Report On The Implementation Of Sec Organizational Reform Recommendations - U.s. Securities And Exchange Comission - 2011 Page 5

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U.S. S
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ECURITIES AND
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SEC O
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ECOMMENDATIONS
The Boston Consulting Group’s Assessment of SEC Organization and Operations
In October 2010, with the express purpose of carrying out the assessment required by Section 967
of the Dodd-Frank Act, the SEC engaged the services of the Boston Consulting Group, Inc. (BCG),
a top-tier organizational consulting firm with significant capital markets expertise, to conduct a
broad and independent assessment of the SEC’s internal operations, structure, funding and the
agency’s relationship with SROs. BCG was selected to conduct the assessment following a
competitive acquisition process conducted in accordance with government procurement regulations
and overseen by the SEC’s Office of Acquisitions. Specific topics of the study also included: the
possible elimination of lower priority and / or redundant units at the SEC; improvement of internal
communications and organizational chain-of-command; the effect of new market technologies, such
as high-frequency trading; hiring authorities and personnel practices; and oversight and reliance on
SROs.
To perform its assessment and formulate recommendations, BCG engaged in significant interaction
with SEC staff, generally through interviews, to understand the existing state of the agency’s
operations. The agency actively encouraged staff to participate fully and candidly in interviews with
BCG throughout the course of the engagement. Over the duration of the project, BCG conducted
more than 300 interviews and meetings with agency employees, including division and office
directors and significant numbers of other agency managers and staff. BCG set the agenda for these
discussions to obtain insights into program operations, learn staff views, validate facts, test
hypotheses and otherwise acquire the knowledge necessary to successfully perform its work. In
conducting its work, BCG also interviewed or met with a significant number of external
stakeholders, including congressional offices, SROs and entities that are regulated by or have
significant interactions with the SEC.
On March 10, 2011, BCG delivered the results of its assessment to the SEC and to Congress: a 263-
page final study, U.S. Securities and Exchange Commission: Organizational Study and Reform. The
final study, which was submitted within the 150-day deadline specified in Section 967 of the Dodd-
1
Frank Act, reflects BCG’s own independent findings and conclusions.
BCG identified 16 specific initiative recommendations across four recommendation categories:
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The full text of the study is available online at
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