM 

makes presentations on matters relating to the securities markets, including issues or concerns 

with potential implications for systemic risk before FSOC or its committees, or otherwise 

provides input or advice. In addition, IM staff coordinates with other U.S. and foreign 

regulators on analysis and monitoring of activity in the money market fund industry and the 

markets in which money market funds participate. The Commission recently proposed rules 

relating to the regulation of money market funds. IM expects to continue to coordinate with 

the Federal Reserve, Federal Reserve Banks, the U.S. Department of the Treasury’s (Treasury) 

Office of Financial Research, and the Consumer Financial Protection Bureau (CFPB) on the 

proposed amendments.

SEC staff worked with domestic and foreign regulators that provided particular focus on the 

impact of COVID-19 pandemic-related market volatility and work-from-home restrictions on 

market infrastructure and financial intermediaries. The pandemic contributed to significant 

increases in trading volumes and message traffic across products, resulting in operational 

challenges. While market infrastructure and financial intermediaries performed well overall, 

TM continues to identify and evaluate potential areas where further policy work may be 

warranted in collaboration with other regulatory agencies. In late 2021, Commission staff 

participated in the preparation and publication of the report by the staff of the Inter-Agency 

Working Group (IAWG) for Treasury Market Surveillance entitled Recent Disruptions and 

Potential Reforms in the U.S. Treasury Market: A Staff Progress Report (IAWG Report). The 

IAWG Report presents the views of the IAWG, which consists of staff from CFTC, Treasury, 

the Board of Governors of the Federal Reserve System, the Federal Reserve Bank of New York, 

and the Commission. The purpose of the IAWG Report is to highlight several broad principles 

for guiding public policy in the Treasury market in light of market disruptions related to the 

onset of the COVID-19 pandemic. IAWG staff collaborated over months to draft the report. 
106 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

The SEC’s oversight of broker-dealers is, in many ways, a coordinated effort with FINRA. 

The SEC and FINRA have regular contact to discuss strategic initiatives, examination 

coordination, risk assessment efforts, rulemaking issues (including the implementation of 

Regulation Best Interest), and evolving industry risks. This coordination ultimately intends to 

make oversight of broker-dealers more effective and efficient and improve compliance within 

the industry. As an example, the two agencies coordinate to formally present Compliance 

Outreach Seminars to representatives of the firms they oversee.

The Division of Corporation Finance worked closely with OIA and the Chair’s Office to 

support Treasury in its engagements on climate-related financial activities with the G-7, G-20, 

and COP26. These efforts ensured that the messages delivered by Treasury in these forums 

were consistent with the SEC’s messages and the Chair’s direction with regard to addressing 

climate-related financial risks relevant to investors in securities. The division’s engagement 

was also designed to ensure consistency with the Commission’s messaging in the context of its 

engagement with IOSCO and the International Financial Reporting Standards Foundation on 

climate-related risks and public company reporting relevant to investors.

The SEC coordinated extensively in the last year with CFTC and other banking regulators, 

including FRB, OCC, FDIC, the Financial Conduct Authority, and the Federal Housing 

Finance Agency (FHFA), to complete the necessary rulemakings and related implementation 

efforts to stand-up the Title VII regime for security-based swap dealers and major securitybased participants. The SEC has also been actively engaged with counterparts at CFTC to 

find ways to further harmonize the Commission’s respective rules with those of CFTC, where 

appropriate, to increase effectiveness as well as reduce complexity and costs. The agency 

remains committed to consulting and coordinating to the benefit of both agencies, as well as 

the markets and market participants they oversee.

SEC staff regularly coordinates with Treasury and other Financial and Banking Information 

Infrastructure Committee agencies to enhance the protection of our critical market 

infrastructure from physical and cyber threats and to implement protocols to address such 

threats or incidents. TM also coordinates and monitors joint self-regulatory organization 

efforts to improve the resilience of critical market infrastructure and single points of failure, 

as well as explore greater harmonization of risk mitigation functionality and rules to address 

trading issues after they occur (e.g., trade halts and trade breaks).
OTHER INFORMATION | 107

The SEC’s Strategic Hub for Innovation and Financial Technology (FinHub) coordinates 

the agency’s oversight and response regarding emerging technologies in financial, regulatory, 

and supervisory systems, including in the areas of distributed ledger technology (including 

crypto-asset markets), automated investment advice, digital marketplace financing, and 

artificial intelligence/machine learning. FinHub staff partners with sibling regulators, including 

through participation in the President’s Working Group on Financial Markets. FinHub staff 

serves as the SEC’s liaison to other regulators in the fintech space, including OCC, CFTC, 

FinCEN, FDIC, FRB, CFPB, Treasury, the Department of Justice, and the Internal Revenue 

Service. FinHub staff also collaborates with international partners through, for example, 

IOSCO, FSB, the Financial Action Task Force, the European Securities and Markets Authority, 

the Organization for Economic Cooperation and Development, and the Global Financial 

Innovation Network. 

Also, to enhance credit rating agency oversight and foster more effective supervision, the 

SEC’s Office of Credit Ratings meets quarterly with international regulators in the Supervisory 

Colleges for Credit Rating Agencies to share information related to internationally active credit 

rating agencies. The office also meets regularly with certain international regulators to share 

information regarding credit rating agency activities.

Strategic Goal 3 

Elevate the SEC’s performance by enhancing our analytical capabilities 

and human capital development.

The Office of Human Resources (OHR) participates in quarterly discussions with FDIC, 

CFTC, OCC, FHFA, the National Credit Union Association, and the Farm Credit 

Administration to benchmark benefits and work-life program offerings among the federal 

financial regulatory agencies. The goal is to benchmark program areas, share information 

about human capital management practices, and explore best practices. OHR and the 

aforementioned organizations collectively participate in a biannual survey to benchmark 

compensation and benefits programs. The survey is conducted by a third party, with the SEC 

OHR compensation team managing the contract and interagency agreements. OHR also 

participates in the Enterprise Data & Analytics Community of Practice, a collaboration effort 

sponsored by the SEC, NASAA, OCC, the General Services Administration (GSA), and the 

U.S. Department of Veterans Affairs to share human capital analytics and data visualization 

best practices.
108 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

In addition, OHR participates in a Financial Agency Rotation (FAR) program with Financial 

Institutions Reform, Recovery, and Enforcement Act of 1989 (FIRREA) agencies. FAR is an 

intra-agency detail program specifically for mid-level employees who directly work on financial 

regulatory and policy issues that aim to encourage employee development and improve interagency cooperation among financial regulators and policymakers.

The Office of the General Counsel (OGC) meets quarterly with labor law attorneys and 

labor relations specialists from the FIRREA agencies to discuss labor law issues. OGC also 

participates in a community practice group of attorneys representing federal agencies in 

employment law matters. Participants regularly schedule speakers from across the federal 

government to present on new developments in federal employment law. Members also 

participate in an active listserv to address issues of common concern.

The Office of Information Technology works with the Cybersecurity and Infrastructure 

Security Agency (CISA) on enhancing the security posture of agency information systems. 

For example, the SEC participates in CISA’s Continuous Diagnostics and Mitigation program 

and works closely with the Federal High Value Asset Program Management Office to assess 

and improve its enterprise cybersecurity risk posture.

The Office of the Chief Data Officer (OCDO) helps the SEC advance its capabilities and gain 

efficiencies by participating in regular meetings with other chief data officers from across 

the federal government to share best practices and discuss government-wide data issues and 

priorities. OCDO also actively promotes cross-agency collaboration by participating in datarelated information sharing sessions and demos with other federal agencies.

The Office of Support Operations (OSO) works closely with GSA to conduct lease 

procurements and manage most SEC facilities. Since 2011, OSO has collaborated with 

GSA to achieve annual rent savings estimated at $8.5 million via rightsizing existing 

leases upon expiration. OSO is currently coordinating with GSA on three prospectus lease 

procurement actions that are underway: SEC headquarters, the New York Regional Office, 

and the San Francisco Regional Office. OSO is also currently working with GSA on two 

non-prospectus lease procurement actions for the Fort Worth Regional Office and the 

Philadelphia Regional Office. 
OTHER INFORMATION | 109

EVIDENCE BUILDING

Internal and external evaluations play a significant role in monitoring and improving SEC 

program performance. Through objective measurement and analysis, agency managers 

determine the extent to which programs are achieving mission objectives, allowing them to 

direct SEC resources accordingly. In FY 2021, there were 6 Government Accountability Office 

reports and 10 Office of Inspector General reports or management letters issued related to 

agency operations. Beyond this, examples of reviews and evaluations the agency initiated and 

plans to continue are listed below.

The SEC conducted investor research to better understand how investors interact with 

markets, including 12 quantitative surveys supported by qualitative research involving focus 

groups and one-on-one interviews. In addition, the agency conducted surveys focused on 

improving the experience and satisfaction of investors using the agency’s online resources and 

tools. The Office of Investor Education and Advocacy and the Office of the Investor Advocate 

will continue to gather information regarding the behavior of Main Street investors, the type 

of information they need and use when making investment decisions, and the usefulness of the 

SEC’s investor education efforts and related programs.

The SEC created the Asset Management Advisory Committee (AMAC) to provide the 

Commission with diverse perspectives on asset management and related advice and recommendations. The AMAC charter provided for a two-year existence, expiring November 4, 

2021. AMAC held five meetings in 2021 and during its pendency, adopted seven sets of 

recommendations that covered topics relating to COVID-19; environmental, social, and 

governance; diversity and inclusion in the asset management industry; private investments; 

small advisers and small funds; and the evolution of advice.

On October 18, 2021, Commission staff published a report primarily examining the January 

2021 trading activity in GameStop Corp. (GME), the most well-known meme stock, against 

the backdrop of contemporaneous trading activity in other meme stocks. A meme stock 

is a stock that has seen an increase in retail investor attention not because of how well the 

company performs, but rather because of discussions on social media and online forums. In 

the report, staff raised a number of issues for additional consideration, including: 

• Events that may cause a brokerage to restrict trading, as well as matters related to clearing 

and settling;

• The use of digital engagement practices, including predictive data analytics, differential 

marketing, and behavioral prompts; 

• Equity market structure and incentives, as well as the role of dark pools and wholesalers; 

and

• The transparency and related market dynamics of short selling.
110 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

The report detailed how these meme stocks—including, but not limited to, GME—exhibited 

significant price volatility, trading volume, and attention in the markets in January 2021. The 

report also provided staff with an opportunity to consider how to further efforts aimed toward 

making the equity markets as fair, orderly, and efficient as possible. 

In late 2021, Commission staff participated in the preparation and publication of the report 

by the staff of the Inter-Agency Working Group (IAWG) for Treasury Market Surveillance, 

entitled Recent Disruptions and Potential Reforms in the U.S. Treasury Market: A Staff 

Progress Report (IAWG Report). The IAWG Report presents the views of the IAWG, which 

consists of staff from the U.S. Department of the Treasury, the Board of Governors of the 

Federal Reserve System, the Federal Reserve Bank of New York, the SEC, and the Commodity 

Futures Trading Commission. The purpose of the IAWG Report is to highlight several broad 

principles for guiding public policy in the Treasury market in light of market disruptions 

related to the onset of the COVID-19 pandemic. IAWG staff collaborated over several months 

to draft the report. 

On a quarterly basis, SEC staff queries and analyzes market data to develop market metrics for 

publication on the Commission’s Market Structure Analytics web page. This data and analysis 

are used by public and private sectors, including the Commission, to monitor markets and 

develop a deeper and more comprehensive view of market trends and dynamics, which helps 

to maintain market integrity and inform policy. 

With respect to rulemaking, the SEC continues to leverage its robust processes for obtaining 

public input and performing rigorous economic analyses of the agency’s rules at both the 

proposal and adoption stages. These efforts are critical to identifying the benefits and costs 

of regulatory actions, including situations in which a rule’s effects may not be consistent 

with expectations. For example, the Division of Investment Management (IM) pioneered the 

development of new and simplified ways for retail investors to provide feedback on proposals 

that directly affect them. These include a “feedback flyer” that allows retail investors to submit 

comments without needing to review the entire rulemaking proposal or write a letter, and the 

“Tell Us” website, which provides a portal for this feedback. The Commission also reviews 

its rules retrospectively by listening to investors and others about how rules are—or are not—

functioning as intended.
OTHER INFORMATION | 111

As part of the SEC’s ongoing response to capital markets developments during the economic 

recovery from the COVID-19 pandemic—including growth and volatility in novel and 

complex corners of capital markets such as cross-border issuances, crypto-assets, and special 

purpose acquisition companies, as well as growth in more traditional areas such as initial 

public offerings—IM has monitored company compliance with disclosure, reporting, and 

other obligations under the federal securities laws. The division has also taken a number of 

actions designed to improve compliance, ensure that investors receive material information 

to make informed investment decisions about complex investments, and promote capital 

formation and market efficiency. 

One example of an area in which the SEC has taken action is with respect to the Holding 

Foreign Companies Accountable Act (HFCAA), which became a law in December 2020. In 

March 2021, the SEC promulgated an interim final rule that implemented the disclosure and 

submission requirements of the statute. Division staff worked on this rulemaking and reviewed 

securities filings by issuers that may be subject to HFCAA. These actions ensure compliance 

with the Act and help protect investors in companies that may not be subject to the reach of 

U.S. securities laws that govern the oversight of audit firms.

The SEC reviews performance goal data on a quarterly basis. Each quarter, the Office of the 

Chief Operating Officer reviews the status of performance goals and indicators to determine 

whether the agency is on target for achieving these goals for the fiscal year. The report 

includes the quarterly result for each performance goal or indicator and the progress achieved 

toward meeting the target for the fiscal year. This review process is in line with the Office of 

Management and Budget and the Performance Improvement Council recommendations for 

frequent data-driven reviews.
112 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

LINKS TO ADDITIONAL INFORMATION 

AND RESOURCES

Reference URL

Strategic Plans, Agency Financial Reports, 

and Congressional Budget Justifications SEC.gov/about/offices/ofm/ofm-documents.htm

Investor.gov Investor.gov

Office of the Whistleblower SEC.gov/whistleblower

Enforcement Actions, Commission Opinions, 

SEC Staff Briefs, Trading Suspensions, and 

Notices Concerning the Creation of Investor 

Claims’ Funds in Specific Cases SEC.gov/page/litigation

Laws that Govern the Securities Industry SEC.gov/about/laws.shtml

Glossary of Terms and Acronyms SEC.gov/fast-answers
A Reader’s Guide to SEC Performance Information..............................................................................114

FY 2021 APR and FY 2023 APP Summary......................................................................................................114

Performance Summary by Strategic Goal...................................................................................................115

Strategic Goal 1: Focus on the long-term interests of our Main Street investors.......... 115

Strategic Goal 2: Recognize significant developments and trends in our 

evolving capital markets and adjust our efforts to ensure 

we are effectively allocating our resources ......................................................123

Strategic Goal 3: Elevate the SEC’s performance by enhancing 

our analytical capabilities and human capital development ...............127

FY 2021 Annual 

Performance Report 

(APR) and FY 2023 

Annual Performance 

Plan (APP)
114 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

A READER’S GUIDE TO SEC 

PERFORMANCE INFORMATION

The SEC is currently developing a Strategic Plan to detail the agency’s vision for the next four years 

that will be published in 2022 for public comment. 

The SEC’s strategic and performance planning framework is based on the FY 2018 – FY 2022 

Strategic Plan, which is available at SEC.gov/strategic-plan. The Strategic Plan outlines the agency’s 

mission, vision, values, strategic goals, and strategic initiatives. The SEC’s work is structured 

around 3 strategic goals that also serve as its strategic objectives, as well as 14 strategic initiatives 

the agency plans to achieve in support of those goals and objectives. 

This section comprises the agency’s FY 2021 APR and FY 2023 APP, which explain how the 

SEC uses resources to achieve each of its three strategic goals. For each strategic goal, this section 

presents the following information:

A Strategic Goal Summary: Reviews the purpose of each strategic goal and provides additional 

information to identify the resources allocated toward achieving the goal. 

Performance Goals and Indicators: Presents the performance goals and performance indicators 

by strategic goal, comparing planned and actual performance levels for FY 2020. Five years of 

historical data is provided for performance goals and performance indicators where available.

FY 2021 APR AND FY 2023 

APP SUMMARY

The SEC dedicates its resources to: (1) focusing on the long-term interests of our Main Street 

investors; (2) recognizing significant developments and trends in our evolving capital markets and 

adjusting our efforts to ensure we are effectively allocating our resources; and (3) elevating the SEC’s 

performance by enhancing our analytical capabilities and human capital development. In FY 2021, 

total SEC obligations were $1.952 billion in support of 4,459 total full-time equivalents (FTE). Of 

19 total performance targets, the agency met or 

exceeded 11; did not meet 7; and data was not 

available for 1.

The budget request for FY 2023 totals $2.149 

billion, an increase of about $197 million relative 

to the agency’s FY 2021 obligations of $1.952 

billion. The FY 2023 budget request funds 4,808 

FTEs, an increase of about 349 FTEs and 464 

positions compared to the FY 2021 level. Strategic

Goal 3

Strategic

Goal 2

Strategic

Goal 1

FY 2021 Performance Results Summary

4

6

2

3

1

2

Exceeded/Met

Not Met

Not Available

1
FY 2021 ANNUAL PERFORMANCE REPORT AND FY 2023 ANNUAL PERFORMANCE PLAN | 115

PERFORMANCE SUMMARY BY 

STRATEGIC GOAL

Strategic Goal 1 

Focus on the long-term interests of our Main Street investors.

1.1 Enhance our understanding of the channels retail and institutional investors use to access 

our capital markets to more effectively tailor our policy initiatives. 

1.2 Enhance our outreach, education, and consultation efforts, including in ways that are 

reflective of the diversity of investors and businesses. 

1.3 Pursue enforcement and examination initiatives focused on identifying and addressing 

misconduct that impacts retail investors. 

1.4 Modernize design, delivery, and content of disclosure so investors, including in particular 

retail investors, can access readable, useful, and timely information to make informed 

investment decisions. 

1.5 Identify ways to increase the number and range of long-term, cost-effective investment 

options available to retail investors, including by expanding the number of companies that 

are SEC-registered and exchange-listed. 

In FY 2021, the SEC continued its mission to protect millions of investors and instill 

confidence in the integrity of our markets by deterring misconduct and punishing wrongdoers. 

The Division of Enforcement brought hundreds of civil enforcement actions against individuals 

and companies for violation of securities laws such as insider trading, accounting fraud, 

market manipulation, and providing false or misleading information about securities and/

or the issuing companies. The Division of Examinations (EXAMS) conducted examinations 

that covered 16 percent of all registered investment advisers and, together with broker-dealer 

self-regulatory organizations, 47 percent of all registered broker-dealers. Moreover, EXAMS 

prioritized reviews of certain practices, products, and services that present heightened risks 

to retail investors, and focused on compliance with new standards of conduct rules including 

Regulation Best Interest and Form CRS. EXAMS also continued its efforts to inform investors 

and promote stronger industry compliance program by publishing Risk Alerts and other 

educational materials (SEC.gov/exams) to raise awareness of critical compliance and industry 

risks. In FY 2021, approximately $1.297 billion and 2,962 FTEs were directed at achieving 

results in Strategic Goal 1. Of the 10 performance targets, the agency met or exceeded 6 and 

did not meet 4. 
116 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

In FY 2023, the SEC will continue to promote informed investment decision-making through 

education initiatives that aim to provide retail investors with a better understanding of our 

capital markets and the opportunities and risks associated with the array of investment choices 

presented to them. The Office of Investor Education and Advocacy (OIEA) will continue to 

educate investors on the benefits of investing and encourage them to use the free financial 

planning tools and information on Investor.gov. OIEA is focused on reaching new investors, 

particularly those who are traditionally underserved, to ensure they are aware of the free 

resources available to help them make informed financial and investment decisions. The SEC 

will continue to conduct investor outreach to serve different segments of the population, 

including military and veteran communities, seniors, minority and Native American communities, women, teachers, students and young adults, and rural communities. For FY 2023, 

the agency is requesting a total of $1.444 billion and 3,194 FTEs toward achieving results 

that focus on the long-term interests of our Main Street investors. 

Goal Leader(s): Director, Office of the Investor Advocate; Director, Office of Investor 

Education and Advocacy; Director, Division of Corporation Finance; Director, Division 

of Investment Management; Director, Division of Trading and Markets; Director, Division 

of Enforcement; Director, Division of Economic and Risk Analysis; Director, Division 

of Examinations

PERFORMANCE GOAL 1

Investor research on the readability/usefulness of disclosures

Description: This metric indicates the number of times the Commission has collected data directly from 

investors through research projects such as surveys, focus groups, and one-on-one interviews in order to 

understand how investors process information to make investment decisions, and to evaluate potential methods 

for enhancing the readability or usefulness of disclosures.

Fiscal Year

FY 

2016

FY 

2017

FY

2018

FY

2019

FY

2020

FY 2021 

Plan

FY 2021 

Actual

FY 2022 

Estimate

FY 2023 

Estimate

Research Projects Prior-year 

data not 

available

4 16 2 15 6 13 6 6

Target: Exceeded

Analysis: In FY 2021, the Office of the Investor Advocate exceeded its target by leveraging materials that had 

been developed in prior fiscal years, leading to a more efficient process for conducting research.

Responsible Division/Office: Office of the Investor Advocate

Data Source: Internal Tracking Log
FY 2021 ANNUAL PERFORMANCE REPORT AND FY 2023 ANNUAL PERFORMANCE PLAN | 117

PERFORMANCE GOAL 2

Number of outreach events, roundtables, educational, and information 

sessions for different types of investors/market participants

Description: This metric indicates the number of two types of activities: (1) educational events that are designed 

primarily to provide individual investors and the general public with information about investing and the securities 

markets; and (2) outreach events that are designed primarily to engage with investors (including small business 

investors) and receive feedback about policy questions. Outreach events could include public events, meetings with 

groups of investors, or a coordinated series of one-on-one meetings (not routine meetings with advocacy groups).

Fiscal Year

FY 

2016

FY 

2017

FY

2018

FY

2019

FY

2020

FY 2021 

Plan

FY 2021 

Actual

FY 2022 

Estimate

FY 2023 

Estimate

Educational Events Prior-year data 

not available N/A 510 403 400 359 425 450

Outreach Events Prior-year data 

not available 19 40 51 29 112 35 50

Target: Educational Events – Not Met; Outreach Events – Exceeded

Analysis: In FY 2021, the SEC continued to educate retail investors by participating in investor education events 

serving different segments of the population, including military and veteran communities; seniors; minority and 

Native American communities; women; teachers; students and young adults; and rural communities. Despite 

scheduling challenges and numerous cancellations due the COVID-19 pandemic, the Office of Investor Education 

and Advocacy (OIEA) worked at more than 350 investor education events, nearly meeting its performance target. 

The Office of the Investor Advocate continued to use a virtual engagement model to conduct 112 outreach events. 

Plan for Improving Program Performance: Increasing the number of active partnerships focused on 

underserved communities will be a continued focus for OIEA during FY 2022 and FY 2023. By leveraging these 

partnerships, OIEA expects to increase the number of opportunities for in-person and virtual educational events 

serving individual investors.

Responsible Division/Office: Office of Investor Education and Advocacy; Office of the Investor Advocate

Data Source: Internal Tracking Logs
118 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

PERFORMANCE GOAL 3

Percentage of enforcement actions in which the Commission obtained 

relief on one or more claims

97% 94% 92% 95% 93% 92%

Percentage

96% 92%

0

20

40

60

80

100

FY 2023

Estimate

FY 2022

Estimate

FY 2021

Actual

FY 2021

Plan

FY 2016 FY 2017 FY 2018 FY 2019 FY 2020

92%

Description: 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.

Target: Exceeded

Analysis: In addition to securing victories in specific cases, the SEC’s litigation efforts also help the agency 

obtain appropriate settlements in other cases by demonstrating that it will pursue litigation and trial, if necessary, 

to obtain appropriate relief. The SEC endeavors to resolve actions quickly and on a favorable basis where 

practicable, while at the same time filing contested matters where favorable settlements are unavailable before 

filing. The agency seeks to direct its limited resources toward cases that are likely to have the greatest impact in 

furthering the SEC’s mission.

Responsible Division/Office: Division of Enforcement

Data Source: Case Tracking System for the Division of Enforcement
FY 2021 ANNUAL PERFORMANCE REPORT AND FY 2023 ANNUAL PERFORMANCE PLAN | 119

PERFORMANCE GOAL 4

Percentage of investment advisers and broker-dealers examined during the year

0

20

40

60

80

FY 2023

Estimate

FY 2022

Estimate

FY 2021

Actual

FY 2021

Plan

FY 2016 FY 2017 FY 2018 FY 2019 FY 2020

Percentage

11% 15% 17% 15% 15% 15% 16%

TBD

50% 48% 48% 43% 44%

15%

47%

0

20

40

60

80

FY 2023

Estimate

FY 2022

Estimate

FY 2021

Actual

FY 2021

Plan

FY 2016 FY 2017 FY 2018 FY 2019 FY 2020

INVESTMENT ADVISERS

Percentage

BROKER-DEALERS

45% 44%

15%

45%

Description: Investment advisers and broker-dealers are critical market participants in terms of their interactions 

with retail investors. This metric indicates the volume of advisers and broker-dealers examined by the SEC or 

a self-regulatory organization (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, limitedscope special inspections to probe emerging risk areas, and oversight examinations of broker-dealers to test 

compliance and the quality of examination by the Financial Industry Regulatory Authority (FINRA). 

Target: Investment Advisers – Exceeded; Broker-Dealers – Exceeded

Analysis: FY 2021 examination priorities focused on both investment advisers and broker-dealers in an effort 

to protect investors and address critical risks in the marketplace. Examinations of these firms focused on key 

issues, including cyber and information security and compliance with recently adopted rules related to standards 

of care (including Regulation Best Interest), as well as additional practices that represent significant risks to 

retail investors such as deceptive sales practices, conflicts of interest, and elder abuse. Overall, coverage rates 

in FY 2021 by the Division of Examinations (EXAMS) and broker-dealer self-regulatory organizations exceeded 

expectations and reflected the continued emphasis on these important market participants. These significant 

results were achieved despite operational and market challenges created by the ongoing global pandemic. In 

addition to its examination efforts, EXAMS also engaged extensively during the year in critical, non-examination 

regulatory outreach to registrants in response to various market events and challenges. Going forward, EXAMS 

will continue to prioritize outreach and examinations of investment advisers and broker-dealers as more and 

more individuals rely on these financial intermediaries to gain access to the financial markets.

Responsible Division/Office: Division of Examinations

Data Source: Tracking and Reporting Exam National Documentation System (TRENDS) (IA and BD SEC Data) 

and SRO Databases (BD SRO Data)
120 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

PERFORMANCE GOAL 5

Percentage of Fair Fund and disgorgement fund plans that have distributed 80 percent of 

the available funds for distribution within 24 months of the approval of the distribution plan

93% 96% 92% 93% 95%

Percentage

0

20

40

60

80

100

FY 2023

Estimate

FY 2022

Estimate

FY 2021

Actual

FY 2021

Plan

FY 2016 FY 2017 FY 2018 FY 2019 FY 2020

80%

80% 85%

98%

Description: 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 in law, 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 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.

Target: Exceeded

Analysis: In FY 2021, the Division of Enforcement exceeded the target by 18 percentage points. Going forward, 

the division will continue its efforts to prioritize the timeliness and efficiency of distributing funds, which have been 

enhanced through such efforts as centralizing certain functions and implementing various process improvements.

Responsible Division/Office: Division of Enforcement

Data Source: Case Tracking System for the Division of Enforcement 
FY 2021 ANNUAL PERFORMANCE REPORT AND FY 2023 ANNUAL PERFORMANCE PLAN | 121

PERFORMANCE GOAL 6

Number of regulatory initiatives (i.e., concept, proposing, and adopting releases and 

exemptive orders) that could impact a company’s ability to become and remain a 

public company, or that are designed to expand the number or range of cost-effective 

investment options available to retail investors

0

40

80

120

160

200

12 10 9 2

Regulatory Initiatives

Note: Data for FY 2016 – FY 2018 is not available.

10 18 21

8

101

74 68

95

FY

2019

FY

2020

FY

2021

Plan

FY

2021

Actual

FY

2022

Est.

9 15

80

INVESTMENT MANAGEMENT

EXEMPTIVE ORDERS

INVESTMENT

MANAGEMENT

RULEMAKING

CORPORATION

FINANCE

RULEMAKING

FY

2023

Est.

FY

2019

FY

2020

FY

2021

Plan

FY

2021

Actual

FY

2022

Est.

FY

2023

Est.

FY

2019

FY

2020

FY

2021

Plan

FY

2021

Actual

FY

2022

Est.

FY

2023

Est.

9 18

76

Description: The SEC staff provides policy recommendations to the Commission that are designed to promote 

capital formation while maintaining investor protection and to help improve the retail investor experience. This 

includes recommending proposed rules, final rules, public requests for comment, issuance of exemptive orders, 

and other initiatives that seek to facilitate investment product innovation, reduce regulatory burdens, and/or 

help retail investors have the tools and information they need to access and understand the investment options 

available to them.

Target: Corporation Finance Rulemaking – Not Met; Investment Management Rulemaking – Not Met; 

Investment Management Exemptive Orders – Not Met

Analysis: In FY 2021, the Divisions of Corporation Finance and Investment Management worked on 10 

proposed rules, final rules, concept releases, and guidance releases. The SEC did not meet the rulemaking 

targets for FY 2021 because the length of time required for the Commission to complete a rulemaking project 

is inherently unpredictable. Competing priorities in the Commission, as well as the time needed to develop 

policy and related rulemaking documents, were factors that contributed to the divisions not achieving their FY 

2021 target. The Division of Investment Management led rulemaking initiatives that were completed in FY 2021, 

including proposed rule amendments that are designed to improve the resiliency and transparency of money 

market funds. These also included proposed rule amendments designed to enhance the information that mutual 

funds, exchange-traded funds, and certain other funds currently report annually about their proxy votes, and to 

make that information easier to analyze.

Plan for Improving Program Performance: The SEC has assembled project teams that are actively working 

on the rule proposals and final rules that the FY 2022 and FY 2023 estimates contemplate. For exemptive orders, 

it is important to note that exemptive applications are submitted voluntarily and not required by the Commission, 

thus the actual figures may vary greatly from year-to-year depending on market developments and trends.

Responsible Division/Office: Division of Corporation Finance; Division of Investment Management 

Data Source: Internal Databases
122 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

PERFORMANCE INDICATOR 1

Number of companies that are SEC-registered and exchange-listed

Description: The estimated number of companies that are both SEC-registered (by annual filings 10-K, 20-F, 

and 40-F) and are listed on major U.S. exchanges. 

Fiscal Year FY 2016 FY 2017 FY 2018 FY 2019 FY 2020

FY 2021 

Actual

Number of Companies 4,245 4,228 4,317 4,278 4,381 5,248

Responsible Division/Office: Division of Economic and Risk Analysis 

Data Source: The Center for Research in Securities Prices (CRSP) 
FY 2021 ANNUAL PERFORMANCE REPORT AND FY 2023 ANNUAL PERFORMANCE PLAN | 123

Strategic Goal 2 

Recognize significant developments and trends in our evolving capital markets 

and adjust our efforts to ensure we are effectively allocating our resources

2.1 Expand market knowledge and oversight capabilities to identify, understand, analyze, and 

respond effectively to market developments and risks. 

2.2 Identify, and take steps to address, existing SEC rules and approaches that are outdated. 

2.3 Examine strategies to address cyber and other system and infrastructure risks faced by our 

capital markets and our market participants. 

2.4 Promote agency preparedness and emergency response capabilities. 

The capital markets are evolving rapidly, mainly as a result of technology and broad, global 

macroeconomic factors. Staying up-to-date with market trends and developments is critical 

to the SEC’s ability to remain an effective regulator. The agency regulates the major securities 

market participants, including broker-dealers, transfer agents, securities information processors, 

securities exchanges, clearing agencies, and other self-regulatory organizations such as the 

Financial Industry Regulatory Authority. In FY 2021, the SEC continued to be responsive 

and innovative in the face of significant market developments and trends. For example, the 

agency conducted 320 examinations specifically requesting information related to an entity’s 

information security, the results of which helped to evaluate whether market participants 

are actively engaged in monitoring and addressing critical cybersecurity risks. In addition to 

the examinations, there were hundreds of outreach efforts to market participants discussing 

information security, many in response to cyber-related events. These examinations and 

outreach efforts help the SEC monitor industry developments and ensure future oversight 

efforts can be appropriately planned and executed. In FY 2021, approximately $262.6 million 

and 600 FTEs were directed at achieving results in Strategic Goal 2. Of five performance 

targets, the agency met or exceeded three and did not meet two. 

Rulemaking does not stop at rule adoption. In FY 2023, the SEC will continue to identify 

outdated Commission rules that may not be functioning as intended in today’s markets. To 

support these efforts, the SEC continues to leverage its robust processes for obtaining public 

input and performing rigorous economic analyses of rules at both the proposing and adopting 

stages to provide greater depth in economic analysis and policymaking support. The SEC will 

continue identifying the benefits and costs of regulatory actions, including situations in which 

a rule’s effects may not be consistent with expectations. For FY 2023, the agency is requesting 

a total of $292.6 million and 647 FTEs to direct toward achieving results in recognizing 

significant developments and trends in the evolving capital markets. 
124 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

Goal Leader(s): General Counsel; Director, Division of Trading and Markets; Director, Division 

of Corporation Finance; Director, Division of Investment Management; Director, Division of 

Economic and Risk Analysis; Director, Division of Examinations; Director, Office of Support 

Operations; Director, Office of Information Technology 

PERFORMANCE GOAL 7

Respond to 95 percent of written requests for guidance within 90 days, in accordance 

with timeframes established by SEC policy 

Description: 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 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.

Fiscal Year

FY 

2016

FY 

2017

FY 

2018

FY 

2019

FY 

2020

FY 2021 

Plan

FY 2021 

Actual

FY 2022 

Estimate

FY 2023 

Estimate

Division of Trading and 

Markets (TM)

Prior-year data 

not available 98% 99% 95% 100% 95% 95%

Division of Investment 

Management (IM)

Prior-year data

not available 100% 100% 95% 98% 95% 95%

Division of Corporation 

Finance (CF)

Prior-year data

not available 99% 100% 95% 99% 95% 95%

Target: TM – Exceeded; IM – Exceeded; CF – Exceeded

Analysis: During FY 2021, the SEC continued to exceed its target of issuing initial comments on exemptive 

applications and guidance letters within 90 days. The Divisions of Corporation Finance, Investment Management, 

and Trading and Markets were able to achieve this level of success because providing initial comments within the 

targeted timeframe has been a continuing priority.

Responsible Division/Office: Division of Trading and Markets; Division of Investment Management; Division of 

Corporation Finance

Data Source: CCO Project Tracker (IM) and Internal Databases (CF, TM)
FY 2021 ANNUAL PERFORMANCE REPORT AND FY 2023 ANNUAL PERFORMANCE PLAN | 125

PERFORMANCE GOAL 8

Number of examinations that request information related to an entity’s information security 

229

335

374

350

Examinations

0

100

200

300

400

FY

2023

Estimate

FY

2022

Estimate

FY

2021

Actual

FY

2021

Plan

FY

2020 

FY

2019

Note: Data for FY 2016 – FY 2018 is not available.

320 325

Description: Managing cyber and information risks is critical to the operation of the financial markets. As a 

result, the SEC’s risk-based examination program will ensure that a portion of its exams each year will assess 

whether regulated entities are monitoring, managing, and appropriately addressing these types of risks. The 

results of these important reviews will inform the SEC regarding industry developments and future work in this 

area. Overall, this metric reflects the continued focus of the SEC’s examination program in this area by measuring 

the number of examinations reviewing critical cyber and information risks.

Target: Not Met

Analysis: The SEC remains focused on ensuring that regulated market participants are actively and effectively 

engaged in managing cybersecurity risks. The SEC protects and monitors developments in this area 

through examinations and outreach conducted by the Division of Examinations (EXAMS). During FY 2021, 

320 examinations specifically requested information related to an entity’s information security, the results of 

which helped to evaluate whether market participants are actively engaged in monitoring and addressing 

critical cybersecurity risks. In addition to the examinations, there were hundreds of outreach efforts to market 

participants discussing information security, many in response to cyber-related events. These examinations 

and outreach efforts help the SEC monitor industry developments and ensure future oversight efforts can be 

appropriately planned and executed.

Plan for Improving Program Performance: The performance target for this measure was set at an 

approximate level and the deviation from the target was minimal. Information security will be a continued focus 

for the Commission and the division during FY 2022 and FY 2023. EXAMS has a number of related examinations 

currently ongoing and expects to reach these estimated levels going forward.

Responsible Division/Office: Division of Examinations

Data Source: Tracking and Reporting Exam National Documentation System (TRENDS)
126 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

PERFORMANCE GOAL 9

Conduct at least a certain number of disaster recovery, crisis management, 

or incident response exercises 

Description: Emergency preparedness is tested in an annual FEMA-directed exercise (called Eagle Horizon) 

that focuses on Continuity of Operations (COOP). Additionally, the SEC will also conduct tests through Occupant 

Emergency Plan (OEP) evacuation and Shelter-In-Place (SIP) exercises, and aims to enhance its computing 

infrastructure to eliminate down time if systems at one site fail. 

Fiscal Year

FY 

2016

FY 

2017

FY 

2018

FY 

2019

FY 

2020

FY 2021 

Plan

FY 2021 

Actual

FY 2022 

Estimate

FY 2023 

Estimate

Number of Response 

Exercises 

Prior-year data 

not available 12 6 11 7 11 11

Target: Not Met

Analysis: The COOP Eagle Horizon exercise was conducted on October 5 – 7, 2021 (FY 2022), resulting in four 

of five Crisis Management exercises being completed in FY 2021. Additionally, the Office of Support Operations 

(OSO) typically conducts Incident Response evacuation drills during the spring and summer months. However, 

these drills were not conducted because most SEC staff continued to telework from home due to COVID-19. 

In total, OSO completed five of nine planned exercises in FY 2021. The Office of Information Technology (OIT) 

performed two Disaster Recovery exercises (DRE) during which services, applications, and systems were failed 

over and failed back between primary and secondary data centers. All applications, services, and systems that 

participated in these exercises were tested by the system owners and end users for their functionality. 

Plan for Improving Program Performance: Once the SEC transitions away from the mandatory telework 

posture, OSO plans to conduct Incident Response evacuation drills and Crisis Management exercises to meet 

the performance target. 

Responsible Division/Office: Office of Information Technology; Office of Support Operations 

Data Source: Data Center Services Branch and Internal Tracking Log
FY 2021 ANNUAL PERFORMANCE REPORT AND FY 2023 ANNUAL PERFORMANCE PLAN | 127

Strategic Goal 3 

Elevate the SEC’s performance by enhancing our analytical capabilities and 

human capital development.

3.1 Focus on the SEC’s workforce to increase our capabilities and leverage our shared 

commitment to investors, and promote diversity, inclusion, and equality of opportunity 

among the agency’s staff. 

3.2 Expand the use of risk and data analytics to inform how we set regulatory priorities and 

focus staff resources, including developing a data management program that treats data 

as an SEC-wide resource with appropriate data protections, enabling rigorous analysis at 

reduced cost. 

3.3 Enhance our analytics of market and industry data to prevent, detect, and prosecute 

improper behavior. 

3.4 Enhance the agency’s internal control and risk management capabilities, including 

developing a robust and resilient program for dealing with threats to the security, integrity, 

and availability of the SEC’s systems and sensitive data. 

3.5 Promote collaboration within and across SEC offices to ensure we are communicating 

effectively across the agency, including through evaluation of key internal processes that 

require significant collaboration. 

The SEC understands that maintaining a high level of staff engagement, performance, and 

morale is critical to executing its mission. In FY 2021, the agency remained committed to its 

employees as they adapted to a long-term, work-from-home posture. The agency sustained 

work schedule flexibilities and implemented updated COVID-19 leave programs in support 

of the unpredictable challenges of the pandemic environment. The SEC continued work-life 

and employee assistance programs to help employees maintain a safe and effective work space 

at home, and provided training and communications designed to maintain collaboration and 

support employee engagement in a primarily virtual environment. 

As proven by the FY 2020 Federal Employee Viewpoint Survey response and results, the SEC 

continues to achieve high scores and demonstrate improvement, including with respect to 

employee engagement and global satisfaction. In addition, the Partnership for Public Service’s 

Best Places to Work rankings recognized the SEC as one of the best agencies in the federal 

government, which further illustrates the commitment of the SEC’s talented staff, particularly 

given the challenges of the past couple of years. In FY 2021, approximately $392.5 million 

and 897 FTEs were directed at achieving results in Strategic Goal 3. Of the four performance 

targets, the agency met or exceeded two and did not meet one. The fourth target, the FY 2021 

Best Places to Work ranking results, will be released in the summer 2022.
128 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

In FY 2023, the SEC will continue to make progress on the initiatives that will enable the 

Commission to use the increasing volumes and variety of data necessary to execute the 

agency’s mission. The SEC will work to develop enhancements to the agency’s cloud and 

enterprise data warehouse capabilities to better enable SEC programs to analyze large and 

complex data more effectively, with appropriate controls to protect non-public information. 

For FY 2023, the agency is requesting a total of $437.2 million and 967 FTEs toward 

achieving results in elevating SEC performance by enhancing our analytical capabilities and 

human capital development. 

Goal Leader(s): Chief Operating Officer; Director, Office of Human Resources; Director, Office 

of Information Technology; Director, Office of Support Operations 

PERFORMANCE GOAL 10

Results of Federal Employee Viewpoint Survey 

62%

69% 71% 69% 73%

Percentage

Ranking

77%

FY

2016

FY

2017

FY

2018

FY

2019

FY

2020

FY

2021

Plan

FY

2021

Actual

FY

2022

Estimate

FY

2023

Estimate

100

80

60

40

20

0

0

2

4

6

8

10

6

5 5

3

4

Best Places to Work Ranking Cooperative Subfactor

4

73%

4 4

Ranking to be

released in

summer 2022

73% 73%

Description: The data gathered via the Federal Employee Viewpoint Survey (FEVS) will be used to determine 

the SEC’s overall success in improving employee morale and cooperation. Specifically, this performance goal will 

be measured via the Partnership for Public Service’s Best Places to Work ranking for mid-size federal agencies, 

as well as the percentage of positive responses to the cooperative subfactor of the FEVS, which focuses on 

managerial communication and collaboration.

Target: Best Places to Work Ranking – N/A; Cooperative Subfactor – Met 

Analysis: These results would not be possible were it not for the efforts of hundreds of managers, frontline 

staff, and union representatives working together to improve employee satisfaction and engagement. The SEC 

believes that this year’s results were driven in part by the agency’s continued effective response to the COVID-19 

pandemic. The FEVS program within the Office of Human Resources (OHR) focuses on driving a high response 

rate to the FEVS each year to ensure accurate results, and helping SEC divisions and offices improve their 

specific results through collaboration, use of various tools, and consulting services led by OHR.

Responsible Division/Office: Office of Human Resources 

Data Source: Annual Partnership for Public Service calculated ranking based on Annual Employee Viewpoint 

Survey (EVS) administered by the Office of Personnel Management
FY 2021 ANNUAL PERFORMANCE REPORT AND FY 2023 ANNUAL PERFORMANCE PLAN | 129

PERFORMANCE GOAL 11

Percentage of Plan of Action and Milestones (POA&Ms) closed or mitigated 

within six months from identification 

0

10

20

30

40

50

60

FY 2023

Estimate

FY 2022

Estimate

FY 2021

Actual

FY 2021

Plan

FY 2018 FY 2019 FY 2020 

50.0%

Percentage

Note: Data for FY 2016 – FY 2017 is not available.

28.1%

53.2% 54.7%

45.0%

55.0%

27.9%

1

Description: The metric captures the percent of POA&Ms closed or mitigated within six months from 

identification, as determined by the Enterprise Governance, Risk, and Compliance Capability.

Target: Exceeded

Analysis: The improved POA&Ms closure performance during FY 2021 was the result of several reporting 

enhancements implemented by the Office of Information Technology (OIT), including: (1) inclusion of this and 

several other POA&Ms performance metrics into status reports; (2) tracking POA&Ms submission due date 

changes and failed POA&M closure attempts to support more proactive identification of challenging POA&Ms; 

(3) tracking additional information about upcoming POA&Ms due dates; and (4) providing statistics related to 

common risks identified by POA&Ms to support root cause analysis. OIT presented these expanded POA&Ms 

reports to the Chief Operating Officer, Chief Information Officer, and other key management stakeholders 

consistently on a biweekly basis to improve situational awareness and support a risk-based approach to 

prioritizing mitigation efforts. OIT anticipates even further improved POA&Ms closure performance in future years 

due to continuation of the actions described, as well as new automated reminder messages and an enhanced 

extension request approval process.

Responsible Division/Office: Office of Information Technology 

Data Source: Information Securities — Enterprise Governance, Risk, and Compliance Capability

1 Beginning in FY 2019, the percentage is based on the new calculation methodology. POA&Ms are identified within a 12-month period, 

where the end of that 12-month period is 6 months prior to the reporting period.
130 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

PERFORMANCE GOAL 12

Percentage of GAO and OIG recommendations closed out within 12 months 

Description: Timely completion of audit recommendations is an important SEC priority. This metric measures 

how well the Commission is doing completing corrective action on GAO and OIG audit recommendations within 

12 months. 

Fiscal Year

FY 

2016

FY 

2017

FY 

2018

FY 

2019

FY 

2020

FY 2021 

Plan

FY 2021 

Actual

FY 2022 

Estimate

FY 2023 

Estimate

GAO and OIG

Recommendations 

Prior-year data

not available 72% 50% 67%1 65% 41% 65% 65%

Target: Not Met

Analysis: The SEC did not meet its FY 2021 target for the timely completion of corrective actions on 

Government Accountability Office (GAO) and Office of Inspector General (OIG) audit recommendations but made 

important progress in closing its aged recommendations—those outstanding for over one year. By focusing 

on these longstanding open recommendations, the SEC achieved a notable drop in the percentage of open 

recommendations that are aged, from 54 percent to 31 percent, over the course of FY 2021. Also, it is important 

to note that this metric is highly dependent on the substance of the recommendations received from GAO and 

OIG. Some recommendations can be addressed more quickly, while others may require sustained efforts that 

take in excess of 12 months.

Plan for Improving Program Performance: The SEC will continue to use data analysis, bolster efforts to 

increase transparency and accountability, and increase its use of risk assessments to help improve the agency’s 

ability to effectively address audit recommendations in a timely, risk-based manner. Specifically, the Office of 

the Chief Operating Officer (OCOO) will continue to augment its data analysis of recommendation remediation 

efforts to better identify specific efforts that may need increased resources or attention. OCOO is also developing 

additional guidance for the development of corrective action plans and providing senior management with 

enhanced transparency into the proposed actions. 

Responsible Division/Office: Office of the Chief Operating Officer 

Data Source: Audit Management System (Archer)

1 The FY 2020 percentage is based on the percentage of closed GAO and OIG recommendations submitted to the auditor for closure within 

12 months of report issuance. The change was made to more accurately measure the time it takes SEC to complete its corrective actions. 
Appendices

Appendix A: Verification and Validation of Performance Data......................................................132

Appendix B: SEC’s Responses to Government Accountability Office Reports..................133

Appendix C: SEC’S Good Accounting Obligation in 

Government Act (GAO-IG Act) Report............................................................................. 136
132 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

APPENDIX A: VERIFICATION AND 

VALIDATION OF PERFORMANCE DATA

The SEC’s programs require accurate data to properly assess program performance and 

make sound management decisions. To ensure data is correct, a system of data verification 

and validation is used. Data verification is a systematic process for evaluating a set of data 

against a set of standards to ascertain its completeness, correctness, and consistency using the 

methods and criteria defined in the project documentation. Data validation follows the data 

verification process in an effort to ensure that performance data is free of systematic error or 

bias, and that what is intended to be measured is actually measured. Together, these processes 

are used to evaluate whether the information has been generated according to specifications, 

satisfies acceptance criteria, and is appropriate and consistent with its intended use.

Below is a list of steps taken to ensure the performance data presented in this report is 

complete, reliable, and accurate.

1. The agency develops performance goals through its strategic planning process. 

2. The SEC’s divisions and offices provide: 

• The procedures used to obtain assurance as to the accuracy and reliability of the data; 

• The data definitions for reference; 

• Documentation and explanation of the performance goal calculations; and 

• The sources of the underlying data elements. 

3. The performance data is approved by the division directors and office heads. This process 

ensures that the data used in the calculation of performance goals is accurate and reliable, 

and that internal control is maintained throughout the approval process.
APPENDICES | 133

APPENDIX B: SEC’S RESPONSES TO 

GOVERNMENT ACCOUNTABILITY 

OFFICE REPORTS

The following are copies of the SEC’s responses sent to the Committees on Appropriations 

of both Houses of Congress. Substantially similar responses were sent to the Committee on 

Homeland Security and Governmental Affairs of the Senate, the Committee on Oversight 

and Government Reform of the House of Representatives, the congressional committees with 

jurisdiction over the agency program or activity that is the subject of the recommendation, the 

Office of Management and Budget, and the Government Accountability Office. 
134 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

GAO Report: “Securities Regulation: SEC Could Take Further Actions to Help Achieve 

its FINRA Oversight Goals” (GAO-21-576SU, dated July 2021)

January 25, 2022

The Honorable Patrick Leahy

Chairman

Committee on Appropriations

United States Senate

S-128, The Capitol

Washington, DC 20510

The Honorable Richard Shelby

Vice Chairman

Committee on Appropriations

United States Senate

S-128, The Capitol

Washington, DC 20510

Dear Chairman Leahy and Vice Chairman Shelby:

I am pleased to provide you with an update on the progress the U.S. Securities and 

Exchange Commission has made in implementing the recommendations of the U.S. Government 

Accountability Office (GAO) in its July 2021 report, Securities Regulation: SEC Could Take 

Further Actions to Help Achieve its FINRA Oversight Goals (GAO-21-576SU). It is the fourth

report GAO has issued under Section 964 of the Dodd-Frank Act of 2010, which requires GAO 

to report triennially on the SEC’s oversight of the Financial Industry Regulatory Authority, Inc. 

(FINRA). 

In its report, GAO notes that the Division of Examinations’ FINRA and Securities 

Industry Oversight (“FSIO”) program conducted inspections and examinations of FINRA that

included the areas specified in Section 964 of the Dodd-Frank Act. The report also made three 

recommendations to the SEC, on which FSIO continues to make progress. First, FSIO is 

working toward updating existing performance measures to reflect leading practices. The 

program also is developing policies and procedures for tracking identified deficiencies and 

associated FINRA corrective actions. Finally, FSIO is in the process of creating policies and 

procedures to identify and communicate the significance of its examination findings.

If you have any questions or would like to discuss this response in more detail, please 

contact me at (202) 551-2100, or have a member of your staff contact Kevin Burris, Director of 

the Office of Legislative and Intergovernmental Affairs, at (202) 551-2010. 

Sincerely,

Gary Gensler

Chair
APPENDICES | 135

GAO Report: “Securities Regulation: SEC Could Take Further Actions to Help Achieve 

its FINRA Oversight Goals” (GAO-21-576SU, dated July 2021)

January 25, 2022

The Honorable Rosa L. DeLauro

Chair

Committee on Appropriations

U.S. House of Representatives

H-307, The Capitol

Washington, DC 20515

The Honorable Kay Granger

Ranking Member

Committee on Appropriations

U.S. House of Representatives

1036 Longworth House Office Building

Washington, DC 20515

Dear Chair DeLauro and Ranking Member Granger:

I am pleased to provide you with an update on the progress the U.S. Securities and 

Exchange Commission has made in implementing the recommendations of the U.S. Government 

Accountability Office (GAO) in its July 2021 report, Securities Regulation: SEC Could Take 

Further Actions to Help Achieve its FINRA Oversight Goals (GAO-21-576SU). It is the fourth

report GAO has issued under Section 964 of the Dodd-Frank Act of 2010, which requires GAO 

to report triennially on the SEC’s oversight of the Financial Industry Regulatory Authority, Inc. 

(FINRA). 

In its report, GAO notes that the Division of Examinations’ FINRA and Securities 

Industry Oversight (“FSIO”) program conducted inspections and examinations of FINRA that

included the areas specified in Section 964 of the Dodd-Frank Act. The report also made three 

recommendations to the SEC, on which FSIO continues to make progress. First, FSIO is 

working toward updating existing performance measures to reflect leading practices. The 

program also is developing policies and procedures for tracking identified deficiencies and 

associated FINRA corrective actions. Finally, FSIO is in the process of creating policies and 

procedures to identify and communicate the significance of its examination findings.

If you have any questions or would like to discuss this response in more detail, please 

contact me at (202) 551-2100, or have a member of your staff contact Kevin Burris, Director of 

the Office of Legislative and Intergovernmental Affairs, at (202) 551-2010. 

Sincerely,

Gary Gensler

Chair
136 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

APPENDIX C: SEC’S GOOD 

ACCOUNTING OBLIGATION IN 

GOVERNMENT ACT (GAO-IG ACT) 

REPORT

The following information is provided pursuant to Section 2(b) of the GAO-IG Act relating to 

U.S. Government Accountability Office (GAO) and SEC Office of Inspector General (OIG) audit 

recommendations outstanding for longer than one year. Specifically, the following information is 

being submitted within the SEC’s annual budget justification submitted to Congress:

• Status of public GAO recommendations outstanding for longer than one year, along with 

whether they have a clear budget implication and the estimated completion date (Section 1);

• Status of public OIG recommendations outstanding for longer than one year, status of 

corrective actions being taken, and the estimated completion date (Section 2);

• A reconciliation of the GAO recommendations listed in this report with the 

recommendations identified on the GAO website (Section 3);

• A reconciliation of the OIG recommendations listed in this report compared with the 

recommendations shown in the latest OIG Semiannual Report (Section 4); and

• A statement by the agency regarding corrective actions on audit recommendations 

outstanding for less than one year (Section 5).
APPENDICES | 137

Section 1: Status of public GAO recommendations outstanding for longer than 

one year that are designated by GAO as “open” or “closed, unimplemented” 

recommendation status, and the estimated timeframe for completion1

Neither of the two open recommendations listed in the below table have clear budget 

implications, and the SEC is taking corrective actions on both recommendations.

SECTION 1

Status of Public GAO “Open” Recommendations

Report Number,

Title, and Date Recommendation

Recommendation Status

(Estimated Completion)

GAO-13-621

Securities and Exchange 

Commission: Improving 

Personnel Management 

Is Critical for Agency’s 

Effectiveness

(dated 7/18/2013)

The Chairman of Securities and Exchange 

Commission should direct the Chief Operating 

Officer and Chief Human Capital Officer to 

conduct periodic validations (with staff input) 

of the performance management system 

and make changes, as appropriate, based 

on these validations.

Corrective actions 

in progress 

(Q3 FY 2022)

GAO-18-256

Financial Services 

Regulation: Procedures 

for Reviews under 

Regulatory Flexibility Act 

Need to Be Enhanced

(dated 1/30/2018)

SEC should publicly disclose its section 610 

reviews, or summaries of the reviews, with the 

basis for any conclusions. Such disclosure could 

include publishing results in the Federal Register 

or on the agency’s website. 

Corrective actions

in progress

(Q4 FY 2022)

1 The SEC is not reporting on closed recommendations that are greater than five years old. The SEC does not have any recommendations 

designated by GAO as "closed, unimplemented" that are less than five years old.
138 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

Section 2: Status of public OIG recommendations outstanding for longer than one 

year, recommendation status, and estimated timeframe for completion 

There are 23 OIG recommendations in this category. 

SECTION 2

Status of Public OIG Recommendations with No Final Action Taken

Report Number, 

Title, and Date Recommendation

Recommendation Status

(Estimated Completion)

546

Audit of SEC’s Compliance 

with the Federal Information 

Security Modernization Act 

for Fiscal Year 2017 

(dated 3/30/2018)

Develop, review, and approve secure baselines 

for all systems included [redacted].

Corrective actions 

in progress 

(Q3 FY 2022)

Define and implement a process, including roles 

and responsibilities, to routinely:

(a) [redacted];

(b) perform [redacted] of all devices within the 

agency’s network; and 

(c) document, track, and address the [redacted], 

including those issues and vulnerabilities 

identified as unmitigated at the time of our audit.

Closure request submitted 

to OIG. Actions completed 

pending confirmation by 

OIG.

[redacted] Corrective actions 

in progress

(Q4 FY 2022)

549 

The SEC Made Progress 

But Work Remains To 

Address Human Capital 

Management Challenges 

and Align With the Human 

Capital Framework

(dated 9/11/2018)

Finalize standard operating procedures for the 

agency’s performance management program.

Corrective actions 

in progress

(Q3 FY 2022)

continued on next page
APPENDICES | 139

SECTION 2

Status of Public OIG Recommendations with No Final Action Taken

Report Number, 

Title, and Date Recommendation

Recommendation Status

(Estimated Completion)

552 

Fiscal Year 2018 

Independent Evaluation of 

SEC’s Implementation of the 

Federal Information Security 

Modernization Act of 2014 

(dated 12/17/2018)

Update configuration management procedures to 

require that [redacted] are approved.

Corrective actions 

in progress

(Q3 FY 2022)

Complete initiatives to implement [redacted]. Corrective actions 

in progress

(Q2 FY 2023)

558

Fiscal Year 2019 

Independent Evaluation of 

SEC’s Implementation of the 

Federal Information Security 

Modernization Act of 2014 

(dated 12/18/2019)

Complete all relevant components of the 

[redacted], including [redacted] expiration and 

review date, according to [redacted].

Corrective actions 

in progress

(Q3 FY 2022)

Develop and document a [redacted]. Corrective actions 

in progress

(Q3 FY 2022)

Develop and document a formal process to either 

prevent or detect [redacted], as well as perform 

a formal review for [redacted] in accordance 

with U.S. Securities and Exchange Commission 

[redacted].

Closure request submitted 

to OIG. Actions completed 

pending confirmation by 

OIG.

559

The SEC’s Office of BrokerDealer Finances Provides 

Effective Oversight, But 

Opportunities To Improve 

Efficiency Exist 

(dated 2/26/2020)

Finalize steps deemed feasible and prudent 

and, as necessary, (a) require broker-dealers 

to electronically file with the Commission annual 

reports and risk assessment reports, and 

(b) raise the capital threshold for reporting under 

the 17-H rules.

Corrective actions 

in progress 

(Q1 FY 2023)

continued on next page
140 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

SECTION 2

Status of Public OIG Recommendations with No Final Action Taken

Report Number, 

Title, and Date Recommendation

Recommendation Status

(Estimated Completion)

562

Opportunities Exist 

To Improve the SEC’s 

Management of Mobile 

Devices and Services 

(dated 9/30/2020)

Establish and implement comprehensive 

processes and procedures and/or update 

existing guidance to: 

(a) Require periodic reviews and reconciliations of 

mobile device usage reports, rate plan analysis 

reports, and mobile device management system 

reports to identify and address key indicators of 

potential inefficient or unauthorized use including 

overuse, underuse, or zero use; and

(b) Require periodic reviews of wireless service 

providers’ invoices to ensure unusual or 

additional charges, such as international charges, 

are accurate, are for authorized purposes, and 

are adequately supported.

Corrective actions 

in progress 

(Q3 FY 2022)

Update existing guidance to include periodic 

assessments and re-certifications of the 

continued need for mobile devices, specify 

criteria for assigning rate plans to mobile device 

users, and establish a process for communicating 

the plans’ limits to users.

Corrective actions 

in progress 

(Q3 FY 2022)

Update applicable system security plans to 

include security controls applicable to mobile 

devices identified in Federal guidance, and 

update documentation [redacted].

Corrective actions 

in progress 

(Q3 FY 2022)

continued on next page
APPENDICES | 141

SECTION 2

Status of Public OIG Recommendations with No Final Action Taken

Report Number, 

Title, and Date Recommendation

Recommendation Status

(Estimated Completion)

562

Opportunities Exist 

To Improve the SEC’s 

Management of Mobile 

Devices and Services 

(dated 9/30/2020)

Update existing policies and procedures to 

include additional controls addressing mobile 

device inventory, provisioning, applications, 

sanitization, and operating system updates. 

Specifically, OIT should update existing policies 

and procedures to: 

(a) Require a periodic reconciliation between 

[redacted] and the mobile device management 

system, and clearly define which mobile 

devices should be enrolled in the mobile device 

management system;

(b) Clearly define the roles, responsibilities, and 

processes for provisioning devices based on 

business need;

(c) Include processes for [redacted];

(d) Include processes to periodically monitor 

mobile devices for [redacted];

(e) Define the roles, responsibilities, and 

processes (including the timeline) [redacted]; and

(f) Include [redacted].

Corrective actions 

in progress 

(Q3 FY 2022)

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142 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

SECTION 2

Status of Public OIG Recommendations with No Final Action Taken

Report Number, 

Title, and Date Recommendation

Recommendation Status

(Estimated Completion)

563

Fiscal Year 2020 

Independent Evaluation of 

SEC’s Implementation of the 

Federal Information Security 

Modernization Act of 2014 

(dated 12/21/2020)

Develop and document: 

(a) Agency requirements for applying security and 

operating system updates to mobile devices in an 

organizationally defined timeframe; 

(b) [redacted]; 

(c) [redacted]; and 

(d) [redacted].

Corrective actions 

in progress 

(Q3 FY 2022)

Develop and document processes for performing 

risk-based reviews [redacted] on an organizationally defined frequency.

Closure request submitted 

to OIG. Actions completed 

pending confirmation by 

OIG.

Define and implement a process to incorporate 

results from the assessments of knowledge, 

skills, and abilities into the security training 

strategy.

Corrective actions 

in progress 

(Q3 FY 2022)

a) Identify and define the U.S. Securities and 

Exchange Commission’s Information and 

Communications Technology Supply Chain 

risks; b) develop and define a supply chain 

risk management strategy which addresses 

the agency’s Information and Communications 

Technology Supply Chain risks with respect 

to contingency planning activities; and 

c) incorporate the supply chain risk management 

strategy into contingency planning policies and 

procedures.

Closure request submitted 

to OIG. Actions completed 

pending confirmation by 

OIG.

continued on next page
APPENDICES | 143

SECTION 2

Status of Public OIG Recommendations with No Final Action Taken

Report Number, 

Title, and Date Recommendation

Recommendation Status

(Estimated Completion)

566

SEC Can Further Strengthen 

the Tips, Complaints, 

and Referrals Program 

(dated 2/24/2021)

Develop and implement an oversight process, 

policies, or controls to ensure that TCRs received 

by SEC staff are timely entered into the TCR 

system in accordance with the Commissionwide Policies and Procedures for Handling Tips, 

Complaints and Referrals.

Closure request submitted 

to OIG. Actions completed 

pending confirmation by 

OIG.

Develop and implement an oversight process, 

policies, or controls to ensure divisions and 

offices adequately and timely describe in 

TCR notes circumstances preventing timely 

resolution in accordance with applicable 

division or office policy.

Closure request submitted 

to OIG. Actions completed 

pending confirmation by 

OIG.

Assess the need to further communicate with 

and/ or train SEC employees responsible 

for entering, triaging, and disposing of TCRs 

to improve awareness of their individual 

responsibilities and the Office of Market 

Intelligence triage process.

Closure request submitted 

to OIG. Actions completed 

pending confirmation by 

OIG.

Continue efforts to plan for the acquisition of 

technologies for a new TCR system, ensuring 

those plans incorporate new system requirements, including end-user recommendations, 

as appropriate, and lessons learned from the 

existing system’s development history.

Closure request submitted 

to OIG. Actions completed 

pending confirmation by 

OIG.

Assess whether the future TCR system should 

include a reporting function for end-users, 

considering the costs and benefits of the current 

TCR reporting method and business needs, and, 

if needed, incorporate a reporting function into 

the requirements for the new TCR system.

Closure request submitted 

to OIG. Actions completed 

pending confirmation by 

OIG.
144 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

Section 3: GAO.gov Recommendation Database Reconciliation 

Section 1 of this report lists two open GAO recommendations. The GAO.gov Recommendation Database lists seven open recommendations as of March 23, 2022. The table below 

provides more detailed information on the five recommendations currently listed as “open” 

on GAO.gov but not listed in Section 1. The five are not listed in Section 1 because they have 

been outstanding for less than one year. 

SECTION 3

Analysis of Discrepancies Between Section 1 Table and GAO.gov

Recommendation Database

Report Number, 

Title, and Date Recommendation

Recommendation Status

(Estimated Completion)

GAO-21-583

COVID-19: Selected 

Agencies Overcame 

Technology Challenges to 

Support Telework but Need 

to Fully Assess Security 

Controls

(dated 9/30/2021)

The Chair of SEC should ensure that the agency 

documents relevant IT security controls and 

enhancements in the security plan for the system 

that provides remote access for telework.

Corrective actions 

in progress 

(Q4 FY 2022)

The Chair of SEC should ensure that the 

agency assesses and sufficiently documents 

the assessment of relevant IT security controls 

and enhancements for the system that provides 

remote access for telework.

Corrective actions 

in progress 

(Q3 FY 2022)

GAO-22-10536

Securities Regulation: 

SEC Could Take Further 

Actions to Help Achieve Its 

FINRA Oversight 

(dated 12/15/2021)

The Director of the Division of Examinations 

should develop FSIO performance measures that 

reflect leading practices, including measuring 

progress in achieving FSIO’s mission, setting 

targets against which actual performance can be 

measured, incorporating key elements of FSIO’s 

oversight activities, and providing information on 

the outcomes of FSIO program activities related 

to its stated mission goals and objectives.

Corrective actions 

in progress 

(Q4 FY 2022)

The Director of the Division of Examinations 

should develop and implement FSIO policies and 

procedures for tracking identified deficiencies and 

associated FINRA corrective actions, including 

establishing when and how to monitor findings 

and FINRA’s implementation of corrective 

measures.

Corrective actions 

in progress 

(Q4 FY 2022)

The Director of the Division of Examinations 

should develop and implement FSIO procedures 

to identify and communicate the significance of 

its inspection and examination findings.

Corrective actions 

in progress 

(Q4 FY 2022)
APPENDICES | 145

Section 4: OIG Semiannual Report Reconciliation

There are nine discrepancies between Table 4 in the OIG Semiannual Report dated 

April 1, 2021 – September 30, 2021 (OIG Report) and the table presented in Section 2 

of this report. All nine discrepancies exist because the OIG has closed these recommendations 

since the release of the OIG Report. 

SECTION 4

Analysis of Discrepancies Between Section 2 Table and OIG Semiannual Report

Recommendations Listed in OIG Semiannual Report

Report Number, 

Title, and Date Recommendation

Recommendation Status

(Estimated Completion)

546

Audit of SEC’s Compliance 

with the Federal Information 

Security Modernization Act 

for Fiscal Year 2017 

(dated 3/30/2018)

Review and update incident response plans, 

policies, procedures, and strategies to (a) address 

all common threat and attack vectors and the 

characteristics of each particular situation; 

(b) identify and define performance metrics 

that will be used to measure and track the 

effectiveness of the agency’s incident response 

program; (c) develop and implement a process 

to ensure that incident response personnel 

obtain data supporting the incident response 

metrics accurately, consistently, and in a 

reproducible format; (d) define incident response 

communication protocols and incident handlers’ 

training requirements; and (e) remove outdated 

terminology and references.

Closed by auditors 

on 11/4/2021

552 

Fiscal Year 2018 

Independent Evaluation of 

SEC’s Implementation of the 

Federal Information Security 

Modernization Act of 2014 

(dated 12/17/2018)

Complete initiatives to implement [redacted]. Closed by auditors 

on 1/1/2022

continued on next page
146 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

SECTION 4

Analysis of Discrepancies Between Section 2 Table and OIG Semiannual Report

Recommendations Listed in OIG Semiannual Report

Report Number, 

Title, and Date Recommendation

Recommendation Status

(Estimated Completion)

556

The SEC Can More 

Strategically and Securely 

Plan, Manage, and 

Implement Cloud 

Computing Services 

(dated 11/7/2019)

Develop a roadmap and implementation plan for 

cloud migration that provides for evaluating the 

agency’s information technology portfolio; prioritizing systems and services for migration to the 

cloud, as appropriate, based on potential benefits 

and risks; and tracking of cloud-related goals.

Closed by auditors 

on 12/1/2021

Develop policies and procedures to ensure 

the following for all new and existing cloud 

computing services: 

(a) Applicable cloud system security controls and 

enhancements are included in the respective SEC 

cloud-based system security plan. 

(b) Applicable cloud system security controls 

and enhancements are assessed and supported 

by sufficient evidence in the respective SEC 

cloud-based system security assessment report. 

(c) The SEC authorizing official is provided with 

complete and appropriate information necessary 

to make risk-based decisions on whether to 

authorize the agency’s cloud systems to operate.

Closed by auditors 

on 1/11/2022

558

Fiscal Year 2019 

Independent Evaluation of 

SEC’s Implementation of the 

Federal Information Security 

Modernization Act of 2014 

(dated 12/18/2019)

a) Develop a methodology to demonstrate the 

control assignments from National Institute of 

Standards and Technology Special Publication 

800-53, Revision 4, including control tailoring and 

inheritance; and

b) Update the Securities and Exchange 

Commission’s System Security Plan templates to 

ensure control tailoring justification corresponds 

to the methodology covered in part a).

Closed by auditors 

on 12/23/2021

563

Fiscal Year 2020 

Independent Evaluation of 

SEC’s Implementation of the 

Federal Information Security 

Modernization Act of 2014 

(dated 12/21/2020)

Develop and document a process to consistently 

[redacted].

Closed by auditors 

on 11/4/2021

continued on next page
APPENDICES | 147

SECTION 4

Analysis of Discrepancies Between Section 2 Table and OIG Semiannual Report

Recommendations Listed in OIG Semiannual Report

Report Number, 

Title, and Date Recommendation

Recommendation Status

(Estimated Completion)

564

The SEC’s OIEA Could 

Benefit From Increased 

Coordination, Additional 

Performance Metrics, and 

Formal Strategic Planning 

(dated 1/13/2021)

Develop and implement methods, including 

specific performance metrics, to measure the 

impact and efficacy of its investor education 

program.

Closed by auditors 

on 1/19/2022

565

The SEC Has Taken Steps 

to Strengthen Its Monitoring 

of ISS Contractor’s 

Performance, But Additional 

Actions Are Needed 

(dated 2/24/2021)

Evaluate quality assurance surveillance guidance 

available in the Office of Acquisitions’ Contract 

Administration Guide and incorporate applicable 

guidance and examples into the agency-wide 

contract administration policies to ensure 

oversight personnel understand its applicability 

and develop timely contract quality assurance 

surveillance plans.

Closed by auditors 

on 10/15/2021

Update the agency’s policies and procedures to 

enhance the timely and quality reporting of past 

performance information by clarifying Contractor 

Performance Assessment Reporting System 

report (1) due dates, and (2) narrative contents 

to more fully support contractor ratings, in 

accordance with Federal Acquisition Regulation 

requirements and government-wide guidance.

Closed by auditors 

on 10/15/2021
148 | FY 2023 CONGRESSIONAL BUDGET JUSTIFICATION

Section 5: Recommendations outstanding for less than one year, for which the 

agency is determining whether to implement the recommendation 

As of March 23, 2022, the SEC has 30 OIG and 5 GAO recommendations outstanding for 

less than one year. The agency is in agreement with all 35 recommendations and is currently 

implementing corrective action plans.
The SEC’s FY 2023 Congressional Budget 

Justification/Annual Performance Plan and 

FY 2021 Annual Performance Report were 

successfully produced through the efforts 

of our talented staff. To these individuals, we 

offer our sincerest appreciation. To comment 

on this report, please send an email to 

OFM_budget_formulation@sec.gov.
U.S. Securities and Exchange Commission

Washington, DC 20549

SEC.gov