Report On The Implementation Of Sec Organizational Reform Recommendations - U.s. Securities And Exchange Comission - 2011 Page 6
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25U.S. S
E
C
– M
A
P
(MAP)
ECURITIES AND
XCHANGE
OMMISSION
ISSION
DVANCEMENT
ROGRAM
R
I
SEC O
R
R
EPORT ON THE
MPLEMENTATION OF
RGANIZATIONAL
EFORM
ECOMMENDATIONS
1. Reprioritizing regulatory activities. Acknowledging that the SEC is making—and will
continue to need to make—difficult tradeoffs in allocating resources to highest priority
needs, the study recommends that the SEC engage in a rigorous assessment to better
prioritize its needs and reallocate resources accordingly.
2. Reshaping the organization. The study recommends several initiatives by which the
SEC can reshape its organizational structure, roles and governance to maximize
efficiency, effectiveness and collaboration and drive continuous improvement.
3. Investing in enabling infrastructure. The study concludes that significant new
investment is needed in the SEC’s key enabling infrastructure, specifically technology,
human resources, risk management and high-priority staff skills.
4. Enhancing engagement with SROs. The study concludes that the SEC can improve
both its oversight of, and engagement with, SROs.
In the months since the study was released, the SEC has made progress to establish the processes
and infrastructure necessary to analyze the BCG study recommendations. This document is the first
of four Congressional reports required by Section 967(c) of the Dodd-Frank Act that will detail the
SEC’s review, analysis and implementation of the recommendations contained in the BCG study.
This report describes the actions that the SEC has taken to receive, delegate and begin analysis of
the BCG study recommendations; will briefly outline the progress of each established workstream;
and will discuss key considerations, challenges and next steps.
3.0
Challenges
The BCG study has provided the SEC with valuable insights into how the SEC should assess its
current operations. Given the broad scope of the BCG study recommendations—which touch on
virtually every aspect of the agency’s operations and offices—determining the appropriate course of
action to take in response and implementing those actions will require careful internal coordination
and prioritization, as well as a significant commitment of staff and other resources.
A critical challenge facing SEC senior management is determining how to best implement the study
recommendations in the current resource-constrained environment, especially when substantial
additional work is dictated by Dodd-Frank Act deadlines. While the BCG study postulated that
recommended initiatives will lead to efficiencies over the long-term, it also acknowledged that
substantial up-front costs would be required to implement the recommendations. The Boston
Consulting Group estimated that between $42 million and $55 million will be required over
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