Securities and Exchange Commission: Preliminary Observations on SEC's Spending and Strategic Planning
Published: 2003-07-23T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: In February 2003, the Securities and Exchange Commission (SEC) received the largest budget increase in the history of the agency. The increased funding was designed to better position SEC to address serious issues identified in the Sarbanes-Oxley Act and to better enable SEC to address numerous operational and human capital management challenges discussed in the GAO report entitled SEC Operations: Increased Workload Creates Challenges (GAO-02-302). To help ensure that SEC spends its budgetary resources in an efficient and effective manner, GAO was asked to review the SEC's efforts to address the issues raised in the 2002 report and to report on how SEC intends to utilize its new budgetary resources. GAO's final report on these matters is expected to be completed this Fall. This testimony provides requested information on the status of SEC's current spending plan and preliminary observations on SEC's strategic and human capital planning efforts.
section_title: What GAO Found
paragraphs: In GAO's 2002 operations report, GAO identified a number of operational challenges facing SEC stemming from an increasing workload (e.g., filings, applications, and examinations) and staffing imbalances that threatened to impair SEC's ability to fulfill its mission. SEC's workload had grown at a much higher rate than its staffing since the mid- 1990s. In response to congressional concerns involving a number of highprofile corporate failures and accounting scandals, SEC's funding was increased 45 percent in 2003. SEC plans to spend most of its 2003 and 2004 budget increases to fund 842 new staff positions and double its information technology budget. However, given the late appropriation and hiring challenges, SEC has to date filled few of these positions, and it is unlikely that SEC will be able to utilize all of its 2003 funds. GAO also found that SEC recognizes the need to develop a new strategic plan and that such a plan is a vital component of its staff allocation and human capital planning processes. A new strategic plan is also vital to SEC's ability to develop performance-oriented, outcome-based performance measures. GAO found that while SEC has not updated its strategic plan, it has begun efforts to overhaul its performance measures to make them more outcome-oriented. This effort seems premature given its lack of a new strategic plan. Moreover, while GAO found that SEC has completed certain aspects of a strategic human capital plan, including development of a new pay structure comparable to other federal financial regulators, greater flexibility to expedite the hiring of certain critically needed professions, plans for more training, and implementation of agencywide-worklife programs, the lack of a new strategic plan inhibits SEC's ability to develop a formal human capital plan.

section_title: Letter
paragraphs: I am pleased to be here today to discuss the Securities and Exchange  Commission’s (SEC) plans for spending the significant increases in its  2003 budget appropriation and its 2004 budget request as well as its  response to our recommendations for enhancing its strategic planning and  human capital planning processes, which are critical ingredients for  ensuring that the new appropriations are put to the best possible use.
As you know, in March 2002 we issued a report entitled SEC Operations:  Increased Workload Creates Challenges (GAO-02-302), which identified  numerous resource challenges SEC faced as its workload increased in  volume and complexity. We also cited other issues, including a turnover  rate among accountants, attorneys, and examiners that was almost twice  as high as the governmentwide average for comparable positions that was  draining staff from SEC and slowing its operations. To address these  issues, we recommended, among other things, that SEC broaden its  strategic planning process to systematically determine its regulatory  priorities and the resource levels needed to fulfill its mission. We also  recommended that SEC engage in a comprehensive coordinated  workforce planning effort to ensure that critical human capital goals and  strategies were implemented.
In the wake of several high-profile corporate failures and accounting  scandals, in February 2003 SEC was given the largest spending increase in  its history. Given this substantial budget increase and the importance of  efficiently and effectively utilizing these gains, you requested that we  review SEC’s efforts to address the issues we raised in March 2002 and  report on how well SEC has utilized its new budgetary resources. We  expect to complete our report on these matters in the Fall. In advance of  the completion of this study, this statement provides requested  information on the status of SEC’s current spending plans for 2003 and  2004 and preliminary observations on SEC’s strategic planning and human  capital planning efforts.
Our observations about the status of SEC’s 2003 and 2004 spending plans  and related planning activities to date are based on our review and  independent analysis of workload, budget, and staffing data provided by  SEC officials or presented in SEC’s 2003 revised budget estimate and 2004  budget request. In addition, we solicited views from a variety of SEC  officials, collected relevant information on SEC’s strategic planning and  human capital efforts, and analyzed statistics on staff turnover. This study  was completed in accordance with generally accepted government  auditing standards.
In summary, the 2003 appropriation of $716 million in February 2003  increased SEC’s budget 45 percent over its previous year’s spending level,  giving it additional resources to address critical staffing shortages and  information technology needs, among other things. However, SEC spent  the first 5 months of the fiscal year operating under a continuing  resolution and thus could not fully implement a spending plan based on its  new budget authority.  In addition, SEC faced difficulties in hiring  accountants, economists, and examiners, further constraining its ability to  acquire needed expertise. Once it received its 2003 appropriation, SEC  determined that most of its increase would be used to fund new positions  and upgrade its technological resources, including doubling the operating  budget of the Office of Information Technology. However, given the late  appropriation and hiring challenges, to date SEC has filled few of these  positions, and it is unlikely that SEC will be able to fully utilize all of its  2003 funds.
We also found that SEC recognizes that it needs to develop a new  agencywide strategic plan and that such a plan is a vital component of its  workforce planning and human capital allocation process. However, SEC  has embarked on an effort to allocate resources and determine its needs  without the benefit of an updated strategic plan. Instead, SEC has relied  on views from its senior managers and on an internal study commissioned  by then Chairman Pitt that assessed the commission’s workload and  evaluated the resources available for doing that work. This study,  currently under review by Chairman Donaldson, has not been widely  distributed throughout the organization. We commend SEC for conducting  this study. Its findings confirm many of the workload and resource  challenges we discussed in our March 2002 report, and it includes  numerous recommendations for improving the agency’s operations.  SEC  has also initiated a number of other efforts but because all of them are  grounded in SEC having a clear strategic direction and goals, all of them  hinge on SEC completing a new strategic plan. Among these are efforts to  develop more outcome-oriented performance measures to gauge the  effectiveness of its regulatory operations in fulfilling its statutory mission  and formalization of its strategic human capital plan.
subsections: section_title: SEC Plans to Spend Most of Its Budgetary Increase on Staffing and Information Technology
paragraphs: In March 2002, we reported that SEC’s workload and staffing imbalances  had challenged SEC’s ability to protect investors and maintain the integrity  of securities markets. Appendix I graphically depicts SEC’s workload and  staffing imbalance from 1990 through 2000 as reported in our 2002 report  and appendix II updates this graphic using SEC budget documents  including its 2003 and 2004 workload and staffing estimates. As reported in  March 2002, we found that SEC generally managed to bridge the gap  between its workload and staff by determining which of its statutorily  mandated duties it could accomplish with existing resources or only  marginally increased resource levels. This approach, while practical,  forced SEC to be largely reactive rather than proactive. We also reported  that SEC tended to develop its annual budget request based on the  previous year’s appropriation rather than on what it would actually need  to fulfill its mission. In 2003, this practice resulted in a modest increase  over the previous year’s request. But several high-profile corporate failures  and accounting scandals, plus concerns that public companies should be  held more accountable for information they report to investors, led  Congress to pass the Sarbanes-Oxley Act of 2002 (Sarbanes-Oxley Act).  The act addresses a number of concerns involving corporate governance,  auditor independence, regulation and oversight of the accounting  profession, and SEC’s resource limitations. In part because of the level  authorized in the Sarbanes-Oxley Act, SEC increased its initial 2003 budget  request of $466 million to $769 million. Ultimately, Congress appropriated  $716 million. For 2004, SEC requested a budget of almost $842 million  reflecting a supplemental carryover, annualization of new 2003 positions,  inflation (pay and nonpay), and merit pay increases less one-time 2003  information technology costs.
subsections: section_title: A Significant Portion of SEC’s Budget Increase Has Been Allocated to New Staff Positions
paragraphs: SEC’s planned allocations appear to be consistent with the Sarbanes-Oxley  Act, which mandated that the $776 million authorization be used to:  fund pay parity, allowing SEC to set salaries for certain staff positions  at levels comparable to those at other federal financial regulators;  fund information technology, security enhancements, and recovery and  mitigation activities in light of the terrorist attacks of September 11,  2001; and  fund no fewer than 200 additional professional staff to increase  oversight of auditors and audit services in order to improve SEC’s  investigative and disciplinary efforts as well as additional professional  support staff necessary to strengthen existing program areas.
SEC’s allocations were also apparently influenced by its internal review of  operations and resource needs and on justifications made by each division  and office. SEC determined that most of the planned increase would be  used to hire an additional 842 staff, primarily accountants, attorneys, and  examiners, and to upgrade its technological resources over the next few  years.
Table 1 provides information on SEC’s staff allocation as of July 1, 2003,  by program area. The 2002 numbers include 125 new positions that were  authorized by a supplemental appropriation to SEC’s 2002 budget to deal  with the increasing workload from financial fraud and reporting cases, to  improve and expedite the review of periodic filings, and to deal with new  programmatic needs and policy. According to an SEC official, the current  and proposed budgets factor in the increased workload resulting from  SEC’s new responsibilities under various new laws including the Sarbanes- Oxley Act, Gramm-Leach-Bliley Act, and Commodity Futures  Modernization Act. For example, between 2002 and 2004, the full  disclosure program is slated to receive the largest percentage increase in  positions  39 percent. This program includes the Division of Corporation  Finance and the Office of the Chief Accountant, which are responsible for  reviewing the financial statement filings for over 17,000 reporting public  companies and providing rule-making and interpretive advice. In this area,  staffing is driven in part by the Sarbanes-Oxley Act, which requires SEC to  review the financial statements of each reporting company every 3 years.  In 2002 SEC’s average translated into a review once every 6 years. The  area slated to receive the next largest percentage increase (35 percent) is  the supervision and regulation of securities markets. This program  includes the Division of Market Regulation and part of the Office of  Compliance, Inspections and Examinations and is responsible for  establishing and maintaining policies for fair, orderly, and efficient  markets and conducting examinations and inspections of 9 registered  securities exchanges and an estimated 8,000 brokerage firms among  others. The prevention and suppression of fraud program, which includes  the Division of Enforcement, is slated to receive a 21 percent increase,  which SEC said would help with the increasing number of investigations  into possible violations of securities laws.
SEC’s staff allocations appear consistent with legislative requirements and  what is currently known about its operating environment. However,  because SEC’s staff positions were allocated without the benefit of a  strategic plan, we are unable to fully assess the appropriateness or  effectiveness of this use of its budget increase.
Given that staff salaries and benefits average about 70 percent of SEC’s  budget, we would expect the spending allocations to roughly correlate to  its staffing allocations. However, SEC was unable to provide us  information to analyze SEC’s budgetary allocation across each program  area. At the time of this study, SEC was in the process of completing its  2005 budget request for OMB, which will include its allocation of its  budgetary resources for its 2004 budget estimate by program area. SEC  expects to have these estimates completed by sometime in late August or  early September.
In 2002, we reported the difficulty SEC faced in hiring accountants for the  125 positions authorized by its 2002 supplemental appropriation. SEC had  identified the existing competitive service hiring requirements as  hampering its ability to fill these and other positions because of the length  of time involved. SEC subsequently asked for and received relief from  competitive hiring requirements under the Accountant, Compliance and  Enforcement Staffing Act of 2003, which was enacted in July 2003. This  new legislation is designed to enable SEC to expedite the hiring of  accountants, economists, and examiners so that the agency can more  quickly fill the 842 positions created. As of July 1, 2003, SEC has only filled  a few of the vacancies for the allocated positions but is now better  positioned to hire under its new authority. It is too soon to determine  whether this new authority will enable SEC to quickly fill the hundreds of  vacancies it needs to fill by the end of 2004.
section_title: Information Technology Will Also Receive a Significant Increase
paragraphs: Information technology was another area identified in our 2002 report as  having funding gaps that had contributed to existing inefficiencies. Like  the rest of the government, SEC’s needs in the area of information  technology continue to increase, and SEC staff must have the necessary  tools to successfully meet the agency’s increasing demands. SEC  maintains a list of technology improvement projects that have not been  funded due to budgetary constraints, which SEC officials said include  applications to improve the manipulation and connectivity of various SEC  data systems and computerized reports. The budget increase has allowed  SEC to begin improving its information technology capabilities. SEC’s  Office of Information Technology, which supports the agency’s  information systems and computer users, received an increase in its 2003  operating budget of more than 100 percent, from around $44 million to  $100 million. Our understanding is that SEC plans to undertake a few small  projects each year such as system upgrades and software purchases, to  enhance its systems and will implement larger long-term projects over  time. SEC began developing an enterprise architecture a strategic  approach to information technology planning in 2001. This architecture is  designed to allow SEC to fund and develop information technology  initiatives based on agencywide needs by strategically identifying and  organizing technology projects. In 2002, SEC continued to develop its  enterprise architecture in order to identify and document relationships  between agency business functions and supporting technologies. SEC  management also began incorporating the enterprise architecture into its  information technology capital planning process. Although most of SEC’s  long-term projects are in the developmental stages, we are cautiously  optimistic that, if properly implemented, they can improve SEC’s  operational efficiencies. Some of these longer-term projects include    Converting SEC’s Electronic Data Gathering Analysis and Retrieval  (EDGAR) system into a searchable database that would help SEC conduct  various types of industry and trend analyses.  EDGAR is the database  system that public companies use to file registration statements, periodic  reports, and other forms electronically. Currently, EDGAR receives and  archives data, but staff cannot immediately and easily analyze it. The goal  is to create filings that will allow anyone to extract relevant data.
Implementing a document management and imaging initiative, intended to  eventually eliminate paper documents and allow SEC staff to review and  electronically file the large volumes of information that are part of  litigation, examination, and enforcement activities. Staff told us that the  planned system will provide an agencywide electronic capture, search, and  retrieval mechanism for all investigative and examination materials.
Implementing a disaster recovery program that is being designed to store  and move large amounts of data among regional or district offices without  first going through Washington, D.C. The current project, when completed,  will allow the agency to back up critical information and data on a daily  basis at multiple locations.
section_title: SEC Has An Outdated Strategic Plan and An Incomplete Human Capital Plan
paragraphs: In 2002, we found that SEC had not engaged in a comprehensive  agencywide strategic planning process and little has changed in this regard  in 2003. As we have previously reported in earlier reports, high-performing  organizations identify their current and future human capital needs— including the appropriate number of employees, the key competencies  needed, and plans for deploying staff across the organization—and then  create strategies to fill any gaps. Given the SEC’s role in the securities  industry’s self-regulatory structure, a critical element of SEC’s strategic  planning process is an evaluation of the external environment in which the  agency operates. SEC’s budget increase has heightened the need for  strategic planning and the significance of the process, as SEC’s spending  plan will have to withstand considerable scrutiny. SEC’s lack of a current  strategic plan may also affect other aspects of SEC’s operations as  strategic plans are the starting point for each agency’s performance  measurement efforts and should provide the basis for strategic human  capital planning.
subsections: section_title: SEC’s Internal Study Provides a Framework for Strategic Planning
paragraphs: In 2002, SEC took a critical step toward developing a strategic plan when  it conducted an internal study of SEC’s current operations, workload,  resource allocations, methods for assigning and managing work, and  measures of performance, productivity and quality of effort. The study,  which was facilitated by a consulting firm (McKinsey & Company) and  includes discussions of staffing and resource allocation issues, appears to  have been a factor in SEC’s allocation of many of the 842 new positions.  But this confidential study has not been widely distributed within SEC,  and it is unclear whether it will be in the near future. This study serves as a  useful framework for SEC as it begins developing a dynamic  comprehensive strategic plan that will better enable it to identify its  mission and staffing needs. More immediately, such an effort is vital as it  determines how best to use its additional resources. We acknowledge that  over the past year and a half, SEC has had to deal with a considerable  amount of change, which has limited its ability to focus on a new strategic  plan. SEC has had to acclimate itself to two new chairmen and adjust to  new management teams, manage a 45 percent budget increase, negotiate  its first agreement with its newly organized union, implement and manage  a new fee rate structure, prepare for its first financial statement audit, and  respond to dozens of new requirements under the Sarbanes-Oxley Act.  However, since SEC issued its existing plan in September 2000, the  financial world has changed significantly.
Although SEC’s Government Performance and Results Act (GPRA) annual  reports attempt to provide a tactical focus, a new long-range planning  effort is long overdo. As stated in SEC’s 2000 plan, “Our strategic plan is a  living document, one that must be continually reexamined and modified to  assure it remains responsive and relevant in an ever-changing  environment.” In addition to the changing external environment, a number  of internal processes and organizational efforts within SEC hinge on SEC  completing a new strategic plan, including developing more outcome- oriented performance measures to gauge the effectiveness of its regulatory  operations in fulfilling its statutory mission and formalizing its strategic  human capital plan. Rather than measuring outputs, SEC is working to  develop measures for how effectively its actions achieve its goals and  fulfill its mission. SEC is also beginning to take steps that will improve its  ability to leverage its technological capabilities.
section_title: SEC Has Embarked on an Effort to Develop Outcome-Oriented Performance Measures
paragraphs: Consistent with the findings in our March 2002 report, SEC’s subsequent  GPRA 2002 annual performance report continued to use measures of  outputs rather than outcomes. For example, under the goal of protecting  investors by improving public awareness and educating investors, SEC  tracks the number of investor education events organized by senior  Commission staff in a given year. Within the goal of maintaining fair,  honest, and efficient markets SEC uses the number self-regulatory  organization rule changes reviewed as a measure of performance. As we  reported, performance measures can help to provide detailed information  SEC needs to make informed workforce decisions, including (1) the  relationship between its budget request for full-time equivalent staff years  and the agency’s plans and ability to meet individual strategic goals and  (2) any excesses or shortages in needed competencies.
In late June, SEC began to take steps to transform its annual plan into a  management tool aimed at helping SEC move to a more outcome-oriented  approach to measuring the performance of its regulatory activities—an  important part of strategic planning. To achieve this end, each program  area is to develop a “performance dashboard”—a collection of measures  identifying those key performance measures that will allow each program  area manager to track performance. This movement to a performance  dashboard, also involves managing the budget at the program level with  each division head being held accountable for managing its individual  budgetary resources.
While this outcome-oriented approach is promising, we are concerned that  SEC is developing new performance measures before it has completed or  even started its new agencywide strategic plan. By identifying  performance measures before it develops a new strategic plan, SEC runs  the risk of having to redo any measures that are inconsistent with its  newly defined strategic vision or allowing the existing measures to  constrain its planning so that the new plan is consistent with them. We see  this approach as analogous to a commuter rail company exploring the  most efficient way to expand rail service to a new location before deciding  whether that location is the best place for the new line.
section_title: An Agencywide Strategic Plan is Vital to a Strategic Human Capital Plan
paragraphs: We are also reviewing the status of SEC’s strategic human capital  planning. As you may recall, in our September 2001 report, we examined  SEC’s strategies for managing its human capital and found that its human  capital practices were driven by its need to confront its growing staffing  crisis. This crisis was evidenced in a turnover rate that was almost twice  the government average for attorneys, accountants, and examiners;  hundreds of vacant positions; and the average tenure for examiners and  attorneys had fallen below 3 years.  We found that to counter its  compensation challenge, SEC—more than the rest of the government— was aggressively using special pay rates and retention allowances to  improve staff compensation. However, such actions were not stemming  their turnover problems. We also identified a number of nonpay issues that  threatened to impair SEC’s ability to carry out its mission and thus  warranted SEC management’s attention.
As we have reported, strategic planning is a key part of human capital  management. Strategic human capital planning focuses on developing  long-term strategies for acquiring, developing, and retaining an  organization’s employees and for implementing human capital approaches  that are clearly linked to achieving programmatic goals. In our 2001  human capital report, we found that SEC had begun to take key steps  toward developing a strategic human capital plan but lacked adequate  succession planning because of its high turnover rate. Moreover, we found  that SEC had not articulated the details of its plans for carrying out its  recruiting and retention efforts. SEC also lacked any formal mechanism to  evaluate the effectiveness of its recruiting efforts and ways to gauge the  effectiveness of its worklife programs. We also found that SEC had not  created a culture that ensured ongoing attention to human capital issues,  that human capital management was still focused on traditional personnel  functions, and that it was not a priority for senior management in  decisionmaking. We made a number of recommendations to SEC aimed at  improving its human capital management, including a recommendation  that it expand its annual performance plan into a comprehensive human  capital plan that includes all program areas.
We are looking into SEC’s progress in the above identified areas. However,  we have found that SEC has not yet developed a formal strategic human  capital plan that articulates how it intends to align its human capital  approaches with its organizational goals. While it has yet to do this, we  have found that SEC continues to take important steps to improve its  strategic human capital management. First, as previously discussed, SEC  has taken steps to improve its recruiting/hiring process. Second, SEC has  begun to take steps to develop its people and has announced plans for an  agencywide training program. One key training component that is  currently in the early stages of development is targeted training for  supervisors—which was an area identified in our 2001 human capital  report as warranting management’s attention. However, it is too soon to  determine the effectiveness of this new training effort.
Third, SEC has taken actions to retain its human capital and address its  staffing crisis. Most significantly, SEC has negotiated an agreement with  the union, which outlines a uniform program for various worklife  programs, such as flextime, flexiplace, and tuition reimbursement, among  others, and has standardized various of these human capital policies.  Historically, many of these programs have varied by division and office.  SEC has just begun to review the use and effectiveness of these programs,  therefore, it is too soon to determine what effect, if any, they will have on  employee retention and morale.
In our 2001 report we found that the single largest retention issue among  attorneys, accountants, and examiners involved compensation.  To  enhance SEC’s ability to adequately compensate its employees, Congress  enacted legislation that allows SEC to create a new pay system. In May  2002, acting on its new compensation authority, SEC implemented a new  system, which established a pay structure more comparable with other  federal financial regulators. This new pay structure increased base pay for  attorneys, accountants, and examiners similar to that of other federal  financial services regulators. More specifically, this new system structure  consists of 20 grade levels, some with up to 31 steps. This new system has  also provided additional compensation based on performance and has  established new pay categories to compensate staff in supervisory  positions. In conjunction with this new merit-based compensation system,  SEC has also implemented a new performance management system, which  is also an important part of the human capital planning process.
Since our 2001 human capital report, we found that at least one symptom  of SEC’s staffing crisis has improved. SEC’s turnover rate for attorneys,  accountants, and examiners has decreased from 9 percent in 2001 to 6  percent on average in 2002, which in part may be attributed to pay parity.   To date SEC reports that its average turnover rate is about 4 percent.  However, the declining turnover rate may also reflect the state of the  economy and resulting changes in the job market.
section_title: Observations
paragraphs: SEC’s dynamic regulatory environment and tumultuous past year has  made focusing on a strategic direction and vision for the agency difficult.  Moreover, because SEC operated under its 2002 allocation for five months  of the year, and had difficulty hiring needed expertise, it has been unable  to fully implement its 2003 spending plan. Although SEC has begun to take  a number of important steps aimed at addressing its operational and  human capital challenges, additional work is needed to ensure that it has  appropriately positioned itself to operate more efficiently and effectively  in the 21st century. First, it is critical that SEC complete its strategic  planning effort, which includes the systematic reevaluation of all of its  current approaches, efforts, goals and activities in light of its current  regulatory environment. An important part of any such effort would  include working with the industry to ensure that SEC has accurately  established priorities that reflect the current environment. For example,  SEC would be benefited by reevaluating its existing rules, regulations, and  regulatory approaches to ensure that they continue to reflect the realities  of today’s financial markets and are consistent with the mission and goals  established by SEC. Second, a critical step involves identifying ways to  leverage existing resources, be it through better technology or regulatory  processes. For example, SEC needs to fully fund and follow through on  technology initiatives that offer the greatest opportunities to increase its  effectiveness. SEC’s technology evolution could perhaps be one of the  most important aspects in improving the efficiency of SEC’s operations  and will likely require a sustained and ongoing resource commitment. SEC  could also reevaluate its historical focus in areas such as small businesses  and initial public offerings to ensure that it continues to meet the needs of  the securities markets. Finally, aligning SEC’s human capital with its  strategic plan is an important part of strategic human capital planning. To  date, SEC has taken important steps aimed at establishing a coordinated  human capital management approach but still lacks a formal plan.
Thank you for your attention to SEC’s operations and planning processes.  The leadership this subcommittee has shown, by holding this hearing  should help to maintain the momentum needed for change at SEC. Mr.  Chairman, this concludes my prepared statement. I would be pleased to  answer any questions you or other members of the subcommittee may  have at this time.
section_title: Contacts and Acknowledgements
paragraphs: For further information regarding this testimony, please contact Orice M.  Williams at (202) 512-8678. Individuals making key contributions to this  testimony include Toayoa Aldridge, Joe E. Hunter, Jose Martinez-Fabre,  and David Tarosky.
section_title: Appendix II: Percent growth in SEC staff years and workload, 1991 - 2004
paragraphs: This is a work of the U.S. government and is not subject to copyright protection in the  United States. It may be reproduced and distributed in its entirety without further  permission from GAO. However, because this work may contain copyrighted images or  other material, permission from the copyright holder may be necessary if you wish to  reproduce this material separately.