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U.S. S

– M

(MAP)

ECURITIES AND

XCHANGE

OMMISSION

ISSION

DVANCEMENT

ROGRAM

SEC O

EPORT ON THE

MPLEMENTATION OF

RGANIZATIONAL

EFORM

ECOMMENDATIONS

approximately the next two years

, in addition to the costs associated with the significant

commitment of SEC management and staff time. Since the study recommendations were released

outside of the standard budgeting request cycle, the agency is currently funding recommendation

analysis and implementation planning through its existing budget.

Both the resource constraints and time demands pose tremendous challenges. Without adequate

funding the agency may not be able to realize the efficiencies, and because of the potential pull on

management and staff time there is a potential risk for detraction from core mission-critical

activities. The agency recognizes this and is carefully managing utilization of leadership and staff

time as the workstreams conduct analysis and design recommendations, then commence throughout

a multi-year implementation period.

Additionally, the agency is aware of the impact of organizational change on management and

employees. Since 2009, the SEC has undergone fast-paced and significant change in processes,

policies, priorities and structure. When analyzing the BCG study recommendations and planning

implementation approaches, the agency must be cognizant of its own ongoing ability to absorb

change.

Since resources and absorptive capacity do not permit the agency to implement all the

recommendations at once, the process will likely focus on thinking strategically and prioritizing the

various initiatives. It is critically important to conduct the analysis of the recommendations at the

same time: otherwise, the cross-workstream overlaps, integration points and dependencies may not

be detected. As the recommendation analysis progresses, the agency will carefully examine, start

and stop activities to ensure consistent decision making. The Program Management Office (PMO)

will also support the workstreams in serving as that cross-workstream integration.

For those initiatives that the agency decides to implement, the analysis workstreams will carefully

develop implementation plans that identify the particular actions to be taken and define a realistic

and achievable schedule for implementation. Those implementation timelines will take into account

workforce impacts, risks, agency change capacity, budget, dependencies / integration needs,

competing demands on management, and staff time to support the day-to-day mission. The agency

is also carefully assessing how to move quickly while also ensuring there is sufficient time to

BCG’s estimated implementation costs consist of a $7 to $10 million investment within the first six to nine months (Wave 1),

followed by an additional $35 to $45 million over the subsequent 12 to 18 months (Waves 2 and 3). See p. 143-144.

AGE

Report On The Implementation Of Sec Organizational Reform Recommendations - U.s. Securities And Exchange Comission - 2011 Page 7

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