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U.S. SECURITIES AND
EXCHANGE COMMISSION
FISCAL YEAR  2019
Congressional Budget Justification
Annual Performance Plan
FISCAL YEAR  2017
Annual Performance Report
PROTECTING INVESTORS
MAINTAINING FAIR, ORDERLY, AND 
EFFICIENT MARKETS
FACILITATING CAPITAL FORMATION

Contents
Agency and Mission Information .......................................................................................................................................1
Executive Summary ....................................................................................................................................................................................3
Mission, Vision, Values, and Goals....................................................................................................................................................7
History and Purpose
 ...................................................................................................................................................................................9
Organizational Structure and Resources
 ..................................................................................................................................10
FY 2019 Budget Request Tables .....................................................................................................................................13
Full-Time Equivalents and Positions by Program ...............................................................................................................15
Obligations by Object Class
 ................................................................................................................................................................16
Strategic Goal and Program
 ................................................................................................................................................................17
Request Summary of Changes
 ........................................................................................................................................................18
FY 2019 Appropriations Language ................................................................................................................................19
FY 2019 Budget Request by Program .........................................................................................................................21
Other Information .....................................................................................................................................................................81
Risks, Internal Controls, and Management Challenges ................................................................................................83
Cross-Agency Collaboration
 .............................................................................................................................................................87
Evidence Building
 .......................................................................................................................................................................................91
Links to Additional Information and Resources 
 .................................................................................................................92
FY 2017 Annual Performance Report (APR) and 
FY 2019 Annual Performance Plan (APP) .................................................................................................................93
A Reader’s Guide to SEC Performance Information ........................................................................................................95
FY 2017 APR and FY 2019 APP Summary
 ................................................................................................................................95
Performance Summary by Strategic Goal and Strategic Objective
 ....................................................................96
Strategic Goal 1: Establish and Maintain an Effective Regulatory Environment .........................96
Strategic Goal 2: Foster and Enforce Compliance with Federal Securities Laws ....................103
Strategic Goal 3: Facilitate Access to the Information Investors Need to Make 
Informed Investment Decisions
  ............................................................................................114
Strategic Goal 4: Enhance the Commission’s Performance through Effective 
Alignment and Management of Human, Information, and 
Financial Capital
 .................................................................................................................................119
Appendices .................................................................................................................................................................................127
Appendix A:  Divisions and Offices .............................................................................................................................................129
Appendix B:  Verification and Validation of Performance Data
 .............................................................................132
Appendix C:  SEC’s Responses to Government Accountability Office Reports
 ........................................133

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) 2019 and the Annual Performance Report 
(APR) for FY 2017, 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.
• GPRA Modernization Act of 2010
• Office of Management and Budget Circular A-11, Preparation, Submission,  
and Execution of the Budget
• Government Management Reform Act of 1994 
• Reports Consolidation Act of 2000 
• Office of Management and Budget Circular A-136, Financial Reporting Requirements
An electronic version of this document and its components is available at www.sec.gov/about/
offices/ofm/ofm-documents.htm. To comment on the SEC’s FY 2019 CBJ and APP and FY 2017 
APR, email [email protected]. 

Agency and Mission 
Information
Executive Summary .................................................................................................................................................3
Mission, Vision, Values, and Goals
 ..................................................................................................................7
History and Purpose
 ...............................................................................................................................................9
Organizational Structure and Resources
 ...............................................................................................10



AGENCY AND MISSION INFORMATION   |   3
EXECUTIVE SUMMARY
The U.S. Securities and Exchange Commission (SEC) 
is pleased to submit its budget request for fiscal year 
(FY) 2019. The SEC is requesting $1.658 billion in 
support of 4,628 positions and 4,457 full-time equiva-
lents (FTE). These expenses will be offset by matching 
collections of fees on securities transactions. 
The FY 2019 budget request level is a 3.5 percent 
increase over the FY 2018 budget request of $1.602 
billion. This level is necessary for the SEC to continue 
the effective pursuit of its mission to protect investors, 
maintain fair, orderly, and efficient markets, and facil-
itate capital formation. The FY 2019 budget request 
also assumes the SEC will have continued access to 
the Commission’s Reserve Fund to fund information 
technology improvements, including cybersecurity. 
Because this funding is assured, the Reserve Fund 
allows the SEC to commit to important, long-term 
technology initiatives that otherwise would be more 
difficult to execute due to funding uncertainties.
The SEC’s broad mission covers a lot of ground. We 
oversee approximately $75 trillion in securities trading 
annually on U.S. equity markets and the activities of 
over 26,000 registered market participants, including 
investment advisers, mutual funds, exchange-traded 
funds (ETF), broker-dealers, and transfer agents. We 
also engage and interact with the investing public on a 
daily basis through a number of activities ranging from 
our investor education programs to alerts on SEC.gov. 
We also provide critical market services through our 
information technology (IT) systems. On a typical  
day, investors and other market participants access 
more than 50 million pages of disclosure documents  
through the Electronic Data Gathering, Analysis,  
and Retrieval (EDGAR) system. The agency also 
oversees 21 national securities exchanges, 10 credit 
rating agencies, and seven active registered clearing 
agencies, as well as the Public Company Account-
ing Oversight Board (PCAOB), Financial Industry 
Regulatory Authority (FINRA), 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 selectively 
reviewing the disclosures and financial statements of 
over 8,000 reporting companies, of which approx-
imately 4,100 are exchange listed. Of the top 100 
public companies in the world, 78 fall under the SEC’s 
reporting requirements.
The SEC’s annual appropriation has remained essen-
tially flat since FY 2016 at a level of approximately 
$1.6 billion. To stay within this level, the SEC imposed 
a hiring freeze at the start of FY 2017 that will 
continue throughout FY 2018. The agency permits 
few exceptions to the hiring freeze and, consequently, 
the overall staffing level is declining and is expected to 
drop to 4,528 positions by the end of FY 2018. 
This budget request seeks to restore 100 positions to 
address critical priority areas and enhance the agency’s 
expertise in key areas. This represents approximately 
one-quarter of the positions lost in the hiring freeze. 
This budget request also aims to leverage technology 
and data to extend the agency’s capabilities, improve 
its cyber risk profile, and further enable the SEC to 
manage the massive amounts of data submitted to 
us. Finally, the request seeks funding to support the 
procurement of a new lease for the New York Regional 
Office by the General Services Administration (GSA).

4   |  FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
The SEC’s funding is deficit-neutral, which means any 
amount appropriated to the agency will be offset by 
transaction fees.
The following sections highlight the agency’s key 
priorities for FY 2019.
Cybersecurity and Risk Management
The FY 2019 request would support key enhancements 
to the agency’s program to protect the security of its 
network, systems, and sensitive data. The FY 2019 
request would provide four additional staff positions to 
enable the SEC to expand its cybersecurity protections, 
particularly with regard to incident management and 
response, advanced threat intelligence monitoring, 
and enhanced database and system security. These 
additional positions would be information system 
security officers who can focus on the security of 
specific systems or programs. 
The SEC is taking action in FY 2018 to establish a 
new chief risk officer position to oversee the agency’s 
enterprise risk program. The FY 2019 request would 
permit the agency to hire two additional staff positions 
under the chief risk officer to strengthen and advance 
the agency’s risk management capabilities.
Facilitating Capital Formation 
The FY 2019 request would enable us to expand 
the SEC’s new, statutorily-mandated Office of the 
Advocate for Small Business Capital Formation. The 
office’s mission is to be a resource and voice for small 
businesses and small business investors by providing 
assistance, conducting outreach to better understand 
their concerns, and making recommendations to 
the Commission and Congress regarding potential 
improvements to the regulatory environment. We are 
in the process of hiring an advocate to oversee the 
establishment of the office and, as part of our FY 2019 
request, we plan to expand its staffing to a total of six 
positions. The FY 2019 request would also support 
expenses for the operation of a new Small Business 
Capital Formation Advisory Committee, which will  
be established in FY 2018 following the selection of  
an advocate.
The resources provided by the FY 2019 request would 
also enable the Division of Corporation Finance to 
assist hundreds of companies that seek to “go public” 
through an initial public offering, or to raise capital 
through follow-on or exempt offerings and to imple-
ment important capital formation initiatives. 
Protecting Main Street Investors  
and Our Markets
A vigorous enforcement program is among the most 
powerful tools used by the SEC in its efforts to protect 
investors. The FY 2019 request would restore 17 
positions for the Division of Enforcement (ENF)
to support key enforcement priorities and provide 
resources to support and expand the work of two new 
groups: The Cyber Unit, which is focused on bringing 
enforcement actions against cyber-related misconduct; 
and the Retail Strategy Task Force, which is focused on 
developing enforcement initiatives to identify miscon-
duct, including broad market misconduct that impacts 
retail investors.
The National Examination Program (NEP) is another 
key area through which the SEC works directly to 
protect the interests of retail investors. Registered 
investment advisers today manage more than $70 
trillion in investor assets—triple the amount from 
15 years ago. Our examination program monitors 
whether money managers handling retail customer 
funds are complying with SEC rules, and also protects 
against fraud. The FY 2019 request would restore 24 
positions within NEP, including six additional staff 
for its Technology Controls Program, which monitors 
critical securities market infrastructure for significant 
cyber events and outages.

AGENCY AND MISSION INFORMATION   |   5
The FY 2019 request would also restore seven staff 
positions within the Division of Investment Manage-
ment (IM), which plays a critical role in protecting 
retail investors through its regulation of mutual funds, 
variable insurance products, and ETFs, among other 
products. IM has a need to recruit professionals with 
specialized expertise in critical areas, including private 
funds, cybersecurity, fund accounting, and quantitative 
analytics. The resources would be used to enhance  
IM’s monitoring and disclosure programs, as well as 
advance key investor-focused rule-writing priorities, 
such as standards of conduct for investment  
professionals.
Effective Oversight of Changing Markets
Over the last decade, technological advancements 
and commercial developments have led to significant 
changes in how our security markets operate. The 
Division of Trading and Markets (TM) plays a critical 
front-line role in ensuring fair, orderly, and efficient 
markets through its work to regulate the major 
securities market participants. The FY 2019 request 
would allow TM to recruit 16 additional professionals 
to expand the agency’s depth of expertise in vital  
areas such as market insight and analysis, clearing 
agencies, broker-dealer operations, cybersecurity, 
electronic trading, and fixed income markets.  
Because technology and markets are changing so 
rapidly, staying current with market trends and  
developments is essential to the SEC’s ability to  
remain an effective regulator.
The FY 2019 request would also provide resources to 
continue the work of the agency’s new Fixed Income 
Market Structure Advisory Committee (FIMSAC) and 
its important work to evaluate and take appropriate 
measures to enhance the efficiency, transparency, and 
effectiveness of fixed income markets. 
Leveraging Technology, Data, and Analytics
The SEC has made progress in modernizing its 
technology systems, with the benefits of streamlining 
operations, increasing our use of data analytics and the 
effectiveness of our programs. 
Recently, the SEC’s ability to continue to invest in 
advanced analytic tools or modernize legacy systems 
has been constrained with annual investments in 
IT development, modernization, and enhancement 
projects declining from $100 million in FY 2015 to 
an anticipated $50 million in FY 2018. Additional 
investment in IT is necessary for the SEC to keep pace 
with the rapid technology advancements occurring 
in areas we regulate, including to meet ever-evolving 
cybersecurity challenges. 
In furtherance of the objectives of the SEC’s 2018– 
2020 Technology Strategic Plan, this request seeks an 
additional $45 million to restore funding for technol-
ogy development, modernization, and enhancement 
projects. Together with the support of the SEC Reserve 
Fund, the FY 2019 request would allow the agency  
to continue implementing a number of multi-year  
technology initiatives. 
Uplifting the agency’s cybersecurity program is a top 
priority. The FY 2019 request would support increased 
investment in tools, technologies, and services to 
protect the security of the agency’s network, systems, 
and sensitive data. Priorities for FY 2019 include 
maturation of controls through continuous diagnostics 
and monitoring, and further enhancements to firewall 
technologies. Another way the FY 2019 request helps 
reduce the agency’s cybersecurity risk profile is by 
enabling the funding of multi-year investments to 
transition legacy IT systems to modern platforms  
with improved embedded security features. 

6   |  FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
Other FY 2019 IT modernization priorities include:
•Continuing the development of advanced analytics
solutions that provide new capabilities to detect and
expose suspicious behavior in high frequency trading
and other complex trading areas across markets;
•Improving storage, processing, security, and manage-
ment of large volumes of data, including the agency’s
e-Discovery program, which is approaching one
petabyte of data;
•Modernizing the SEC’s infrastructure and computing
environment to enhance security, improve perfor-
mance, and streamline delivery;
•Improving the SEC’s ability to analyze fixed income
market data;
•Updating selected operational components of the
agency’s legacy EDGAR system to make it easier for
registrants to fulfill their disclosure responsibilities
through the system, for investors to access the
information they need, and for the SEC to operate
and secure the system; and
•Executing a relocation of one of the agency’s current
data centers to achieve operational efficiencies and
support improvements.
These key priorities—many of which are driven by 
changes in our markets—will enhance the SEC’s ability 
to serve the public as well as analyze and act on large 
amounts of data.
Along with increasing the SEC’s use of analytic tools, 
we also anticipate a growing need for professionals 
who are trained in data management and analysis, 
including data scientists, quantitative analysts, and 
financial economists. To this end, the FY 2019 request 
would include four additional positions for the 
Division of Economic and Risk Analysis (DERA) to 
support the agency’s increased analytic needs and add 
depth to DERA’s policy support and risk assessment 
functions, including robust economic analysis. In 
particular, DERA needs expertise in data management, 
risk assessment, structured finance, clearance and 
settlement, investment advice, asset management, and 
fixed income markets.
Real Property Leasing
With the current lease for the SEC’s New York 
Regional Office set to expire in 2021, the FY 2019 
request includes funds required for the GSA procure-
ment of a new lease. As with the SEC’s headquarters’ 
lease procurement in FY 2018, GSA requires that the 
SEC set aside funds in the budget to account for poten-
tial buildout costs in the event that the competitive 
acquisition process results in the New York Regional 
Office needing to move to a new facility. These costs 
are estimated by GSA to be $37 million.
1
 As with our 
FY 2018 appropriations request, we have proposed 
legislative language assuring that none of these funds 
would be used for the operations of the SEC, and that 
any unused portion would be refunded to fee payers.
1	 This	figure	has	been	revised	for	a	new	estimate	provided	to	the	SEC	too	late	for	inclusion	in	the	President’s	Budget	materials.	The	President’s	Budget	
reflects	the	previous	estimate	of	$40,750,443.

AGENCY AND MISSION INFORMATION   |   7
MISSION, VISION, VALUES, AND GOALS
MISSION 
The mission of the SEC is to protect investors, 
maintain fair, orderly, and efficient markets, 
and facilitate capital formation.
VISION
The SEC strives to promote a securities  
market that is worthy of the public’s trust and 
characteriz
ed by transparency and integrity. 
VALUES
Integrity
Excellence
Accountability
Effectiveness
Teamwork
Fairness

8   |  FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
Strategic Goals and Strategic Objectives of the FY 2014–FY 2018 Strategic Plan
The SEC is in the process of writing a new Strategic Plan for FYs 2018–2022. Pending the 
finalization of that updated plan, the SEC’s current plan remains in effect. 
Strategic Goal 1: Establish and maintain an effective regulatory environment
Strategic Objective 1.1: The SEC establishes and maintains a regulatory environment that promotes 
high-quality disclosure, financial reporting, and governance, and that prevents abusive practices by 
registrants, financial intermediaries, and other market participants.
Strategic Objective 1.2: The SEC promotes capital markets that operate in a fair, efficient, transpar-
ent, and competitive manner, fostering capital formation and useful innovation.
Strategic Objective 1.3: The SEC adopts and administers regulations and rules that are informed by 
robust economic analysis and public comment and that enable market participants to understand 
clearly their obligations under the securities laws.
Strategic Objective 1.4: The SEC engages with a multitude of stakeholders to inform and enhance 
regulatory activities domestically and internationally.
Strategic Goal 2: Foster and enforce compliance with the federal securities laws 
Strategic Objective 2.1: The SEC fosters compliance with the federal securities laws.
Strategic Objective 2.2: The SEC promptly detects and deters violations of the federal securities laws.
Strategic Objective 2.3: The SEC prosecutes violations of federal securities laws and holds violators 
accountable through appropriate sanctions and remedies.
Strategic Goal 3: Facilitate access to the information investors need to make informed 
investment decisions 
Strategic Objective 3.1: The SEC works to ensure that investors have access to high-quality 
disclosure materials that facilitate informed investment decision-making.
Strategic Objective 3.2: The SEC works to understand investor needs and educate investors so they 
are better prepared to make informed investment decisions.
Strategic Goal 4: Enhance the Commission’s performance through effective alignment and 
management of human, information, and financial capital 
Strategic Objective 4.1: The SEC promotes a results-oriented work environment that attracts, 
engages, and retains a technically proficient and diverse workforce, including leaders who provide 
motivation and strategic direction.
Strategic Objective 4.2: The SEC encourages a collaborative environment across divisions and offices 
and leverages technology and data to fulfill its mission more effectively and efficiently.
Strategic Objective 4.3: The SEC maximizes the use of agency resources by continually improving 
agency operations and bolstering internal controls. 

AGENCY AND MISSION INFORMATION   |   9
HISTORY AND PURPOSE
History
During the peak of the Great Depression, Congress 
passed the Securities Act of 1933
1
 (Securities Act) 
and the Securities Exchange Act of 1934
2
 (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 invest-
ment 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, the MSRB, 
and the PCAOB. Under the Dodd-Frank Wall Street 
Reform and Consumer Protection Act of 2010
3
 
(Dodd-Frank Act), the agency’s jurisdiction was 
expanded to include certain participants in the  
derivatives markets, private fund advisers, and  
municipal advisors. 
We have sought to put forward 
the rule of fair play in finance  
and industry.
—Former President Franklin D. Roosevelt during 
a speech to Congress two days after signing 
the Securities Exchange Act of 1934
Each year, the SEC brings hundreds of civil enforce-
ment actions against individuals and companies for 
violation of securities laws. Examples of infractions 
are insider trading, accounting fraud, market manipu-
lation, 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 compa-
nies and other market participants are required to file 
with the SEC. These can be found at: www.sec.gov/
edgar/searchedgar/companysearch.html.
1 More	information	about	the	Securities	Act	of	1933	can	be	found	at	www.sec.gov/about/laws/sa33.pdf 
2 More	information	about	the	Securities	Exchange	Act	of	1934	can	be	found	at	www.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	 
www.sec.gov/about/laws/wallstreetreform-cpa.pdf

10   |  FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
ORGANIZATIONAL STRUCTURE 
AND RESOURCES
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 enforce-
ment 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.
SEC Headquarters
Atlanta Regional Office
Georgia, North Carolina, South Carolina, Tennessee, Alabama
Boston Regional Office
Connecticut, Maine, Massachusetts, New Hampshire, Vermont, Rhode Island
Chicago Regional Office
Illinois, Indiana, Iowa, Kentucky, Michigan, Minnesota, Missouri, Ohio, Wisconsin
Denver Regional Office
Colorado, Kansas, Nebraska, New Mexico, North Dakota, South Dakota, Wyoming
Fort Worth Regional Office
Texas, Oklahoma, Arkansas, Kansas (except for the exam program, which is 
administered by the Denver Regional Office)
Los Angeles Regional Office
Arizona, Hawaii, Guam, Nevada, Southern California (zip codes 93599 and below, except for 93200–93299)
Miami Regional Office
Florida, Mississippi, Louisiana, U.S. Virgin Islands, Puerto Rico
New York Regional Office
New York, New Jersey
Philadelphia Regional Office
Delaware, Maryland, Pennsylvania, Virginia, West Virginia, District of Columbia
Salt Lake Regional Office
Utah
San Francisco Regional Office
Washington, Oregon, Alaska, Montana, Idaho, Northern California (zip codes 93600 and up, plus 93200–93299)
Fort Worth
Chicago
Denver
Salt Lake
Philadelphia
Los Angeles
San Francisco
Miami
Atlanta
New York
Boston
SEC Headquarters
SEC Headquarters and Regional Office Locations

AGENCY AND MISSION INFORMATION   |   11
Organizational Structure 
The SEC is an independent federal agency led by a 
bipartisan, five-member Commission—one of whom 
is designated as the Chairman—with staggered 
five-year terms. 
Each member of the Commission is appointed by  
the President and confirmed by the Senate. The  
Chairman serves as the chief executive and, by law,  
no more than three of the Commissioners may belong 
to the same political party. 
The Commission convenes on a regular basis, and 
meetings are open to the public and the news media 
unless the discussion pertains to a confidential subject, 
such as whether to begin an enforcement investigation. 
The agency’s functional responsibilities are organized 
into five divisions and 25 offices. In FY 2017, the SEC 
employed 4,616 full-time equivalents (FTE). 
The organization chart above is accurate as of 
September 30, 2017.

FY 2019 Budget 
Request Tables
Full-Time Equivalents (FTE) and Positions by Program ...............................................................15
Obligations by Object Class
 ............................................................................................................................16
Strategic Goal and Program
 ............................................................................................................................17
Request Summary of Changes
 .....................................................................................................................18



FY 2019 BUDGET REQUEST TABLES   |   15
FULL-TIME EQUIVALENTS (FTE) AND POSITIONS  
BY PROGRAM
FY 2017
Actuals
FY 2018
Annualized Continuing 
Resolution 
1
FY 2019
Request
FTE
Actual 
PositionsFTE
Estimated 
PositionsFTE
Estimated 
Positions
Enforcement1,3931,3931,3731,3621,3481,379
Compliance Inspections and Examinations1,0631,0991,0471,0621,0321,086
Corporation Finance461454433435423438
Trading and Markets263263248253250269
Investment Management182186176180175187
Economic and Risk Analysis157154147142145146
General Counsel141139134135131135
Other Program Offices
Chief Accountant494950444944
Investor Education and Advocacy434342414242
International Affairs555753535153
Administrative Law Judges131412141214
Investor Advocate111111101211
Credit Ratings444441414143
Municipal Securities91010111011
Advocate for Small Business Capital Formation——1136
Total224228220215220224
Agency Direction and Administrative Support
Executive Staff2831
35323132
Public Affairs152221202120
Secretary242525242424
Chief Operating Officer151413151417
Financial Management989895969396
Information Technology171175173180177196
Human Resources120113107104105106
Acquisitions575956555555
Support Operations1009794949294
Strategic Initiatives152729282928
Ethics Counsel181919181918
Minority and Women Inclusion9109999
Equal Employment Opportunity141415151515
Total684704691690684710
Inspector General485449544954
Total FTE and Positions4,6164,6744,5184,5284,4574,628
                                       
                                 
                                                                .
1	 Estimated	End	of	Year	Positions	for	FY	2018	reflect	the	effects	of	an	agency-wide	hiring	freeze.	The	actual	impact	to	individual	organizations	may	vary.

16   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
OBLIGATIONS BY OBJECT CLASS
FY 2017FY 2018FY 2019
1
Actual Annualized Continuing Request
(DOLLARS IN THOUSANDS)Resolution 
2
Personnel Compensation and Benefits
Total Personnel Compensation (11.0)$      862,458$       882,013$      879,272
Civilian Personnel Benefits (12.0)291,468281,131280,246
Subtotal Cost of Compensation$   1,153,926$    1,163,145$   1,159,518
Other Expenses
Benefits for Former Personnel (13.0)1,6353031
Travel and Transportation of Persons (21.0)8,96110,80311,276
Transportation of Things (22.0)148195199
Rent, Communications, and Utilities (23.0)32,41538,05769,858
Printing and Reproduction (24.0)7,0711,8921,924
Other Contractual Services (25.0)341,890322,205337,173
Supplies and Materials (26.0)1,6952,3342,424
Equipment (31.0)27,37216,27954,407
Building Alterations (32.0)1,5314,6055,597
Claims and Indemnities (42.0)344840854
Subtotal Cost of Other Expenses423,062397,241483,742
Subtotal, Obligations$   1,576,988$    1,560,386$   1,643,260
Budget Authority used to Liquidate Prior Obligations for Deficient Leases, 
per an October 3, 2011, Report from the Comptroller General74,32970,91540,042
Total Budget Authority
$   1,651,317$    1,631,300$   1,683,302
Less:  Anticipated Recoveries of Prior Budget Years Obligations
(25,000)(25,000)
Request for SEC Operations 
$    1,606,300$   1,658,302
Estimate of Potential Buildout Costs Associated with 
New York Regional Office Lease Replacement$        37,189
 
3
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  FY	2018	Annualized	Continuing	Resolution	does	not	include	estimated	amounts	for	costs	associated	with	the	headquarters’	lease	replacement.
3	 This	figure	has	been	revised	for	a	new	estimate	provided	to	the	SEC	too	late	for	inclusion	in	the	President’s	Budget	materials.	The	President’s	Budget	
reflects	the	previous	estimate	of	$40,750,443.

FY 2019 BUDGET REQUEST TABLES   |   17
STRATEGIC GOAL AND PROGRAM
(DOLLARS IN THOUSANDS)FY 2019 Request
SEC Program
FY 2017
Actual 
1
 
FY 2018 
Annualized 
CR 
2
Goal 1
Effective
Regulatory
Environment
Goal 2
Enforce
Securities
Laws
Goal 3
Facilitate
Access To 
Information
Goal 4
Align and
Manage
Resources
FY 2019
Request
Enforcement$     512,256     $     505,768     $      5,317      $   510,392   $            —            $      15,950      $      531,659      
Compliance Inspections and  
Examinations347,273 346,292 3,658 347,491 3,658 10,973 365,781 
Corporation Finance148,065 144,145 22,590 3,012 109,939 15,060 150,601 
Trading and Markets85,169 83,708 44,912 22,456 22,456 — 89,824 
Investment Management59,344 57,742 23,646 16,977 18,796 1,213 60,631 
Economic and Risk Analysis68,007 72,392 30,032 27,780 10,511 6,757 75,081 
General Counsel46,855 45,707 9,964 26,095 949 10,438 47,446 
Other Program Offices81,064 77,761 24,278 29,797 28,636 675 83,386 
Agency Direction and  
Administrative Support
214,457 210,968 6,145 3,027 15,531 197,504 222,207 
Inspector General14,499 15,903 — 166 166 16,311 16,644 
Subtotal, Obligations$ 1,576,988 $  1,560,386  $  170,541  $  987,195  $   210,643   $    274,882    $  1,643,260  
Budget Authority used to Liquidate 
Prior Obligations for Deficient 
Leases, per an October 3, 2011, 
Report from the Comptroller 
General  
 74,329  70,915  — —— —40,042  
Budget Authority for  
SEC Operations$ 1,651,317 $  1,631,300   $ 1,683,302
Less:  Anticipated Recoveries of  
Prior Years Obligations (25,000) (25,000)
Request for SEC Operations$  1,606,300  $ 1,658,302  
Potential Buildout Costs Associated 
with New York Regional Office 
Lease Replacement  $ 37,189
’
 
3
  
 
   
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 FY	2018	Annualized	Continuing	Resolution	does	not	include	estimated	amounts	associated	with	the	headquarters’	lease	replacement.
3	 This	figure	has	been	revised	for	a	new	estimate	provided	to	the	SEC	too	late	for	inclusion	in	the	President’s	Budget	materials.	The	President’s	Budget	 
reflects	the	previous	estimate	of	$40,750,443.

18   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
REQUEST SUMMARY OF CHANGES
1
 (DOLLARS IN THOUSANDS)PositionsFTEAmount
FY 2018 Estimated Continuing Resolution (Annualized) 
2
 4,528 4,518 $  1,631,300  
FY 2019 Base Changes 
Net Changes in Compensation Expenses (111)(16,610)
Net Change in Real Property Facilities Costs 1,592 
Non-Compensation Inflation of 1.7% 6,753 
Subtotal, Base Changes—(111)(8,264)
FY 2019 Current Services Level 4,528 4,407 $  1,623,036
FY 2019 Program Increases 
Restoration of 100 Positions (50 FTE)  
Enforcement17 8 
Compliance Inspections and Examinations 24 12 
Corporation Finance 3 1 
Trading and Markets 16 8 
Investment Management 7 4 
Economic and Risk Analysis 4 2 
Other Program Offices 9 5 
Agency Direction and Administrative Support 20 10 
          Subtotal, Staffing Increases100 50 15,266 
Restore Information Technology Development 45,000 
Subtotal, Program Increases 100 50 
$        60,266        
Proposed FY 2019 Obligations for SEC Operations  4,628 4,457 $   1,683,302   
    Less:  Anticipated Recovery of Prior Fiscal Years Obligations (25,000)
FY 2019 Request for SEC Operations4,628 4,457 $   1,658,302   
Estimate of Potential Buildout Costs Associated with  
New York Regional Office Lease Replacement
$        37,189
3
1	 These	figures	include	amounts	in	FY	2018	and	FY	2019	necessary	to	liquidate	prior	obligations	on	deficient	leases.
2 FY	2018	Annualized	Continuing	Resolution	does	not	include	estimated	amounts	associated	with	the	headquarters’	lease	replacement.
3	 This	figure	has	been	revised	for	a	new	estimate	provided	to	the	SEC	too	late	for	inclusion	in	the	President’s	Budget	materials.	The	President’s	Budget	
reflects	the	previous	estimate	of	$40,750,443.

APPROPRIATIONS LANGUAGE  |   19
FY 2019 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, $1,658,302,366, to remain 
available until expended; of which not less than 
$15,206,269 shall be for the Office of Inspector 
General; of which not to exceed $75,000 shall be 
available for a permanent secretariat for the Interna-
tional 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 admin-
istrative 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 costs 
associated with relocation under a replacement lease 
for the Commission’s New York regional office facili-
ties, not to exceed $37,188,942
1
, 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 2019, all amounts appropriated 
under this heading shall be deemed to be the regular 
appropriation to the Commission for fiscal year 2019.
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 
$1,658,302,366 of such offsetting collections shall 
be available until expended for necessary expenses of 
this account and not to exceed $37,188,942
1
 of such 
offsetting collections shall be available until expended 
for costs under this heading associated with relocation 
under a replacement lease for the Commission’s New 
York regional office facilities: Provided further, That 
the total amount appropriated under this heading from 
the general fund for fiscal year 2019 shall be reduced 
as such offsetting fees are received so as to result in 
a final total fiscal year 2019 appropriation from the 
general fund estimated at not more than $0: Provided 
further, That if any amount of the appropriation for 
costs associated with relocation under a replacement 
lease for the Commission’s New York regional office 
facilities is subsequently de-obligated by the Commis-
sion, 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 2019.
1	 This	figure	has	been	revised	for	a	new	estimate	provided	to	the	SEC	too	late	for	inclusion	in	the	President’s	Budget	materials.	The	President’s	Budget	
reflects	the	previous	estimate	of	$40,750,443.

FY 2019 Budget 
Request by Program
Division of Enforcement .....................................................................................................................................23
Office of Compliance Inspections and Examinations
 ....................................................................27
Division of Corporation Finance
 ...................................................................................................................31
Division of Trading and Markets
 ...................................................................................................................33
Division of Investment Management
 ........................................................................................................37
Division of Economic and Risk Analysis
 ..................................................................................................39
Office of the General Counsel
 ........................................................................................................................41
Other Program Offices
 .........................................................................................................................................43
Office of the Chief Accountant ...................................................................................................................................45
Office of Investor Education and Advocacy ....................................................................................................47
Office of International Affairs ........................................................................................................................................48
Office of Administrative Law Judges ....................................................................................................................50
Office of the Investor Advocate .................................................................................................................................52
Office of Credit Ratings ....................................................................................................................................................54
Office of Municipal Securities .....................................................................................................................................56
Office of the Advocate for Small Business Capital Formation .........................................................58
Agency Direction and Administrative Support ..................................................................................59
Agency Direction..................................................................................................................................................................60
Office of the Chief Operating Officer .....................................................................................................................64
Office of the Ethics Counsel .........................................................................................................................................75
Office of Minority and Women Inclusion ...........................................................................................................76
Office of Equal Employment Opportunity ........................................................................................................78 
Office of Inspector General ..............................................................................................................................79



FY 2019 BUDGET REQUEST BY PROGRAM   |   23
DIVISION OF ENFORCEMENT
(DOLLARS IN THOUSANDS)
FY 2017
Actual
FY 2018
Annualized CR
FY 2019
Request
Full-Time Equivalents 1,393  1,373  1,348 
Cost:
Salaries and Benefits
$   349,202$   360,495$    357,874
Non-Personnel Expenses163,055145,274173,785
Total Costs
$   512,256$   505,768$    531,659
Totals	may	not	appear	to	sum	from	detail	lines	due	to	rounding	of	actual	values
The Division of Enforcement (ENF) is critical to the 
Commission’s ability to fulfill its three-part mission: 
protect investors, maintain fair, orderly, and efficient 
markets, and facilitate capital formation. ENF’s efforts 
to deter misconduct 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, ENF brings hundreds of civil and admin-
istrative enforcement actions against individuals and 
entities for fraud, financial and accounting irregular-
ities and misstatements, and other misconduct. The 
substantial remedies that ENF obtains are meaningful 
and impactful. They deter future wrongdoing, and 
when ENF obtains disgorgement of ill-gotten gains, 
the Commission is often able to return fraudulently 
obtained 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 has a broad mandate with responsibility for 
covering the country’s vast capital markets; however, 
at the most basic level, ENF’s area of greatest focus—  
protection of retail investors—remains constant. Today, 
this priority is driving ENF’s allocation of limited 
resources to risks posed by cyber-related misconduct; 
issues raised by the activities of investment advisers, 
broker-dealers, and other registrants; financial report-
ing and disclosure issues involving public companies; 
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 retail 
investors and market integrity.
FY 2017 was a successful and impactful year for ENF 
despite the transition in leadership. Acting on recom-
mendations by ENF, the Commission authorized a 
diverse mix of 754 enforcement actions, of which:
• 446 were “standalone” actions brought in federal 
court or as administrative proceedings;
• 196 were “follow-on” proceedings seeking bars 
based on the outcome of Commission actions  
or actions by criminal authorities or other  
regulators; and
• 112 were proceedings to deregister public compa-
nies—typically microcap— that were delinquent in 
their Commission filings.
The SEC also obtained judgments and orders for over 
$3.8 billion in penalties and disgorgement, returned 
a record $1.07 billion to harmed investors, ordered 
over $50 million in payments to whistleblowers, 
suspended trading in the securities of 309 issuers to 
combat market manipulation and microcap fraud, and 
barred or suspended more than 625 individuals. The 
SEC’s enforcement actions during the year spanned the 
entire spectrum of the securities industry, and ENF’s 
workload is not slowing down. At the close of FY 
2017, ENF had 1,695 ongoing investigations. These 
achievements belie the significant challenges ENF faces 
that stretch its limited resources. 

24   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
Current Enforcement Challenges
Broad Spectrum of Securities Laws  
Violations Across the United States
ENF is tasked with enforcing a wide variety of statutes 
and rules, some applicable only to certain types of 
firms such as broker-dealers or investment advisers, 
and some, such as antifraud provisions, that apply 
broadly to all market participants. Moreover, this 
mandate to protect investors and enforce the securities 
laws applies everywhere, from New York to San Diego 
and Anchorage to Miami—a massive expanse for a 
limited corps of professionals. 
Cyber-Based Securities Law Violations 
Technology has dramatically transformed our markets 
and the ability of wrongdoers to engage in cyber- 
enabled misconduct. Just a few years ago, it was 
difficult to conceive of a market manipulation effectu-
ated by hacking into the electronic accounts of others 
and then forcing trades to pump up a stock price, or 
the brokering of stolen inside information on the “dark 
web,” paid for in untraceable cryptocurrency. These 
are the sorts of schemes ENF staff now frequently 
encounter, and they are among the greatest risks facing 
our securities markets. ENF needs the technological 
resources to keep up with misconduct in now cyber- 
focused markets.
Fragmented and Complex Equity Markets 
In recent years, the securities markets have grown 
increasingly complex and opaque. There has been 
a proliferation in sophisticated tools and trading 
methods used in the markets, including the use of high 
frequency trading, complex algorithmic trading, and 
off exchange trading venues like “dark pools.” Unlaw-
ful trading strategies such as “layering,” in which a 
trader sends and then cancels a series of orders that the 
trader does not intend to have executed to manipulate 
the price of a security, are becoming increasingly 
complex and more difficult to identify. ENF is commit-
ted to uncovering and charging violations of the law by 
all market participants in these new trading venues and 
elsewhere. Accordingly, ENF needs sufficient analytical 
tools and staff to analyze data from these tools to 
ensure it keeps pace with this constantly evolving 
environment.
Ever-Increasing Volume of Data 
Analysis of large datasets—including filings, disclo-
sures, and trading data in equities, options, municipal 
bonds, and other securities—is critical to effectively 
identify, investigate, and prosecute potential miscon-
duct. The volume of these datasets continues to rise 
and will only increase in FY 2019. Through its Center 
for Risk and Quantitative Analytics and other efforts, 
ENF expects that its improved information processing 
and analysis is likely to yield additional case leads 
through FY 2019. ENF needs commensurate staffing to 
review, analyze, and pursue these leads. 
Increasing Volume of Tips to Investigate 
The SEC receives approximately 16,500 tips and 
complaints each year, which ENF reviews to identify 
leads warranting further investigation. Additionally, 
ENF’s Office of the Whistleblower receives and 
analyzes thousands of tips per year, generating a fresh 
stream of case leads that require investigation. Since 
FY 2013, the Office of the Whistleblower has seen an 
increase of 30 percent in the number of tips received, 
and a 132 percent increase in the number of eligible 
award applications received. The office is currently 
tracking over 700 matters involving whistleblowers. 
Complexities of Advanced Technology 
The increasing use of technology to evade fraud detec-
tion requires ENF to spend more resources on forensic 
services, which have increased by approximately 20 
percent since FY 2013. Each month, ENF receives 
between eight and nine terabytes of electronic data 
in its investigations, and hosts nearly 925 terabytes 
of data related to investigations and litigation. The 
Commission’s e-Discovery data footprint grows at 
a rate of 10–15 percent per year. In FY 2017, ENF 

FY 2019 BUDGET REQUEST BY PROGRAM   |   25
received over 42,000 productions of documents and 
other information, an average of 3,500 productions per 
month. The total size of these productions increased by 
10 percent compared to FY 2016. The sheer volume 
of digital evidence produced to the SEC in its investi-
gations requires greater storage and processing powers  
as well as additional time for investigators to review 
that mass of information. Additionally, in today’s 
society, violators of the federal securities laws have 
an ever-expanding array of technological options to 
conceal misconduct and encrypt or otherwise obfuscate 
the evidence of their wrongdoing. 
FY 2019 Request 
To enable ENF to meet these challenges, and maintain 
an effective investigative capacity and deterrent 
presence, ENF must be adequately staffed to address 
increasingly complex financial products and trans-
actions; handle the increasing size and complexity of 
the securities markets; identify emerging threats; take 
prompt action to halt violations; and recover funds 
for the benefit of harmed investors. The volume of 
potential securities violations continues to rise, yet ENF 
presently employs fewer than 1,200 professionals to 
police the markets for wrongdoing. For FY 2019, ENF 
is requesting 17 restored positions. 
ENF’s ability to litigate its increased caseload is 
mission-critical. ENF handles an expansive and 
sophisticated docket of litigation and trials, often 
against well-funded defendants. Some of the toughest 
and most important cases are filed as litigated matters. 
Ensuring that appropriate resources are devoted to 
these cases after they are filed is critical to the SEC’s 
investor protection efforts. Successful litigation deters 
wrongdoing, sanctions those responsible for miscon-
duct, and can result in relief for victims. In addition 
to trial victories, ENF’s litigation efforts help it obtain 
strong settlements by making clear that ENF will go as 
far as required to obtain appropriate relief. In recent 
years, an increasing percentage of enforcement actions 
have been filed as contested matters as opposed to 
being fully settled at the outset. Restoring trial attorney 
positions in FY 2019 will help reinforce the agency’s 
litigation operations nationwide and enable the SEC to 
continue to be a respected and serious trial threat.
Additional litigation support is essential to manage the 
increasing e-Discovery burden, and will help ENF keep 
pace and manage the vast influx of digital documents 
and other data, analysis that is crucial to fulfilling 
ENF’s mission. As previously noted, the amount of 
e-Discovery information that ENF already houses—
and continues to regularly receive during the course of 
its investigations and litigations—is substantial. The 
complex data- and document-intensive cases brought 
by the SEC require substantial investments in staff time 
and e-Discovery resources. 
Some of the restored positions sought in this request 
will be used to support two key priorities of the 
division: protecting retail investors and combatting 
cyber-related threats. To execute and meet these 
priorities, in FY 2017, ENF announced the creation of 
the Retail Strategy Task Force and the Cyber Unit. 
The Retail Strategy Task Force will develop effective 
strategies and methods to identify potential harm 
to retail investors. In particular, the Task Force will 
focus on harnessing the Commission’s ability to use 
technology and data analytics to identify large-scale 
wrongdoing. 
The Cyber Unit will focus on combating cyber- 
related threats, which are among the greatest risks 
facing U.S. securities markets. This Unit combines 
ENF’s substantial, existing cyber-related expertise and 
its proficiency in digital ledger technology. Its members 
investigate and prosecute these increasing techno-
logically-driven violations, and coordinate with the 
Department of Justice and other criminal authorities.

26   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
Workload Data
Activity
FY 2017
Actual
FY 2018
Estimate
FY 2019
Request
Intelligence Analysis
Investor Tips and Complaints17,09816,50016,500
Matters Under Inquiry (MUI) Opened900950950
Investigations
Opened965950950
Ongoing at End of Year 
1
1,6951,7001,700
Proceedings
Administrative
Opened569550550
Pending at End of Year 
2
812810810
Civil Litigation
Opened185200200
Pending at End of Year 
3
1,5811,5801,580
1	 “Ongoing”	investigations	define	those	in	which	the	investigation	remains	active.	It	excludes	those	that	are	open	solely	because	they	are	in	litigation;	those	in	
which	the	SEC	is	seeking	to	collect	assets	and	funds	to	satisfy	outstanding	judgments	and	debts	owed	to	the	SEC;	those	in	which	the	SEC	is	distributing	
funds	to	harmed	investors;	and	those	that	are	in	some	other	post-litigation	activity.	“Ongoing”	investigations	also	exclude	those	that	are	in	the	process	of	
being	closed.
2	 These	estimates	may	be	impacted	by	a	number	of	factors	beyond	the	division’s	control,	including	–	but	not	limited	to	–	increases	in	the	complexity	of	
proceedings;	higher	than	anticipated	attrition	rates;	and	the	timing	and	amounts	of	the	resources	made	available.	Further,	given	the	time	required	to	bring	
on-board	new	staff	after	hiring	levels	are	approved,	the	full	effect	of	FY	2016	and/or	FY	2017	positions	will	not	be	realized	until	later	years.
3	 "Pending	at	End	of	Year”	refers	to	those	enforcement	actions,	filed	civilly	or	administratively,	that	remain	open	due	to	ongoing	litigation	and	post-judgment	
issues,	including	delinquent	debts	and	distributions.

FY 2019 BUDGET REQUEST BY PROGRAM   |   27
OFFICE OF COMPLIANCE INSPECTIONS  
AND EXAMINATIONS
(DOLLARS IN THOUSANDS)
FY 2017
Actual
FY 2018
Annualized CR
FY 2019
Request
Full-Time Equivalents 1,063  1,047  1,032 
Cost:
Salaries and Benefits
$   267,780$   272,855$   271,740
Non-Personnel Expenses79,49373,43794,040
Total Costs
$   347,273$   346,292$   365,781
Totals	may	not	appear	to	sum	from	detail	lines	due	to	rounding	of	actual	values
The Office of Compliance Inspections and Examina-
tions (OCIE) directs the SEC’s National Examination 
Program (NEP). OCIE’s mission is to protect investors, 
ensure market integrity, and support responsible  
capital formation through risk-focused strategies that:  
(1) improve compliance; (2) prevent fraud; (3) monitor 
risk; and (4) inform regulatory policy. The NEP 
maintains a critical presence among market participants 
by conducting thousands of exams annually, which 
provide timely, accurate, and reliable information to 
assist the program and SEC in fulfilling its mission. 
The resources being requested are essential for OCIE 
to meet its objectives and fulfill the agency’s mission. 
Importantly, this request would allow the program to 
restore critical staffing losses from the last two years. 
Among other things, these resources are needed to:  
(1) address critical risks impacting market participants, 
including issues such as cybersecurity and anti-money 
laundering; (2) continue efforts to protect retail 
investors and those saving for retirement; (3) further 
address the disparity between the number of exam 
staff and the growing number, size, and complexity 
of registered firms, particularly in the investment 
management industry; (4) examine new categories of 
regulated entities now registered, or to be registered, 
as a result of legislation; and (5) enhance and expand 
quantitative and data analytic efforts throughout the 
NEP. OCIE will also continue its efforts to promote 
industry compliance efforts through initiatives such as 
the Compliance Outreach Program. 
OCIE requests 24 positions to partially restore critical 
staffing losses from the last two years and address these 
areas. Overall, OCIE’s risk-based program is designed 
to focus resources on those firms and practices that 
pose the greatest potential risk of securities law viola-
tions that can harm investors and the markets. 
Key Observations, Issues, and Challenges  
Limitations of Exam Coverage for  
Securities Markets 
The staff examined approximately 15 percent of 
registered investment advisers in FY 2017 and nearly 
35 percent of all registered investment advisers have 
never been examined. At the same time, the population 
of registered advisers subject to SEC oversight contin-
ues to grow. To highlight, in just the last five years, 
the number of registered advisers has grown by over 
15 percent and the assets under management of these 
firms has increased by more than 40 percent. Signifi-
cant additional resources are critical to the examina-
tion program in order to improve the examination 
coverage of these entities. 
Complexity of Registrants and Markets
The securities markets continue to grow increasingly 
complex, with a proliferation of new and sophisticated 
products and services, tools, and trading strategies. 
Innovations in technology have also changed the way 
entities conduct business and investors access securities 

28   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
markets and facilitated developments in areas such as 
algorithmic trading and automated investment advice. 
More recently, the rapid growth of distributed ledger 
(i.e., blockchain) technologies and the cryptocurrency 
markets has drawn interest from both investors and 
financial services firms. At the same time, cyber threats 
in securities markets have continued to increase in both 
frequency and sophistication. These types of industry 
developments and financial innovation will continue 
to present challenges to the staff, requiring additional 
staff expertise, resources, and a program that is agile, 
responsive, and continuously improving.
Impact of Legislation and Rulemaking 
The registration of municipal advisors has added 
responsibility in recent years for hundreds of additional 
registrants with increasingly complex business lines. 
Additionally, as the Commission finalizes rules to 
create a regulatory regime for the security-based swap 
market, staff resources and additional expertise will be 
required in FY 2019 for OCIE to effectively carry out 
its expanded responsibilities.
FY 2019 Request
In light of the examination program’s limited resources 
and these existing challenges, the office is requesting 
the restoration of 24 positions in FY 2019, which it 
intends to use to address the issues identified above, 
including: filling critical staffing losses from the last 
two years that have not been restored, enhancing 
examination coverage of investment advisers, focus-
ing on critical risks impacting market participants, 
addressing new responsibilities, and implementing 
other program improvements. 
Investment Adviser/Investment Company 
Examination Program
The FY 2019 request seeks 13 restored positions to 
focus on examinations of investment advisers and 
investment companies. As stated above, the number of 
registered investment advisers and their assets under 
management has grown steadily over the years, while 
staff resources have not kept pace with the growing 
responsibilities. OCIE expects this growth to continue 
through FY 2018 and FY 2019 and estimates there  
will be approximately 20 investment advisers per  
staff member. In addition, it is anticipated that the 
population of investment advisers will be larger and 
more complex than ever. With the resources requested, 
the staff will continue efforts to improve overall 
coverage of investment advisers, including an emphasis 
on the nearly 35 percent of advisers who have never 
been examined. 
Among other things, these resources are critically 
needed to continue OCIE’s efforts of protecting retail 
investors and investors saving for retirement. Retail 
investors continue to face complex and evolving 
options when determining how to invest their money. 
Additionally, as investors are more dependent than 
ever on their own investments during retirement, 
the financial services industry is offering a broad 
array of information, advice, products, and services 
to retail investors to help them plan for, and live in, 
their retirement years. OCIE will dedicate resources 
toward examining practices that represent risks to 
retail and retirement investors, such as services offered 
from remote locations and fee structures that create 
conflicts, as well as examining for indications of 
churning, reverse churning, unsuitable recommenda-
tions, deceptive sales practices, misleading disclosure, 
and elder abuse. 
Technology Controls Program
The capital market’s use of, and dependence on, 
technology has evolved for decades, causing an increase 
in the complexity, interconnectedness, and speed of 
transactions, all of which continue to challenge market 
participants and regulators. In FY 2019, in support 
of Regulation Systems Compliance and Integrity (Reg 
SCI) to strengthen the technology infrastructure of the 
U.S. securities markets, OCIE’s Technology Controls 
Program (TCP) will continue to conduct risk-targeted 
exams of Reg SCI entities, which include self-regula-
tory organizations (SRO)(including stock and options 
exchanges, registered clearing agencies, the Financial 
Industry Regulatory Authority [FINRA], and the 
Municipal Securities Rulemaking Board [MSRB]), 

FY 2019 BUDGET REQUEST BY PROGRAM   |   29
certain alternative trading systems, disseminators of 
consolidated market data, and certain exempt clearing 
agencies. TCP will examine Reg SCI entities to evalu-
ate whether they have established, maintained, and 
enforced written policies and procedures reasonably 
designed to ensure the capacity, integrity, resiliency, 
availability, and security of their Reg SCI systems. TCP 
will also continue to examine technology focused issues 
of other registered entities, including those that may 
be new to SEC registration such as derivative markets 
participants. 
In addition, as cyber threats continue to increase in both 
frequency and sophistication at financial institutions 
and within the securities markets, OCIE and the TCP 
will also seek to enhance cybersecurity examinations 
by working with the Department of the Treasury, the 
Department of Homeland Security, the Department of 
Justice, and the intelligence community. TCP also will 
monitor market operations and track system disrup-
tions, system intrusions, and system compliance issues 
reported by Reg SCI entities. To adequately fulfill the 
above obligations, TCP would need to hire profession-
als with specialized experiences and skills. Six restored 
positions are requested to further enhance the work of 
the TCP.
Clearance and Settlement Examination Program 
Three restored positions are being requested to enhance 
the oversight of clearing agencies, security-based 
swap data repositories, and transfer agents. Focusing 
resources in this area is critical given the important 
role these entities play in ensuring the stability of 
the marketplace. In recent years, both the scope and 
number of clearing agencies required to be examined 
by the SEC have grown. Examinations of these entities 
are complex and time consuming and require particu-
lar expertise in an evolving area.
The SEC is required to conduct examinations, on at 
least an annual basis, of securities clearing agencies 
that are designated as “systemically important” and 
for which it is the supervisory agency. These examina-
tions are conducted in consultation with the Board of 
Governors of the Federal Reserve System. In addition, 
as security-based swap data repositories register with 
the SEC, additional staff will be needed to perform 
periodic examinations of these entities. The requested 
positions will help OCIE build a dedicated team of 
derivatives and clearing specialists that will be able to 
conduct cross-sector examinations of clearing agencies, 
collaborate and respond to requests for assistance from 
the Division of Trading and Markets and other regula-
tors engaged in clearance and settlement oversight,  
and enhance the NEP’s clearing and credit default 
swap/derivatives expertise.
The requested resources also will help OCIE conduct 
examinations of transfer agents, including joint 
examinations with federal banking regulators.  
Efficient transfer agent operations are critical to 
secondary securities markets. Examination efforts 
will continue to focus on transfers, record-keeping, 
safeguarding of customer information, and custody  
of shareholder funds.
Additional Significant Examination  
Program Efforts 
OCIE also requires staffing in other critical areas, 
including its Broker-Dealer and Exchange (BDX)
Program and its FINRA and Securities Industry 
Oversight (FSIO) Program. As described below, 
resources during the year will also be dedicated to 
significant program-wide efforts such as outreach 
initiatives, and risk assessment and surveillance. 
Broker-Dealer and Exchange Program. BDX continues 
to have significant responsibilities and one restored 
position is being requested in order to supplement 
existing staff and address new areas of responsibility. 
Resources in this program will be used to continue 
critical examination work related to, among others, 
broker-dealers, national securities exchanges, municipal 
advisors, the Public Company Accounting Oversight 
Board (PCAOB), and the Securities Investor Protection 
Corporation. BDX resources will also be used to cover 
several new categories of security-based swap market 
participants registering with the Commission, including 

30   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
security-based swap dealers and major security-based 
swap participants. During the year, staff will focus on 
high risk areas, including the sales and marketing of 
high risk products, with a particular emphasis on  
retail investors.
FINRA and Securities Industry Oversight Program. 
One restored position is requested to help FSIO with 
its oversight responsibilities of FINRA and MSRB. 
Oversight of FINRA is vitally important, as it is the 
primary regulator for broker-dealers. Examinations in 
FY 2019 will continue to focus on FINRA’s operations 
and regulatory programs and the quality of FINRA’s 
examinations of broker-dealers. Additionally, given the 
responsibility of MSRB to regulate municipal securities 
firms, staff will continue to examine the MSRB to 
evaluate the effectiveness of select operational and 
internal policies, procedures, and controls. 
Other Significant Initiatives. OCIE will continue to 
improve its analytic, surveillance, and risk assessment 
functions in FY 2019, leveraging data and information 
available to the exam program. As part of this work, 
the program will continue to perform preliminary risk 
analysis on thousands of entities in order to help focus 
the program’s limited resources on firms and industry 
practices posing the greatest risk to investors and  
the markets. 
In FY 2019, OCIE will continue efforts aimed at 
encouraging stronger industry compliance programs. 
These efforts include conducting OCIE’s Compliance 
Outreach programs, which provide information and 
resources for compliance personnel of registered 
entities; issuing reports and risk alerts to the public and 
industry; and speaking at conferences concerning areas 
of regulatory interest.
Developing Regulatory Technology and  
Data Analytics
As technology continues to evolve and alter the way 
entities conduct business, it is imperative that the 
examination program make appropriate investments 
to keep pace and to more effectively and efficiently 
conduct its regulatory oversight functions. Long-term 
investment and development in technology and analyt-
ical tools will be critical to the future success of the 
Commission’s oversight responsibilities. Particularly 
important in FY 2019 will be a continued focus on 
enhancing quantitative and data analytic efforts. These 
tools will provide staff with a greater ability to monitor 
for trends and emerging risks, ultimately enabling the 
staff to allocate SEC resources more effectively.
Workload Data
Activity
FY 2017
Actual
FY 2018
Estimate
1
FY 2019
Request 
1
Investment Adviser Examinations2,1142,1202,160
Investment Company Examinations (includes administrators)95100100
Broker-Dealer Examinations325300300
Transfer Agent Examinations574547
Municipal Advisor Examinations837575
Market Oversight Inspections 
2
115128128
Technology Controls Program Inspections707080
Clearing Agency Examinations141112
1	 These	estimates	may	be	impacted	by	a	number	of	factors	beyond	the	office’s	control,	including—but	not	limited	to—increases	in	the	 
complexity	of	firms	being	examined;	higher	than	anticipated	attrition	rates;	and	the	timing	and	amounts	of	the	resources	made	available.
2	 Market	oversight	inspections	include	inspections	of	exchanges	conducted	by	OCIE’s	BDX	group	as	well	as	programmatic	inspections	and	 
oversight	exams	of	FINRA	conducted	by	OCIE’s	FSIO	group.

FY 2019 BUDGET REQUEST BY PROGRAM   |   31
DIVISION OF CORPORATION FINANCE
(DOLLARS IN THOUSANDS)
FY 2017
Actual
FY 2018
Annualized CR
FY 2019
Request
Full-Time Equivalents 461  433  423 
Cost:
Salaries and Benefits
$   116,144$   115,096$   113,708
Non-Personnel Expenses31,92129,04936,894
Total Costs
$   148,065$   144,145$   150,601
Totals	may	not	appear	to	sum	from	detail	lines	due	to	rounding	of	actual	values
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 provides interpretive assistance to companies on 
SEC rules and forms.
Rulemaking and Interpretive Advice
During FY 2019, CF will continue to assist the 
Commission, as needed, with implementing any new 
rules to further facilitate capital formation and identi-
fying any unnecessary barriers that impede capital 
formation. As part of this effort, CF will consider 
proposing amendments to modernize certain disclosure 
requirements in Regulation S-K as part of its ongoing 
Disclosure Effectiveness Initiative and implement 
recommendations resulting from the Regulation S-K 
study required by the Fixing America’s Surface Trans-
portation (FAST) Act of 2015.
FY 2019 Request
The division requests three restored positions in  
FY 2019 to meet its goals and to enhance its ongoing 
efforts to facilitate capital formation. The new positions 
would allow CF to better support the volume of 
rulemakings by increasing the number of CF staff 
members dedicated to rulemaking. For example, in 
addition to the Disclosure Effectiveness Initiative 
described above, CF will consider recommending that 
the Commission propose amendments to further facil-
itate capital formation through exempt and registered 
offerings. The division will also consider recommending 
that the Commission propose amendments to Regula-
tion S-K and Regulation S-X to modernize and stream-
line industry-specific disclosures applicable to real estate 
companies, including real estate investment trusts. The 
new positions would enable CF to fully support these 
and other rulemaking priorities. 

32   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
Workload Data
Activity
FY 2017
Actual
FY 2018
Estimate
FY 2019
Request
Review
Reporting Company Reviews 4,2004,1004,100
Number of New Issuer Reviews    
IPO 1933 Act 430400400
New 1934 Act 90100100
New Issuer Reviews 
1
520500500
Total Reviews 4,7204,6004,600
Rulemaking and Interpretive 
General Advice and Coordination 
No-Action Letters/Interpretive Requests 95100100
No-Action Letters (Shareholder Proposals) 295300300
1	 Because	of	the	inherent	difficulty	of	predicting	future	market	and	economic	conditions,	the	division	assumes	for	planning	purposes	a	steady	level	of	 
transactional	filings	for	future	periods.

FY 2019 BUDGET REQUEST BY PROGRAM   |   33
DIVISION OF TRADING AND MARKETS
(DOLLARS IN THOUSANDS)
FY 2017
Actual
FY 2018
Annualized CR
FY 2019
Request
Full-Time Equivalents 263  248  250 
Cost:
Salaries and Benefits
$   66,008$   65,405$   66,611
Non-Personnel Expenses19,16118,30323,212
Total Costs
$   85,169$   83,708$   89,824
Totals	may	not	appear	to	sum	from	detail	lines	due	to	rounding	of	actual	values
The mission of the Division of Trading and Markets 
(TM) is to establish and maintain 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, each of which has specific functions and 
is focused on a specific part of the markets. These 
include: (i) Broker-Dealer Finance/Risk; (ii) Chief 
Counsel; (iii) Clearance and Settlement; (iv) Derivatives 
Policy and Trading Practices; and (v) Market Supervi-
sion. In addition, the division has two groups that serve 
in supporting functions: the Office of Analytics and 
Research, and the Office of the Managing Executive.
Overall, TM supervises the SROs and other major 
market participants in the U.S. securities markets, 
including 21 securities exchanges (equities and 
options), 81 alternative trading systems (ATS), over 
3,900 broker-dealers, seven active clearing agencies, 
nearly 380 transfer agents, FINRA, and various 
securities information processors.
TM is responsible for numerous separate rulemaking 
initiatives. Many of these rulemakings are focused on 
modernizing or establishing new ongoing supervisory 
and regulatory functions that will extend into FY 2019 
and beyond. These initiatives include:
• Development and implementation of pilot programs 
designed to test shifts in fee models; 
• Establishment of clear standards of conduct for 
broker-dealers to ensure transparency and fairness  
to investors;
• Implementation of a modernized regulatory  
framework for ATSs, enhancing transparency and  
protecting consumer information; and 
• Continuation of work related to the regulatory 
frameworks for security-based swaps and other 
derivatives products.
Ongoing work of the division includes the review of 
SRO rule proposals for consistency with the Exchange 
Act standards of investor protection, fair and orderly 
markets and market structure, and other statutory 
requirements. Additionally, staff throughout the 
division regularly responds to requests for interpretive 
guidance on existing rules to ensure compliance, as 
well as requests for exemptive and no-action relief. In 
FY 2017, TM processed 165 amendments to national 
securities exchange registrations (Form 1), registered 
13 new ATSs, and processed about 4,800 new invest-
ment product submissions (19b-4e).
FY 2019 Request
In FY 2019, TM requests 16 restored positions to 
undertake new market-related responsibilities resulting 
from ongoing or recently completed rulemakings, and 
to continue improving the agency’s market oversight 
and supervision. This includes a significantly enhanced 

34   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
focus on fixed income markets, requiring specialized 
industry expertise and staffing to support the new 
Fixed Income Market Structure Advisory Committee, 
established in early FY 2018. That committee’s work 
will initially focus on the structure and operation of the 
U.S. fixed income markets, bond market liquidity, and 
the extent to which any corporate bond market recom-
mendations might also be relevant for the municipal 
bond market. Staff will be required to fully develop, 
propose, and implement related recommendations. 
In FY 2019, the division will expand its work related 
to cybersecurity and other risks that present a threat 
to market stability. This work is required across the 
industry where this sort of risk continues to increas-
ingly become a greater concern. Such cyber risks 
have the potential to be significantly disruptive to 
U.S. markets and enhanced expertise is required to 
adequately ameliorate this risk. 
FY 2019’s work will include implementation of rule 
initiatives from FY 2018, and will incorporate lessons 
from the pilot programs underway. Building off lessons 
from the Tick Size Pilot, the division expects to further 
explore policies to enhance market structure in the 
small cap, illiquid segment of the market, to better 
encourage capital formation for smaller companies. 
Significant market structure changes may be warranted 
in this area and an additional pilot may be required to 
gather the requisite data to improve the structure of 
our markets for this segment. 
Risks and opportunities within the markets associated 
with new Financial Service Technologies (FinTech) 
is another area of division focus, requiring study 
of the flexibility of current regulatory frameworks 
and policies and application of lessons learned. As 
technology underpinning the U.S. markets evolves at a 
rapid pace, the division seeks to study the rise of such 
technologies, including new types of electronic match-
ing platforms and other secondary market tools and 
their impact on market liquidity. These studies, and 
associated pilot programs, will inform future regula-
tory considerations and initiatives. 
The division seeks to expand the agency’s depth of 
expertise in the area of market insight and analysis, 
enabling improved information sharing and issue 
spotting in support of the agency’s market threat 
detection and response capabilities. Staying current 
with market trends and developments is essential to 
the agency’s ability to remain an effective regulator. 
The requested restored positions would also help the 
division implement its new and enhanced responsibili-
ties to oversee clearing agencies and swap data repos-
itories as well as supplement staffing on existing work 
affected by the hiring freeze. 
Other restored positions would: (i) help improve 
the SEC’s analytics and reporting on broker-dealers’ 
finances, internal controls, and risk management 
practices; (ii) process an increasing number of rule 
proposals from a growing number of SROs; and (iii) 
provide interpretive guidance related to existing rules. 

FY 2019 BUDGET REQUEST BY PROGRAM   |   35
Workload Data
Activity
FY 2017
Actual
FY 2018
Estimate
FY 2019
Request
Securities Firm Supervision
SRO Proposed Rule Changes Reviewed 
1
456356
SEC Rulemaking, Exemptive Orders, and Interpretive and Other Actions255
Interpretive, Exemptive, and No-Action Request Letters Closed 
2
121515
Reviews of Potential Enforcement Actions1,2231,3001,300
Notices filed by SROs relating to Applications for Admission or Continuance as or  
with an SRO Member Notwithstanding a Statutory Disqualification 
3
152525
Provision of Interpretation and Guidance and Responding to General Questions 
4
16,24016,50016,500
Tips, Complaints, and Referrals (TCR)474450450
Risk Assessment of Broker-Dealers Filing Form 17-H
Firms Assessed100100100
Filings Reviewed 300300300
Risk Supervision of Alternative Net Capital Broker-Dealers
Firms Assessed 777
Filings Reviewed 848484
Risk Supervision of OTC Derivatives Dealers and Security-Based Swap Dealers
Firms Assessed8812
Filings Reviewed9696144
Applications Reviewed444
Broker-Dealers
Registrants3,9173,8753,850
Registration Applications Filed174170165
Registration Amendments Filed10,83510,80010,750
Registrations Withdrawn or Cancelled412400390
Financial Reports Filed5,6245,4005,100
Security-Based Swap Dealers
Registrants——15
Registration Applications Filed——15
Major Security-Based Swap Participants
Registrants——2
Registration Applications Filed——2
Funding Portals3650150 
Securities Market & Infrastructure Supervision
SRO Proposed Rule Changes and Advance Notices Reviewed 
1
2,9043,0942,728
NMS & SRO Plan Amendments Filed262020
SEC Rulemaking, Exemptive Orders, and Interpretive and Other Actions121010
continued on next page 
1	 This	data	includes	filings,	pre-filings,	and	amendments	reviewed.
2	 This	data	includes	requests	for	which	a	formal	response	was	not	issued,	such	as	items	that	were	withdrawn,	but	omit	routine	correspondence	(such	as	
routine	broker-dealer	financial	responsibility	correspondence	and	foreign	control	location	letters	filed	under	Rule	15c3-3	of	the	Securities	Exchange	Act).
3	 Activity	description	changed	from	“Registered	Representative	Reentry	Applications	Filed”	to	better	describe	this	data.
4	 Calls	and	emails	received	by	TM	staff	directly	from	the	public	increased	dramatically	over	last	year.	This	increase	was	driven	in	large	part	by	a	move	to	
allow	certain	registrants	to	file	certain	filings	electronically,	which	generated	significant	questions	and	requests	for	assistance.

36   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
Workload Data (continued)
Activity
FY 2017
Actual
FY 2018
Estimate
FY 2019
Request
Securities Market & Infrastructure Supervision (continued)
Interpretive, Exemptive, and No-Action Request Letters Closed383030
Securities Exchanges
Registrants212223
Registration Applications Filed—11
Registration Amendments Filed165173180
Registrations Withdrawn or Cancelled———
Alternative Trading Systems
Registrants9098111
Initial Operations Reports Filed181520
Initial Operations Report Amendments Filed149162183
Cessations977
Quarterly Reports329358405
Security-Based Swap Execution Facilities 
5
Registrants———
Registration Applications Filed———
Proposed Rule Changes Filed ———
Clearing Agencies (Active) 
6
Registrants91010
Registration Applications Filed1——
Security-Based Swap Data Repositories 
7
Registrants—22
Registration Applications Filed2——
Transfer Agents 
8
Registrants299290290
Registration Applications Filed777
Registration Amendments Filed179175170
Registrations Withdrawn or Cancelled192225
Annual Reports Filed243240235
Large Traders
Registrants6,2696,5576,857
Registration Applications Filed589580580
Registration Amendments Filed2,7552,9003,000
Terminated or Inactive301300300
Annual Reports Filed3,1556,5576,857
5	 The	Commission	has	granted	an	exemption	from	the	statutory	requirement	to	register	as	a	“security-based	swap	execution	facility”	to	any	facility	that	
trades	security-based	swaps,	pending	adoption	and	implementation	of	final	rules	governing	security-based	swap	execution	facilities.
6	 As	of	December	31,	2017,	it	is	unclear	whether	additional	clearing	agencies	will	seek	registration	in	2018.
7	 As	of	December	31,	2017,	it	is	unclear	whether	additional	security-based	swap	data	repositories	will	seek	registration	in	2018.
8	 This	data	only	includes	SEC-registered	transfer	agents	and	omits	the	approximately	80	transfer	agents	registered	with	a	bank	regulatory	agency,	which	
the	Commission	also	oversees.

FY 2019 BUDGET REQUEST BY PROGRAM   |   37
DIVISION OF INVESTMENT MANAGEMENT
(DOLLARS IN THOUSANDS)
FY 2017
Actual
FY 2018
Annualized CR
FY 2019
Request
Full-Time Equivalents                  
182 
                  
176 
                  
175 
Cost:
Salaries and Benefits
$   47,193$   47,254$   47,491
Non-Personnel Expenses12,15110,48813,140
Total Costs
$   59,344$ 57,742$ 60,631
Totals	may	not	appear	to	sum	from	detail	lines	due	to	rounding	of	actual	values
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 developing regulatory policy 
for open-end management investment companies 
(commonly known as mutual funds), exchange-traded 
funds (ETF), closed-end funds, variable insurance 
products and other investment companies, and for 
investment advisers. 
Investment companies—including mutual funds and 
ETFs—are the principal means by which middle class 
Americans invest in the capital markets. Investment 
companies provide a crucial link between U.S. house-
holds seeking an investment return on dollars saved 
for education or retirement, and U.S. corporations, 
non-profits, and national, state, and local governments 
seeking capital from the securities markets to fund 
projects that provide needed goods, services, and 
economic growth. 
Investment companies supply significant amounts of 
debt and equity capital to a variety of issuers. In terms 
of percentage of market value of outstanding securities, 
they hold: 
• 31 percent of U.S. corporate stock
• 19 percent of U.S. and foreign corporate bonds
• 13 percent of U.S. Treasury and government  
agency securities
• 23 percent of U.S. municipal securities 
As of September 2017, there were 12,616 SEC- 
registered investment advisers reporting approximately 
$71.7 trillion in regulatory assets under management. 
Approximately 51 percent of these advisers provide 
investment advice to mainstream retail investors. 
Approximately 37 percent provide investment advice 
to private funds such as hedge funds and private equity 
funds with gross assets of about $11.6 trillion. In 
addition to registered investment advisers, the SEC  
also receives reports from approximately 3,743  
exempt reporting advisers—those who are exempt 
from registering with the SEC because they are  
venture capital fund advisers or mid-sized private  
fund advisers—who report managing approximately 
$2.6 trillion in private funds.
FY 2019 Request
The SEC requests a total of seven restored positions  
for IM to implement key policy objectives. 
One new position is requested for an ETF industry 
professional. Among other responsibilities, the staff 
person would evaluate novel and complex ETF 
products, structures, trading mechanisms and index 
replication methodologies; obtain and interpret 
information resulting from dialogue with portfolio 
managers, authorized participants, index arbitrage 
traders, operations managers, personnel involved in 
physical and synthetic index replication, and other 
technical experts; and assist in targeted examinations 
that involve ETF industry participants. 

38   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
One new position is requested for a derivatives  
professional to apply sophisticated quantitative  
analysis techniques to the review of disclosure filings  
of investment companies.
Two new positions are requested to work with asset 
management industry participants to formulate policy 
recommendations with respect to issues involving the 
impact of new technologies on the investment manage-
ment and investment adviser industries, including 
issues related to cybersecurity, FinTech, and the 
emergence of roboadvice. 
One new position is requested for expertise specific 
to fixed income mutual funds and ETFs to help the 
division analyze and address market structure issues 
involving bond funds and ETFs and work with the 
Commission’s new Fixed Income Market Structure 
Advisory Committee on these matters.
One new position is requested to strengthen IM’s 
capacity to conduct ongoing analysis of data related 
to IM disclosure, regulatory, and industry engagement 
programs, and enhance IM’s ability to respond rapidly 
to market events with policy recommendations that are 
informed by sophisticated quantitative analysis. 
One new position is requested to improve oversight  
of private funds, their investment advisers, and 
business development companies (BDC). The position 
would be used to augment capacity to analyze Form PF 
data; enhance IM’s ability to respond to private fund 
adviser interpretive requests, identify policy issues, and 
recommend regulatory changes in light of changing 
conditions; and assist the division and other Commis-
sion staff in understanding the investment process used 
by BDCs.
Workload Data
Activity
FY 2017
Actual
FY 2018
Estimate
FY 2019
Request
Disclosure 
New Portfolios and Insurance Contracts Filed on Registration Statements 2,7952,8502,850
New Portfolio Disclosures and Insurance Contracts Reviewed 1,7261,8301,830
Existing Portfolios and Insurance Contracts Filed on  
Post-Effective Amendments 
1, 2
34,87133,80033,975
Existing Portfolio Disclosures and Insurance Contracts Reviewed 
2
5,4925,2335,237
Portfolios and Insurance Contracts Filed on Proxy Statements 1,7811,4501,450
Portfolios and Insurance Contracts Filed on Proxy Statements Reviewed 1,7811,4501,450
Annual and Periodic Reports Filed 14,51114,40014,475
Annual and Periodic Reports Partially Reviewed 5,0094,8004,825
Total Filings 53,95852,50052,750
Total Filings Reviewed 14,00813,31313,342
Percent Reviewed 26%25%25%
Interpretive Guidance  
Formal and Informal Requests for Guidance 1,2321,2051,205
Enforcement-Related Matters Reviewed 2,352840850
Exemptive Relief Requests Concluded 309275275
1	 Included	in	post-effective	amendments	are	open-end,	closed-end,	and	unit	investment	trust	(UIT)	portfolios.
2	 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.	Because	of	their	repetitive	nature,	amendments	to	UIT	portfolios	are	generally	not	reviewed.

FY 2019 BUDGET REQUEST BY PROGRAM   |   39
DIVISION OF ECONOMIC AND RISK ANALYSIS
(DOLLARS IN THOUSANDS)
FY 2017
Actual
FY 2018
Annualized CR
FY 2019
Request
Full-Time Equivalents 157 147 145 
Cost:
Salaries and Benefits
$   39,919$   39,428$   39,323
Non-Personnel Expenses28,08832,96435,758
Total Costs
$   68,007$   72,392$   75,081
Totals	may	not	appear	to	sum	from	detail	lines	due	to	rounding	of	actual	values
The Division of Economic and Risk Analysis (DERA) 
continues to provide a powerful combination of 
sophisticated economic, financial, and legal expertise, 
and rigorous data analytic and quantitative methodol-
ogies in furtherance of the SEC’s mission. The division 
is involved across the entire range of SEC activities, 
including policy-making, rulemaking, enforcement, 
and examination. As the agency’s “think tank,” 
DERA relies on a variety of academic disciplines, 
quantitative and non-quantitative approaches, and 
knowledge of market institutions and practices to help 
the Commission approach complex matters in a fresh 
light. DERA also assists in the Commission’s efforts 
to identify, analyze, and respond to risks and trends, 
including those associated with new financial products 
and strategies. Through the range and nature of its 
activities, DERA serves the critical function of promot-
ing collaborative efforts throughout the agency and 
breaking through silos that might otherwise limit the 
impact of the agency’s institutional expertise.
The division produces high-quality, data-driven analy-
ses that address the economic issues associated with the 
regulation of the financial markets and the enforcement 
of federal securities laws. DERA’s support for the SEC 
primarily falls into four categories. 
Informing Policy-Making with Robust 
Economic Analysis and Cutting-Edge 
Research
DERA provides economic expertise for policy-making 
by analyzing the economic effects of regulations and 
other priority initiatives, and by engaging in novel 
research regarding the regulation of financial markets. 
DERA provides theoretical and data-driven economic 
analyses to support the Commission’s broad regulatory 
agenda. These analyses typically examine the need for 
regulatory action, consider potential economic effects 
by collecting and analyzing market data and evaluating 
pertinent academic literature, among other methods, 
and evaluate public comments. 
Producing Papers and Studies on  
Significant Economic Issues 
DERA produces papers and studies on significant 
economic issues that support the Commission’s 
mission. These staff-authored white papers and 
memoranda are publicly available on the DERA 
website and are often cross-referenced in Commission 
rulemakings or other policy initiatives. These papers 
showcase DERA staff’s academically rigorous research 
that aims to inform policy as it is being developed.

40   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
Supporting Enforcement and  
Inspection Activities
DERA economists directly support the SEC’s enforce-
ment and litigation activities by applying economic 
methods to address agency investigations, negotiations, 
and distribution of recovered funds to harmed inves-
tors. With increasing frequency, DERA is requested 
to testify as fact and expert witnesses on behalf of the 
Commission. The fact that this expertise is resident in 
the division is extremely cost effective when compared 
to the cost associated with contracting outside 
professionals. DERA also supports agency staff with 
examination planning, including providing guidance 
on the collection and analysis of data to help promote 
risk-based examination programs.
Improving Accessibility and Usability  
of SEC Data
DERA takes innovative approaches to developing 
solutions that make market information accessible 
to internal and external audiences. Structured data 
reporting enhances access for the Commission and 
other users to key information about registrants, 
their practices, and their offerings. DERA works 
closely with agency offices and divisions to design 
data structuring approaches for required disclosures, 
and supports the SEC’s data collection and usage by 
designing taxonomies, validation rules, data quality 
assessments, and dissemination tools to facilitate 
high-quality data analyses. Once this data is ingested, 
DERA provides a variety of platforms—and continues 
to develop new ones—that allow non-technical staff to 
access and use vast quantities of market data. 
FY 2019 Request
The SEC seeks four restored positions to begin to 
address both the most critical staffing needs that have 
resulted from attrition and the continued demand for 
economic expertise from across the agency. All four 
positions would be filled with financial economists 
and will be targeted to fill essential skill gaps within 
DERA’s risk assessment and policy offices. Two of 
these financial economists are for DERA’s Office of 
Risk Assessment to address unmet customer demand 
for support and expertise in cyber/operational risk, 
structured finance, and investment advisers/asset 
management. 
The remaining two financial economists positions 
are for DERA’s policy offices to enhance the level of 
economic expertise to focus on policy and rule- 
making matters related to financial accounting and 
disclosure (including PCAOB matters) as well as  
private funds, registered investment companies, and 
investment advisers. 
Workload Data
Activity
FY 2017
Actual
FY 2018
Estimate
FY 2019
Request
Reviews of Commission Rules
 1
788082
Reviews of SRO and PCAOB Filings 555759
Advice on Regulatory, Enforcement, and Risk Assessment Issues 3,4433,5003,500
Interactive Data Compliance Monitoring 8,3347,9607,600
Interactive Data Programs Supported 131314
1	 Includes	staff	participation	in	Commission	rulemaking	at	all	stages	of	development	as	well	as	10-year	rule	reviews	required	by	the	Regulatory	Flexibility	Act.

FY 2019 BUDGET REQUEST BY PROGRAM   |   41
OFFICE OF THE GENERAL COUNSEL
(DOLLARS IN THOUSANDS)
FY 2017
Actual
FY 2018
Annualized CR
FY 2019
Request
Full-Time Equivalents141134131
Cost:
Salaries and Benefits
$   36,938$   36,647$   36,252
Non-Personnel Expenses9,9179,06011,194
Total Costs
$   46,855$   45,707$   47,446
Totals	may	not	appear	to	sum	from	detail	lines	due	to	rounding	of	actual	values
The General Counsel serves as the chief legal officer of 
the SEC and heads the Office of the General Counsel 
(OGC). OGC provides independent legal analysis and 
advice to the Chairman, Commissioners, and operating 
divisions 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 SEC 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 2019, OGC will continue to focus 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 and 
address legal challenges to rulemakings. 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. The staff 
will also continue to provide assistance and advice in 
responding to Congressional requests for information 
and documents. 

42   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
Workload Data
Activity
FY 2017
Actual
FY 2018
Estimate
FY 2019
Request
Appellate Cases 
Open Matters 174175175
Adjudicatory Matters
Pending Beginning of Year 677770
Received 523232
Completed 423939
Pending End of Year 777063
Legislation
Testimony 42020
Correspondence with Congress and Others 91180180
Legislative Analysis and Technical Assistance 501380380
Other91110110
Advisory Services
SEC Statutes 
Analysis of Enforcement Memoranda 2,2252,2002,200
Review of Rulemaking and Other Projects 465600630
Review of Articles and Speeches 358300300
Non-SEC Statutes 
Freedom of Information Act (FOIA) – Internal Appeals 605620620
Personnel Matters 245245245
Procurement Matters 750760780
Labor Matters 253030
Attorney Misconduct Investigations 410425430
Other (Subpoenas) 515050
Corporate Reorganization
Petitions Involving Public Investor Interest 546060
Chapter 11 Cases: Appearances 
Filed 293030
Closed 463030
Chapter 11 Cases: Monitored 
Filed 253030
Closed 292525
Disclosure Statement Reviews 829090
Disclosure Statements Commented On 606060

FY 2019 BUDGET REQUEST BY PROGRAM   |   43
OTHER PROGRAM OFFICES
(DOLLARS IN THOUSANDS)
FY 2017
Actual
FY 2018
Annualized CR
FY 2019
Request
Full-Time Equivalents:
Office of the Chief Accountant 49  50  49 
Office of Investor Education and Advocacy 43  42  42 
Office of International Affairs 55  53  51 
Office of Administrative Law Judges 13  12  12 
Office of the Investor Advocate 11  11  12 
Office of Credit Ratings 44  41  41 
Office of Municipal Securities 9  10  10 
Office of the Advocate for Small Business  
Capital Formation
—13
Total Full-Time Equivalents224220220
Cost:
Salaries and Benefits
$    57,392$    57,013$    57,612
Non-Personnel Expenses23,67220,74725,774
Total Costs
$    81,064$    77,761$    83,386
Totals	may	not	appear	to	sum	from	detail	lines	due	to	rounding	of	actual	values
This section describes the responsibilities and activities 
of the agency’s smaller program offices.
Office of the Chief Accountant: Establishes accounting 
and auditing policy and works to improve the profes-
sional performance of public company auditors to 
ensure that financial statements used for investment 
decisions are presented fairly and have credibility.
Office of Investor Education and Advocacy: Serves inves-
tors who complain to the SEC about investment fraud 
or the mishandling of their investments by securities 
professionals, ensures the views of retail investors 
inform the Commission’s regulatory policies and 
disclosure programs, and works to improve investors’ 
financial literacy. 
Office of International Affairs: Advances international 
regulatory and enforcement cooperation, promotes 
high regulatory standards worldwide, and facilitates 
technical assistance programs in foreign countries.
Office of Administrative Law Judges: Adjudicates allega-
tions of securities law violations.
Office of the Investor Advocate: Provides assistance to 
investors in resolving significant problems they may 
have with the SEC or with SROs, and identifying areas 
in which investors would benefit from changes to 
federal laws or to SEC regulations or SRO rules. 

44   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
Office of Credit Ratings: Administers the rules of the 
Commission with respect to the practices of nationally 
recognized statistical rating organizations (NRSRO) in 
determining ratings; protects the users of credit ratings; 
promotes accuracy in credit ratings issued by NRSROs; 
and ensures that such ratings are not unduly influenced 
by conflicts of interest.
Office of Municipal Securities: Administers the rules of 
the Commission with respect to the practices of munic-
ipal securities brokers and dealers, municipal advisors, 
and investors in, and issuers of, municipal securities. 
The office also coordinates with MSRB on rulemaking 
and enforcement actions.
Office of the Advocate for Small Business Capital  
Formation: 
Will be created by the SEC as required by 
the SEC Small Business Advocate Act (P.L. 114-284). 
Among other functions, the office will identify needs  
of small businesses and small business investors, and 
how the regulations of the Commission or SROs can  
be changed to better address those needs.

FY 2019 BUDGET REQUEST BY PROGRAM   |   45
OFFICE OF THE CHIEF ACCOUNTANT
(DOLLARS IN THOUSANDS)
FY 2017
Actual
FY 2018
Annualized CR
FY 2019
Request
Full-Time Equivalents495049
Cost:
Salaries and Benefits
$   14,427$   14,616$   14,510
Non-Personnel Expenses3,8693,5744,538
Total Costs
$   18,297$   18,191$   19,048
Totals	may	not	appear	to	sum	from	detail	lines	due	to	rounding	of	actual	values
The Office of the Chief Accountant (OCA) is respon-
sible for establishing and interpreting accounting 
and auditing policy to enhance the transparency and 
relevancy of financial reporting for investors. OCA 
works to improve the professional performance of 
public company auditors to ensure that financial 
statements used for investment decisions are presented 
fairly and have credibility. OCA leads the SEC’s efforts 
to oversee accounting standard-setting by the Financial 
Accounting Standards Board (FASB) and auditor 
oversight and standard-setting by the PCAOB, and to 
monitor international accounting standard-setting by 
the International Accounting Standards Board (IASB).
FY 2019 Objectives and Priorities
The Accounting Group will continue to advise on signif-
icant ongoing changes in the accounting and disclosure 
standards developed and issued by the FASB and 
IASB, such as revenue recognition, leases, and financial 
instruments. Also, the Accounting Group will continue 
to consult with companies and auditors regarding the 
application of accounting and disclosure standards, 
including the impact of the comprehensive tax reform 
from the Tax Cuts and Jobs Act of 2017.
The Professional Practice Group (PPG) will continue 
to provide expert advice related to auditing, indepen-
dence, and internal control over financial reporting. 
PPG also assists the Commission in its oversight of 
the PCAOB. PPG primarily provides this advice in 
rulemaking support, overseeing the PCAOB (includ-
ing PCAOB standard-setting), and consultations. In 
addition, PPG has been assisting in PCAOB oversight 
since its formation in the early 2000s. PCAOB 
has reached a relative steady state, but has grown 
tremendously during this time, which results in larger 
oversight activity. 
The Office of the Chief Counsel and Enforcement Liaison 
(OCCEL)
 will continue to assist ENF on cases involving 
accounting, auditing, and auditor independence. Based 
on the increased number and complexity of cases in 
these areas, OCCEL finds an ever increasing need to 
work with ENF teams at an earlier stage of their  
investigations. In addition, rulemaking activities in  
OCA are expected to increase. Furthermore, OCCEL 
will continue to assist with staff speeches, panel discus-
sions, and briefing statements that involve or relate to 
OCA activity. 
The International Group anticipates continuing monitor-
ing work on international accounting standards. The 
International Group is expecting that implementation 
questions associated with new major standards going 
into effect will cause it to spend additional time on 
interpretive activities. In addition, the IASB is now 
moving forward on fundamental work related to 
disclosure effectiveness, which is an area the Interna-
tional Group wants to closely monitor given the SEC’s 
existing rules and pending rulemaking efforts.

46   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
Workload Data
Activity
FY 2017
Actual
FY 2018
Estimate
FY 2019
Request
Oversight of Accounting and Auditing Standard-Setting   
U.S. Accounting Standard Setter Trustee and Board Appointments455
U.S. Accounting Standard-Setting Projects and Interpretations646565
International Accounting Standard-Setting Projects and Interpretations546161
U.S. Auditing Oversight (PCAOB) Board Appointments—5—
Inspections of PCAOB Programs1——
U.S. Auditing Standards and Other Rules Issued by PCAOB and  
Approved by SEC
—33
International Audit/Ethics Standard-Setting Projects and Interpretations131311
    
Development of Commission Accounting and Auditing Policies   
SEC Rule Amendments and SEC Staff Announcements and Bulletins71212
International Organization of Securities Commissions (IOSCO)  
Policy Statements, Consultation Papers, and Reports
132
    
Interpretation of Accounting Standards, Policies, and Positions   
Resolution of Accounting Issues of SEC Registrants130140130
Discussions of International Accounting Issues304952
    
Recommendations for Actions on the Qualification of Accountants 
to Practice Before the Commission
   
PCAOB Inspections of Audit Firms Subject to SEC Oversight273247250
Auditor Independence Consultations205225250
    
Supervision of the Procedures for the Commission’s Accounting 
and Auditing Enforcement Activities
   
Consultations on Potential Enforcement Investigations311311311
Rule 102(e) Accountant Reinstatement Applications262121
    
Assistance with Resolving Differences on Accounting Issues 
Between Registrants and the Commission
   
 (Included within Interpretation of Accounting Standards,  
Policies, and Positions listed above)
N/AN/AN/A
    
OCA External Outreach and Communication   
Speeches, Panel Discussions, and Meetings with Constituent Groups143159159

FY 2019 BUDGET REQUEST BY PROGRAM   |   47
OFFICE OF INVESTOR EDUCATION AND ADVOCACY
(DOLLARS IN THOUSANDS)
FY 2017
Actual
FY 2018
Annualized CR
FY 2019
Request
Full-Time Equivalents434242
Cost:
Salaries and Benefits
  $ 10,922     $ 10,654  $ 10,766     
Non-Personnel Expenses
8,391      5,793    7,088   
Total Costs
  $ 19,313    $ 16,447   $ 17,854   
Totals	may	not	appear	to	sum	from	detail	lines	due	to	rounding	of	actual	values
The Office of Investor Education and Advocacy (OIEA) 
seeks to provide individual investors with the informa-
tion they need to make sound investment decisions. 
OIEA administers two primary programs to promote this 
mission: assisting individual investors with complaints 
and inquiries about the securities markets and market 
participants, and conducting educational outreach to 
individual investors. OIEA also helps to inform Commis-
sion policy by advising the Commission and Commission 
staff on various issues from the perspective of the indi-
vidual investor, including with respect to rulemakings, 
Investor Advisory Committee recommendations, and 
through IOSCO’s Committee on Retail Investors.
Research indicates that many retail investors are not 
taking key steps to protect their money from investment 
fraud, including researching the background of an invest-
ment professional before investing. In FY 2019, OIEA 
plans to continue its “Before You Invest, Investor.gov” 
public service campaign focused on helping individuals 
protect themselves from investment fraud, including 
raising awareness about Investor.gov. 
OIEA is seeking one restored position to expand its in- 
vestor education efforts by focusing on initiatives aimed 
at increasing the number of investment professional 
background checks on Investor.gov by retail investors.
Workload Data
Activity
FY 2017
Actual
FY 2018
Estimate
FY 2019
Request
Investor Assistance 
Total Investor Assistance Matters Closed16,75616,00016,000
Percentage of Investor Assistance Matters Closed Within: 
7 Days 65%62%62%
30 Days 94%90%90%
Investor Education 
Page Views on OIEA Web Pages 
1
9,100,0008,000,00010,000,000
In-Person Investor Events 1469090
Number of Investor Alerts and Bulletins Issued 343232
1	 OIEA	implemented	technical	changes	in	FY	2016	to	help	users	navigate	SEC	online	investor	education	material	more	efficiently,	resulting	in	fewer	page	
views.	As	a	result,	the	target	for	FY	2017	was	changed	from	37.5	million	to	eight	million	page	views.	

48   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
OFFICE OF INTERNATIONAL AFFAIRS
(DOLLARS IN THOUSANDS)
FY 2017
Actual
FY 2018
Annualized CR
FY 2019
Request
Full-Time Equivalents555351
Cost:
Salaries and Benefits
$  13,198$  13,536$  13,159
Non-Personnel Expenses3,4003,4734,771
Total Costs
$  16,598$  17,009$  17,930
Totals	may	not	appear	to	sum	from	detail	lines	due	to	rounding	of	actual	values
The Office of International Affairs (OIA) advances the 
SEC’s mission by promoting international enforcement 
and supervisory cooperation; developing and imple-
menting strategies to further SEC policy interests in 
the regulation and oversight of cross-border securities 
activities; managing and executing the SEC’s partici-
pation in international regulatory bodies; engaging in 
regulatory dialogues with international counterparts; 
and providing technical assistance to strengthen 
partnerships with foreign authorities. 
FY 2019 Objectives and Priorities 
The Regulatory Policy Group will continue to advise 
the Chairman, Commissioners, and staff on strategies 
for advancing the Commission’s objectives in interna-
tional organizations, including the Financial Stability 
Board (FSB) and IOSCO, and to coordinate the 
Commission’s participation in these bodies; promote 
the Commission’s bilateral relationships with other 
jurisdictions and work with foreign authorities to 
address cross-border policy issues that may have an 
impact on U.S. market participants, i.e., the Markets in 
Financial Instruments Directive; and collaborate with 
other divisions and offices with respect to developing 
or operationalizing SEC rulemakings or other policy 
initiatives with cross-border elements.
The International Enforcement Cooperation Group  
will assist ENF in conducting investigations and 
enforcement proceedings with international aspects, 
including where wrongdoers, witnesses, evidence, or 
the proceeds of fraud are located abroad; advise and 
help foreign authorities with their investigations and 
litigation, e.g., where perpetrators, witnesses, evidence, 
or the proceeds of a fraud are located in the United 
States; and move forward the Commission’s policy 
objectives in the international cooperation area, includ-
ing promoting best practices and overcoming obstacles 
with respect to cross-border enforcement-related 
information sharing. Consistent with the Commission’s 
enforcement priorities, which include a focus on retail 
investors and cyber-related misconduct, the Interna-
tional Enforcement Cooperation Group will continue 
to promote initiatives to address frauds that affect 
retail investors such as cross-border pump and dump 
frauds. OIA’s International Enforcement Group will 
also assist ENF to combat cyber-enabled misconduct 
such as market manipulation schemes accomplished  
by foreign hackers and initial coin offering (ICO)- 
related frauds. 

FY 2019 BUDGET REQUEST BY PROGRAM   |   49
The Supervisory Cooperation Group plans to assist SEC 
examination staff in OCIE and OCR on cross-border 
supervisory issues; advise and help foreign regulators 
with supervisory matters involving globally-active 
regulated entities; and develop and implement 
additional cooperation memoranda of understanding 
and other supervisory cooperation arrangements with 
foreign regulatory authorities.
The Technical Assistance Group will continue to build 
capacity and strong relationships with the same foreign 
counterparts the agency relies on for assistance with 
SEC enforcement cases and overseas examinations. In 
response to requests from foreign securities authorities, 
the group will provide technical advice and training; 
review regulatory oversight regimes and suggest 
improvements; and consult on draft legislation,  
regulations, and operational processes and procedures.
Workload Data
Activity
FY 2017
Actual
FY 2018
Estimate
FY 2019
Request
SEC ENF Requests to SEC OIA for International Assistance 
1
1,2721,3891,506
Responses to Foreign Requests for SEC Enforcement Assistance 
1
599627655
Number of International Regulatory and Law Enforcement Officials Trained 
2
1,8371,8501,850
SEC Requests for Supervisory Cooperation Assistance 
3
169174179
Responses to Foreign Requests for SEC Supervisory Cooperation 
Assistance 
4
153158163
International Regulatory Initiatives (including regulatory initiatives) 
5
 144178178
1	 OIA’s	FY	2018	estimate	and	FY	2019	request	use	a	linear	trend	analysis	of	actual	results	from	the	last	five	fiscal	years	in	combination	with	FY	2018	Q1	 
actual	results.	The	FY	2018	estimate	and	FY	2019	request	to	OIA	are	higher	than	OIA’s	previous	submission	and	the	FY	2018	estimate	and	FY	2019	
request	for	responses	to	foreign	requests	are	lower	than	OIA’s	previous	submission	as	a	result	of	such	analysis.
2	 OIA’s	FY	2018	and	FY	2019	figures	are	contingent	on	the	availability	of	sufficient	domestic	and	foreign	resources.
3	 OIA	projects	a	three	percent	increase	in	the	number	of	requests	for	supervisory	cooperation	from	SEC	staff,	including	OCIE,	OCR,	and	TM.	 
The	FY	2018	estimate	is	higher	than	OIA’s	previous	submission	because	OIA	used	FY	2017	actual	results	to	calculate	the	FY	2018	estimate.
4	 OIA	projects	a	three	percent	increase	in	the	number	of	foreign	requests	for	SEC	assistance	in	supervisory	matters.	The	FY	2018	estimate	is	higher	than	
OIA’s	previous	submission	because	OIA	used	FY	2017	actual	results	to	calculate	the	FY	2018	estimate.
5	 The	Regulatory	Policy	Unit	tracks	bilateral	and	multilateral	engagements	for	the	Chairman,	Commissioners,	and	OIA	staff	that	the	Regulatory	Policy	Unit	
coordinates	and	supports.	The	Regulatory	Policy	Unit	also	supports	staff	throughout	the	agency	on	internal	projects	with	international	aspects	and	 
international	projects	that	are	not	quantified	in	this	tracking	mechanism.

50   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
OFFICE OF ADMINISTRATIVE LAW JUDGES
(DOLLARS IN THOUSANDS)
FY 2017
Actual
FY 2018
Annualized CR
FY 2019
Request
Full-Time Equivalents131212
Cost:
Salaries and Benefits
  $ 2,542       $ 2,472  $ 2,498 
Non-Personnel Expenses             648574 709
Total Costs
  $ 3,190      $ 3,046   $ 3,207     
Totals	may	not	appear	to	sum	from	detail	lines	due	to	rounding	of	actual	values
The Office of Administrative Law Judges (OALJ) 
supports the SEC’s mission by conducting hearings, 
issuing initial decisions, and adjudicating ancillary 
matters in administrative proceedings. The Commis-
sion initiates an administrative proceeding by issuing 
an order instituting proceedings, which contains ENF’s 
allegations against one or more respondents. In most 
cases, an order instituting proceedings directs that a 
public hearing be held before an administrative law 
judge for the purpose of taking evidence, determining 
whether the allegations are true, and issuing an initial 
decision within a specific time period.
Administrative law judges serve as independent adjudi-
cators. Under the Administrative Procedure Act and 
the Commission’s Rules of Practice, administrative law 
judges conduct public hearings in a manner similar to 
federal bench trials, at locations throughout the United 
States. They preside at and regulate the course of these 
hearings, which may include setting filing deadlines, 
issuing subpoenas, holding prehearing conferences, 
and ruling on motions. Following the hearing and 
consideration of the parties’ post-hearing submis-
sions, the administrative law judge prepares an initial 
decision setting forth his or her factual findings and 
legal conclusions and, where appropriate, determining 
whether sanctions are warranted.
If a respondent fails to file an answer to the order insti-
tuting proceedings, appear at a conference or hearing, 
respond to a dispositive motion, or otherwise defend 
the proceeding, the administrative law judge may issue 
an initial decision finding the respondent in default and 
accepting the allegations as true. In certain proceedings, 
summary disposition, as opposed to a live hearing, may 
be used to resolve all or some of the issues. 
OALJ anticipates the Commission will institute and 
order public hearings in 200 proceedings in FY 2019. 
The exact number and specific nature of these cases 
are unknown. In FY 2018, OALJ expects to dispose of 
many of the new assignments and the 109 proceedings 
recently remanded by the Commission. See Pending 
Admin. Proc., Securities Act of 1933 Release No. 
10440, 2017 SEC LEXIS 3724 (Nov. 30, 2017),  
www.sec.gov/litigation/opinions/2017/33-10440.pdf. 
OALJ expects that with its currently allocated staff 
levels it will be capable of handling the 200 proceedings 
anticipated in FY 2019. Two hundred proceedings 
exceeds the 185 proceedings assigned in 2017, but 
is less than the number of cases assigned per year in 
2014–2016 and the number of cases anticipated in  
FY 2018.

FY 2019 BUDGET REQUEST BY PROGRAM   |   51
Workload Data
Activity
FY 2017
Actual
FY 2018
Estimate
FY 2019
Request
Proceedings Inventory 
Pending Disposition Beginning of Year 84101101
Ordered for Hearing 185300200
Disposed168300200
Canceled Before Hearing 5215050
Canceled After Hearing 1——
Initial Decision Issued 115150150
Pending Disposition End of Year 101101101

52   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
OFFICE OF THE INVESTOR ADVOCATE
(DOLLARS IN THOUSANDS)
FY 2017
Actual
FY 2018
Annualized CR
FY 2019
Request
Full-Time Equivalents111112
Cost:
Salaries and Benefits
$     2,720$     2,747$     3,035
Non-Personnel Expenses1,6312,3402,536
Total Costs
$     4,350$     5,087$     5,571
Totals	may	not	appear	to	sum	from	detail	lines	due	to	rounding	of	actual	values
The mandate for the Office of the Investor Advocate 
(OIAD) is set forth in Section 4(g) of the Securities 
Exchange Act of 1934. The office is responsible for, 
among other things, identifying areas in which inves-
tors would benefit from changes to federal laws, SEC 
regulations, or the rules of SROs, and for providing 
assistance to investors in resolving significant problems 
they may have with the SEC or SROs.
Investor Advocacy 
Consistent with the requirements of Section 4(g), 
the office 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
The office is responsible for submitting two reports 
to Congress per year. 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. The 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.
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 proce-
dures and make recommendations to encourage the 
investing public and other interested persons to submit 
questions to the Investor Advocate regarding compli-
ance 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. 

FY 2019 BUDGET REQUEST BY PROGRAM   |   53
Investor Testing
OIAD uses investor testing and other outreach 
efforts, as appropriate, to gather input on rulemak-
ing initiatives and better understand investor-based 
informational needs. OIAD is currently conducting 
monthly online polls, a research project to assess 
the current state of investor awareness concerning 
the different types of financial professionals and the 
associated standards of care, and a research project 
on mutual fund fee disclosure. These research projects 
entail surveys coupled with focus groups and one-on-
one interviews. OIAD anticipates additional research 
projects will develop in FY 2019 to support the 
Commission’s rulemaking agenda. As a result, OIAD 
has an acute need for additional staff with the expertise 
and skills necessary to conduct high-quality investor 
research and analysis. The restored position requested 
in FY 2019 would provide this type of expertise  
and directly align with the Commission’s strategic  
goals by strengthening its ability to evaluate retail 
investor issues.
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.
Workload Data
Activity
FY 2017
Actual
FY 2018
Estimate
FY 2019
Request
Ombudsman 
Investor Matters226275325
Investor Contacts1,3311,5001,650
Outreach Events/Speeches 221820
Investor Advocacy
SEC Rulemakings Reviewed 162025
SRO Rulemakings Reviewed 444450450
Policy Recommendations  to SEC, SROs, or Congress 288
Outreach Events/Speeches 373636
Investor Advisory Committee Support 
In-Person Committee Meetings 454

54   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
OFFICE OF CREDIT RATINGS
(DOLLARS IN THOUSANDS)
FY 2017
Actual
FY 2018
Annualized CR
FY 2019
Request
Full-Time Equivalents444141
Cost:
Salaries and Benefits
$   11,371$   10,489$  10,599
Non-Personnel Expenses5,1944,3155,226
Total Costs
$   16,565$   14,804$  15,825
Totals	may	not	appear	to	sum	from	detail	lines	due	to	rounding	of	actual	values
The Office of Credit Ratings (OCR) is charged with 
administering Commission rules with respect to the 
practices of 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 policy oversight 
of NRSROs and conducts examinations.
As required under the Dodd-Frank Act, OCR staff 
must possess knowledge of and expertise in corporate, 
municipal and structured debt finance. 
FY 2019 Request
OCR seeks to restore two securities compliance 
examiner positions. The first position would 
provide OCR with the opportunity to build out its 
senior management team in support of the office’s 
examination and monitoring responsibilities and the 
OCR-DERA Credit Ratings Analytical Data Unit.  
This unit would allow OCR to perform in-depth 
analyses of models against data sets and data feeds to 
strengthen OCR’s oversight of NRSROs. 
The second restored position would strengthen OCR’s 
examination and monitoring programs and allow 
for more detailed analyses of rating files, documents, 
methodologies, and policies and procedures. The 
examination and monitoring of NRSROs for compli-
ance with the federal securities laws and Commission 
rules would continue to account for the most signif-
icant portion of OCR’s workload in any fiscal year. 
OCR will further monitor and review registrants’ 
technological initiatives, cybersecurity governance, and 
risk assessment processes relating to access rights, data  
loss prevention, vendor management, training, and 
incident response. In addition, OCR will continue  
to evaluate and monitor credit models quantitatively 
and qualitatively, and will initiate specialized examina-
tions to conduct sweeps and targeted examinations  
as appropriate.

FY 2019 BUDGET REQUEST BY PROGRAM   |   55
Workload Data
Activity
FY 2017
Actual
FY 2018
Estimate
FY 2019
Request
Annual Examinations and Other Examination Compliance Activities 454445
Studies, Reports, and Related Matters 283133
Regulatory and Legislative Initiatives 858
Orders and No-Action Letters 157
Monitoring Meetings 343638
Form NRSRO – Initial Applications and Annual Certifications 575158
Enforcement/TCR 636063
International Activities 112114115
Business Processes 373941

56   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
OFFICE OF MUNICIPAL SECURITIES
(DOLLARS IN THOUSANDS)
FY 2017
Actual
FY 2018
Annualized CR
FY 2019
Request
Full-Time Equivalents91010
Cost:
Salaries and Benefits
$   2,211$   2,302$   2,326
Non-Personnel Expenses540522634
Total Costs
$   2,750$   2,824$   2,960
Totals	may	not	appear	to	sum	from	detail	lines	due	to	rounding	of	actual	values
The Office of Municipal Securities (OMS) oversees the 
$3.8 trillion municipal securities market and admin-
isters the Commission’s rules pertaining to municipal 
securities brokers and dealers, municipal advisors, 
investors in municipal securities, and municipal issuers. 
OMS also coordinates with MSRB on rulemaking and 
enforcement actions.
OMS advises the Commission on policy matters 
relating to the municipal securities market, and is 
responsible for policy development, coordination, and 
implementation of Commission initiatives to improve 
the municipal securities market. OMS provides 
technical assistance to other SEC offices and divisions, 
including OCIE and ENF. OMS is responsible for 
reviewing and processing all MSRB proposed rule 
changes on behalf of the Commission. OMS also 
regularly engages in public awareness and outreach 
activities, and closely monitors current issues in the 
municipal securities market.
In FY 2019, OMS will continue to coordinate the 
SEC’s municipal securities activities, administer SEC 
rules relating to the municipal securities market, 
oversee MSRB rulemaking, inform the Commission 
on current market issues, advise the Commission on 
policy matters relating to the municipal securities 
market, and provide technical assistance to other SEC 
offices and divisions. In addition, OMS will continue 
to lead semiannual meetings with MSRB and FINRA 
regarding the municipal securities market, as required 
by the Dodd-Frank Act; meet with MSRB and FINRA 
staff regularly to discuss rulemaking, examination, and 
enforcement activities; meet with Internal Revenue 
Service staff; and coordinate with other regulators as 
needed. OMS will also continue to work closely with 
the municipal securities industry to educate market 
participants about the federal securities laws applicable 
to the municipal securities market. 

FY 2019 BUDGET REQUEST BY PROGRAM   |   57
Workload Data
Activity
FY 2017
Actual
FY 2018
Estimate
FY 2019
Request
SRO Proposed Rule Changes Reviewed 
1
9912
SEC Rulemaking and Interpretive Actions 122
Interpretive, Exemptive, and No-Action Request Letters Closed 222
Reviews of Potential Enforcement Actions 222323
Congressional, Governmental, Industry, and Public  
Correspondence and Inquiries 
2
 
580650650
Public Awareness and Market Outreach 283232
Municipal Advisors 
3
Registrants 
4
651596606
Registration Applications Filed 434550
Registration Amendments Filed 5991,1921,212
Registrations Withdrawn or Canceled 
5
6010040
1			 This	data	includes	filings,	pre-filings,	and	amendments	reviewed.
2			 This	data	combines	correspondence	and	telephone/internet	inquiries.
3			 This	data	reflects	the	expanded	responsibilities	assigned	to	the	Commission	for	oversight	of	municipal	advisors	(firms	and	sole	proprietors).	 
by	the	Dodd-Frank	Act.	In	addition,	there	are	approximately	3,675	Form	MA-Is	on	file	with	the	Commission	in	relation	to	natural	persons	engaged	 
in	municipal	advisory	activities.
4			These	figures	reflect	all	active	MA	registrations	as	of	September	30	of	the	applicable	fiscal	year.
5			 These	figures	reflect	the	number	of	registration	withdrawals	or	cancellations	effective	as	of	September	30	of	the	applicable	fiscal	year.

58   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
OFFICE OF THE ADVOCATE FOR SMALL BUSINESS 
CAPITAL FORMATION
(DOLLARS IN THOUSANDS)
FY 2017
Actual
FY 2018
Annualized CR
FY 2019
Request
Full-Time Equivalents—13
Cost:
Salaries and Benefits
$       —$     197$     719
Non-Personnel Expenses—156273
Total Costs
$       —$     353$     992
Totals	may	not	appear	to	sum	from	detail	lines	due	to	rounding	of	actual	values
The SEC is in the process of establishing the Office 
of the Advocate for Small Business Capital Forma-
tion (OASB), as required by the SEC Small Business 
Advocate Act (P.L. 114-284), to help small businesses 
and investors resolve significant problems incurred 
with the SEC or SROs. OASB conducts outreach 
with small businesses and small business investors to 
solicit views on relevant capital formation issues and 
analyzes the impact of proposed regulations and rules 
on small businesses and small business investors. OASB 
also proposes changes in SEC regulations that aim to 
mitigate problems and promote the interests of small 
businesses and small business investors. In addition, 
OASB will consult with the Investor Advocate on 
issues related to small businesses and small business 
investors. 
The SEC is currently engaged in the process of hiring 
the advocate for Small Business Capital Formation, 
who will oversee this new office. In FY 2019, the  
SEC requests five additional positions to carry out  
the functions of the office.

FY 2019 BUDGET REQUEST BY PROGRAM   |   59
AGENCY DIRECTION AND ADMINISTRATIVE SUPPORT
(DOLLARS IN THOUSANDS)
FY 2017
Actual
FY 2018
Annualized CR
FY 2019
Request
Full-Time Equivalents:
Agency Direction
Office of Executive Staff 28  35  31 
Office of Public Affairs 15  21  21 
Office of the Secretary 24  25  24 
Subtotal 67  81  76 
Administrative Support
Office of the Chief Operating Officer 15  13  14 
Office of Financial Management 98  95  93 
Office of Information Technology 171  173  177 
Office of Human Resources 120  107  105 
Office of Acquisitions 57  56  55 
Office of Support Operations 100  94  92 
Office of Strategic Initiatives 15  29  29 
Office of the Ethics Counsel 18  19  19 
Office of Minority and Women Inclusion 9  9  9 
Office of Equal Employment Opportunity 14  15  15 
Subtotal 617  610  608 
Total Full-Time Equivalents 684  691  684 
Cost: 
Salaries and Benefits
$    161,993$   156,972$   156,802
Non-Personnel Expenses52,46453,99665,405
Total Costs
$    214,457$   210,968$   222,207
Totals	may	not	appear	to	sum	from	detail	lines	due	to	rounding	of	actual	values
This section details the SEC’s agency-wide executive 
activities, operations, and administrative functions. 
Agency Direction: Includes the Chairman and Commis-
sioners’ Offices, Office of Legislative and Intergovern-
mental Affairs (OLIA), Office of Public Affairs (OPA), 
and Office of the Secretary (OS). 
Office of the Chief Operating Officer: Provides executive 
leadership by directing the management and coordina-
tion of the SEC’s core mission support activities. 
Office of the Ethics Counsel: Administers the Commis-
sion’s Ethics Program and interprets the SEC’s Supple-
mental Ethics Rules as well as federal government-wide 
ethics laws, rules, and regulations. 
Office of Minority and Women Inclusion: Develops 
standards for all agency matters relating to diversity  
in management, employment, and business activities. 
Office of Equal Employment Opportunity: Strives to 
enhance access to employment opportunities for the 
best and brightest talent, and to foster an equitable 
work environment in which employees can perform  
the SEC’s mission.

60   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
AGENCY DIRECTION
(DOLLARS IN THOUSANDS)
FY 2017
Actual
FY 2018
Annualized CR
FY 2019
Request
Full-Time Equivalents:
Office of Executive Staff 28  35  31 
Office of Public Affairs 15  21  21 
Office of the Secretary 24 25  24 
Total Full-Time Equivalents 67  81  76 
Cost: 
Salaries and Benefits
$   15,383$   18,858$   17,758
Non-Personnel Expenses7,0998,2899,747
Total Costs
$   22,482$   27,147$   27,504
Totals	may	not	appear	to	sum	from	detail	lines	due	to	rounding	of	actual	values
Agency Direction includes the Commissioners and  
their staff, as well as Office of Legislative and  
Intergovernmental Affairs, Office of Public Affairs,  
and Office of the Secretary.

FY 2019 BUDGET REQUEST BY PROGRAM   |   61
EXECUTIVE STAFF
(DOLLARS IN THOUSANDS)
FY 2017
Actual
FY 2018
Annualized CR
FY 2019
Request
Full-Time Equivalents283531
Cost: 
Salaries and Benefits
$    7,061$    8,967$    8,022
Non-Personnel Expenses2,1622,0412,402
Total Costs
$    9,223$  11,008$  10,424
Totals	may	not	appear	to	sum	from	detail	lines	due	to	rounding	of	actual	values
The Executive Staff is comprised of the Chairman, the 
Commissioners, their staff, and OLIA. 
The Chairman serves as the agency’s senior responsible 
executive, overseeing all aspects of agency opera-
tions and setting the agency’s substantive policy and 
rulemaking agenda. In addition, the Chairman 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; overseeing SROs in the securities, accounting, 
and auditing fields; and coordinating U.S. securities 
regulation with federal, state, and foreign authori-
ties. The staff in the Chairman’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 Congres-
sional 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 infor-
mation 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. 
Workload Data
Activity
FY 2017
Actual
FY 2018
Estimate
FY 2019
Request
Commission Meetings 879196
Calendar Items 565593623
Seriatim Actions 485509534
Congressional Testimonies 466
Chairman’s and Congressional Correspondence 1,1101,5001,500

62   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
OFFICE OF PUBLIC AFFAIRS
(DOLLARS IN THOUSANDS)
FY 2017
Actual
FY 2018
Annualized CR
FY 2019
Request
Full-Time Equivalents152121
Cost:
Salaries and Benefits
$    3,395$    4,619$    4,667
Non-Personnel Expenses1,3702,2052,444
Total Costs
$    4,766$    6,823$    7,111
Totals	may	not	appear	to	sum	from	detail	lines	due	to	rounding	of	actual	values
The Office of Public Affairs (OPA) assists the Commis-
sion with making the work of the SEC open to the 
public, understandable to investors, and accountable 
to taxpayers. The office helps every other SEC division 
and office accomplish the agency’s mission—to protect 
investors, maintain fair, orderly, and efficient markets, 
and facilitate capital formation. 
OPA leverages technology and multimedia capabil-
ities to deliver news, data, and other information 
to inform the public and facilitate the ability of the 
public to interact with the SEC. The group maintains 
the agency’s website, SEC.gov, which is among the 
most-visited websites in the federal government. OPA 
also manages content on the SEC’s social media and 
other digital platforms using the forms and formats 
investors prefer and rely on. Additionally, OPA helps 
enhance SEC workforce efficiency, collaboration, 
and engagement by executing strategic communica-
tion initiatives and facilitating access to knowledge 
databases and systems.
OPA will continue these activities in FY 2019, includ-
ing continuous improvements and customizations 
to the SEC’s modernized intranet site that will be 
deployed in FY 2018 to fit individual staff needs and 
further enhance staff performance. In doing so, OPA 
will reduce costs and increase efficiency by working 
with SEC divisions and offices to consolidate their 
content from multiple proprietary software platforms 
to a single, unified open source platform.
Workload Data
Activity
FY 2017
Actual
FY 2018
Estimate
FY 2019
Request
News Releases and Statements328385385
Email and Mobile Bulletins4,4534,5004,500
Social Media Posts 
1
6,8927,5008,000
Number of SharePoint Top-Level Sites, Web Pages, or Applications 
Created and/or Administered 
2
211515
Number of Internal Communications Artifacts, including Articles, 
Reminders, and Daily Emails Distributed
3,8044,3484,600
Website Content Updates32,88435,00035,000
Number of Digital Signage Slides, Posters, and Kiosk Announcements459480575
1	 Social	media	posts	include	those	done	by	the	individual	divisions/offices	on	SEC-official	accounts	(10	Twitter	accounts,	2	Facebook	accounts,	1	Flickr	
account,	1	YouTube	account,	1	Pinterest	account,	and	1	LinkedIn	account).	See	www.sec.gov/opa/socialmedia
2
	 Number	only	represents	the	top-level	(i.e.,	first	level/parent)	sites.	A	total	of	nearly	490	subsites,	pages,	and/or	workflows	comprise	these	sites.

FY 2019 BUDGET REQUEST BY PROGRAM   |   63
OFFICE OF THE SECRETARY
(DOLLARS IN THOUSANDS)
FY 2017
Actual
FY 2018
Annualized CR
FY 2019
Request
Full-Time Equivalents242524
Cost:
Salaries and Benefits
$    4,927$    5,272$    5,068
Non-Personnel Expenses3,5664,0434,901
Total Costs
$    8,494$    9,316$    9,969
Totals	may	not	appear	to	sum	from	detail	lines	due	to	rounding	of	actual	values
The Office of the Secretary (OS) reviews all doc-
uments issued by the Commission, schedules and 
coordinates Commission meetings, prepares and 
maintains records of Commission actions, and advises 
the Commission and staff about practice and proce-
dure. OS directly supports the Commission staff and 
receives and tracks filings in administrative proceed-
ings. OS is responsible for the public dissemination of 
Commission documents, such as notices, orders, and 
rulemakings and, in collaboration with OPA, manag-
ing the web content management system.
Because all enforcement actions, examination reports, 
and rulemakings flow through OS, the agency’s 
rulemaking agenda and enforcement program will 
have a significant impact on OS workload in FY 
2019. In recent years, OS has generally experienced 
significantly increased workload levels. The higher 
workload OS has experienced aligns with the agency’s 
increased enforcement actions and rulemaking activity 
during that timeframe. In addition, OS has also 
focused resources on improving operational efficiency 
and effectiveness and the development of new infor-
mation technology (IT) systems designed to replace 
legacy systems or improve the services OS provides to 
the public.
 In FY 2019, OS will continue to support Commission 
operations. OS expects that the workload directly tied 
to supporting Commission operations will remain 
steady or slightly above the workload levels OS expe-
rienced in the last few years. In FY 2019, OS will also 
continue to improve business operations and enhance 
recently implemented IT systems to further improve 
OS efficiency and effectiveness.
Workload Data
Activity
FY 2017
Actual
FY 2018
Estimate
FY 2019
Request
Releases Processed 3,4124,5004,700
Public Comment Letters Processed 22,00024,00026,000
Documents Posted on Website 5,3355,4005,450
Administrative Proceedings Items Processed 5,0665,2005,350
Service of Process – Administrative Proceedings 8,1699,80010,045

64   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
OFFICE OF THE CHIEF OPERATING OFFICER
(DOLLARS IN THOUSANDS)
FY 2017
Actual
FY 2018
Annualized CR
FY 2019
Request
Full-Time Equivalents:
Office of the Chief Operating Officer 15  13  14 
Office of Financial Management 98  95  93 
Office of Information Technology 171 173  177 
Office of Human Resources 120 107  105 
Office of Acquisitions 57  56  55 
Office of Support Operations 100  94  92 
Office of Strategic Initiatives 15  29  29 
Total Full-Time Equivalents 576  567  565 
Cost: 
Salaries and Benefits
$   136,952$   127,567$   128,387
Non-Personnel Expenses41,87542,12651,539
Total Costs
$   178,827$   169,693$   179,926
Totals	may	not	appear	to	sum	from	detail	lines	due	to	rounding	of	actual	values
The Office of the Chief Operating Officer (OCOO) 
develops, coordinates, and 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 six offices within OCOO: 
• Office of Financial Management (OFM) 
• Office of Information Technology (OIT) 
• Office of Human Resources (OHR) 
• Office of Acquisitions (OA) 
• Office of Support Operations (OSO) 
• Office of Strategic Initiatives (OSI)
OCOO in FY 2018 has also established a new chief 
risk officer position to coordinate the agency’s risk 
management functions, and a small front office staff 
who perform specialized activities and functions to 
support the SEC’s mission.

FY 2019 BUDGET REQUEST BY PROGRAM   |   65
OFFICE OF THE CHIEF OPERATING OFFICER  
(FRONT OFFICE)
(DOLLARS IN THOUSANDS)
FY 2017
Actual
FY 2018
Annualized CR
FY 2019
Request
Full-Time Equivalents151314
Cost:
Salaries and Benefits
$   3,468$   2,728$    3,016
Non-Personnel Expenses2,0381,3922,821
Total Costs
$   5,506$   4,120$    5,837
Totals	may	not	appear	to	sum	from	detail	lines	due	to	rounding	of	actual	values
The front office of the Office of the Chief Operating 
Officer (OCOO) oversees and coordinates the  
activities of the six component offices described in 
subsequent pages. 
Chief Risk Officer, Enterprise Risk and Internal Controls, 
and Audit Coordination and Follow-up:
 The OCOO 
front office will be home to the agency’s chief risk 
officer (CRO) who will coordinate the agency’s 
enterprise risk management functions, as required 
under OMB Circular A-123. The CRO will be respon-
sible for the agency’s internal controls over operations 
and coordinating the annual management assurance 
statements. 
Small Office Managing Executive Support: OCOO 
will continue to support small offices throughout the 
agency by providing administrative and management 
support to help those offices focus on their specific 
missions.
FY 2019 Request 
The OCOO requests two restored positions to further 
support establishment of the CRO and enhance risk 
management programs. Specifically, this request 
would include initiatives to expand the management 
of enterprise-wide risks such as risks identified by 
audit organizations, and enhance the agency’s internal 
control program.
Workload Data
Activity
FY 2017
Actual
FY 2018
Estimate
FY 2019
Request
Number of Audits Facilitated353535
Number of Projects and Operational Activities Supported111102102

66   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
OFFICE OF FINANCIAL MANAGEMENT
(DOLLARS IN THOUSANDS)
FY 2017
Actual
FY 2018
Annualized CR
FY 2019
Request
Full-Time Equivalents989593
Cost:
Salaries and Benefits
$   21,059$   21,330$   21,035
Non-Personnel Expenses6,0165,7897,001
Total Costs
$   27,074$   27,119$   28,036
Totals	may	not	appear	to	sum	from	detail	lines	due	to	rounding	of	actual	values
The Office of Financial Management (OFM) is respon-
sible for the SEC’s financial and budgetary operations. 
Specifically, OFM oversees the agency’s financial 
systems; prepares financial statements and reports; 
maintains the formulation and execution of the SEC’s 
annual budget; coordinates the agency’s performance 
and cost reporting; and manages internal controls over 
financial reporting.
During FY 2019, OFM will continue to improve 
the efficiency and effectiveness of the SEC’s financial 
systems and processes as well as support the necessary 
rulemaking efforts to tag registration fee data to 
automate a highly manual review process. OFM also 
plans to continue the development and implementation 
of a Disgorgement and Penalty System. OFM has 
completed the implementation of the EDGAR Fee 
System Modernization and will continue working to 
refine the system.
Workload Data
Activity
FY 2017
Actual
FY 2018
Estimate
FY 2019
Request
Accounting and Finance 
Quarterly/Annual Financial Statements Issued 
1
363636
Financial Transactions Analyzed 
2
7,211,0227,200,0007,200,000
Analysis and Reconciliation Reports Prepared 
3
6,4896,5546,619
Planning and Budget
Number of Conference Requests Submitted in AERS838383
Percent of Reserve Fund Letters Delivered to Congress on Time  93%100%100%
1  This	workload	metric	includes	the	five	required	financial	statements—Balance	Sheet,	Statement	of	Net	Cost,	Statement	of	Changes	in	Net	Position,	
Statement	of	Budgetary	Resources,	and	the	Statement	of	Custodial	Activity—on	a	quarterly	and	annual	basis	(20	statements	total);	and	the	four	Investor	
Protection	Fund	financial	statements	required	on	a	quarterly	and	annual	basis	(16	statements	total).	This	metric	does	not	include	the	government-wide	
financial	statements.
2  This	workload	metric	captures	all	financial	transactions	processed	in	the	financial	system	and	analyzed	by	SEC	staff.
3 This	workload	metric	accounts	for	all	analysis	and	reconciliation	reports	prepared	during	the	review	of	transactions.

FY 2019 BUDGET REQUEST BY PROGRAM   |   67
OFFICE OF INFORMATION TECHNOLOGY
(DOLLARS IN THOUSANDS)
FY 2017
Actual
FY 2018
Annualized CR
FY 2019
Request
Full-Time Equivalents171173177
Cost:
Salaries and Benefits
$    40,939$    42,813$    44,301
Non-Personnel Expenses18,70021,81825,410
Total Costs
$    59,639$    64,631$    69,711
Totals	may	not	appear	to	sum	from	detail	lines	due	to	rounding	of	actual	values
Technology, data, and analytics are critical to the 
mission of the SEC and its ability to deliver informa-
tion to the public. The increasing size and complexity 
of the U.S. capital markets require the SEC to more 
efficiently leverage technology to streamline operations 
and increase the effectiveness of the agency’s programs. 
The Office of Information Technology (OIT) is advanc-
ing a robust cybersecurity program to strengthen the 
agency’s data management capabilities and migrate 
select applications and workloads to secure cloud 
environments. 
FY 2019 Request
In support of these efforts, the SEC is seeking an 
additional $45 million to fund critical requirements, 
including:
• Continuing the development of advanced analytics 
solutions that provide new capabilities to detect and 
expose suspicious behavior in high frequency trading 
and other complex trading areas across markets;
• Improving storage, processing, security, and manage-
ment of large volumes of data, including the agency’s 
e-Discovery program, which is approaching one 
petabyte of data;
• Modernizing the SEC’s infrastructure and computing 
environment to enhance security, improve perfor-
mance, and streamline delivery; and
• Improving the SEC’s ability to analyze fixed income 
market data. 
OIT is also focused on enhancing cybersecurity efforts 
to prevent threats, which pose risks to investors, 
financial services firms, markets, and the SEC itself. 
These efforts build on the significant progress made 
over the past several years in modernizing technology 
systems. OIT supports the Commission and staff of 
the SEC in all aspects of IT. OIT has overall manage-
ment responsibility for the Commission’s IT program, 
including application development, infrastructure 
operations and engineering, user support, IT program 
management, capital planning, security, and enterprise 
architecture. OIT operates the EDGAR system, which 
electronically receives, processes, and disseminates 
more than 500,000 financial statements and other 
corporate filings every year. OIT also maintains a 
dynamic and robust website that receives more than 18 
billion page views annually. The website provides free 
public access to the EDGAR database and contains a 
wealth of information about the Commission and the 
securities industry.
OIT is also requesting 16 additional positions to be 
applied within the areas of cybersecurity, data manage-
ment, and governance. OIT intends to expand its cloud 
and data management capabilities and enhance its 
cybersecurity posture by continuing the buildout of 
the SEC’s information security defenses and monitor-

68   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
ing capabilities to ensure the appropriate controls, 
policies, and procedures are in place to safeguard the 
Commission. The requested positions would allow 
OIT to continue focusing on service delivery to ensure 
internal business partners obtain the most value from 
technology investments. These positions would allow 
OIT to meet increasing internal and external demand 
for data with secure, efficient technology solutions that 
expand the Commission’s capability to detect fraud 
and suspicious activity.
Workload Data
Activity
FY 2017
Actual
FY 2018
Estimate
FY 2019
Request
EDGAR Filings, Disclosure, and Review 
Online Searches for EDGAR Filings (in millions) 14,89914,933 16,389
Number of Electronic Filings Received (in millions)1.761.81.9
Internal Process Improvements and Employee Productivity 
User Requests for Helpdesk Assistance 167,548165,000165,000
Amount of Network-Based Storage (Terabytes) 21,91524,00025,200
Network Users 6,2546,8006,800
Information Security and Disaster Recovery 
Percentage of Major Systems Certified and Accredited 86%94%94%
Technical Support – Internet and Email Inquiries 
1
135N/AN/A
Technical Support – Telephone Inquiries 
1
27,581N/AN/A
1	 Technical	Support	measures	moved	to	OSI	in	2018.

FY 2019 BUDGET REQUEST BY PROGRAM   |   69
OFFICE OF HUMAN RESOURCES
(DOLLARS IN THOUSANDS)
FY 2017
Actual
FY 2018
Annualized CR
FY 2019
Request
Full-Time Equivalents120107105
Cost:
Salaries and Benefits
$   38,095$   23,513$   23,240
Non-Personnel Expenses6,5985,8877,248
Total Costs
$   44,692$   29,399$   30,488
Totals	may	not	appear	to	sum	from	detail	lines	due	to	rounding	of	actual	values
The Office of Human Resources (OHR) provides 
leadership for the strategic management of the SEC’s 
human capital in order to enhance the SEC’s perfor-
mance through effective alignment and management 
of human capital. OHR consults with management, 
administers programs, establishes policies, and ensures 
compliance with federal regulations. 
OHR develops, implements, and evaluates the 
Commission’s human capital programs and policies for 
the following areas:
• Recruitment, staffing, and retention
• Position management and classification
• Compensation administration
• Benefits counseling and processing
• Leadership and employee development
• Performance management and awards
• Labor relations
• Disability program
• Work-life programs
• Telework
• Employee records processing and maintenance
OHR’s FY 2019 allocation will further the strategic 
management of the SEC’s human capital by attract-
ing and retaining a diverse and talented workforce; 
administering programs to enhance employee engage-
ment and leadership development; implementing 
advanced technologies to enhance and streamline work 
processes; and establishing policies and procedures 
to ensure compliance with federal regulations and 
negotiated agreements.
Workload Data
Activity
FY 2017
Actual
FY 2018
Estimate
FY 2019
Request
AskHR Inquiries3,18313,56414,000
Personnel Actions Processed 
1
22,53022,53023,205
Recruitment Actions118209212
Training Sessions Held940830830
Number of Training Session Attendees 33,29828,00028,000
Studies, Reviews, and Policies Issued538547564
1	 Comparative	analysis	of	end	Q2,	FY	2017.	Assumptions	are	very	conservative	and	based	on	a	fiscal	outlook	that	includes	a	flat	budget	with	limited	 
hiring	and	normal	and/or	induced	attrition,	i.e.,	Voluntary	Early	Retirement	Authority	and	Voluntary	Separation	Incentive	Payments.	These	also	account	
for	personnel	actions	processing	for	regular	and	recurring	actions	associated	with	current	employees	such	as	career	ladder	promotions,	career	tenure	
changes,	awards,	etc.

70   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
OFFICE OF ACQUISITIONS
(DOLLARS IN THOUSANDS)
FY 2017
Actual
FY 2018
Annualized CR
FY 2019
Request
Full-Time Equivalents575655
Cost:
Salaries and Benefits
$   11,473$   12,047$   11,914
Non-Personnel Expenses2,6672,3612,955
Total Costs
$   14,140$   14,408$   14,868
Totals	may	not	appear	to	sum	from	detail	lines	due	to	rounding	of	actual	values
The Office of Acquisitions (OA) is responsible for 
procuring all goods and services—except real property 
and employee training—for the SEC. OA provides 
oversight of the Government Purchase Card (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, 
closing out contracts, and the implementation and 
enforcement of 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 the 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 with respect to numer-
ous federal programs. 
In early FY 2018, OA further strengthened internal 
controls over the contractual aspects of financial 
reporting. OA also focused on enhancements for the 
Electronic Contract File (eFile) Project, which resulted 
in improved contract administration, greater trans-
parency, and improved reporting. OA’s focal point in 
early FY 2018 was to make sure CORs received proper 
training and enforced their use of eFile. The redesign 
for the OA Customer Support SharePoint site was 
implemented, providing OA customers access to all 
documents and information required for the acquisi-
tion of supplies and services. In FY 2019, OA plans to 
continue the COR Improvement Initiative to create a 
more comprehensive COR Program that will provide 
efficient and functional control, transparency, and 
management of the COR Program across the SEC. 

FY 2019 BUDGET REQUEST BY PROGRAM   |   71
Workload Data
Activity
FY 2017
Actual
FY 2018
Estimate
FY 2019
Request
Procurement Actions (Contracts and Purchase Orders) 2,5302,5002,500
Total Value of Contracts with Business Funded by SEC 
$    406,721,133$    407,000,000$    407,000,000
Additional Value of Interagency Agreements Obligated  
(in dollars) 
$      24,959,993$      25,000,000$      25,000,000
GPC Cardholders Audited 115115115
Closeout Actions Processed 790750750
Dollars Recovered for Reuse (Closeouts & ULO De-Obligations) 
$      35,000,000$      25,000,000$      25,000,000
CORs Managed 460460465
Small Business Actions Processed 1,5601,5001,500
Dollars Spent with Small Business 
$    214,836,658$    210,000,000$    210,000,000
Percent Small Business Dollars  
(23% Federal-Wide Minimum Goal) 
56.00%55.00%55.00%
Multi-Agency Collaborative Actions 1,1661,1701,170
Multi-Agency Contract Value Awarded (in dollars) 
$    289,183,630$    289,000,000$    289,000,000

72   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
OFFICE OF SUPPORT OPERATIONS
(DOLLARS IN THOUSANDS)
FY 2017
Actual
FY 2018
Annualized CR
FY 2019
Request
Full-Time Equivalents1009492
Cost:
Salaries and Benefits
$    18,700$    18,717$    18,394
Non-Personnel Expenses5,0293,9824,980
Total Costs
$    23,730$    22,699$    23,374
Totals	may	not	appear	to	sum	from	detail	lines	due	to	rounding	of	actual	values
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 and Privacy 
Acts (FOIA), 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.
In FYs 2018 and 2019, the office will work with the 
General Services Administration (GSA) to support 
GSA’s procurement of new leases for both the SEC’s 
headquarters and its New York Regional Office. 
Workload Data
Activity
FY 2017
Actual
FY 2018
Estimate
FY 2019
Request
Records Management – Official Certifications 1,9182,0142,115
Records Management – Document Requests 801841883
FOIA Requests Carried Forward from Prior FYs 565559559
New FOIA/PA Requests Received 13,06313,50014,000
FOIA/PA Requests Completed 13,06913,20013,500
Security Services – Interim Suitability Determinations Made 2,6162,0502,050
Security Services – HSPD-12 Credentials Issued 2,4991,7301,800
Security Services – HSPD-12 Credential Certificates Updated 1,1131,2241,225
Print Production (millions of pages) 2.42.42.4

FY 2019 BUDGET REQUEST BY PROGRAM   |   73
OFFICE OF STRATEGIC INITIATIVES
(DOLLARS IN THOUSANDS)
FY 2017
Actual
FY 2018
Annualized CR
FY 2019
Request
Full-Time Equivalents152929
Cost:
Salaries and Benefits
$   3,219$   6,419$   6,487
Non-Personnel Expenses8288981,125
Total Costs
$   4,046$   7,317$   7,611
Totals	may	not	appear	to	sum	from	detail	lines	due	to	rounding	of	actual	values
The Office of Strategic Initiatives (OSI) provides exec-
utive-level oversight for the ongoing transformation 
of specific functions and programs to include business 
ownership of EDGAR and the respective EDGAR 
Redesign (ERD) Program initiative.
EDGAR Business Owner/Program Office
The EDGAR Program Office (EPO) provides opera-
tional support to the EDGAR business owner and is 
responsible for coordinating EDGAR issues that arise 
from filer interactions as well as providing coordina-
tion between SEC divisions/offices to resolve EDGAR- 
related issues. The EPO also serves as a business part-
ner to OIT and represents the business interests of the  
SEC’s divisions/offices in the EDGAR software devel-
opment lifecycle.
EDGAR Redesign Program
ERD is a multi-year, cross-SEC initiative to develop  
and deliver the next generation electronic disclosure 
system. This effort is aimed toward making it easier 
for registrants to fulfill their disclosure responsibilities 
through the EDGAR system, for investors to find use-
ful disclosure information, and for the SEC to manage  
the system.
Information Services and Data
OSI is responsible for managing the Commission’s 
steady-state budget and contract actions, in coordina-
tion with SEC’s OA for purchasing data and informa-
tion used in support of the SEC’s divisions and offices. 
This includes data used in analytics, electronic infor-
mation services, and physical information collections 
across the SEC. 

74   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
Workload Data
Activity
FY 2017
Actual
FY 2018
Estimate
FY 2019
Request
EDGAR Business Owner/Program Office
EDGAR Development Releases20128
EDGAR Infrastructure Releases444
EDGAR Filer Manual Seriatim Updates554
Technical Support – Internet and Email Inquiries 
1
N/A150175
Assistance and Technical Support – Telephone Inquiries 
1
N/A33,00034,122
EDGAR Form IDs Processed53,48355,08756,740
Information Services
   
Public Reference – Visitors 500500500
Library Password Management – Active Passwords22,19821,00021,000
Library Acquisitions – Contracts Managed117114114
Library Acquisitions – Invoices Reviewed/Paid702700700
Creating New Content293300310
Library Reference – Quick Reference Requests1,9832,0002,000
1 The	Filer	Technical	Support	program	and	corresponding	workload	items	have	been	transferred	to	OSI	from	OIT,	effective	FY	2018.	This	program	has	been	
renamed	“Filer	Assistance	and	Technical	Support”	and	the	“Assistance	and	Technical	Support	Telephone	Inquiries”	workload	item	now	consists	of	both	
Filer	Support	and	Filer	Technical	Support	telephoning	functions.

FY 2019 BUDGET REQUEST BY PROGRAM   |   75
OFFICE OF THE ETHICS COUNSEL
(DOLLARS IN THOUSANDS)
FY 2017
Actual
FY 2018
Annualized CR
FY 2019
Request
Full-Time Equivalents181919
Cost:
Salaries and Benefits
$    4,257$    4,653$    4,702
Non-Personnel Expenses9118771,092
Total Costs
$    5,168$    5,529$    5,794
Totals	may	not	appear	to	sum	from	detail	lines	due	to	rounding	of	actual	values
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 Chairman, 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 Supplemental Ethics Rules and provides train-
ing and counseling on personal trading questions. OEC 
is also the SEC’s liaison with the United States Office of 
Government Ethics (OGE). OEC expects its workload 
and responsibilities to increase as the overall workforce 
of the SEC increases and as the number of enforcement 
matters increase in FY 2019.
In FY 2019, OEC will continue to advise and counsel 
all SEC employees and members on personal and finan-
cial conflicts of interest; post-employment restrictions; 
securities holdings and transactions of SEC employees 
and their immediate families; gifts; seeking and negoti-
ating other employment; outside activities; and financial 
disclosure. Additionally, OEC continues Commission 
memoranda reviews for potential conflicts of employees 
with complex financial holdings. Further, the office will 
strive to automate the OGE form 450 filing process, 
the 8B letter process, and plans to migrate the Personal 
Trading Compliance System to an enhanced platform. 
OEC will continue compliance testing of SEC popula-
tion data. Additionally, OEC will continue compliance 
testing agency-wide. Lastly, OEC will steadily improve 
and enhance the SEC Ethics Program to best service the 
agency and its employees.
Workload Data
Activity
FY 2017
Actual
FY 2018
Estimate
FY 2019
Request
Ethics Counseling Inquiries8,4009,2009,476
Review of Public Financial Disclosure Forms380410422
Commission Memoranda Reviews1,4501,5501,597
Review of Confidential Financial Disclosure Forms4,2104,6004,738
Clearance of 8B Requests240260268
Pre-clearance of Requests for Trading34,00037,40038,522
Employees Trained in Ethics5,4706,0006,180
Review of SEC Forms 682 – Financial Disclosure Forms570620639

76   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
OFFICE OF MINORITY AND WOMEN INCLUSION
(DOLLARS IN THOUSANDS)
FY 2017
Actual
FY 2018
Annualized CR
FY 2019
Request
Full-Time Equivalents999
Cost:
Salaries and Benefits
$   2,088$   2,101$   2,123
Non-Personnel Expenses1,1601,1811,321
Total Costs
$   3,248$   3,282$   3,444
Totals	may	not	appear	to	sum	from	detail	lines	due	to	rounding	of	actual	values
The Office of Minority and Women Inclusion (OMWI) 
is responsible for all matters related to diversity in 
management, employment, and business activities 
at the SEC. The responsibilities of OMWI include 
developing standards for equal employment opportu-
nity and the diversity of the SEC’s workforce (including 
senior management); facilitating increased participa-
tion of minority-owned and women-owned businesses 
in the SEC’s programs and contracts; ensuring the 
fair inclusion of women and minorities within the 
workforce of existing contractors (and, as applicable, 
of subcontractors); and assessing the diversity policies 
and practices of entities regulated by the SEC. In accor-
dance with Title VII of the Jumpstart Our Business 
Startups (JOBS) Act, OMWI conducts outreach efforts 
to businesses owned by veterans, women, and minori-
ties to inform them about the JOBS Act and how it can 
support capital formation across our communities.
OMWI will continue to promote diversity and inclu-
sion in its core areas of workforce, business activities, 
and regulated entities. OMWI’s workforce activity 
will remain focused on development, advancement, 
and collaboration with divisions and offices that fill 
positions in FY 2019 to tailor outreach efforts. OMWI 
will continue to direct efforts toward enhancing diver-
sity at the senior levels of the SEC workforce. OMWI 
will also continue its work building the financial 
services industry and SEC “pipeline” of diverse talent 
through its own outreach and events as well as through 
partnerships, conferences, career fairs, and other events 
held by diverse professional associations, organi-
zations, and educational institutions. With regard 
to business activities, OMWI works to introduce 
minority-owned and women-owned businesses of all 
sizes to opportunities at the SEC, and will continue to 
collaborate with OA to promote access to contracting 
and sub-contracting opportunities through its extensive 
outreach and matchmaking at industry events, and via 
one-on-one meetings at SEC Vendor Outreach Days. 
Given the SEC’s focus on information technology and 
cybersecurity, OMWI anticipates emphasizing supplier 
outreach in those areas. 

FY 2019 BUDGET REQUEST BY PROGRAM   |   77
Workload Data
Activity
FY 2017
Actual
FY 2018
Estimate
FY 2019
Request
Diversity AssessmentsN/A6075
Advancing Employee DevelopmentN/A22
Reporting Requirements and Data Analyses167110110
Diversity and Inclusion Programs706565
Diversity and Inclusion Training211515
Roundtable or Public Meetings555
Vendor Outreach826060
Targeted Advertisement Sources2658080
Diversity Standards and Policies422
Good Faith Effort Contract Reviews 
1
997075
1	 Effective	FY	2017,	OMWI	changed	the	calculation	methodology	for	Good	Faith	Effort	(GFE)	contract	reviews	to	the	number	of	GFE	reviews	conducted	
rather	than	the	percentage	of	GFE	reviews	conducted.

78   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
OFFICE OF EQUAL EMPLOYMENT OPPORTUNITY
(DOLLARS IN THOUSANDS)
FY 2017
Actual
FY 2018
Annualized CR
FY 2019
Request
Full-Time Equivalents141515
Cost:
Salaries and Benefits
$   3,312$   3,793$   3,833
Non-Personnel Expenses1,4191,5231,706
Total Costs
$   4,732$   5,316$   5,540
Totals	may	not	appear	to	sum	from	detail	lines	due	to	rounding	of	actual	values
The Office of Equal Employment Opportunity 
(OEEO) strives to enhance equal access to employ-
ment opportunities for the best and brightest talent 
and foster an equitable work environment in which 
employees perform the SEC’s mission. SEC employ-
ees come from diverse backgrounds and are entitled 
to a workplace where employment decisions are 
made without regard to race, color, sex, age, religion, 
national origin, or genetic information. Like other 
demographic groups protected by statute, the law 
shields individuals with disabilities from discrimi-
nation. However, individuals with disabilities may 
lawfully receive preferential treatment, e.g., in the 
hiring process. To maintain the neutrality and impar-
tiality necessary to fulfill its responsibilities, OEEO is 
required to be independent of any other SEC office, 
and the OEEO director reports to the SEC Chairman. 
OEEO has two primary analytical functions: Compli-
ance and Barrier Analysis. 
The Compliance function applies legal principles to the 
processing and adjudication of complaints of discrim-
ination under Title VII of the Civil Rights Act, the 
Age Discrimination in Employment Act, the Reha-
bilitation and Americans with Disabilities Acts, and 
the Genetic Information Nondiscrimination Act. The 
Equal Employment Opportunity Commission enforc-
es these laws, adjudicates cases, and regulates equal 
employment opportunity programs across the federal 
government.
The Barrier Analysis function analyzes quantitative 
and qualitative data to determine whether a policy, 
practice, or procedure impedes access to employment 
opportunities for members of a protected demograph-
ic group. When OEEO identifies such an impediment, 
the office collaborates with stakeholders to identi-
fy options to eliminate the potential barrier in the 
employment lifecycle, starting with recruitment and 
ending with separation. In support of its two analyt-
ical functions, OEEO also provides opportunities to 
quickly resolve disputes, conducts mandatory train-
ing, and files required annual reports with external 
stakeholders. OEEO engages frequently with internal 
and external stakeholders to perform its functions.
Workload Data
Activity
FY 2017
Actual
FY 2018
Estimate
FY 2019
Request
Compliance530500500
Reporting 888
Barrier Analysis2,3992,2252,225
Mission Support1,2571,2501,250

FY 2019 BUDGET REQUEST BY PROGRAM   |   79
OFFICE OF INSPECTOR GENERAL
(DOLLARS IN THOUSANDS)
FY 2017
Actual
FY 2018
Annualized CR
FY 2019
Request
Full-Time Equivalents484949
Cost:
Salaries and Benefits
$   11,357$   11,979$   12,105
Non-Personnel Expenses3,1423,9244,539
Total Costs
$   14,499$   15,903$   16,644
Totals	may	not	appear	to	sum	from	detail	lines	due	to	rounding	of	actual	values
The Office of Inspector General (OIG) is an indepen-
dent office that conducts audits of programs and 
operations of the SEC and investigations into allega-
tions 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 2019, the OIG will continue to focus on improv-
ing agency programs and operations through audits, 
evaluations, and reviews. The office also will enhance 
staff and agency integrity by investigating allegations 
of misconduct involving the SEC’s programs and 
operations. The OIG’s workload remains high and the 
office expects both its investigative and audit teams to 
maintain active workloads through FY 2019.
The Dodd-Frank Wall Street Reform and Consumer 
Protection Act of 2010 (Dodd-Frank Act) enacted on 
July 21, 2010, imposed significant new responsibilities 
on the SEC as a whole and, as a result, on the OIG. 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 SEC. 
During FY 2019, 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 recogniz-
ing employees who make suggestions, through the ESP, 
that result in increased work efficiency, effectiveness, 
or productivity of the SEC, or reduce waste, abuse, 
misconduct, or mismanagement, as provided for by the 
Dodd-Frank Act.
In addition, there has been continued coordination 
with other Inspector Generals (IG) 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 in FY 2019 to prepare a section of CIGFO’s 

80   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
annual report to Congress. 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’s OIG to conduct other 
audit or review activities on behalf of CIGFO. 
The OIG currently has 54 authorized positions. For  
FY 2019, the OIG is not requesting any additional 
positions. 
Regulatory Requirement
The Inspector General Reform Act of 1978 (as 
amended through P.L. 114-317) requires that each IG 
submit a budget estimate and request each fiscal year 
to the head of the agency to which the IG reports. 
Section 6(f)(1) requires that the request include:
• The aggregate amount of funds requested for the 
operations of the 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 FY; and
Workload Data
Activity
FY 2017
Actual
FY 2018
Estimate
FY 2019
Request
Audits/Evaluations
Pending Beginning of Year 
1
454
Opened131212
Completed121312
Pending End of Year546
• 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 SEC submits the 
following information for the OIG’s budget estimate 
and request for FY 2019.
• The aggregate budget request for the operations of 
the OIG is $15,206,268.75.
• 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. 
OIG estimates FY 2019 specialized training costs of 
$108,000. The IG certifies that the aggregate amount 
of the request satisfies all training requirements 
for the OIG for FY 2019 and also any assessment 
required to support CIGIE. 
• The estimated amount of the SEC OIG’s contribu-
tion to CIGIE is 0.22 percent of the budget request, 
or $33,380.35.
1	 The	total	FTE	on	the	previous	table	represents	the	entire	OIG	organization;	however,	the	workload	data	above	only	includes	the	Office	of	Audits.	The	inves-
tigative	workload	of	the	OIG	is	not	included	in	the	workload	table	because	it	would	be	inappropriate	to	speculate	on	the	number	of	investigations	the	OIG	
would	need	to	conduct	during	a	given	time	period.

Other Information
Risks, Internal Controls, and Management Challenges ...............................................................83
Cross-Agency Collaboration
 ..........................................................................................................................87
Evidence Building
 ...................................................................................................................................................91
Links to Other Information and Resources
 ...........................................................................................92



OTHER INFORMATION   |   83
RISKS, INTERNAL CONTROLS, AND 
MANAGEMENT CHALLENGES
As the markets, products, and participants that 
the SEC oversees and regulates increase in size and 
complexity, the agency’s mandate to protect investors, 
maintain fair, orderly, and efficient markets, and facil-
itate capital formation becomes more challenging. To 
maximize the use of the SEC’s resources to fulfill this 
mission, the agency continually strives to allocate its 
time and funds toward the highest and best uses. The 
SEC must always reevaluate its operations to identify 
emerging risks and ensure the agency’s resources are 
deployed to most efficiently address agency priorities. 
Risk Management
The Office of the Chief Operating Officer will be 
home to the agency’s first-ever chief risk officer 
(CRO), slated to be hired in FY 2018. The CRO’s 
responsibilities include coordinating the agency’s 
enterprise risk management functions, as required 
under OMB Circular A-123. The enterprise risk 
management program assists the agency in achieving 
its strategic and operational objectives by providing 
an enterprise-wide, strategically aligned, systematic, 
and structured methodology for managing the agency’s 
most significant risks and challenges. The CRO will 
be a key member of the Risk Management Oversight 
Committee and provides governance and oversight of 
the SEC’s enterprise risk management program. This 
committee oversees the development and implemen-
tation of strategic and programmatic risk policies, 
frameworks, and methodologies, and also produces 
and maintains the agency’s risk profile. In FY 2019, 
the SEC will continue to focus on its enterprise risk 
management practices and work to integrate enterprise 
risk management with our strategic goals, performance 
metrics, and our internal control environment, as well 
as support risk-informed decision-making.
Management Assessments of  
Internal Challenges
The SEC remains committed to maintaining strong 
internal controls. Internal control is an integral 
component of effective agency management, providing 
reasonable assurance that the following objectives 
are being achieved: effectiveness and efficiency of 
operations, reliability of reporting, and compliance 
with laws and regulations. The Federal Managers’ 
Financial Integrity Act of 1982 (FMFIA) establishes 
management’s responsibility to assess and report on 
internal accounting and administrative controls. Such 
controls include program, operational, and admin-
istrative areas, as well as accounting and financial 
management. The FMFIA requires federal agencies to 
establish controls that reasonably ensure obligations 
and costs are in compliance with applicable law; funds, 
property, and other assets are safeguarded against 
waste, loss, unauthorized use, or misappropriation; 
and revenues and expenditures are properly recorded 
and accounted for to maintain accountability over the 
assets. The FMFIA also requires agencies to annually 
assess whether financial management systems conform 
to related requirements (FMFIA § 4).
Section 963 of the Dodd-Frank Wall Street Reform 
and Consumer Protection Act of 2010 (Dodd-Frank 
Act) describes the responsibility of SEC management 
to establish and maintain adequate internal controls 
and procedures for financial reporting. This section 
requires an annual financial controls audit, a Govern-
ment Accountability Office (GAO) audit of the SEC’s 
assessment of the effectiveness of internal control, and 
internal controls attestations by the Chairman and the 
chief financial officer (CFO). 

84   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
The assurance statements are based on reports from 
each division director and office head on the effec-
tiveness of their controls. These statements are based 
on self-assessments and internal reviews supported 
by control testing, as well as recommendations for 
improvement from audits, investigations, and reviews 
conducted internally by the SEC’s Office of Inspector 
General (OIG) and GAO. In evaluating internal 
controls, the SEC also considers other sources of 
information, which include, but are not limited to,  
the following:
• An entity-level control assessment;
• Internal management reviews, self-assessments, and 
tests of internal controls;
• Management’s personal knowledge gained from 
daily operations;
• Reports from GAO and the OIG;
• Reviews of financial management systems;
• Reports pursuant to the Federal Information  
Security Management Act (FISMA) and  
OMB Circular A-130, Management of Federal 
Information Resources;
• Reports and other information from Congress or 
agencies such as the OMB, the Office of Personnel 
Management (OPM), or the General Services Admin-
istration (GSA) reflecting the adequacy of internal 
controls; and
• Additional reviews relating to a division or office’s 
operations.
The SEC’s annual assessment of internal controls, 
based on these sources, 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 2017 AFR provides a summary of the 
most serious management and performance challenges 
facing the SEC, as identified by the OIG in the Other 
Information section. The AFR also details the actions 
currently being taken to address these challenges.
The table on the next page describes how the resources 
requested for FY 2019 will help address the challenges 
identified by the Inspector General.

OTHER INFORMATION   |   85
Management Challenge 
Identified by the 
Inspector General
How the FY 2019 Budget Addresses the Challenge
Regulatory Oversight
The SEC must continue to find ways to use its limited resources to keep pace with changes in the size 
and complexity of the securities markets and the market participants the SEC oversees and regulates, 
absent additional funding increases.
The Office of Compliance Inspections and Examinations (OCIE) has worked to increase its examination 
coverage of investment advisers, including re-allocating staff and enhancing its use of advanced quantitative 
techniques, and continues to seek new ways to increase its efficiency while strengthening internal controls. 
The SEC continues to recognize the need to maximize technology to better identify risks, uncover frauds, 
sift through large volumes of data, inform policy-making, and streamline operations. Key information 
technology (IT) initiatives include the following:
•  Expanding data analytics tools;
• Improving examinations through risk assessment and surveillance tools;
•  Enhancing systems that support the enforcement program;
•  Improving access and usefulness of information available to the public through the Electronic Data 
Gathering, Analysis, and Retrieval (EDGAR) system; and
•  Investing in further business process automation and enhancements.
Information Security
To ensure an effective information security program, the SEC is increasing investments in information 
security to address the ability to monitor and avoid advanced persistent threats, and to improve 
risk management and monitoring. The SEC is conducting an ongoing assessment of the agency’s 
cybersecurity risk profile and preparedness, including: (1) the formation of a senior-level cybersecurity 
working group to coordinate information sharing; (2) risk and threat monitoring; (3) incident response 
and other cross-divisional and interagency efforts; and (4) an assessment of reporting and escalation 
procedures. Each of these efforts is moving forward and, as is the nature of matters of this type, will 
require substantial time and effort to complete. Chairman Clayton’s October 4, 2017, testimony before 
the House Financial Services Committee, available at www.sec.gov/news/testimony/testimony-
examining-secs-agenda-operation-and-budget, provides a detailed overview of the agency’s ongoing 
efforts to strengthen and uplift its cybersecurity risk profile.
In FY 2018, the SEC is conducting reviews of agency systems, assessing the types of data the SEC 
keeps and the related security systems, processes, and controls. The agency is also working to enhance 
escalation protocols for cybersecurity incidents in order to enable greater agency-wide visibility and 
understanding of potential cyber vulnerabilities and attacks.
Acquisition 
Management
In FY 2019, the Office of Acquisitions (OA) will continue working on a variety of fronts to further 
promote effective contract management by improving communications between Contracting Officers 
and Contracting Officer Representatives; conducting annual reviews of contract files to make sure 
they contain the appropriate documentation; and improving reporting. In parallel, OA and the Office of 
Information Technology are addressing each of the particular OIG recommendations related to the data 
center and EDGAR contracts.
continued on next page 

86   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
Management Challenge 
Identified by the 
Inspector General
How the FY 2019 Budget Addresses the Challenge (continued)
Human Capital 
Management
During FY 2016, the SEC released a Human Capital Strategic Plan to align the agency’s human capital 
with the achievement of its mission, goals, and objectives. The agency also released an SEC Strategic 
Workforce Plan, which provides an overview of the current workforce; identifies critical workforce 
competencies for SEC mission-critical occupations; and identifies perceived workforce competency 
gaps from supervisors/managers. The Office of Human Resources (OHR) will conduct periodic reviews  
to assess whether the plan aligns with current agency workforce and succession planning efforts. 
The SEC also took several actions during the year to strengthen workforce planning and performance 
management. In FY 2017, the SEC conducted a training needs assessment for staff within OHR and 
plans to conduct a competency assessment in FY 2018 for other key occupations not previously 
assessed.
In FY 2019, the Office of Minority and Women Inclusion (OMWI) will continue to work with all divisions 
and offices, SEC senior leadership, the agency’s Diversity Council, the Office of Equal Employment 
Opportunity, and OHR to promote diversity in the agency’s workforce and cultivate an inclusive work 
environment. The SEC will continue to implement existing initiatives and explore new strategies 
for improving gender, racial, and ethnic diversity in SEC mission-critical occupations and senior 
management positions. Further, OMWI will continue to work with OA to build on the agency’s success in 
advancing the agency’s supplier diversity goals.
OMWI will also continue to conduct post-award reviews of agency contractors to determine compliance 
with the SEC’s Contract Standard for Contractor Workforce Inclusion.

OTHER INFORMATION   |   87
CROSS-AGENCY COLLABORATION
The SEC values its many partnerships with other  
federal agencies, financial regulators, foreign govern-
ments, and SEC divisions and offices. 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 for it to meet its strategic goals. Some examples 
of collaboration efforts taking place at the SEC during  
FY 2017–2019 are highlighted below. 
Strategic Goal 1  
To establish an effective regulatory environment, 
several SEC divisions and offices regularly  
collaborate with both internal and external partners. 
For example, the SEC participates in international 
regulatory organizations such as the Financial Stability 
Board (FSB), which promotes international financial 
stability by coordinating national financial authorities 
and international standard-setting bodies as they work 
toward developing strong regulatory, supervisory and 
other financial sector policies. The FSB fosters a level 
playing field by encouraging coherent implementation 
of these policies across sectors and jurisdictions. The 
SEC also participates in the International Organization 
of Securities Commissions (IOSCO), the international 
body that brings together the world’s securities regula-
tors. The SEC works with foreign securities regulators 
from over 30 countries to develop international 
guidance, recommendations and standards, and assesses 
the implementation of financial market reforms and 
their ramifications for U.S. investors. The Office of 
International Affairs (OIA) also represents the SEC in 
the Joint U.S.-EU Financial Regulatory Forum/U.S.-EU 
Financial Services Committee, and the US-India 
Financial Regulatory Dialogue, where regulatory and 
economic issues are discussed with foreign counterparts.
To enhance credit rating agency oversight, the SEC’s 
Office of Credit Ratings (OCR) meets with interna-
tional regulators in the Supervisory General Colleges 
for Credit Rating Agencies, where topics that are 
relevant to the industry such as business strategy, 
compliance and risk management, cybersecurity, and 
technology matters are addressed. OCR also shares 
information and examination findings with the inter-
national regulators of the three largest, globally-active 
credit rating agencies to further strengthen regulatory 
oversight of nationally recognized statistical rating 
organizations. 
 
Strategic Goal 2 
To foster and enforce compliance with the federal 
securities laws, the SEC works closely with other 
agencies and foreign governments. 
Oversight of broker-dealers is in many ways a coordi-
nated effort with the Financial Industry Regulatory 
Authority (FINRA). The SEC and FINRA work 
together on matters of mutual interest with respect to 
regulated entities and securities offerings. The SEC’s 
Office of Compliance Inspections and Examinations 
(OCIE) and FINRA have regular contact to discuss 
strategic initiatives, examination coordination, risk 
assessment efforts, rulemaking issues, industry risks, 
etc. This type of coordination is ultimately intended 
to make oversight of broker-dealers more effective 
and efficient and to improve compliance within the 
industry. As an example, the two agencies coordinate 
to formally present Compliance Outreach Seminars. 
The SEC also participates in semi-annual meetings with 
FINRA to discuss topics relating to financial reporting 
of broker-dealers. OCIE also makes a number of 
referrals for further investigation to other regulators 
and law enforcement as well as informational referrals 
throughout the year.

88   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
The Division of Enforcement (ENF) collaborates 
with a number of law enforcement entities to enforce 
compliance with securities laws. For example, ENF, 
the U.S. Department of Justice (DOJ), and the 94 U.S. 
Attorneys’ Offices frequently collaborate on individual 
cases and broad sweeps or task forces through access 
grants to their respective investigative files. ENF also 
collaborates with the Federal Bureau of Investigation 
(FBI) on individual matters and through a Memoran-
dum of Understanding to embed, on a full-time basis, 
several agents and intelligence analysts from the FBI’s 
Economic Crimes Unit into the division’s Office of 
Market Intelligence (OMI) for the purpose of informa-
tion sharing and leveraging each other’s resources  
and expertise.
ENF also collaborates with other federal agencies, 
routinely exchanging tips, complaints, and referrals 
(received by OMI), and sharing information and 
intelligence. ENF primarily collaborates in this regard 
with the DOJ, the 94 U.S. Attorneys’ Offices, and the 
FBI, but also collaborates with other federal and state 
agencies including, among others, the Consumer Finan-
cial Protection Bureau (CFPB), the Commodity Futures 
Trading Commission (CFTC), the Department of 
Education, the Department of Labor, the Federal Trade 
Commission (FTC), the Internal Revenue Service, the 
Financial Crimes Enforcement Network (FinCEN), and 
the Office of the Comptroller of the Currency (OCC).
To promote international cooperation among securities 
regulators in their respective investigations and cases, 
the SEC’s Office of International Affairs (OIA) and 
ENF often support the SEC’s law enforcement and 
regulatory counterparts abroad. This collaboration 
includes, for example, requests from ENF for inter-
national assistance and requests for assistance from 
foreign regulatory and law enforcement authorities. 
In addition, each year ENF participates in the SEC’s 
Annual International Enforcement Institute, where 
ENF staff share important information about enforce-
ment-related issues. OIA also collaborates with the 
DOJ and foreign law enforcement agencies on inves-
tigations of possible violations of U.S. securities laws 
where international issues exist.
The work performed by the SEC’s Division of  
Investment Management (IM) and Division of Trading 
and Markets (TM) further supports the SEC’s goal 
to enforce compliance with securities laws. IM, for 
example, routinely shares information with the DOJ, 
CFTC, Federal Reserve Board (FRB), Swiss securities 
regulator, UK securities regulator, and the New York 
Deparment of Financial Services in connection with 
various enforcement actions resulting in injunctive 
actions or criminal convictions against financial 
services entities that implicate provisions of the Invest-
ment Company Act of 1940. In addition, IM and  
TM frequently collaborate with FinCEN on various 
matters relating to anti-money laundering. IM staff 
and their colleagues provided technical guidance 
and comment to the U.S. responses to the Financial 
Action Task Force’s Anti-Money Laundering techni-
cal compliance criteria, Treasury’s national money 
laundering and terrorist financing risk assessments, and 
FinCEN’s consideration of rules that would subject 
investment advisers to certain anti-money laundering 
requirements.
Strategic Goal 3 
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 collabora-
tion activities with other regulators, federal agencies, 
and committees to make information accessible to 
investors. For example, 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 Ameri-

OTHER INFORMATION   |   89
cans for life-long financial success. Jump$tart partners 
include, among others, FDIC, FRB, FTC, FINRA, 
GSA, OCC, North American Securities Administrators 
Association (NASAA), and the U.S. Department of 
Agriculture. 
 
The SEC also collaborates with external partners to 
protect the financial wellbeing of American seniors. 
The SEC works closely with the Elder Justice Inter-
agency 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 the groups of the SEC’s 
initiatives to protect older Americans from invest-
ment fraud and abusive sales practices. Furthermore, 
through the Outsmarting Investing Fraud program, 
OIEA staff conducts educational programs with the 
FINRA Investor Education Foundation, state securities 
regulators, and AARP on how to identify common 
persuasion techniques used by con artists. 
OIEA also participates on behalf of 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 
over 20 additional federal agencies. The Commission 
was tasked to develop a national financial education 
website (MyMoney.gov) and a national strategy on 
financial education. 
An attorney in OIEA’s Office of Chief Counsel and the 
assistant director of OIEA’s Office of Investor Educa-
tion have also been coordinating with various special 
emphasis groups regarding outreach efforts to inves-
tors. These groups include the Asian Pacific American 
Committee, the Caribbean American Heritage 
Committee, and the Hispanic and Latino Opportunity, 
Leadership, and Advocacy Committee. 
Strategic Goal 4
To enhance the Commission’s performance 
through effective alignment and management 
of human, information, and financial capital, the 
Commission’s administrative offices often work 
collaboratively with other agencies. 
Below are just a few examples of activities in which the 
SEC participates to help further enhance the effective-
ness of core operations.
The Office of Human Resources (OHR) participates 
in quarterly discussions with the FDIC, CFTC, 
Federal Housing Finance Administration, OCC, 
National Credit Union Association, and Farm Credit 
Administration to benchmark benefits and work-life 
program offerings among the Financial Institutions 
Reform, Recovery, and Enforcement Act of 1989 
(FIRREA) agencies. The shared goal is to benchmark 
program areas, share information about their human 
capital management practices, and explore best 
practices. OHR and these organizations participate in 
a bi-annual survey to benchmark compensation and 
benefits programs. The survey is conducted by a third 
party with the SEC compensation team managing the 
contract and internal agency agreements. OHR also 
partakes in the Enterprise Data & Analytics Commu-
nity of Practice, a collaboration effort sponsored by the 
SEC, GSA, NASAA, OCC, and the U.S. Department of 
Veterans Affairs to share human capital analytics and 
data visualization best practices.
The Office of 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 of practice 
group of attorneys representing federal agencies 
in employment law matters. Participants regularly 
schedule speakers from across the federal government 

90   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
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 exten-
sively with the Department of Homeland Security 
(DHS) and OMB on the security of agency systems. As 
one example, the SEC has been taking advantage of 
government-wide DHS offerings meant to help assess 
and bolster agency information security programs.
The Office of Strategic Initiatives helps the SEC gain 
efficiencies by participating in the Information Services 
(Library) collaboration effort with an emphasis on 
fostering relationships with peer FSOC libraries 
to develop a forum for discussing common issues, 
including licensing terms, data sharing, and library 
infrastructure needs. Participants include the Senate, 
Georgetown University Law Library, Law Library of 
Congress, Jones Day, Crowell & Moring, Finnegan, 
and FSOC libraries. By meeting with peer and other 
external libraries, the SEC is able to discuss best 
practices and develop benchmarking metrics. 
The Office of Support Operations (OSO) works closely 
with GSA to consolidate SEC’s real estate portfolio 
nationwide. Since 2011, OSO has identified and 
pursued eight opportunities representing an estimated 
annual rent savings of up to $15.9 million by 2021 
primarily by exiting leases and rightsizing rentable 
square feet requirements upon existing lease expirations. 

OTHER INFORMATION   |   91
EVIDENCE BUILDING
Internal and external evaluations play a significant role 
in monitoring and improving SEC program perfor-
mance. 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 
2017, there were seven GAO reports and 11 Office of 
Inspector General reports related to agency operations. 
Beyond this, examples of reviews and evaluations  
that the agency has initiated and plans to continue  
are listed below.
• The agency will continue to advance broad-based 
reviews of core agency programs. For example, the 
Division of Trading and Markets also continues to 
work with staff at other applicable regulators to 
explore ways to improve price transparency and 
address potential regulatory gaps in the government 
securities markets.
• Through customer satisfaction surveys and other 
research, the Office of Investor Education and 
Advocacy and the Office of the Investor Advocate 
will seek additional information regarding the 
behavior of individual investors, the type of infor-
mation they need and use when making investment 
decisions, and the usefulness of SEC’s investor 
education programs and materials.
• In 2017, the SEC initiated an assessment of the 
agency’s internal cybersecurity risk profile and 
approach to cybersecurity from a regulatory and 
oversight perspective.
• The SEC reviews performance goal data on a 
quarterly basis. Each quarter, the SEC’s performance 
improvement office reviews the status of perfor-
mance 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 OMB 
and Performance Improvement Council recommen-
dations for frequent data-driven reviews.
• The agency tracks the number of SEC staff partici-
pants in mission-focused training and development 
programs and will report on specific items through 
the use of post-course evaluations to assess the 
impact and results of this training on a five-point 
scale. In FY 2016, the agency began offering more 
virtual training to enhance the accessibility of 
real-time training and reduce costs associated with 
classroom-based training.

92   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
LINKS TO ADDITIONAL INFORMATION AND 
RESOURCES 
ReferenceURL
Strategic Plan for 2014–2018  www.sec.gov/about/sec-strategic-plan-2014-2018.pdf
FY 2017 Agency Financial Reportwww.sec.gov/files/sec-2017-agency-financial-report.pdf  
Prior Year Congressional Budget Justifications www.sec.gov/reports
Investor.gov  www.investor.gov
Office of the Whistleblower www.sec.gov/whistleblower 
Enforcement Actions  www.sec.gov/spotlight/enf-actions-fc.shtml
Laws that Govern the Securities Industrywww.sec.gov/about/laws.shtml
Glossary of Terms and Acronymswww.sec.gov/fast-answers

FY 2017 Annual 
Performance Report 
(APR) and FY 2019 
Annual Performance 
Plan (APP)
A Reader’s Guide to the SEC’s Performance Information .........................................................95
FY 2017 APR and FY 2019 APP Summary
 ..............................................................................................95
Performance Summary by Strategic Goal and Strategic Objective
 ..................................96
Strategic Goal 1: Establish and Maintain an Effective  
 Regulatory Environment ..................................................................................................96
Strategic Goal 2: Foster and Enforce Compliance with the  
 Federal Securities Laws .................................................................................................103
Strategic Goal 3: Facilitate Access to the Information Investors  
 Need to Make Informed Investment Decisions ...........................................114
Strategic Goal 4: Enhance the Commission’s Performance through  
 Effective Alignment and Management of Human,  
 Information, and Financial Capital ...........................................................................119



FY 2017 ANNUAL PERFORMANCE REPORT AND FY 2019 ANNUAL PERFORMANCE PLAN   |   95
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 five years that 
will be published in 2018 for public comment. 
The chapters included within this section comprise 
the agency’s FY 2017 APR and FY 2019 APP and 
explain how the SEC uses resources to achieve each of 
its four strategic goals. These strategic goals, strategic 
objectives, and performance goals and indicators were 
developed as part of the Strategic Plan process for  
FY 2014–2018. 
Strategic Goal Summary: Reviews the purpose of each 
strategic goal and provides additional information to 
identify the resources allocated toward achieving the goal.
Strategic Objective: Describes the SEC’s strategic objec-
tives that are used to gauge the agency’s performance as 
related to each strategic goal.
Performance Goals and Indicators: Presents the perfor-
mance goals and performance indicators by objective, 
comparing planned and actual performance levels for FY 
2017. Four years of historical data is provided for perfor-
mance goals and performance indicators where available.
FY 2017 APR AND FY 2019 APP SUMMARY
The SEC focuses its resources on: (1) establishing  
and maintaining an effective regulatory environment; 
(2) fostering and enforcing compliance with the federal
securities laws; (3) facilitating access to the information
investors need to make informed investment decisions;
and (4) enhancing the agency’s performance through
effective alignment and management of human,
information, and financial capital. In FY 2017, total
SEC obligations were $1.651 billion
1
 in support of
4,616 total full-time equivalents (FTE). Of 53 total
performance targets, the agency met or exceeded 49
and did not meet four.
The budget request for FY 2019 totals $1.683 billion,
2
 
an increase of about $32 million relative to the agency’s 
FY 2017 obligations of $1.651 billion. The FY 2019 
budget request funds 4,457 FTEs, a decrease of about  
159 FTEs and 46 positions compared to the FY 2017 level.
FY 2017 Performance Results Summary Table
Goal 1Goal 2Goal 3Goal 4
Exceeded/Met
Not Met
1010
2
12
17
2
1	 This	figure	excludes	use	of	budget	authority	to	liquidate	prior	obligations	for	deficient	leases.
2	 This	amount	is	the	sum	of	$1.658	billion	in	new	budget	authority	and	$0.025	billion	projected	to	come	from	de-obligations	of	prior	fiscal	years’	actions.

96   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
PERFORMANCE SUMMARY BY STRATEGIC 
GOAL AND STRATEGIC OBJECTIVE
STRATEGIC GOAL 1: Establish and 
Maintain an Effective Regulatory 
Environment
The SEC believes that its rules and regulations should 
be drafted to enable market participants to clearly 
understand their obligations under the federal securities 
laws and to conduct their activities in compliance with 
law. The SEC aims to promulgate rules that are clearly 
written, easily understood, and tailored toward specific 
ends. In addition, the agency recognizes that regular 
reviews of our regulations and rulemaking processes 
are necessary to confirm that intended results are being 
achieved. When properly crafted, these rules serve to 
further the agency’s mission and allow for accurate and 
reliable information to be made available to investors. 
In FY 2017, the agency met or exceeded all 10 perfor-
mance targets in Strategic Goal 1. The SEC devotes 
a large share of resources to responding to no-action 
letters and interpretive and other requests from regulat-
ed entities, public companies, and other outside parties. 
The agency is committed to increasing the response time 
to such requests. 
In FY 2019, the agency is requesting a total of $170.5 
million and 463 FTEs toward achieving results in 
establishing an effective regulatory environment. Inves-
tor protection, market stability, and capital formation 
remain central to the SEC’s rulemaking agenda. 
Strategic Objective 1.1: The SEC establishes and main-
tains a regulatory environment that promotes high- 
quality disclosure, financial reporting, and governance, 
and that prevents abusive practices by registrants,  
financial intermediaries, and other market participants.
Goal Leader(s): Director, Division of Trading and 
Markets; Director, Division of Corporation Finance; 
Director, Division of Investment Management 
PERFORMANCE INDICATOR (PROCESS) 1.1.1 
Number of investor testing research projects
Description: This metric tracks the number of research initiatives used to gather feedback from investors on the usefulness of 
disclosures and other input on SEC rulemaking.
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017 
Actual
Number of projects200001
Responsible Division/Office: Office of the Investor Advocate
Data Source: Microsoft Office Suite Tools

FY 2017 ANNUAL PERFORMANCE REPORT AND FY 2019 ANNUAL PERFORMANCE PLAN   |   97
Strategic Objective 1.2: The SEC promotes capital  
markets that operate in a fair, efficient, transparent,  
and competitive manner, fostering capital formation 
and useful innovation.
Goal Leader(s): Director, Division of Trading  
and Markets; Director, Division of Corporation Finance
PERFORMANCE GOAL 1.2.1 
Time to complete SEC review of SRO rules that are subject to SEC approval
Description: The SEC reviews SRO rule proposals for consistency with the Exchange Act standards of investor protection, fair and 
orderly operation of the markets and market structure, as well as other statutory requirements. This metric gauges the timeliness of 
those reviews.
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017 
Plan
FY 2017 
Actual
FY 2018 
Estimate
FY 2019 
Estimate
Within 45 days75%74%75%63%60%60%64%60%60%
Target: Exceeded
Analysis: During FY 2017, the SEC approved or disapproved 302 SRO rule changes filed pursuant to Section 19(b)(2) of the Exchange 
Act. Of the 302 filings, 64 percent were approved or disapproved within the 45-day standard for publication, which exceeds the 60 
percent target established. 
Responsible Division/Office: Division of Trading and Markets
Data Source: SRO Rule Tracking System (SRTS)
PERFORMANCE INDICATOR (PROCESS) 1.2.1 
Percentage of SRO rule filings that are submitted for immediate effectiveness
Description: This indicator gauges the proportion of SRO rule proposals that can be submitted for immediate effectiveness without 
Commission approval.
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017 
Actual
Percentage72%78%72%78%77%69%
Responsible Division/Office: Division of Trading and Markets
Data Source: SRO Rule Tracking System (SRTS)

98   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
PERFORMANCE INDICATOR (PROCESS) 1.2.2 
Percentage of transaction dollars settled on time each year
Description: This indicator measures the efficiency of the U.S. clearance and settlement system for equity securities.
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017 
Actual
Percentage99%98%99%99%99%99%
Responsible Division/Office: Division of Trading and Markets
Data Source: Depository Trust & Clearing Corporation and NYSE Technologies
PERFORMANCE INDICATOR (PROCESS) 1.2.3 
Percentage of market outages at SROs and electronic communications networks (ECN)  
that are corrected within targeted timeframes 
1
Description: Market outages reflect problems in the systems’ underlying the securities markets that could have an adverse effect on 
the markets’ ability to function as required. The SEC assesses the reliability and resiliency of these systems to minimize the number and 
duration of outages. This metric gauges how quickly outages are resolved so that market activity can resume.
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017 
Actual
Within 2 hours71%80%80%63%41%49%
Within 4 hours89%86%85%77%54%58%
Within 24 hours100%98%96%96%71%83%
Responsible Division/Office: Office of Compliance Inspections and Examinations 
Data Source: Reporting pursuant to Regulation SCI
1	 Performance	data	reported	for	this	measure	from	FY	2011–FY	2015	was	reported	under	the	agency’s	voluntary	Automation	Review	Policy	program	(ARP).	
During	FY	2016,	Regulation	SCI	went	into	effect,	effectively	replacing	this	voluntary	program.	Under	the	old	ARP	program,	entities	reported	on	outages,	but	
under	Regulation	SCI,	entities	are	now	being	asked	to	report	“disruptions.”	Disruptions	are	a	broader	list	of	events	that	may	have	resulted	in	longer	periods	
of	event	duration.	In	addition,	there	is	a	greater	breadth	of	events	being	reported,	as	there	has	been	a	significant	increase	in	the	number	of	entities	now	
being	required	to	report.	

FY 2017 ANNUAL PERFORMANCE REPORT AND FY 2019 ANNUAL PERFORMANCE PLAN   |   99
Strategic Objective 1.3: The SEC adopts and adminis-
ters regulations and rules that are informed by robust 
economic analysis and public comment and that enable 
market participants to understand clearly their obliga-
tions under the securities laws.
Goal Leader(s): Director, Division of Trading and 
Markets; Director, Division of Corporation Finance; 
Director, Division of Investment Management; Director, 
Division of Economic and Risk Analysis
PERFORMANCE GOAL 1.3.1 
Length of time to respond to written requests for no-action letters (NAL),  
exemptive applications, and written interpretive requests
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 such requests for guidance, when provided, are generally available to the public, 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 YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017  
Plan
FY 2017 
Actual
FY 2018 
Estimate
FY 2019 
Estimate
Division of Trading and Markets: No-action letters, exemptive applications, and written interpretive requests (combined figure)
Percentage within required  
timeframe
89%93%83%88%81%80%86%80%80%
Target: Exceeded
Analysis: TM exceeded the established target for FY 2017. Its target is based on a fixed deadline for responses to written requests 
for no-action letters, exemptive applications, and written interpretive requests (collectively, “requests”). Some requests are extremely 
complex and require extensive consideration and consultation both within and outside TM. TM’s approach has been to allow these 
requests the thorough consideration they demand, even when that means the request is not closed within the targeted timeframe, so 
that nuance and detail can be properly considered. 
Responsible Division/Office: Division of Trading and Markets
Data Source: TM Request Tracking Log
Division of Investment Management
No-action letters and interpretive 
requests
100%100%100%100%97%80%97%80%80%
Exemptive applications100%99%99%100%100%80%100%80%80%
Target: No-action letters and interpretive requests – Exceeded; Exemptive applications – Exceeded
Analysis: IM continues to exceed its target of issuing initial comments on no-action letters and exemptive applications within 120 
days. IM has been 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 Investment Management
Data Source: CCO Tracker 
Division of Corporation Finance
No-action letters and interpretive 
requests 
98%98%97%94%93%90%98%90%90%
Shareholder proposals100%100%100%100%100%100%100%100%100%
Target: No-action letters and interpretive requests – Exceeded; Shareholder proposals – Met
Analysis: CF achieved its target of responding to 100 percent of shareholder proposal requests prior to the company’s proxy filing date. 
CF surpassed its FY 2017 target by providing initial comments on no-action letters within 30 days for 98 percent of requests.
Responsible Division/Office: Division of Corporation Finance
Data Source: Division No-Action Letter database and Division Shareholder Proposal database

100   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
PERFORMANCE GOAL 1.3.2 
Timeliness of responses to requests for informal guidance received by the  
Trading and Markets dedicated hotline or email box
Description: The Division of Trading and Markets maintains a dedicated phone line and an email account to provide market participants 
with avenues to request information and informal guidance regarding the Exchange Act and rules thereunder. This metric reflects the 
timeliness of the staff’s responses to these requests.
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017 
Plan
FY 2017 
Actual
FY 2018 
Estimate
FY 2019 
Estimate
Respond to or refer inquiries 
within 2 weeks
Prior-year data  
not available
99%98%99%95%98%95%95%
Target: Exceeded
Analysis: TM surpassed its FY 2017 target by responding to or referring inquiries within 2 weeks for 98 percent of inquiries. 
Responsible Division/Office: Division of Trading and Markets
Data Source: Division of Trading and Markets’ Office of Interpretation and Guidance Log
PERFORMANCE INDICATOR (CONTEXTUAL) 1.3.1 
Number of published economic reports
Description: This indicator gauges the number of economic reports that staff of the Division of Economic and Risk Analysis publishes 
annually on the SEC’s website.
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017 
Actual
Number of reports
Prior-year data  
not available
2315293343
Responsible Division/Office: Division of Economic and Risk Analysis
Data Source: SEC.gov
PERFORMANCE INDICATOR (PROCESS) 1.3.2 
Number of amendments to national securities exchange registrations (Form 1)
Description: This indicator provides information about the volume of material filed with the SEC that involves amendments to  
exchange registrations.
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017 
Actual
Number of amendments
Prior-year data  
not available
117161160165
Responsible Division/Office: Division of Trading and Markets
Data Source: Form 1 Amendments List 

FY 2017 ANNUAL PERFORMANCE REPORT AND FY 2019 ANNUAL PERFORMANCE PLAN   |   101
PERFORMANCE INDICATOR (PROCESS) 1.3.3 
Number of Alternative Trading System registrations (Form ATS)
Description: This indicator provides information about the volume of material filed with the SEC that involves filings related to ATS 
registrations.
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017 
Actual
Number of registrations
Prior-year data  
not available
129616
Responsible Division/Office: Division of Trading and Markets
Data Source: ATS Events List
PERFORMANCE INDICATOR (PROCESS) 1.3.4 
Number of new investment product submissions
Description: This indicator provides information about the volume of material filed with the SEC that involves new product submissions 
pursuant to Rule 19b-4(e) of the Exchange Act.
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017 
Actual
Number of submissions
Prior-year data  
not available
2,0472,2854,6354,855
Responsible Division/Office: Division of Trading and Markets
Data Source: 19b-4(e) Log     

102   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
Strategic Objective 1.4: The SEC engages with a multi-
tude of stakeholders to inform and enhance regulatory 
activities domestically and internationally.
Goal Leader(s): Director, Office of International Affairs
PERFORMANCE GOAL 1.4.1 
Supervisory cooperation requests from foreign authorities for SEC assistance and SEC requests for 
assistance on supervisory cooperation from foreign authorities
Description: The SEC makes requests to foreign authorities for supervisory cooperation assistance and responds to such requests 
from foreign regulators through both formal mechanisms, such as supervisory memoranda of understanding, and on an ad hoc basis.
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017 
Plan
FY 2017 
Actual
FY 2018 
Estimate
FY 2019 
Estimate
Supervisory cooperation  
requests from foreign  
authorities
Prior-year 
data not 
available
25117113148152153158163
SEC requests for assistance  
on supervisory cooperation 
from foreign authorities
Prior-year 
data not 
available
11896135135139169174179
Target: Supervisory cooperation requests from foreign authorities – Exceeded; SEC requests for assistance on supervisory cooperation 
from foreign authorities – Exceeded
Analysis: The actual SEC results in FY 2017 exceeded the estimate by approximately 22 percent. 
Responsible Division/Office: Office of International Affairs
Data Source: International Program Oversight Database and Business Objects Reports
PERFORMANCE GOAL 1.4.2 
Number of non-U.S. regulators trained
Description: This metric shows the reach of the SEC’s technical assistance programs for regulators around the world. The SEC 
conducts these training sessions to assist countries in developing and maintaining robust protections for investors and promoting cross-
border enforcement and supervisory assistance.
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017 
Plan
FY 2017 
Actual
FY 2018 
Estimate
FY 2019 
Estimate
Number of non-U.S. regulators1,7851,7162,3821,6662,1451,8001,8371,8501,850
Target: Exceeded
Analysis: The actual results for FY 2017 exceeded the performance target.
Responsible Division/Office: Office of International Affairs
Data Source: International Program Oversight Database and Business Objects Reports

FY 2017 ANNUAL PERFORMANCE REPORT AND FY 2019 ANNUAL PERFORMANCE PLAN   |   103
 STRATEGIC GOAL 2: Foster and  
Enforce Compliance with Federal 
Securities Laws
Fostering compliance with federal securities laws is 
interwoven through all of the SEC’s programs and is 
central to fulfilling the critical mission of the agency. 
Through disclosure reviews and examinations of bro-
ker-dealers, investment advisers, self-regulatory organi-
zations (SRO), and other market participants, the SEC 
seeks both to detect violations of the securities laws and 
rules, and to foster strong compliance and risk man-
agement practices within these firms and organizations. 
The SEC’s enforcement program also investigates and 
prosecutes violations of the law with the aim of holding 
wrongdoers accountable, returning funds to harmed 
investors whenever possible, and building deterrence 
against future violations. In FY 2017, the agency met 
or exceeded 10 and did not meet two performance 
targets in Strategic Goal 2. For FY 2019, the agency is 
requesting a total of $987.2 million and 2,678 FTEs for 
Goal 2. These resources will allow the SEC to expand 
the reach of the examination program and address the 
growing number and complexity of registered firms. 
Additionally, the Commission will be able to take 
prompt action to halt misconduct, sanction wrongdoers 
effectively, and return funds to harmed investors. 
Strategic Objective 2.1: The SEC fosters compliance 
with the federal securities laws.
Goal Leader(s): Director, Office of Compliance 
Inspections and Examinations
PERFORMANCE GOAL 2.1.1 
Number of industry outreach and education programs targeted to areas 
identified as raising particular compliance risks
Description: Targeted communication with industry participants on topics shaping the examination program is intended to enhance 
compliance practices and prevent violations before they occur. This metric identifies the number of major outreach efforts conducted, 
including the SEC’s national and regional compliance outreach events, published risk alerts, and other educational programs and 
initiatives.
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017 
Plan
FY 2017 
Actual
FY 2018 
Estimate
FY 2019 
Estimate
Number of major 
outreach efforts
121563129158100128100100
Target: Exceeded
Analysis: The SEC seeks to encourage a strong culture of ethical behavior and decision-making at organizations and promote 
compliance with federal securities laws. As part of its efforts to promote compliance within the industry, OCIE conducted more than 
125 outreach and educational programs events during the year, including Compliance Outreach seminars and various other outreach 
initiatives with registrants, regulators, and industry groups. As part of this work, the program also issued six National Risk Alerts, 
presented at SEC Speaks, and published other significant materials during the year. In addition, staff from throughout the program 
participated in a number of other outreach efforts, including speaking at more than a hundred industry conferences and related 
engagements that are not reflected in the above numbers. 
Responsible Division/Office: Office of Compliance Inspections and Examinations
Data Source: Internal tracking, although many of the events noted above are referenced on the SEC’s website

104   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
PERFORMANCE GOAL 2.1.2 
Percentage of firms receiving deficiency letters that take corrective  
action in response to all exam findings
Description: At the conclusion of examinations, the staff communicates identified deficiencies to registrants in the form of a deficiency 
letter. Registrants are then given a chance to respond to staff findings and often take action to remedy any problems and potential risks, 
including monetary compensation to clients and enhancements to disclosures, policies, and procedures. Most often, registrants respond 
that they have corrected the deficiencies and implemented measures to prevent recurrence.
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017 
Plan
FY 2017 
Actual
FY 2018 
Estimate
FY 2019 
Estimate
Percentage92%86%89%90%88%89%91%90%90%
Target: Exceeded
Analysis: The SEC works to enforce and foster compliance with federal securities laws through its examination program. During 
examinations in FY 2017, the staff identified a number of areas where firms appeared not to be in compliance with federal securities 
laws. In response to deficiency letters that were sent to firms by the staff, the vast majority of registrants have continued to assert 
that they are taking corrective action in response to the staff’s findings. This measure continues to show that registrants are using 
examination results to improve operations and compliance with federal securities laws.
Responsible Division/Office: Office of Compliance Inspections and Examinations
Data Source: Tracking and Reporting Exam National Documentation System (TRENDS)

FY 2017 ANNUAL PERFORMANCE REPORT AND FY 2019 ANNUAL PERFORMANCE PLAN   |   105
Strategic Objective 2.2: The SEC promptly detects and 
deters violations of the federal securities laws.
Goal Leader(s): Director, Office of Compliance Inspec-
tions and Examinations
PERFORMANCE GOAL 2.2.1 
Percentage of investment advisers, investment companies,  
and broker-dealers examined during the year
Description: This metric indicates the number of registrants examined by the SEC or an 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, limited-scope special inspections to probe emerging risk areas, and oversight examinations of broker-dealers to test 
compliance and the quality of examinations by FINRA.
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017 
Plan
FY 2017 
Actual
FY 2018 
Estimate
FY 2019 
Estimate
Investment advisers8%9%10%10%11%13%15%15%15%
Investment companies12%11%10%15%17%10%11%11%11%
Broker-dealers49%46%49%51%50%48%48%48%48%
Target: Investment advisers – Exceeded; Investment companies – Exceeded; Broker-dealers – Met
Analysis: Building and maintaining examination coverage of the industry helps the Commission promptly detect violations of federal 
securities laws and promote compliance with such laws. During FY 2017, the examination program met or exceeded its coverage 
targets. The program focused particular efforts in the investment adviser space and was able to improve coverage beyond targeted 
levels. In addition to conducting examinations, the staff continued to exert considerable time and attention during the year on  
enhancing its risk assessment efforts to ensure that the program is spending its limited time and resources on those activities and  
firms presenting the highest risk. Further, program resources were also allocated during the past year to other critical activities intended 
to improve the long-term performance of the program, including industry outreach initiatives, rulemaking projects, and other program 
improvement efforts. 
Responsible Division/Office: Office of Compliance Inspections and Examinations
Data Source: Tracking and Reporting Exam National Documentation System (TRENDS) (IA, IC, and BD SEC data) and SRO Databases 
(BD SRO Data)
PERFORMANCE GOAL 2.2.2 
Percentage of compliance exams that are timely concluded in accordance with the  
Office of Compliance Inspections and Examinations’ (OCIE) statutory deadline
Description: The staff conducts examinations each year of registered entities, including investment advisers, investment company 
complexes, transfer agents, and broker-dealers. The staff strives to complete its examinations and communicate findings in the most 
efficient and effective manner and within its statutory deadline. This metric reflects the percentage of examinations concluded within the 
statutory deadline.
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017 
Plan
FY 2017 
Actual
FY 2018 
Estimate
FY 2019 
Estimate
Percentage
Prior-year data 
not available
100%100%100%100%100%100%100%100%
Target: Met
Analysis: The staff’s goal is to identify and communicate potential issues to firms to ensure that compliance problems and issues are 
corrected quickly. During FY 2017, 100 percent of completed examinations were done within OCIE’s statutory deadline. Overall, this 
performance goal helps the SEC ensure that deficiencies are promptly resolved by firms. 
Responsible Division/Office: Office of Compliance Inspections and Examinations
Data Source: Tracking and Reporting Exam National Documentation System (TRENDS) 

106   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
PERFORMANCE GOAL 2.2.3 
Number of joint exams, information sharing agreements, and  
formal meetings with other regulators
Description: The SEC attempts to coordinate and collaborate with other regulators on areas of mutual interest. This helps to ensure 
that all regulators are informed of ongoing risks and issues related to broad market practices as well as specific entities of mutual 
interest. This cooperation is critical to the exam program to ensure that certain higher risk firms and activities are addressed in the most 
efficient and effective manner. This metric tracks critical cooperation activities that are occurring between the SEC’s exam program and 
other regulators.
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017 
Plan
FY 2017 
Actual
FY 2018 
Estimate
FY 2019 
Estimate
Number of joint exams, active  
sharing agreements, and  
formal meetings
Prior-year data  
not available
391442445375376350350
Target: Exceeded
Analysis: The exam program continued to conduct joint/coordinated exams and held hundreds of meetings with other regulators, which 
has proved an effective method of overseeing entities and issues that cross jurisdictional lines. The program also maintained a number of 
sharing agreements with these regulators to help ensure that information could be shared in an appropriate and timely manner.
Responsible Division/Office: Office of Compliance Inspections and Examinations
Data Source: Tracking and Reporting Exam National Documentation System (TRENDS) 
PERFORMANCE INDICATOR (CONTEXTUAL) 2.2.1 
Percentage of exams that identify deficiencies, the percentage that result in a “significant finding,”  
and the percentage referred to the Division of Enforcement
Description: Examiners find a wide range of deficiencies during examinations. Some of the deficiencies are more technical in nature, 
such as failing to include all information that is required to be in a record. However, other deficiencies may cause harm to customers 
or clients of a firm, have a high potential to cause harm, or reflect recidivist misconduct. The latter deficiencies are among those 
categorized as “significant.” This indicator identifies the percentage of exams that identified deficiencies, that resulted in significant 
deficiency findings, and that were referred to Enforcement.
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017 
Actual
Percentage that identify deficiencies80%80%76%77%72%72%
Percentage that result in a “significant finding”42%35%30%31%27%20%
Percentage referred to the Division of Enforcement
Prior-year data  
not available
13%12%11%9%7%
Responsible Division/Office: Office of Compliance Inspections and Examinations
Data Source: Tracking and Reporting Exam National Documentation System (TRENDS)     

FY 2017 ANNUAL PERFORMANCE REPORT AND FY 2019 ANNUAL PERFORMANCE PLAN   |   107
PERFORMANCE INDICATOR (OUTPUT) 2.2.2 
Number of cause exams that result from tips, complaints, and referrals
Description: Analysis of a tip can support the request for a cause exam. This indicator would identify the number of SEC cause exams 
that result from tips collected through outreach efforts.
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017 
Actual
Number of cause exams
Prior-year data  
not available
222149173191177
Responsible Division/Office: Office of Compliance Inspections and Examinations
Data Source: Tracking and Reporting Exam National Documentation System (TRENDS)     
PERFORMANCE INDICATOR (OUTPUT) 2.2.3 
Number of rulemaking initiatives assisted by the National Exam Program 
Description: The examination program interacts with registrants on a regular basis, and this work provides critical feedback toward 
ensuring effective and practical rulemaking and policy efforts. This indicator tracks how frequently the examination program assists with 
rulemaking initiatives.
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017 
Actual
Number of rulemaking initiatives assisted by the NEP
Prior-year data  
not available
30262416
Responsible Division/Office: Office of Compliance Inspections and Examinations
Data Source: Internal tracking   
PERFORMANCE INDICATOR (OUTPUT) 2.2.4 
Number of investigations or inquiries originating from a tip or complaint 
Description: Analysis of a tip or complaint can result in the need for further enforcement investigation. The indicator identifies the 
volume of SEC investigations that result from tips and complaints received by the SEC.
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017 
Actual
Number of investigations296289291325336307
Responsible Division/Office: Division of Enforcement
Data Source: HUB case management and tracking system for the Division of Enforcement   

108   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
PERFORMANCE INDICATOR (OUTPUT) 2.2.5 
SEC investigations in which requests for access to information were granted by the SEC to other authorities, 
such as SROs or other state, federal, and foreign enforcement authorities 
Description: The SEC works closely with other regulators and authorities. This measure identifies the number of investigations in which 
the SEC granted one or more authorities access to information concerning an investigation during the fiscal year. This may include 
requests for access to SEC investigative files concerning investigations that the SEC continues to pursue, as well as those in which the 
SEC has completed its investigation.
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017 
Actual
Number of investigations515504501498496505
Responsible Division/Office: Division of Enforcement
Data Source: HUB case management and tracking system for the Division of Enforcement  
PERFORMANCE INDICATOR (OUTPUT) 2.2.6 
Requests from foreign authorities for SEC assistance and SEC requests for assistance from foreign 
authorities 
Description: Each year, the SEC makes hundreds of requests for enforcement assistance to foreign regulators, while responding 
to hundreds of such requests from other nations. To facilitate this type of assistance, and encourage other countries to enact laws 
necessary to allow regulators to cooperate with their foreign counterparts, the SEC has entered into bilateral information sharing 
arrangements, as well as the Multilateral Memorandum of Understanding, an information sharing arrangement negotiated through the 
International Organization of Securities Commissions (IOSCO). 
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017 
Actual
Number of requests from foreign authorities450508541531636599
Number of SEC requests7187179669291,0271,272
Responsible Division/Office: Office of International Affairs
Data Source: International Program Oversight Database and Business Objects reports  

FY 2017 ANNUAL PERFORMANCE REPORT AND FY 2019 ANNUAL PERFORMANCE PLAN   |   109
Strategic Objective 2.3: The SEC prosecutes violations 
of federal securities laws and holds violators account-
able through appropriate sanctions and remedies. 
Goal Leader(s): Director, Division of Enforcement
PERFORMANCE GOAL 2.3.1 
Percentage of enforcement actions in which the Commission  
obtained relief on one or more claims
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.
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017 
Plan
FY 2017 
Actual
FY 2018 
Estimate
FY 2019 
Estimate
Percentage89%93%94%95%97%92%94%92%92%
Target: Exceeded
Analysis: In addition to securing victories in specific cases through litigation and trial, the SEC’s litigation efforts also help the SEC 
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 of the SEC’s mission. 
Responsible Division/Office: Division of Enforcement
Data Source: HUB case management and tracking system for the Division of Enforcement
PERFORMANCE GOAL 2.3.2 
Percentage of first enforcement actions filed within two years of the opening of an investigation
Description: This metric concerns the pace of investigations that lead to the filing of enforcement actions. Specifically, this metric 
captures the rate at which the first enforcement action arising out of an investigation was filed within two years of the opening of the 
investigation. If the investigation was preceded by a matter under inquiry, the metric draws on the date of the opening of the matter 
under inquiry. In conducting investigations, the Enforcement program continually strives to balance the need for complete, effective, and 
fair investigations with the need to file enforcement actions in as timely a manner as possible.
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017 
Plan
FY 2017 
Actual
FY 2018 
Estimate
FY 2019 
Estimate
Percentage63%58%64%58%53%65%52%65%65%
Target: Not Met
Analysis: In FY 2017, the percentage of first enforcement actions filed within two years of the opening of the matter under inquiry (MUI) 
or investigation was 52 percent, which is a decrease compared to the FY 2016 result (53 percent). While timeliness in filing actions can 
be influenced by a number of factors, it is important because it can enhance the action’s deterrent impact. 
Plan for Improving Program Performance: To address the issue of timeliness in investigations, the division is taking measures that 
include emphasizing expediency in quarterly case reviews, promoting best practices regarding efficiencies in various phases of the 
investigative process, leveraging data analytics capabilities, and conducting training on tools that expedite investigations.
Responsible Division/Office: Division of Enforcement
Data Source: HUB case management and tracking system for the Division of Enforcement

110   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
PERFORMANCE GOAL 2.3.3 
Average months between opening a matter under inquiry or an  
investigation and commencing an enforcement action
Description: This metric captures the average number of months between the opening of an investigation and the filing of the first 
enforcement action arising out of that investigation. If the investigation was preceded by a matter under inquiry, the metric draws on  
the date of opening of the matter under inquiry. In conducting investigations, the enforcement program continually strives to balance  
the need for complete, effective, and fair investigations with the need to file enforcement actions in as timely a manner as possible.  
While not all investigations result in the filing of enforcement actions, this metric provides information concerning the pace of 
investigations that do lead to such actions and supplements the previous goal, which measures the percentage of first enforcement 
actions filed within two years.
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017 
Plan
FY 2017 
Actual
FY 2018 
Estimate
FY 2019 
Estimate
Months212121242420242020
Target: Not Met
Analysis: In FY 2017, the average number of months between opening a matter under inquiry (MUI) or investigation and commencing 
an enforcement action was 24 months, which was the same as FY 2016. Timeliness in filing actions is important because it can enhance 
the action’s deterrent impact. At the same time, many of the division’s cases are complex and can take extended periods of time to 
develop successfully. 
Plan for Improving Program Performance: To address the issue of timeliness in investigations, the division is taking measures that 
include emphasizing expediency in quarterly case reviews, promoting best practices regarding efficiencies in various phases of the 
investigative process, leveraging data analytics capabilities, and conducting training on tools that expedite investigations.
Responsible Division/Office: Division of Enforcement
Data Source: HUB case management and tracking system for the Division of Enforcement
PERFORMANCE GOAL 2.3.4 
Percentage of debts where either a payment has been made or a collection activity  
has been initiated within 180 days of the due date of the debt
Description: The SEC can seek a wide range of remedies for failure to comply with the securities laws. These remedies include civil 
monetary penalties and disgorgement. When the remedies are imposed by the SEC or the federal district court, payments must be 
made by a certain date. This metric identifies the percentage of debts where debtors have made payments, or the SEC has initiated a 
collection activity within 180 days of the due date. Such collection activities include, among other things , demand letters, negotiation of 
payment plans, enforcing the payment of the debt through the courts, or other judicial remedies.
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017 
Plan
FY 2017 
Actual
FY 2018 
Estimate
FY 2019 
Estimate
Percentage92%95%92%95%96%92%99%92%92%
Target: Exceeded
Analysis: The division has successfully integrated all collections functions within the Office of Collections and, as a result, exceeded  
the target for this performance measure. 
Responsible Division/Office: Division of Enforcement
Data Source: DELPHI, HUB case management and tracking system for the Division of Enforcement

FY 2017 ANNUAL PERFORMANCE REPORT AND FY 2019 ANNUAL PERFORMANCE PLAN   |   111
PERFORMANCE GOAL 2.3.5 
Percentage of Fair Fund and disgorgement fund plans that have distributed 80 percent of the available 
funds for distribution within twenty-four (24) months of the approval of the distribution plan
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 twenty-four (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.
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017 
Plan
FY 2017 
Actual
FY 2018 
Estimate
FY 2019 
Estimate
Percentage80%73%81%96%93%80%96%80%80%
Target: Exceeded
Analysis: In FY 2017, the division exceeded the target by 16 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 the function 
and implementing various process improvements. 
Responsible Division/Office: Division of Enforcement
Data Source: HUB case management and tracking system for the Division of Enforcement
PERFORMANCE INDICATOR (CONTEXTUAL) 2.3.1 
Percentage of filed enforcement actions reflecting characteristics that present  
enhanced risk to investors and markets, as measured by the nature of the  
investigation, conduct, parties and impact 
Description: This indicator assesses the quality of the cases filed by the Division of Enforcement. The indicator focuses on cases 
filed by the SEC that involve factors reflecting enhanced risk to investors and markets. Such cases may involve: (i) those identified 
through risk analytics and cross-disciplinary initiatives to reveal difficult-to-detect or early stage misconduct, thus minimizing investor 
loss and preventing the spread of unlawful conduct and practices; (ii) particularly egregious or widespread misconduct and investor 
harm; (iii) vulnerable victims; (iv) a high degree of scienter; (v) involvement of individuals occupying substantial positions of authority, or 
having fiduciary obligations or other special responsibilities to investors; (vi) involvement of recidivists; (vii) high amount of investor loss 
prevented; (viii) misconduct that is difficult to detect due to the complexity of products, transactions, and practices; (ix) use of innovative 
investigative or analytical techniques; (x) effective coordination with other law enforcement partners; and/or (xi) whether the matter 
involves markets, transactions, or practices identified as an enforcement priority, or that advances the programmatic priorities of other 
SEC Divisions or Offices.
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017 
Actual
Percentage
Prior-year data  
not available
62%58%57%44%
Responsible Division/Office: Division of Enforcement
Data Source: Qualitative Index Spreadsheet  

112   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
PERFORMANCE INDICATOR (CONTEXTUAL) 2.3.2 
Total amount distributed within the fiscal year, and the number of Fair Funds  
from which those distributions came 
Description: In its enforcement actions, the SEC may seek to return funds to harmed investors through disgorgement of ill-gotten 
gains or through the Fair Funds provision of the Sarbanes-Oxley Act. This provision permits the SEC to combine amounts paid as 
penalties with disgorged funds, or to create a Fair Fund from penalties only, to reduce losses to injured parties. This reflects the SEC’s 
efforts to return funds to injured investors. This indicator identifies the total amount distributed within the fiscal year, and the number of 
Fair Funds from which those distributions came. This indicator may increase or decrease in dollar amount and number of distribution 
funds based on the number of SEC enforcement actions brought involving distributions, amounts ordered and paid in those actions, 
and other factors. Due to the variation in reporting timelines established for each individual distribution, reported amounts are based 
on the agency’s best available information. Reported amounts do not include those funds distributed through receiverships. 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 Commission’s own expenses.
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017 
Actual
Amount distributed (in millions)$815$251$424$158$140$1,073
Number of Fair Funds312228343532
Responsible Division/Office: Division of Enforcement
Data Source: HUB case management and tracking system for the Division of Enforcement Distributions Management System 
PERFORMANCE INDICATOR (OUTPUT) 2.3.3 
Percent of enforcement actions filed that arose out of national priority investigations 
Description: The Division of Enforcement conducts many enforcement actions each year that can be characterized as high impact and 
of national priority. High impact or national priority investigations include investigations that are significant for one or more of the following 
reasons—the matter: (i) presents an opportunity to send a particularly strong and effective message of deterrence, including with 
respect to markets, products, and transactions that are newly developing or that are long established but by their nature present limited 
opportunities to detect wrongdoing and thus to deter misconduct; (ii) involves particularly egregious or extensive misconduct; (iii) involves 
potentially widespread and extensive harm to investors; (iv) involves misconduct by persons occupying positions of substantial authority 
or responsibility, or who owe fiduciary or other enhanced duties and obligations to a broad group of investors or others; (v) involves 
potential wrongdoing as prohibited under newly-enacted legislation or regulatory rules; (vi) concerns potential misconduct that occurred 
in connection with products, markets, transactions, or practices that pose particularly significant risks for investors or a systemically 
important sector of the market; (vii) involves a substantial number of potential victims and/or particularly vulnerable victims; (viii) involves 
products, markets, transactions, or practices that the Enforcement Division has identified as priority areas; and/or (ix) provides an 
opportunity to pursue priority interests shared by other law enforcement agencies on a coordinated basis.
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017 
Actual
Percentage20%15%16%25%27%19%
Responsible Division/Office: Division of Enforcement
Data Source: HUB case management and tracking system for the Division of Enforcement 

FY 2017 ANNUAL PERFORMANCE REPORT AND FY 2019 ANNUAL PERFORMANCE PLAN   |   113
PERFORMANCE INDICATOR (CONTEXTUAL) 2.3.4 
Criminal actions related to conduct under investigation by the SEC 
Description: In some instances, conduct may involve both civil and criminal violations and may be investigated by both the SEC and the 
criminal authorities. This indicator identifies the number of criminal actions that are related to conduct under investigation by the SEC.
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017 
Actual
Number of criminal investigations126126127134109128
Responsible Division/Office: Division of Enforcement
Data Source: HUB case management and tracking system for the Division of Enforcement 
PERFORMANCE INDICATOR (CONTEXTUAL) 2.3.5 
Disgorgement and penalties ordered and the amounts collected 
Description: In addition to other types of relief, the SEC may seek orders requiring parties to disgorge any money obtained through 
wrongdoing. The SEC is also empowered to seek civil penalties for violations of the securities laws. In some cases, the SEC will seek 
to obtain large monetary sanctions, even in instances where the prospect of collecting on a judgment is slight. The rationale for seeking 
monetary relief in these circumstances is that such relief, even when likely uncollectible, might become collectible in the future based 
on the defendant’s changed circumstances, and also because such relief can serve to deter others from violating the securities laws. 
Where appropriate, the SEC has sought to return disgorged funds to harmed investors. Funds not returned to investors are sent to the 
Treasury or the Investor Protection Fund established pursuant to Section 21F(g) of the Securities Exchange Act of 1934. This indicator 
lists disgorgement and penalties ordered as a result of SEC cases in each fiscal year and the amounts collected in those actions as of 
the end of FY 2015. The indicator for collected amounts could change over time based on various factors.
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017 
Actual
Ordered amounts (in millions)$3,104$3,424$4,166$4,195$4,082$3,789
Collected amounts (in millions)$1,236$2,334$2,580$2,408$2,656$1,873 
Responsible Division/Office: Division of Enforcement
Data Source: DELPHI

114   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
 Strategic Goal 3: Facilitate Access 
to the Information Investors Need to 
Make Informed Investment Decisions 
A strong economy and a vibrant securities market rely 
on investor confidence and the widespread availability 
of relevant information about those securities. The SEC 
promotes informed investment decisions through two 
main approaches. The first is to require that investors 
have accurate, adequate, and timely public access to 
disclosure materials that are easily understood and ana-
lyzed. The second is to implement a variety of investor 
education initiatives aimed at giving investors a better 
understanding of the operations of the nation’s securi-
ties markets. In FY 2017, the agency exceeded all 12 
performance targets in Strategic Goal 3. For FY 2019, 
the SEC is requesting a total of $210.6 million and 571 
FTEs toward achieving results in Strategic Goal 3.
Strategic Objective 3.1: The SEC works to ensure that 
investors have access to high-quality disclosure materi-
als that facilitate informed investment decision-making. 
Goal Leader(s): Director, Division of Corporation 
Finance; Director, Division of Investment Management 
PERFORMANCE GOAL 3.1.1 
Percentage of public companies and investment companies with disclosures reviewed each year
Description: The Sarbanes-Oxley Act requires that the SEC review, at least once every three years, the disclosures of all companies 
and investment company portfolios reporting under the Exchange Act. These reviews help improve the information available to investors 
and may identify possible violations of the federal securities laws. This metric gauges the number of public companies and investment 
companies reviewed each year.
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017 
Plan
FY 2017 
Actual
FY 2018 
Estimate
FY 2019 
Estimate
Division of Corporation Finance
Corporations48%52%52%51%56%33%56%33%33%
Target: Exceeded
Analysis: CF exceeded its planned level of companies reviewed in FY 2017. 
Responsible Division/Office: Division of Corporation Finance
Data Source: Electronic Data Gathering, Analysis, and Retrieval (EDGAR) System, Filing Activity Tracking System (FACTS)
Division of Investment Management
Investment company portfolios36%34%35%35%36%33%35%33%33%
Target: Exceeded
Analysis: Consistent with Section 408 of the Sarbanes Oxley-Act of 2002, IM strives to review disclosures made by certain public 
issuers, including issuers’ financial statements, no less frequently than once every three years. The targeted number of annual reviews 
assumes that IM meets this goal. 
Responsible Division/Office: Division of Investment Management
Data Source: Microsoft Office Suite Tools        

FY 2017 ANNUAL PERFORMANCE REPORT AND FY 2019 ANNUAL PERFORMANCE PLAN   |   115
PERFORMANCE GOAL 3.1.2 
Time to issue initial comments on Securities Act filings
Description: The target of 30 days or less has become a de facto industry standard for the maximum time to receive initial comments.
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017 
Plan
FY 2017 
Actual
FY 2018 
Estimate
FY 2019 
Estimate
Days24.925.625.826.025.5<30.025.4<30.0<30.0
Target: Exceeded
Analysis: CF achieved its goal of having a response time for initial comments of less than 30 days. 
Responsible Division/Office: Division of Corporation Finance
Data Source: Division of Corporation Finance Management Dashboards        
PERFORMANCE GOAL 3.1.3 
Percentage of investment company disclosure reviews for which initial  
comments are completed within timeliness goals
Description: For initial registration statements, the SEC’s goal is to issue initial comments within 30 days after they are filed (60 days for 
registration statements of insurance product separate accounts and related mutual funds). The SEC also aims to comment on post-
effective amendments within 45 days, and on preliminary proxy statements within 10 days after they are filed.
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017 
Plan
FY 2017 
Actual
FY 2018 
Estimate
FY 2019 
Estimate
Initial registration statements96%98%98%98%98%85%100%85%85%
Post-effective amendments95%99%99%98%100%90%99%90%90%
Preliminary proxy statements100%98%99%98%99%99%100%99%99%
Target: Initial registration statements – Exceeded; Post-effective amendments – Exceeded; Preliminary proxy statements – Exceeded
Analysis: IM strives to review all significant disclosures made by registrants in Commission filings under the Investment Company Act, 
including initial registration statements and post-effective amendments with material changes. IM may limit the scope of a review, through 
selective review procedures, to a review of only the disclosure in a filing that has not been previously reviewed. During periods of increased 
filings, IM is able to handle the increased workload largely through the use of such selective review procedures. IM generally does not set 
a target for the number of filings that are reviewed in a fiscal year because IM does not dictate the number of filings that registrants make. 
Instead, other factors, such as registrant business decisions or the implementation of new disclosure requirements, typically drive whether 
investment companies make filings and the type of filings that they make. IM sets targets for the timeliness of reviews. 
Responsible Division/Office: Division of Investment Management
Data Source: Electronic Data Gathering, Analysis, and Retrieval (EDGAR) System       

116   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
PERFORMANCE INDICATOR (CONTEXTUAL) 3.1.1 
Total digital audience including website, social media, and mobile media 
Description: Digital media has become the dominant channel for investors seeking to access information. These statistics will help 
evaluate the extent to which investors are turning to the SEC, identify the channels they use, and quantify the amount of information  
they receive.
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017 
Actual
SEC.gov page views (in billions)
Prior-year data 
not available
3.724.496.377.9018.40
Social media followers236,700258,733308,261382,702399,086434,908
Total email/mobile subscriptions631,839 740,318 799,055 982,817 1,051,625 1,395,591
Total email bulletins sent (in millions)33.4440.8547.0156.4557.6443.6
Total mobile bulletins sent150,303238,815366,032461,753614,325554,548
Responsible Division/Office: Office of Public Affairs
Data Source: Akamai Technologies, Google Analytics, GovDelivery, Hootsuite, social media channels
Strategic Objective 3.2: The SEC works to understand 
investor needs and educate investors so they are better 
prepared to make informed investment decisions. 
Goal Leader(s): Director, Office of Investor  
Education and Advocacy
PERFORMANCE GOAL 3.2.1 
Number of page views of online investor education content, and number of in-person events,  
including those with specifically targeted communities and organizations
Description: The Office of Investor Education and Advocacy (OIEA) initiates investor education campaigns on key strategies for 
making informed investment decisions, including publicizing online resources for researching investment professionals and investments, 
understanding fees, and identifying fraud. OIEA staff also participates in in-person events for investors, both general and those targeted 
toward specific investors, such as seniors, service members, and other affinity groups. This metric tracks page views of SEC online investor 
education materials and the number of investor events in which OIEA staff participated. 
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017 
Plan
FY 2017 
Actual
FY 2018 
Estimate
FY 2019 
Estimate
Number of page views  
(in millions)
Prior-year data 
not available
12.122.223.623.78.09.18.010.0
Number of in-person 
events
Prior-year data 
not available
525171112801469090
Target: Number of page views – Exceeded; Number of in-person events – Exceeded
Analysis: The public’s use of Investor.gov and investor education materials on SEC.gov exceeded the SEC’s performance target, with 
particular interest in the calculators, tools, and resources for checking the background of investment professionals. OIEA participated in 
70 events focused on military personnel and their families as part of the SEC’s Military Financial Literacy Campaign, helping it exceed its 
target for in-person events. 
Responsible Division/Office: Office of Investor Education and Advocacy
Data Source: Google Analytics, Microsoft Office Suite Tools         

FY 2017 ANNUAL PERFORMANCE REPORT AND FY 2019 ANNUAL PERFORMANCE PLAN   |   117
PERFORMANCE GOAL 3.2.2 
Timeliness of responses to investor contacts
Description: OIEA serves the tens of thousands of investors each year who contact the SEC with investment-related complaints and 
questions. The staff aims to close out as many new investor assistance matters as possible within seven to thirty business days. 
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017 
Plan
FY 2017 
Actual
FY 2018 
Estimate
FY 2019 
Estimate
Closed within 7 days54%62%62%65%64%62%65%62%62%
Closed within 30 days93%93%92%93%92%90%94%90%90%
Target: Closed within 7 days – Exceeded; Closed within 30 days – Exceeded
Analysis: OIEA continued to focus its efforts on identifying and referring key investor assistance matters to the agency’s Tips, 
Complaints, and Referrals (TCR) system and exceeded its 7-day and 30-day targets for FY 2017.
Responsible Division/Office: Office of Investor Education and Advocacy
Data Source: Internal log using IRIS data
PERFORMANCE GOAL 3.2.3 
Customer satisfaction rating of OIEA’s online investor education resources
Description: This metric gauges the effectiveness, helpfulness, and usability of OIEA’s online investor education resources. 
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017  
Plan
FY 2017 
Actual
FY 2018 
Estimate
FY 2019 
Estimate
Satisfaction index
Prior-year data 
not available
81838483
Benchmark for 
federal government 
websites (73)
82TBDTBD 
Target: Exceeded
Analysis: Investor.gov’s customer satisfaction score (82) continued to exceed the federal government benchmark (73) due in part to site 
refinements based on feedback from Investor.gov visitors. 
Responsible Division/Office: Office of Investor Education and Advocacy
Data Source: ForeSee results online portal

118   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
PERFORMANCE GOAL 3.2.4 
Number of new investor education materials designed specifically to help  
investors protect themselves from fraud 
Description: Through OIEA—and often in conjunction with other organizations, the staff issues Investor Alerts and other forms of 
educational materials that inform investors about different permutations of fraud, new investment products, and other topical issues. This 
metric measures the number of new investor education materials issued by OIEA. 
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017 
Plan
FY 2017 
Actual
FY 2018 
Estimate
FY 2019 
Estimate
Number of education materials242628313232343232
Target: Exceeded
Analysis: In FY 2017, OIEA published 34 investor alerts and bulletins to meet its goal, many of which were focused on warning investors 
about possible fraudulent schemes. 
Responsible Division/Office: Office of Investor Education and Advocacy
Data Source: SEC.gov and Investor.gov
PERFORMANCE INDICATOR (PROCESS) 3.2.1 
Number of investor testing research projects 
Description: This metric tracks the number of research initiatives used to gather feedback from investors regarding the usefulness of 
disclosures and other input on SEC rulemaking.
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017 
Actual
Number of projects200001
Responsible Division/Office: Office of the Investor Advocate
Data Source: Microsoft Office Suite Tools
PERFORMANCE INDICATOR (PROCESS) 3.2.2 
Number of sets of recommendations prepared by the investor advisory committee 
Description: This indicator tracks the recommendations from the Investor Advisory Committee regarding investors’ perspectives  
and priorities.
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017  
Actual
Number of sets of recommendations044440
Responsible Division/Office: Office of the Investor Advocate
Data Source: SEC.gov

FY 2017 ANNUAL PERFORMANCE REPORT AND FY 2019 ANNUAL PERFORMANCE PLAN   |   119
 Strategic Goal 4: Enhance the 
Commission’s Performance through 
Effective Alignment and Management 
of Human, Information, and Financial 
Capital
The investing public and the securities markets are best 
served by an efficient, well-managed, and agile SEC. 
The Office of the Chief Operating Officer (OCOO) 
and its six operational offices—the Office of Support 
Operations (OSO), the Office of Financial Manage-
ment (OFM), the Office of Human Resources (OHR), 
the Office of Strategic Initiatives (OSI), the Office 
of Acquisitions (OA), and the Office of Information 
Technology (OIT)—will focus on providing organiza-
tional and infrastructure improvements necessary to 
advance the Commission’s mission. The SEC is also 
extremely mindful of its responsibility to maximize the 
impact of public funds. In FY 2017, the agency met or 
exceeded 17 and did not meet two performance targets 
in Strategic Goal 4. During FY 2019, the agency 
will continue to focus on recruiting, developing, and 
retaining high-performing staff with current market 
expertise. Furthermore, the SEC will continue to 
strengthen internal controls. The agency is requesting 
a total of $274.9 million and 745 FTEs in FY 2019 to 
achieve results in Strategic Goal 4.
Strategic Objective 4.1: The SEC promotes a results- 
oriented work environment that attracts, engages,  
and retains a technically proficient and diverse work-
force, including leaders who provide motivation and 
strategic direction.
Goal Leader(s): Director, Office of Human Resources; 
Director, Office of Minority and Women Inclusion
PERFORMANCE GOAL 4.1.1 
Turnover 
Description: When employee morale and engagement are high, high-performing employees tend to remain in the organization. Although 
turnover can fluctuate based on a variety of factors, the SEC aims to keep its turnover rate relatively low, below eight percent per year.
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017 
Plan
FY 2017 
Actual
FY 2018 
Estimate
FY 2019 
Estimate
Percentage turnover6.58%6.58%5.60%6.20%3.61%<8.00%4.61%<8.00%<8.00%
Target: Met
Analysis: The agency’s results were within target. The two main sources of attrition in FY 2017 were employees leaving the SEC for 
private sector employment (approximately 45 percent of SEC losses) or retiring (approximately 40 percent of SEC losses). 
Responsible Division/Office: Office of Human Resources
Data Source: Interior Business Center

120   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
PERFORMANCE GOAL 4.1.2 
Expanding staff expertise 
Description: Internal training and hiring programs are designed to help the agency recruit and develop a diverse and qualified staff with 
the key skills, industry knowledge, and expertise to support the SEC mission. In particular, there is a need to train examiners, attorneys, 
economists, and other experts for subject matter expertise relevant to the marketplace and investment and trading practices. This metric 
tracks whether certain areas requiring significant training are being addressed. The agency will track the number of SEC staff participants in 
mission-focused training and development programs and will report on specific items through the use of post-course evaluations to assess 
the impact and results of this training on a five-point scale.
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017 
Plan
FY 2017 
Actual
FY 2018 
Estimate
FY 2019 
Estimate
Mission-focused training attendance
Prior-year data  
not available
16,27017,09317,27316,00026,25216,00016,000
Post-course evaluations of mission- 
focused training
Prior-year data  
not available
4.144.244.334.304.324.304.30
Target: Mission-focused training attendance – Exceeded; Post-course evaluations of mission-focused training – Exceeded
Analysis: The metric tracks instructor led training, for which the agency’s results exceeded the target goal for FY 2017 by 64 percent. 
Beginning in FY 2016 and continuing in FY 2017, the agency also began offering more training virtually to enhance the accessibility of 
real-time training and reduce costs associated with classroom-based training. During FY 2017, the agency had over 55,000 instances of 
virtual training, an increase of approximately 12,000 instances. 
Responsible Division/Office: Office of Human Resources
Data Source: Course Attendance Identified in LEAP (Instructor-led courses only) and End of Course Evaluation Report Summary 
provided by Metrics that Matter 
PERFORMANCE GOAL 4.1.3 
Number of diversity-related partnerships/alliances 
Description: Increased numbers of diversity-related partnerships or alliances with professional associations and educational organizations 
provides additional opportunities to educate students about the SEC’s work and to recruit career professionals from all segments of society. 
The SEC will track the number of partnerships and/or alliances with diverse professional associations and educational organizations. 
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017 
Plan
FY 2017 
Actual
FY 2018 
Estimate
FY 2019 
Estimate
Number of partnerships/alliances121318181820202020
Target: Met
Analysis: In FY 2017, OMWI met the performance target of 20. The office established 2 new partnerships during the fiscal year and 
intends to maintain 20 partnerships moving forward. 
Responsible Division/Office: Office of Minority and Women Inclusion
Data Source: Office of Minority and Women Inclusion Internal Records and Section 342 of DFA

FY 2017 ANNUAL PERFORMANCE REPORT AND FY 2019 ANNUAL PERFORMANCE PLAN   |   121
PERFORMANCE GOAL 4.1.4 
Survey rankings  
Description: Annual and other rankings, together with other metrics and indicators of federal government agencies will be used as one 
kind of metric to determine the SEC’s overall success in improving employee morale and employee engagement.
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017 
Plan
FY 2017 
Actual
FY 2018 
Estimate
FY 2019 
Estimate
Best Places to Work ranking
Ranked  
#19
Ranked 
#15
Ranked 
#14
Ranked 
#10
Ranked 
#6
Ranked 
#5
Ranked 
#5
Ranked 
#5
Ranked 
#5 
Average of employee engagement 
and global satisfaction index
Prior-year data 
not available
61%66%68%75%75%77%80%81%
Target: Best Places to Work ranking – Met; Average of satisfaction index – Exceeded
Analysis: In 2017, the SEC moved up one spot and now ranks #5 in the mid-size agency category. 
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 OPM and Average of Employee Engagement and Global Satisfaction Index from OPM EVS
PERFORMANCE GOAL 4.1.5 
Bench strength
1
  
Description: To maintain mission effectiveness, it is essential that attrition in the leadership ranks is quickly addressed by having a highly-
qualified and diverse pool of internal candidates ready to assume those critical roles. This metric is calculated as an average ratio of the 
number of qualified internal candidates for key leadership positions. 
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017 
Plan
FY 2017 
Actual
FY 2018 
Estimate
FY 2019 
Estimate
Percentage
Prior-year data  
not available
68%149%266%280%366%300%300%
Target: Exceeded
Analysis: The agency has recently placed a greater emphasis on focused leadership development cohort programs such as Aspiring 
Leaders and Leadership Development for our SK-14, SK-15, SK-16, and SK-17 employees. This increases our bench strength while 
developing cross-group collaboration. 
Responsible Division/Office: Office of Human Resources
Data Source: Course Attendance Identified in LEAP (Instructor-led courses only) and End of Course Evaluation Report Summary 
provided by Metrics that Matter 
1				Percentage	equals	the	number	of	SK	14–17	staff	with	significant	leadership	development	divided	by	the	number	of	senior	officer	positions	typically	filled	 
by	internal	staff.

122   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
Strategic Objective 4.2: The SEC encourages a collab-
orative environment across divisions and offices and 
leverages technology and data to fulfill its mission more 
effectively and efficiently. 
Goal Leader(s): Director, Office of Information  
Technology 
PERFORMANCE GOAL 4.2.1 
Ensure SEC’s systems and applications are available 
Description: The SEC aims to enhance its computing infrastructure to eliminate downtime if systems at one site fail, among other 
objectives. This metric will capture the percentage of systems and applications that can fail over within 8 hours.
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017 
Plan
FY 2017 
Actual
FY 2018 
Estimate
FY 2019 
Estimate
Percentage of servers virtualized79%93%95%95%95%95%91%95%95%
Percentage fail over within 8 hoursPrior-year data  
not available
100%100%100%100%100%100%100%
Target: Percentage of servers virtualized – Not Met; Percentage fail over within 8 hours – Met
Analysis: OIT continues to leverage virtualization technologies for the SEC’s computing infrastructure. Virtual servers are considered the 
standard for all server builds. Dedicated physical server use requires CIO approval and remained under 5 percent. 
Responsible Division/Office: Office of Information Technology
Data Source: OIT Network Operations Center (NOC) – automated network monitoring tools
PERFORMANCE GOAL 4.2.2 
Equip the SEC with an enhanced technology infrastructure to support enterprise infrastructure
Description: The SEC aims to promote collaboration and information sharing across the enterprise. To improve efficiency and knowledge 
management, the SEC will consolidate and centralize its collaborative technologies to a commonly used enterprise set by 2020. This metric 
will measure the percentage of the SEC’s offices and divisions that utilize centralized enterprise collaboration solutions.
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017 
Plan
FY 2017 
Actual
FY 2018 
Estimate
FY 2019 
Estimate
Number of enterprise solutions25%30%35%40%45%45%45%45%45%
Target: Met
Analysis: Enterprise solutions are leveraged across SEC offices and divisions, but higher percentages for this metric will require 
consolidation of related capabilities within the office and divisions. 
Responsible Division/Office: Office of Information Technology
Data Source: Approved software applications list

FY 2017 ANNUAL PERFORMANCE REPORT AND FY 2019 ANNUAL PERFORMANCE PLAN   |   123
PERFORMANCE GOAL 4.2.3 
Expand the SEC’s video teleconferencing (VTC) capabilities to support  
an increasing geographically dispersed workforce
Description: The SEC seeks to develop a state of the art video teleconference solution that allows users to conduct a video/
teleconference meeting between HQ, regional offices, and multiple endpoints simultaneously; collaborate and share presentation materials; 
and use VoIP technology to host video teleconferences from their offices/workspaces with other SEC users or conference rooms. This 
metric will measure the average “uptime” or availability of all VTC systems.
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017 
Plan
FY 2017 
Actual
FY 2018 
Estimate
FY 2019 
Estimate
Availability rate for  
VTC solutions
Prior-year data  
not available
80.00%99.99%99.99%99.99%99.99%99.99%99.99%99.99%
Target: Met
Analysis: VTC services are leveraged across the SEC. Their high availability is attributed to the SEC’s investments in better technology, 
documented procedures, and training. 
Responsible Division/Office: Office of Information Technology
Data Source: Telecommunications monitoring system
PERFORMANCE GOAL 4.2.4 
Pursue continuous technology cost reductions and efficiencies
Description: Recent technology enhancements—e.g., data center consolidation, virtualization, and maintenance contract reductions—are 
producing technical efficiencies and cost savings. This metric will measure the amount of these costs savings.
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017 
Plan
FY 2017 
Actual
FY 2018 
Estimate
FY 2019 
Estimate
Percent reduction in opera-
tional run cost leveraging 
technology and process 
efficiencies
Prior-year 
data not 
available
18.70% 1.00% 1.00% 1.00% 1.00% 1.00% 1.00% 1.00%
Target: Met
Analysis: OIT has implemented a strategic initiative, the Steady State Cost Reduction Plan, to review all Steady State project costs. 
This plan has both short- and long-term objectives as well as business impact assessments. This effort is SEC-wide, with a focus on 
leveraging market data to capture significant improvements during contract negotiations. 
Responsible Division/Office: Office of Information Technology
Data Source: OIT Network Operations Center (NOC)

124   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
PERFORMANCE GOAL 4.2.5 
Enhance the SEC’s enterprise data warehouse infrastructure and performance
Description: The Enterprise Data Warehouse (EDW) infrastructure will enable the provisioning of data to Commission staff for search and 
analysis through a virtual data warehouse platform. This metric will measure the availability of EDW and data sources.
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017 
Plan
FY 2017 
Actual
FY 2018 
Estimate
FY 2019 
Estimate
Availability rate for the EDW 
infrastructure components  
in production
Prior-year data  
not available
99%99%99%99%99%99%99%
Target: Met
Analysis: EDW services are leveraged across the SEC. Availability is attributed to the use of redundant clustered servers, improved 
procedures, and training. 
Responsible Division/Office: Office of Information Technology
Data Source: OIT Network Operations Center (NOC) – automated network monitoring tools
Strategic Objective 4.3: The SEC maximizes the use 
of agency resources by continually improving agency 
operations and bolstering internal controls. 
Goal Leader(s): Chief Financial Officer; Chief  
Operating Officer
PERFORMANCE GOAL 4.3.1 
Financial audit results
Description: Under the Accountability of Taxpayer Dollars Act of 2002, the agency is required to meet all proprietary and budgetary 
accounting guidelines for federal agencies and to undergo annual audits. The SEC’s audits are conducted by the Government 
Accountability Office.
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017 
Plan
FY 2017 
Actual
FY 2018 
Estimate
FY 2019 
Estimate
Unqualified opinionYe sYe sYe sYe sYe sYe sYe sYe sYe s
Material weakness000000000
Significant deficiency211000000
Target: Unqualified opinion – Met; Material weakness – Met; Significant deficiency – Met
Analysis: In FY 2017, the Government Accountability Office (GAO) released an unmodified opinion on SEC’s financial statements and 
internal controls over financial reporting in which no significant issues were identified. This sustained achievement underscores SEC’s 
commitment to sound financial management and our high standards of accountability, transparency, and ethics. 
Responsible Division/Office: Office of Financial Management
Data Source: GAO’s Independent Auditor’s Report in the FY 2017 SEC Agency Financial Report

FY 2017 ANNUAL PERFORMANCE REPORT AND FY 2019 ANNUAL PERFORMANCE PLAN   |   125
PERFORMANCE GOAL 4.3.2 
Assurance statement on internal control over operations
Description: In accordance with OMB A-123 and Section 961 of the Dodd-Frank Act, the SEC conducts an annual assessment of 
the effectiveness of internal controls. The SEC will continue to develop its Operational Risk program and enhance cross-organizational 
processes to support all division and office management assurance statements. Success is measured by the quality of risk and control 
assessments and management self-identification and resolution of improvement opportunities.
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017 
Plan
FY 2017 
Actual
FY 2018 
Estimate
FY 2019 
Estimate
Unmodified opinionYe sYe sYe sYe sYe sYe sNoYe sYe s
Material weakness000000100
Target: Unmodified opinion – Not Met; Material weakness – Exceeded
Analysis: For FY 2017, the SEC did not provide an unmodified opinion on its internal control over operations. A material weakness 
related to cybersecurity risks was identified. 
Plan for Improving Program Performance: The SEC is proactively working to address and mitigate these deficiencies in FY 2018, 
which includes taking steps to improve communication and escalation protocols and enhance the information security of the Electronic 
Data Gathering, Analysis, and Retrieval (EDGAR) system.
Responsible Division/Office: Office of the Chief Operating Officer
Data Source: SEC Financial Audit Report
PERFORMANCE GOAL 4.3.3 
Timely completion of corrective action on Office of Inspector General (OIG)  
and the GAO audit recommendations
Description: Timely completion of audit recommendations is an important SEC priority. This metric measures how well the Commission is 
doing in completing corrective action on OIG audit recommendations within established timeframes.
Fiscal YearFY 2012FY 2013FY 2014FY 2015FY 2016
FY 2017 
Plan
FY 2017 
Actual
FY 2018 
Estimate
FY 2019 
Estimate
OIG recommendations  
completed in less than  
one year
Prior-year data 
not available
78%76%74%67%75%86%75%75%
Target: Exceeded
Analysis: In FY 2017, the SEC completed 86 percent of corrective actions on OIG and GAO audit recommendations on time. 
Responsible Division/Office: Office of the Chief Operating Officer
Data Source: Audit Management System (Archer) 

Appendices
Appendix A: Divisions and Offices ............................................................................................................129
Appendix B: Verification and Validation of Performance Data
 ..............................................132
Appendix C: SEC’s Responses to Government Accountability Office Reports
 ..........133



APPENDICES  |   129
APPENDIX A: DIVISIONS AND OFFICES
Headquarters
DIVISION OF CORPORATION FINANCE
William Hinman, Director
(202) 551-3100
DIVISION OF ECONOMIC AND RISK ANALYSIS
Jeffrey Harris, Director
(202) 551-6600
DIVISION OF ENFORCEMENT
Stephanie Avakian, Co-Director
Steven Peikin, Co-Director 
(202) 551-4500
DIVISION OF INVESTMENT MANAGEMENT
Dalia Blass, Director
(202) 551-6720
DIVISION OF TRADING AND MARKETS
Brett Redfearn, Director  
(202) 551-5500
OFFICE OF ACQUISITIONS
Vance Cathell, Director 
(202) 551-7300
OFFICE OF ADMINISTRATIVE LAW JUDGES
Brenda P. Murray, Chief Administrative Law Judge 
(202) 551-6030
OFFICE OF THE CHIEF ACCOUNTANT
Wesley Bricker, Chief Accountant
(202) 551-5300
OFFICE OF THE CHIEF OPERATING OFFICER
Kenneth A. Johnson, Chief Operating Officer
(202) 551-2200
OFFICE OF COMPLIANCE INSPECTIONS  
AND EXAMINATIONS 
Peter Driscoll, Director
(202) 551-6200
OFFICE OF CREDIT RATINGS
Jessica Kane, Acting Director 
(212) 336-9080
OFFICE OF EQUAL EMPLOYMENT OPPORTUNITY
Peter Henry, Acting Director
(202) 551-6040
OFFICE OF THE ETHICS COUNSEL
Shira Pavis Minton, Ethics Counsel/ 
Designated Agency Ethics Official
(202) 551-5170
OFFICE OF FINANCIAL MANAGEMENT
Caryn Kauffman, Acting Chief Financial Officer 
(202) 551-7840
OFFICE OF THE GENERAL COUNSEL
Robert Stebbins, General Counsel 
(202) 551-5100
OFFICE OF HUMAN RESOURCES
Lacey Dingman, Chief Human Capital Officer 
(202) 551-7500
OFFICE OF INFORMATION TECHNOLOGY
Pamela Dyson, Director/Chief Information Officer 
(202) 551-8800
OFFICE OF INSPECTOR GENERAL
Carl W. Hoecker, Inspector General 
(202) 551-6061

130   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
OFFICE OF INTERNATIONAL AFFAIRS
Paul A. Leder, Director
(202) 551-6690
OFFICE OF THE INVESTOR ADVOCATE
Rick Fleming, Investor Advocate 
(202) 551-3302
OFFICE OF INVESTOR EDUCATION AND 
ADVOCACY
Lori Schock, Director
(202) 551-6500
OFFICE OF LEGISLATIVE AND  
INTERGOVERNMENTAL AFFAIRS 
Bryan Wood, Director
(202) 551-2010
OFFICE OF MINORITY AND  
WOMEN INCLUSION 
Pamela A. Gibbs, Director 
(202) 551-6046
OFFICE OF MUNICIPAL SECURITIES
Rebecca Olsen, Acting Director 
(202) 551-5680
OFFICE OF PUBLIC AFFAIRS
John Nester, Director 
(202) 551-4120
OFFICE OF THE SECRETARY
Brent Fields, Secretary 
(202) 551-5400
OFFICE OF STRATEGIC INITIATIVES
Mark Ambrose, Director
(202) 551-8600
OFFICE OF SUPPORT OPERATIONS
Barry Walters, Director/Chief FOIA Officer
(202) 551-8400
Note:	 As	required	by	the	SEC	Small	Business	Advocate	Act,	the	agency	created	the	Office	of	the	Advocate	for	Small	Business	 
Capital	Formation	in	FY	2017.	This	office	will	be	staffed	in	FY	2018.	

APPENDICES  |   131
Regional Offices
ATLANTA REGIONAL OFFICE
Richard Best, Regional Director 
950 East Paces Ferry Road NE, Suite 900
Atlanta, GA 30326
(404) 842-7600
email: [email protected]
BOSTON REGIONAL OFFICE
Paul Levenson, Regional Director 
33 Arch Street, 24th Floor
Boston, MA 02110
(617) 573-8900
email: [email protected]
CHICAGO REGIONAL OFFICE
Robert J. Burson, Acting Regional Director
Jane E. Jarcho, Acting Regional Director 
175 W. Jackson Boulevard, Suite 900 
Chicago, IL 60604
(312) 353-7390
email: [email protected]
DENVER REGIONAL OFFICE
Julie K. Lutz, Regional Director 
1961 Stout Street, Suite 1700 
Denver, CO 80294
(303) 844-1000
email: [email protected]
FORT WORTH REGIONAL OFFICE
Shamoil Shipchandler, Regional Director
Burnett Plaza
801 Cherry Street
Suite 1900, Unit 18 
Fort Worth, TX 76102 
(817) 978-3821 
email: [email protected]
LOS ANGELES REGIONAL OFFICE
Michele Wein Layne, Regional Director 
444 South Flower Street, Suite 900 
Los Angeles, CA 90071
(323) 965-3998
email: [email protected]
MIAMI REGIONAL OFFICE
Eric I. Bustillo, Regional Director 
801 Brickell Avenue, Suite 1800 
Miami, FL 33131
(305) 982-6300
email: [email protected]
NEW YORK REGIONAL OFFICE
Marc P. Berger, Regional Director 
Brookfield Place
200 Vesey Street, Suite 400
New York, NY 10281
(212) 336-1100
email: [email protected]
PHILADELPHIA REGIONAL OFFICE
G. Jeffrey Boujoukos, Regional Director 
One Penn Center
1617 John F. Kennedy Boulevard 
Suite 520
Philadelphia, PA 19103
(215) 597-3100
email: [email protected]
SALT LAKE REGIONAL OFFICE
Dan Wadley, Acting Regional Director 
351 S. West Temple Street
Suite 6.100
Salt Lake City, UT 84101
(801) 524-5796
email: [email protected]
SAN FRANCISCO REGIONAL OFFICE
Jina L. Choi, Regional Director
44 Montgomery Street, Suite 2800 
San Francisco, CA 94104
(415) 705-2500
email: [email protected]

132   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
APPENDIX B: VERIFICATION AND 
VALIDATION OF PERFORMANCE DATA
The SEC’s programs require accurate data to properly 
assess program performance and make good manage-
ment 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 performance 
procedures documentation. Data validation follows 
the data verification process in an effort to ensure that 
performance data are 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 perfor-
mance goal calculations; and 
• The sources of the underlying data elements.
(3) The divisions and offices calculate and report 
the performance goals to the Office of Financial 
Management, and the performance goals are 
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 C: SEC’S RESPONSES TO 
GOVERNMENT ACCOUNTABILITY OFFICE 
REPORTS
This appendix provides the SEC’s responses to Government Accountability Office (GAO) reports that 
included recommendations for the agency head.
The following are examples of letters that were sent to each appropriate committee.

134   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
GAO Report: “Telecommunications: Agencies Need to Apply Transition Planning Practices to 
Reduce Potential Delays and Added Costs” (GAO-17-464, dated September 21, 2017)

APPENDICES  |   135
GAO Report: “Telecommunications: Agencies Need to Apply Transition Planning Practices to 
Reduce Potential Delays and Added Costs” (GAO-17-464, dated September 21, 2017) (continued)

136   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
GAO Report: “Telecommunications: Agencies Need to Apply Transition Planning Practices to 
Reduce Potential Delays and Added Costs” (GAO-17-464, dated September 21, 2017) (continued)

APPENDICES  |   137
GAO Report: “Telecommunications: Agencies Need to Apply Transition Planning Practices 
to Reduce Potential Delays and Added Costs” (GAO-17-464, dated September 21, 2017)

138   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
GAO Report: “Telecommunications: Agencies Need to Apply Transition Planning Practices to 
Reduce Potential Delays and Added Costs” (GAO-17-464, dated September 21, 2017) (continued)

APPENDICES  |   139
GAO Report: “Telecommunications: Agencies Need to Apply Transition Planning Practices to 
Reduce Potential Delays and Added Costs” (GAO-17-464, dated September 21, 2017) (continued)

140   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
GAO Report: “Telecommunications: Agencies Need to Apply Transition Planning Practices 
to Reduce Potential Delays and Added Costs” (GAO-17-464, dated September 21, 2017)

APPENDICES  |   141
GAO Report: “Telecommunications: Agencies Need to Apply Transition Planning Practices to 
Reduce Potential Delays and Added Costs” (GAO-17-464, dated September 21, 2017) (continued)

142   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
GAO Report: “Telecommunications: Agencies Need to Apply Transition Planning Practices to 
Reduce Potential Delays and Added Costs” (GAO-17-464, dated September 21, 2017) (continued)

APPENDICES  |   143
GAO Report: “Telecommunications: Agencies Need to Apply Transition Planning Practices to 
Reduce Potential Delays and Added Costs” (GAO-17-464, dated September 21, 2017)

144   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
GAO Report: “Telecommunications: Agencies Need to Apply Transition Planning Practices to 
Reduce Potential Delays and Added Costs” (GAO-17-464, dated September 21, 2017) (continued)

APPENDICES  |   145
GAO Report: “Telecommunications: Agencies Need to Apply Transition Planning Practices to 
Reduce Potential Delays and Added Costs” (GAO-17-464, dated September 21, 2017) (continued)

146   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
GAO Reports: “Information Security: SEC Improved Control of Financial Systems but 
Needs to Take Additional Actions” (GAO-17-469 and GAO-17-429SU, dated July 27, 2017)

APPENDICES  |   147
GAO Reports: “Information Security: SEC Improved Control of Financial Systems but Needs to 
Take Additional Actions” (GAO-17-469 and GAO-17-429SU, dated July 27, 2017) (continued)

148   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
GAO Reports: “Information Security: SEC Improved Control of Financial Systems but Needs to 
Take Additional Actions” (GAO-17-469 and GAO-17-429SU, dated July 27, 2017)

APPENDICES  |   149
GAO Reports: “Information Security: SEC Improved Control of Financial Systems but Needs to 
Take Additional Actions” (GAO-17-469 and GAO-17-429SU, dated July 27, 2017) (continued)

150   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
GAO Report: "Federal Telework: Additional Controls Could Strengthen Telework Program 
Compliance and Data Reporting” (GAO-17-247, dated March 20, 2017)

APPENDICES  |   151
GAO Report: "Federal Telework: Additional Controls Could Strengthen Telework Program 
Compliance and Data Reporting” (GAO-17-247, dated March 20, 2017) (continued)

152   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION
GAO Report: "Federal Telework: Additional Controls Could Strengthen Telework Program 
Compliance and Data Reporting” (GAO-17-247, dated March 20, 2017)

APPENDICES  |   153
GAO Report: "Federal Telework: Additional Controls Could Strengthen Telework Program 
Compliance and Data Reporting” (GAO-17-247, dated March 20, 2017) (continued)

The SEC’s FY 2019 Congressional Budget 
Justification/Annual Performance Plan and 
FY 2017 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 
[email protected].

U.S. Securities and 
Exchange Commission 
100 F Street NE
Washington, DC 20549
www.sec.gov

U . S .  S E C U R I T I E S  A N D
E XC H A N G E  C O M M I S S I O N

F I S C A L  Y E A R   2 0 1 9

Congressional Budget Justification

Annual Performance Plan

F I S C A L  Y E A R   2 0 1 7

Annual Performance Report

PROTECTING INVESTORS

MAINTAINING FAIR, ORDERLY, AND 
EFFICIENT MARKETS

FACILITATING CAPITAL FORMATION



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

Executive Summary..................................................................................................................................................................................... 3
Mission, Vision, Values, and Goals.................................................................................................................................................... 7
History and Purpose....................................................................................................................................................................................9
Organizational Structure and Resources...................................................................................................................................10

FY 2019 Budget Request Tables......................................................................................................................................13
Full-Time Equivalents and Positions by Program................................................................................................................15
Obligations by Object Class.................................................................................................................................................................16
Strategic Goal and Program................................................................................................................................................................. 17
Request Summary of Changes.........................................................................................................................................................18

FY 2019 Appropriations Language.................................................................................................................................19

FY 2019 Budget Request by Program..........................................................................................................................21

Other Information...................................................................................................................................................................... 81
Risks, Internal Controls, and Management Challenges.................................................................................................83
Cross-Agency Collaboration..............................................................................................................................................................87
Evidence Building........................................................................................................................................................................................91
Links to Additional Information and Resources .................................................................................................................. 92

FY 2017 Annual Performance Report (APR) and 
FY 2019 Annual Performance Plan (APP)..................................................................................................................93

A Reader’s Guide to SEC Performance Information.........................................................................................................95
FY 2017 APR and FY 2019 APP Summary.................................................................................................................................95
Performance Summary by Strategic Goal and Strategic Objective.....................................................................96

Strategic Goal 1:	 Establish and Maintain an Effective Regulatory Environment..........................96
Strategic Goal 2:	 Foster and Enforce Compliance with Federal Securities Laws..................... 103
Strategic Goal 3:	 Facilitate Access to the Information Investors Need to Make 

Informed Investment Decisions .............................................................................................114
Strategic Goal 4:	 Enhance the Commission’s Performance through Effective 

Alignment and Management of Human, Information, and 
Financial Capital..................................................................................................................................119

Appendices..................................................................................................................................................................................127
Appendix A:  Divisions and Offices..............................................................................................................................................129
Appendix B:  Verification and Validation of Performance Data.............................................................................. 132
Appendix C:  SEC’s Responses to Government Accountability Office Reports......................................... 133



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) 2019 and the Annual Performance Report 
(APR) for FY 2017, 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.

•	 GPRA Modernization Act of 2010
•	 Office of Management and Budget Circular A-11, Preparation, Submission,  

and Execution of the Budget
•	 Government Management Reform Act of 1994 
•	 Reports Consolidation Act of 2000 
•	 Office of Management and Budget Circular A-136, Financial Reporting Requirements

An electronic version of this document and its components is available at www.sec.gov/about/
offices/ofm/ofm-documents.htm. To comment on the SEC’s FY 2019 CBJ and APP and FY 2017 
APR, email [email protected]. 



Agency and Mission 
Information
Executive Summary..................................................................................................................................................3

Mission, Vision, Values, and Goals...................................................................................................................7

History and Purpose................................................................................................................................................ 9

Organizational Structure and Resources................................................................................................10





AGENCY AND MISSION INFORMATION   |   3

EXECUTIVE SUMMARY

The U.S. Securities and Exchange Commission (SEC) 
is pleased to submit its budget request for fiscal year 
(FY) 2019. The SEC is requesting $1.658 billion in 
support of 4,628 positions and 4,457 full-time equiva-
lents (FTE). These expenses will be offset by matching 
collections of fees on securities transactions. 

The FY 2019 budget request level is a 3.5 percent 
increase over the FY 2018 budget request of $1.602 
billion. This level is necessary for the SEC to continue 
the effective pursuit of its mission to protect investors, 
maintain fair, orderly, and efficient markets, and facil-
itate capital formation. The FY 2019 budget request 
also assumes the SEC will have continued access to 
the Commission’s Reserve Fund to fund information 
technology improvements, including cybersecurity. 
Because this funding is assured, the Reserve Fund 
allows the SEC to commit to important, long-term 
technology initiatives that otherwise would be more 
difficult to execute due to funding uncertainties.

The SEC’s broad mission covers a lot of ground. We 
oversee approximately $75 trillion in securities trading 
annually on U.S. equity markets and the activities of 
over 26,000 registered market participants, including 
investment advisers, mutual funds, exchange-traded 
funds (ETF), broker-dealers, and transfer agents. We 
also engage and interact with the investing public on a 
daily basis through a number of activities ranging from 
our investor education programs to alerts on SEC.gov. 
We also provide critical market services through our 
information technology (IT) systems. On a typical  
day, investors and other market participants access 
more than 50 million pages of disclosure documents  
through the Electronic Data Gathering, Analysis,  
and Retrieval (EDGAR) system. The agency also 

oversees 21 national securities exchanges, 10 credit 
rating agencies, and seven active registered clearing 
agencies, as well as the Public Company Account-
ing Oversight Board (PCAOB), Financial Industry 
Regulatory Authority (FINRA), 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 selectively 
reviewing the disclosures and financial statements of 
over 8,000 reporting companies, of which approx-
imately 4,100 are exchange listed. Of the top 100 
public companies in the world, 78 fall under the SEC’s 
reporting requirements.

The SEC’s annual appropriation has remained essen-
tially flat since FY 2016 at a level of approximately 
$1.6 billion. To stay within this level, the SEC imposed 
a hiring freeze at the start of FY 2017 that will 
continue throughout FY 2018. The agency permits 
few exceptions to the hiring freeze and, consequently, 
the overall staffing level is declining and is expected to 
drop to 4,528 positions by the end of FY 2018. 

This budget request seeks to restore 100 positions to 
address critical priority areas and enhance the agency’s 
expertise in key areas. This represents approximately 
one-quarter of the positions lost in the hiring freeze. 
This budget request also aims to leverage technology 
and data to extend the agency’s capabilities, improve 
its cyber risk profile, and further enable the SEC to 
manage the massive amounts of data submitted to 
us. Finally, the request seeks funding to support the 
procurement of a new lease for the New York Regional 
Office by the General Services Administration (GSA).

www.sec.gov


4   |  FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

The SEC’s funding is deficit-neutral, which means any 
amount appropriated to the agency will be offset by 
transaction fees.

The following sections highlight the agency’s key 
priorities for FY 2019.

Cybersecurity and Risk Management
The FY 2019 request would support key enhancements 
to the agency’s program to protect the security of its 
network, systems, and sensitive data. The FY 2019 
request would provide four additional staff positions to 
enable the SEC to expand its cybersecurity protections, 
particularly with regard to incident management and 
response, advanced threat intelligence monitoring, 
and enhanced database and system security. These 
additional positions would be information system 
security officers who can focus on the security of 
specific systems or programs. 

The SEC is taking action in FY 2018 to establish a 
new chief risk officer position to oversee the agency’s 
enterprise risk program. The FY 2019 request would 
permit the agency to hire two additional staff positions 
under the chief risk officer to strengthen and advance 
the agency’s risk management capabilities.

Facilitating Capital Formation 
The FY 2019 request would enable us to expand 
the SEC’s new, statutorily-mandated Office of the 
Advocate for Small Business Capital Formation. The 
office’s mission is to be a resource and voice for small 
businesses and small business investors by providing 
assistance, conducting outreach to better understand 
their concerns, and making recommendations to 
the Commission and Congress regarding potential 
improvements to the regulatory environment. We are 
in the process of hiring an advocate to oversee the 
establishment of the office and, as part of our FY 2019 
request, we plan to expand its staffing to a total of six 
positions. The FY 2019 request would also support 

expenses for the operation of a new Small Business 
Capital Formation Advisory Committee, which will  
be established in FY 2018 following the selection of  
an advocate.

The resources provided by the FY 2019 request would 
also enable the Division of Corporation Finance to 
assist hundreds of companies that seek to “go public” 
through an initial public offering, or to raise capital 
through follow-on or exempt offerings and to imple-
ment important capital formation initiatives. 

Protecting Main Street Investors  
and Our Markets
A vigorous enforcement program is among the most 
powerful tools used by the SEC in its efforts to protect 
investors. The FY 2019 request would restore 17 
positions for the Division of Enforcement (ENF)
to support key enforcement priorities and provide 
resources to support and expand the work of two new 
groups: The Cyber Unit, which is focused on bringing 
enforcement actions against cyber-related misconduct; 
and the Retail Strategy Task Force, which is focused on 
developing enforcement initiatives to identify miscon-
duct, including broad market misconduct that impacts 
retail investors.

The National Examination Program (NEP) is another 
key area through which the SEC works directly to 
protect the interests of retail investors. Registered 
investment advisers today manage more than $70 
trillion in investor assets—triple the amount from 
15 years ago. Our examination program monitors 
whether money managers handling retail customer 
funds are complying with SEC rules, and also protects 
against fraud. The FY 2019 request would restore 24 
positions within NEP, including six additional staff 
for its Technology Controls Program, which monitors 
critical securities market infrastructure for significant 
cyber events and outages.



AGENCY AND MISSION INFORMATION   |   5

The FY 2019 request would also restore seven staff 
positions within the Division of Investment Manage-
ment (IM), which plays a critical role in protecting 
retail investors through its regulation of mutual funds, 
variable insurance products, and ETFs, among other 
products. IM has a need to recruit professionals with 
specialized expertise in critical areas, including private 
funds, cybersecurity, fund accounting, and quantitative 
analytics. The resources would be used to enhance  
IM’s monitoring and disclosure programs, as well as 
advance key investor-focused rule-writing priorities, 
such as standards of conduct for investment  
professionals.

Effective Oversight of Changing Markets
Over the last decade, technological advancements 
and commercial developments have led to significant 
changes in how our security markets operate. The 
Division of Trading and Markets (TM) plays a critical 
front-line role in ensuring fair, orderly, and efficient 
markets through its work to regulate the major 
securities market participants. The FY 2019 request 
would allow TM to recruit 16 additional professionals 
to expand the agency’s depth of expertise in vital  
areas such as market insight and analysis, clearing 
agencies, broker-dealer operations, cybersecurity, 
electronic trading, and fixed income markets.  
Because technology and markets are changing so 
rapidly, staying current with market trends and  
developments is essential to the SEC’s ability to  
remain an effective regulator.

The FY 2019 request would also provide resources to 
continue the work of the agency’s new Fixed Income 
Market Structure Advisory Committee (FIMSAC) and 
its important work to evaluate and take appropriate 
measures to enhance the efficiency, transparency, and 
effectiveness of fixed income markets. 

Leveraging Technology, Data, and Analytics
The SEC has made progress in modernizing its 
technology systems, with the benefits of streamlining 
operations, increasing our use of data analytics and the 
effectiveness of our programs. 

Recently, the SEC’s ability to continue to invest in 
advanced analytic tools or modernize legacy systems 
has been constrained with annual investments in 
IT development, modernization, and enhancement 
projects declining from $100 million in FY 2015 to 
an anticipated $50 million in FY 2018. Additional 
investment in IT is necessary for the SEC to keep pace 
with the rapid technology advancements occurring 
in areas we regulate, including to meet ever-evolving 
cybersecurity challenges. 

In furtherance of the objectives of the SEC’s 2018– 
2020 Technology Strategic Plan, this request seeks an 
additional $45 million to restore funding for technol-
ogy development, modernization, and enhancement 
projects. Together with the support of the SEC Reserve 
Fund, the FY 2019 request would allow the agency  
to continue implementing a number of multi-year  
technology initiatives. 

Uplifting the agency’s cybersecurity program is a top 
priority. The FY 2019 request would support increased 
investment in tools, technologies, and services to 
protect the security of the agency’s network, systems, 
and sensitive data. Priorities for FY 2019 include 
maturation of controls through continuous diagnostics 
and monitoring, and further enhancements to firewall 
technologies. Another way the FY 2019 request helps 
reduce the agency’s cybersecurity risk profile is by 
enabling the funding of multi-year investments to 
transition legacy IT systems to modern platforms  
with improved embedded security features. 



6   |  FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

Other FY 2019 IT modernization priorities include:
• Continuing the development of advanced analytics

solutions that provide new capabilities to detect and
expose suspicious behavior in high frequency trading
and other complex trading areas across markets;

• Improving storage, processing, security, and manage-
ment of large volumes of data, including the agency’s
e-Discovery program, which is approaching one
petabyte of data;

• Modernizing the SEC’s infrastructure and computing
environment to enhance security, improve perfor-
mance, and streamline delivery;

• Improving the SEC’s ability to analyze fixed income
market data;

• Updating selected operational components of the
agency’s legacy EDGAR system to make it easier for
registrants to fulfill their disclosure responsibilities
through the system, for investors to access the
information they need, and for the SEC to operate
and secure the system; and

• Executing a relocation of one of the agency’s current
data centers to achieve operational efficiencies and
support improvements.

These key priorities—many of which are driven by 
changes in our markets—will enhance the SEC’s ability 
to serve the public as well as analyze and act on large 
amounts of data.

Along with increasing the SEC’s use of analytic tools, 
we also anticipate a growing need for professionals 
who are trained in data management and analysis, 
including data scientists, quantitative analysts, and 
financial economists. To this end, the FY 2019 request 
would include four additional positions for the 
Division of Economic and Risk Analysis (DERA) to 
support the agency’s increased analytic needs and add 
depth to DERA’s policy support and risk assessment 
functions, including robust economic analysis. In 
particular, DERA needs expertise in data management, 
risk assessment, structured finance, clearance and 
settlement, investment advice, asset management, and 
fixed income markets.

Real Property Leasing
With the current lease for the SEC’s New York 
Regional Office set to expire in 2021, the FY 2019 
request includes funds required for the GSA procure-
ment of a new lease. As with the SEC’s headquarters’ 
lease procurement in FY 2018, GSA requires that the 
SEC set aside funds in the budget to account for poten-
tial buildout costs in the event that the competitive 
acquisition process results in the New York Regional 
Office needing to move to a new facility. These costs 
are estimated by GSA to be $37 million.1 As with our 
FY 2018 appropriations request, we have proposed 
legislative language assuring that none of these funds 
would be used for the operations of the SEC, and that 
any unused portion would be refunded to fee payers.

1	 This figure has been revised for a new estimate provided to the SEC too late for inclusion in the President’s Budget materials. The President’s Budget 
reflects the previous estimate of $40,750,443.



AGENCY AND MISSION INFORMATION   |   7

MISSION, VISION, VALUES, AND GOALS

MISSION 
The mission of the SEC is to protect investors, 
maintain fair, orderly, and efficient markets, 
and facilitate capital formation.

VISION
The SEC strives to promote a securities  
market that is worthy of the public’s trust and 
characterized by transparency and integrity. 

VALUES
Integrity
Excellence
Accountability

Effectiveness
Teamwork
Fairness



8   |  FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

Strategic Goals and Strategic Objectives of the FY 2014–FY 2018 Strategic Plan
The SEC is in the process of writing a new Strategic Plan for FYs 2018–2022. Pending the 
finalization of that updated plan, the SEC’s current plan remains in effect. 

Strategic Goal 1: Establish and maintain an effective regulatory environment
Strategic Objective 1.1: The SEC establishes and maintains a regulatory environment that promotes 
high-quality disclosure, financial reporting, and governance, and that prevents abusive practices by 
registrants, financial intermediaries, and other market participants.

Strategic Objective 1.2: The SEC promotes capital markets that operate in a fair, efficient, transpar-
ent, and competitive manner, fostering capital formation and useful innovation.

Strategic Objective 1.3: The SEC adopts and administers regulations and rules that are informed by 
robust economic analysis and public comment and that enable market participants to understand 
clearly their obligations under the securities laws.

Strategic Objective 1.4: The SEC engages with a multitude of stakeholders to inform and enhance 
regulatory activities domestically and internationally.

Strategic Goal 2: Foster and enforce compliance with the federal securities laws 
Strategic Objective 2.1: The SEC fosters compliance with the federal securities laws.

Strategic Objective 2.2: The SEC promptly detects and deters violations of the federal securities laws.

Strategic Objective 2.3: The SEC prosecutes violations of federal securities laws and holds violators 
accountable through appropriate sanctions and remedies.

Strategic Goal 3: Facilitate access to the information investors need to make informed 
investment decisions 

Strategic Objective 3.1: The SEC works to ensure that investors have access to high-quality 
disclosure materials that facilitate informed investment decision-making.

Strategic Objective 3.2: The SEC works to understand investor needs and educate investors so they 
are better prepared to make informed investment decisions.

Strategic Goal 4: Enhance the Commission’s performance through effective alignment and 
management of human, information, and financial capital 

Strategic Objective 4.1: The SEC promotes a results-oriented work environment that attracts, 
engages, and retains a technically proficient and diverse workforce, including leaders who provide 
motivation and strategic direction.

Strategic Objective 4.2: The SEC encourages a collaborative environment across divisions and offices 
and leverages technology and data to fulfill its mission more effectively and efficiently.

Strategic Objective 4.3: The SEC maximizes the use of agency resources by continually improving 
agency operations and bolstering internal controls. 



AGENCY AND MISSION INFORMATION   |   9

HISTORY AND PURPOSE

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 invest-

ment 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, the MSRB, 
and the 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. 

We have sought to put forward 
the rule of fair play in finance  
and industry.

—Former President Franklin D. Roosevelt during 
a speech to Congress two days after signing 

the Securities Exchange Act of 1934

Each year, the SEC brings hundreds of civil enforce-
ment actions against individuals and companies for 
violation of securities laws. Examples of infractions 
are insider trading, accounting fraud, market manipu-
lation, 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 compa-
nies and other market participants are required to file 
with the SEC. These can be found at: www.sec.gov/
edgar/searchedgar/companysearch.html.

1	 More information about the Securities Act of 1933 can be found at www.sec.gov/about/laws/sa33.pdf 
2	 More information about the Securities Exchange Act of 1934 can be found at www.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  

www.sec.gov/about/laws/wallstreetreform-cpa.pdf

http://www.Investor.gov
http://www.sec.gov/edgar/searchedgar/companysearch.html
http://www.sec.gov/edgar/searchedgar/companysearch.html
http://www.sec.gov/about/laws/sa33.pdf
http://www.sec.gov/about/laws/sea34.pdf
http://www.sec.gov/about/laws/wallstreetreform-cpa.pdf


10   |  FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

ORGANIZATIONAL STRUCTURE 
AND RESOURCES

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 enforce-

ment 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.

SEC Headquarters

Atlanta Regional Office
Georgia, North Carolina, South Carolina, Tennessee, Alabama

Boston Regional Office
Connecticut, Maine, Massachusetts, New Hampshire, Vermont, Rhode Island

Chicago Regional Office
Illinois, Indiana, Iowa, Kentucky, Michigan, Minnesota, Missouri, Ohio, Wisconsin

Denver Regional Office
Colorado, Kansas, Nebraska, New Mexico, North Dakota, South Dakota, Wyoming

Fort Worth Regional Office
Texas, Oklahoma, Arkansas, Kansas (except for the exam program, which is 
administered by the Denver Regional Office)

Los Angeles Regional Office
Arizona, Hawaii, Guam, Nevada, Southern California (zip codes 93599 and below, except for 93200–93299)

Miami Regional Office
Florida, Mississippi, Louisiana, U.S. Virgin Islands, Puerto Rico

New York Regional Office
New York, New Jersey

Philadelphia Regional Office
Delaware, Maryland, Pennsylvania, Virginia, West Virginia, District of Columbia

Salt Lake Regional Office
Utah

San Francisco Regional Office
Washington, Oregon, Alaska, Montana, Idaho, Northern California (zip codes 93600 and up, plus 93200–93299)

Fort Worth

Chicago

Denver

Salt Lake
Philadelphia

Los Angeles

San Francisco

Miami

Atlanta

New York
Boston

SEC Headquarters

SEC Headquarters and Regional Office Locations



AGENCY AND MISSION INFORMATION   |   11

Organizational Structure 
The SEC is an independent federal agency led by a 
bipartisan, five-member Commission—one of whom 
is designated as the Chairman—with staggered 
five-year terms. 

Each member of the Commission is appointed by  
the President and confirmed by the Senate. The  
Chairman serves as the chief executive and, by law,  
no more than three of the Commissioners may belong 
to the same political party. 

The Commission convenes on a regular basis, and 
meetings are open to the public and the news media 
unless the discussion pertains to a confidential subject, 
such as whether to begin an enforcement investigation. 

The agency’s functional responsibilities are organized 
into five divisions and 25 offices. In FY 2017, the SEC 
employed 4,616 full-time equivalents (FTE). 

The organization chart above is accurate as of 
September 30, 2017.



FY 2019 Budget 
Request Tables
Full-Time Equivalents (FTE) and Positions by Program................................................................ 15

Obligations by Object Class.............................................................................................................................16

Strategic Goal and Program............................................................................................................................. 17

Request Summary of Changes......................................................................................................................18





FY 2019 BUDGET REQUEST TABLES   |   15

FULL-TIME EQUIVALENTS (FTE) AND POSITIONS  
BY PROGRAM

FY 2017
Actuals

FY 2018
Annualized Continuing 

Resolution 1

FY 2019
Request

FTE
Actual 

Positions FTE
Estimated 
Positions FTE

Estimated 
Positions

Enforcement 1,393 1,393 1,373 1,362 1,348 1,379

Compliance Inspections and Examinations 1,063 1,099 1,047 1,062 1,032 1,086

Corporation Finance 461 454 433 435 423 438

Trading and Markets 263 263 248 253 250 269

Investment Management 182 186 176 180 175 187

Economic and Risk Analysis 157 154 147 142 145 146

General Counsel 141 139 134 135 131 135

Other Program Offices

Chief Accountant 49 49 50 44 49 44

Investor Education and Advocacy 43 43 42 41 42 42

International Affairs 55 57 53 53 51 53

Administrative Law Judges 13 14 12 14 12 14

Investor Advocate 11 11 11 10 12 11

Credit Ratings 44 44 41 41 41 43

Municipal Securities 9 10 10 11 10 11

Advocate for Small Business Capital Formation — — 1 1 3 6

Total 224 228 220 215 220 224

Agency Direction and Administrative Support

Executive Staff 28 31 35 32 31 32

Public Affairs 15 22 21 20 21 20

Secretary 24 25 25 24 24 24

Chief Operating Officer 15 14 13 15 14 17

Financial Management 98 98 95 96 93 96

Information Technology 171 175 173 180 177 196

Human Resources 120 113 107 104 105 106

Acquisitions 57 59 56 55 55 55

Support Operations 100 97 94 94 92 94

Strategic Initiatives 15 27 29 28 29 28

Ethics Counsel 18 19 19 18 19 18

Minority and Women Inclusion 9 10 9 9 9 9

Equal Employment Opportunity 14 14 15 15 15 15

Total 684 704 691 690 684 710

Inspector General 48 54 49 54 49 54

Total FTE and Positions 4,616 4,674 4,518 4,528 4,457 4,628

	 		

	 		
				    .

1	 Estimated End of Year Positions for FY 2018 reflect the effects of an agency-wide hiring freeze. The actual impact to individual organizations may vary.



16   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

OBLIGATIONS BY OBJECT CLASS

FY 2017 FY 2018 FY 2019
1Actual Annualized Continuing Request

(DOLLARS IN THOUSANDS) Resolution 2

Personnel Compensation and Benefits

Total Personnel Compensation (11.0) $ 862,458 $ 882,013 $ 879,272

Civilian Personnel Benefits (12.0) 291,468 281,131 280,246

Subtotal Cost of Compensation $ 1,153,926 $ 1,163,145 $ 1,159,518

Other Expenses

Benefits for Former Personnel (13.0) 1,635 30 31

Travel and Transportation of Persons (21.0) 8,961 10,803 11,276

Transportation of Things (22.0) 148 195 199

Rent, Communications, and Utilities (23.0) 32,415 38,057 69,858

Printing and Reproduction (24.0) 7,071 1,892 1,924

Other Contractual Services (25.0) 341,890 322,205 337,173

Supplies and Materials (26.0) 1,695 2,334 2,424

Equipment (31.0) 27,372 16,279 54,407

Building Alterations (32.0) 1,531 4,605 5,597

Claims and Indemnities (42.0) 344 840 854

Subtotal Cost of Other Expenses 423,062 397,241 483,742

Subtotal, Obligations $ 1,576,988 $ 1,560,386 $ 1,643,260

Budget Authority used to Liquidate Prior Obligations for Deficient Leases, 
per an October 3, 2011, Report from the Comptroller General 74,329 70,915 40,042

Total Budget Authority $ 1,651,317 $ 1,631,300 $ 1,683,302

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

Request for SEC Operations $ 1,606,300 $ 1,658,302

Estimate of Potential Buildout Costs Associated with 
New York Regional Office Lease Replacement $ 37,189 3

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 	 FY 2018 Annualized Continuing Resolution does not include estimated amounts for costs associated with the headquarters’ lease replacement.
3	 This figure has been revised for a new estimate provided to the SEC too late for inclusion in the President’s Budget materials. The President’s Budget 

reflects the previous estimate of $40,750,443.



FY 2019 BUDGET REQUEST TABLES   |   17

STRATEGIC GOAL AND PROGRAM

(DOLLARS IN THOUSANDS) FY 2019 Request

SEC Program
FY 2017
Actual 1 

FY 2018 
Annualized 

CR 2

Goal 1
Effective

Regulatory
Environment

Goal 2
Enforce

Securities
Laws

Goal 3
Facilitate
Access To 
Information

Goal 4
Align and
Manage

Resources
FY 2019
Request

Enforcement $ 512,256 $ 505,768 $ 5,317 $ 510,392 $ — $ 15,950 $ 531,659 

Compliance Inspections and  
Examinations 347,273 346,292 3,658 347,491 3,658 10,973 365,781 

Corporation Finance 148,065 144,145 22,590 3,012 109,939 15,060 150,601 

Trading and Markets 85,169 83,708 44,912 22,456 22,456 — 89,824 

Investment Management 59,344 57,742 23,646 16,977 18,796 1,213 60,631 

Economic and Risk Analysis 68,007 72,392 30,032 27,780 10,511 6,757 75,081 

General Counsel 46,855 45,707 9,964 26,095 949 10,438 47,446 

Other Program Offices 81,064 77,761 24,278 29,797 28,636 675 83,386 

Agency Direction and  
Administrative Support 214,457 210,968 6,145 3,027 15,531 197,504 222,207 

Inspector General 14,499 15,903 — 166 166 16,311 16,644 

Subtotal, Obligations $ 1,576,988 $ 1,560,386 $ 170,541 $ 987,195 $ 210,643 $ 274,882 $ 1,643,260 

Budget Authority used to Liquidate 
Prior Obligations for Deficient 
Leases, per an October 3, 2011, 
Report from the Comptroller 
General   74,329  70,915  —  — —  — 40,042  

Budget Authority for  
SEC Operations $ 1,651,317 $ 1,631,300  $ 1,683,302

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

Request for SEC Operations $ 1,606,300  $ 1,658,302  

Potential Buildout Costs Associated 
with New York Regional Office 
Lease Replacement  $ 37,189

’
 3



 

	  	

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	 FY 2018 Annualized Continuing Resolution does not include estimated amounts associated with the headquarters’ lease replacement.
3	 This figure has been revised for a new estimate provided to the SEC too late for inclusion in the President’s Budget materials. The President’s Budget  

reflects the previous estimate of $40,750,443.



18   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

REQUEST SUMMARY OF CHANGES1

 (DOLLARS IN THOUSANDS) Positions FTE Amount

FY 2018 Estimated Continuing Resolution (Annualized) 2 4,528 4,518 $ 1,631,300 

FY 2019 Base Changes 

Net Changes in Compensation Expenses (111) (16,610)

Net Change in Real Property Facilities Costs 1,592 

Non-Compensation Inflation of 1.7% 6,753 

Subtotal, Base Changes — (111) (8,264)

FY 2019 Current Services Level 4,528 4,407 $ 1,623,036

FY 2019 Program Increases 

Restoration of 100 Positions (50 FTE)  

Enforcement 17 8 

Compliance Inspections and Examinations 24 12 

Corporation Finance 3 1 

Trading and Markets 16 8 

Investment Management 7 4 

Economic and Risk Analysis 4 2 

Other Program Offices 9 5 

Agency Direction and Administrative Support 20 10 

          Subtotal, Staffing Increases 100 50 15,266 

Restore Information Technology Development 45,000 

Subtotal, Program Increases 100 50 $ 60,266 

Proposed FY 2019 Obligations for SEC Operations  4,628 4,457 $ 1,683,302 

    Less:  Anticipated Recovery of Prior Fiscal Years Obligations (25,000)

FY 2019 Request for SEC Operations 4,628 4,457 $ 1,658,302 

Estimate of Potential Buildout Costs Associated with  
New York Regional Office Lease Replacement

$ 37,189 3

1	 These figures include amounts in FY 2018 and FY 2019 necessary to liquidate prior obligations on deficient leases.
2	 FY 2018 Annualized Continuing Resolution does not include estimated amounts associated with the headquarters’ lease replacement.
3	 This figure has been revised for a new estimate provided to the SEC too late for inclusion in the President’s Budget materials. The President’s Budget 

reflects the previous estimate of $40,750,443.APPROPRIATIONS LANGUAGE  |   19

FY 2019 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, $1,658,302,366, to remain 
available until expended; of which not less than 
$15,206,269 shall be for the Office of Inspector 
General; of which not to exceed $75,000 shall be 
available for a permanent secretariat for the Interna-
tional 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 admin-
istrative 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 costs 
associated with relocation under a replacement lease 
for the Commission’s New York regional office facili-
ties, not to exceed $37,188,9421, 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 2019, all amounts appropriated 
under this heading shall be deemed to be the regular 
appropriation to the Commission for fiscal year 2019.

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 
$1,658,302,366 of such offsetting collections shall 
be available until expended for necessary expenses of 
this account and not to exceed $37,188,9421 of such 
offsetting collections shall be available until expended 
for costs under this heading associated with relocation 
under a replacement lease for the Commission’s New 
York regional office facilities: Provided further, That 
the total amount appropriated under this heading from 
the general fund for fiscal year 2019 shall be reduced 
as such offsetting fees are received so as to result in 
a final total fiscal year 2019 appropriation from the 
general fund estimated at not more than $0: Provided 
further, That if any amount of the appropriation for 
costs associated with relocation under a replacement 
lease for the Commission’s New York regional office 
facilities is subsequently de-obligated by the Commis-
sion, 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 2019.

1	 This figure has been revised for a new estimate provided to the SEC too late for inclusion in the President’s Budget materials. The President’s Budget 
reflects the previous estimate of $40,750,443.



FY 2019 Budget 
Request by Program
Division of Enforcement......................................................................................................................................23

Office of Compliance Inspections and Examinations.....................................................................27

Division of Corporation Finance.................................................................................................................... 31

Division of Trading and Markets....................................................................................................................33

Division of Investment Management.........................................................................................................37

Division of Economic and Risk Analysis...................................................................................................39

Office of the General Counsel.........................................................................................................................41

Other Program Offices..........................................................................................................................................43

Office of the Chief Accountant....................................................................................................................................45

Office of Investor Education and Advocacy.....................................................................................................47

Office of International Affairs.........................................................................................................................................48

Office of Administrative Law Judges.....................................................................................................................50

Office of the Investor Advocate..................................................................................................................................52

Office of Credit Ratings.....................................................................................................................................................54

Office of Municipal Securities......................................................................................................................................56

Office of the Advocate for Small Business Capital Formation..........................................................58

Agency Direction and Administrative Support...................................................................................59

Agency Direction.................................................................................................................................................................. 60

Office of the Chief Operating Officer......................................................................................................................64

Office of the Ethics Counsel.......................................................................................................................................... 75

Office of Minority and Women Inclusion............................................................................................................76

Office of Equal Employment Opportunity.........................................................................................................78 

Office of Inspector General...............................................................................................................................79





FY 2019 BUDGET REQUEST BY PROGRAM   |   23

DIVISION OF ENFORCEMENT

(DOLLARS IN THOUSANDS)
FY 2017
Actual

FY 2018
Annualized CR

FY 2019
Request

Full-Time Equivalents  1,393  1,373  1,348 

Cost:

Salaries and Benefits $	 349,202 $	 360,495 $	 357,874

Non-Personnel Expenses 163,055 145,274 173,785

Total Costs $	 512,256 $	 505,768 $	 531,659

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

The Division of Enforcement (ENF) is critical to the 
Commission’s ability to fulfill its three-part mission: 
protect investors, maintain fair, orderly, and efficient 
markets, and facilitate capital formation. ENF’s efforts 
to deter misconduct 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, ENF brings hundreds of civil and admin-
istrative enforcement actions against individuals and 
entities for fraud, financial and accounting irregular-
ities and misstatements, and other misconduct. The 
substantial remedies that ENF obtains are meaningful 
and impactful. They deter future wrongdoing, and 
when ENF obtains disgorgement of ill-gotten gains, 
the Commission is often able to return fraudulently 
obtained 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 has a broad mandate with responsibility for 
covering the country’s vast capital markets; however, 
at the most basic level, ENF’s area of greatest focus—  
protection of retail investors—remains constant. Today, 
this priority is driving ENF’s allocation of limited 
resources to risks posed by cyber-related misconduct; 
issues raised by the activities of investment advisers, 
broker-dealers, and other registrants; financial report-
ing and disclosure issues involving public companies; 
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 retail 
investors and market integrity.

FY 2017 was a successful and impactful year for ENF 
despite the transition in leadership. Acting on recom-
mendations by ENF, the Commission authorized a 
diverse mix of 754 enforcement actions, of which:
•	 446 were “standalone” actions brought in federal 

court or as administrative proceedings;
•	 196 were “follow-on” proceedings seeking bars 

based on the outcome of Commission actions  
or actions by criminal authorities or other  
regulators; and

•	 112 were proceedings to deregister public compa-
nies—typically microcap— that were delinquent in 
their Commission filings.

The SEC also obtained judgments and orders for over 
$3.8 billion in penalties and disgorgement, returned 
a record $1.07 billion to harmed investors, ordered 
over $50 million in payments to whistleblowers, 
suspended trading in the securities of 309 issuers to 
combat market manipulation and microcap fraud, and 
barred or suspended more than 625 individuals. The 
SEC’s enforcement actions during the year spanned the 
entire spectrum of the securities industry, and ENF’s 
workload is not slowing down. At the close of FY 
2017, ENF had 1,695 ongoing investigations. These 
achievements belie the significant challenges ENF faces 
that stretch its limited resources. 



24   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

Current Enforcement Challenges

Broad Spectrum of Securities Laws  
Violations Across the United States
ENF is tasked with enforcing a wide variety of statutes 
and rules, some applicable only to certain types of 
firms such as broker-dealers or investment advisers, 
and some, such as antifraud provisions, that apply 
broadly to all market participants. Moreover, this 
mandate to protect investors and enforce the securities 
laws applies everywhere, from New York to San Diego 
and Anchorage to Miami—a massive expanse for a 
limited corps of professionals. 

Cyber-Based Securities Law Violations 
Technology has dramatically transformed our markets 
and the ability of wrongdoers to engage in cyber- 
enabled misconduct. Just a few years ago, it was 
difficult to conceive of a market manipulation effectu-
ated by hacking into the electronic accounts of others 
and then forcing trades to pump up a stock price, or 
the brokering of stolen inside information on the “dark 
web,” paid for in untraceable cryptocurrency. These 
are the sorts of schemes ENF staff now frequently 
encounter, and they are among the greatest risks facing 
our securities markets. ENF needs the technological 
resources to keep up with misconduct in now cyber- 
focused markets.

Fragmented and Complex Equity Markets 
In recent years, the securities markets have grown 
increasingly complex and opaque. There has been 
a proliferation in sophisticated tools and trading 
methods used in the markets, including the use of high 
frequency trading, complex algorithmic trading, and 
off exchange trading venues like “dark pools.” Unlaw-
ful trading strategies such as “layering,” in which a 
trader sends and then cancels a series of orders that the 
trader does not intend to have executed to manipulate 
the price of a security, are becoming increasingly 
complex and more difficult to identify. ENF is commit-
ted to uncovering and charging violations of the law by 

all market participants in these new trading venues and 
elsewhere. Accordingly, ENF needs sufficient analytical 
tools and staff to analyze data from these tools to 
ensure it keeps pace with this constantly evolving 
environment.

Ever-Increasing Volume of Data 
Analysis of large datasets—including filings, disclo-
sures, and trading data in equities, options, municipal 
bonds, and other securities—is critical to effectively 
identify, investigate, and prosecute potential miscon-
duct. The volume of these datasets continues to rise 
and will only increase in FY 2019. Through its Center 
for Risk and Quantitative Analytics and other efforts, 
ENF expects that its improved information processing 
and analysis is likely to yield additional case leads 
through FY 2019. ENF needs commensurate staffing to 
review, analyze, and pursue these leads. 

Increasing Volume of Tips to Investigate 
The SEC receives approximately 16,500 tips and 
complaints each year, which ENF reviews to identify 
leads warranting further investigation. Additionally, 
ENF’s Office of the Whistleblower receives and 
analyzes thousands of tips per year, generating a fresh 
stream of case leads that require investigation. Since 
FY 2013, the Office of the Whistleblower has seen an 
increase of 30 percent in the number of tips received, 
and a 132 percent increase in the number of eligible 
award applications received. The office is currently 
tracking over 700 matters involving whistleblowers. 

Complexities of Advanced Technology 
The increasing use of technology to evade fraud detec-
tion requires ENF to spend more resources on forensic 
services, which have increased by approximately 20 
percent since FY 2013. Each month, ENF receives 
between eight and nine terabytes of electronic data 
in its investigations, and hosts nearly 925 terabytes 
of data related to investigations and litigation. The 
Commission’s e-Discovery data footprint grows at 
a rate of 10–15 percent per year. In FY 2017, ENF 



FY 2019 BUDGET REQUEST BY PROGRAM   |   25

received over 42,000 productions of documents and 
other information, an average of 3,500 productions per 
month. The total size of these productions increased by 
10 percent compared to FY 2016. The sheer volume 
of digital evidence produced to the SEC in its investi-
gations requires greater storage and processing powers  
as well as additional time for investigators to review 
that mass of information. Additionally, in today’s 
society, violators of the federal securities laws have 
an ever-expanding array of technological options to 
conceal misconduct and encrypt or otherwise obfuscate 
the evidence of their wrongdoing. 

FY 2019 Request 
To enable ENF to meet these challenges, and maintain 
an effective investigative capacity and deterrent 
presence, ENF must be adequately staffed to address 
increasingly complex financial products and trans-
actions; handle the increasing size and complexity of 
the securities markets; identify emerging threats; take 
prompt action to halt violations; and recover funds 
for the benefit of harmed investors. The volume of 
potential securities violations continues to rise, yet ENF 
presently employs fewer than 1,200 professionals to 
police the markets for wrongdoing. For FY 2019, ENF 
is requesting 17 restored positions. 

ENF’s ability to litigate its increased caseload is 
mission-critical. ENF handles an expansive and 
sophisticated docket of litigation and trials, often 
against well-funded defendants. Some of the toughest 
and most important cases are filed as litigated matters. 
Ensuring that appropriate resources are devoted to 
these cases after they are filed is critical to the SEC’s 
investor protection efforts. Successful litigation deters 
wrongdoing, sanctions those responsible for miscon-
duct, and can result in relief for victims. In addition 
to trial victories, ENF’s litigation efforts help it obtain 
strong settlements by making clear that ENF will go as 
far as required to obtain appropriate relief. In recent 
years, an increasing percentage of enforcement actions 

have been filed as contested matters as opposed to 
being fully settled at the outset. Restoring trial attorney 
positions in FY 2019 will help reinforce the agency’s 
litigation operations nationwide and enable the SEC to 
continue to be a respected and serious trial threat.

Additional litigation support is essential to manage the 
increasing e-Discovery burden, and will help ENF keep 
pace and manage the vast influx of digital documents 
and other data, analysis that is crucial to fulfilling 
ENF’s mission. As previously noted, the amount of 
e-Discovery information that ENF already houses—
and continues to regularly receive during the course of 
its investigations and litigations—is substantial. The 
complex data- and document-intensive cases brought 
by the SEC require substantial investments in staff time 
and e-Discovery resources. 

Some of the restored positions sought in this request 
will be used to support two key priorities of the 
division: protecting retail investors and combatting 
cyber-related threats. To execute and meet these 
priorities, in FY 2017, ENF announced the creation of 
the Retail Strategy Task Force and the Cyber Unit. 

The Retail Strategy Task Force will develop effective 
strategies and methods to identify potential harm 
to retail investors. In particular, the Task Force will 
focus on harnessing the Commission’s ability to use 
technology and data analytics to identify large-scale 
wrongdoing. 

The Cyber Unit will focus on combating cyber- 
related threats, which are among the greatest risks 
facing U.S. securities markets. This Unit combines 
ENF’s substantial, existing cyber-related expertise and 
its proficiency in digital ledger technology. Its members 
investigate and prosecute these increasing techno-
logically-driven violations, and coordinate with the 
Department of Justice and other criminal authorities.



26   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

Workload Data

Activity
FY 2017
Actual

FY 2018
Estimate

FY 2019
Request

Intelligence Analysis

Investor Tips and Complaints 17,098 16,500 16,500

Matters Under Inquiry (MUI) Opened 900 950 950

Investigations

Opened 965 950 950

Ongoing at End of Year 1 1,695 1,700 1,700

Proceedings

Administrative

Opened 569 550 550

Pending at End of Year 2 812 810 810

Civil Litigation

Opened 185 200 200

Pending at End of Year 3 1,581 1,580 1,580

1	 “Ongoing” investigations define those in which the investigation remains active. It excludes those that are open solely because they are in litigation; those in 
which the SEC is seeking to collect assets and funds to satisfy outstanding judgments and debts owed to the SEC; those in which the SEC is distributing 
funds to harmed investors; and those that are in some other post-litigation activity. “Ongoing” investigations also exclude those that are in the process of 
being closed.

2	 These estimates may be impacted by a number of factors beyond the division’s control, including – but not limited to – increases in the complexity of 
proceedings; higher than anticipated attrition rates; and the timing and amounts of the resources made available. Further, given the time required to bring 
on-board new staff after hiring levels are approved, the full effect of FY 2016 and/or FY 2017 positions will not be realized until later years.

3	 "Pending at End of Year” refers to those enforcement actions, filed civilly or administratively, that remain open due to ongoing litigation and post-judgment 
issues, including delinquent debts and distributions.



FY 2019 BUDGET REQUEST BY PROGRAM   |   27

OFFICE OF COMPLIANCE INSPECTIONS  
AND EXAMINATIONS

(DOLLARS IN THOUSANDS)
FY 2017
Actual

FY 2018
Annualized CR

FY 2019
Request

Full-Time Equivalents  1,063  1,047  1,032 

Cost:

Salaries and Benefits $	 267,780 $	 272,855 $	 271,740

Non-Personnel Expenses 79,493 73,437 94,040

Total Costs $	 347,273 $	 346,292 $	 365,781

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

The Office of Compliance Inspections and Examina-
tions (OCIE) directs the SEC’s National Examination 
Program (NEP). OCIE’s mission is to protect investors, 
ensure market integrity, and support responsible  
capital formation through risk-focused strategies that:  
(1) improve compliance; (2) prevent fraud; (3) monitor 
risk; and (4) inform regulatory policy. The NEP 
maintains a critical presence among market participants 
by conducting thousands of exams annually, which 
provide timely, accurate, and reliable information to 
assist the program and SEC in fulfilling its mission. 

The resources being requested are essential for OCIE 
to meet its objectives and fulfill the agency’s mission. 
Importantly, this request would allow the program to 
restore critical staffing losses from the last two years. 
Among other things, these resources are needed to:  
(1) address critical risks impacting market participants, 
including issues such as cybersecurity and anti-money 
laundering; (2) continue efforts to protect retail 
investors and those saving for retirement; (3) further 
address the disparity between the number of exam 
staff and the growing number, size, and complexity 
of registered firms, particularly in the investment 
management industry; (4) examine new categories of 
regulated entities now registered, or to be registered, 
as a result of legislation; and (5) enhance and expand 
quantitative and data analytic efforts throughout the 
NEP. OCIE will also continue its efforts to promote 
industry compliance efforts through initiatives such as 
the Compliance Outreach Program. 

OCIE requests 24 positions to partially restore critical 
staffing losses from the last two years and address these 
areas. Overall, OCIE’s risk-based program is designed 
to focus resources on those firms and practices that 
pose the greatest potential risk of securities law viola-
tions that can harm investors and the markets. 

Key Observations, Issues, and Challenges  

Limitations of Exam Coverage for  
Securities Markets 
The staff examined approximately 15 percent of 
registered investment advisers in FY 2017 and nearly 
35 percent of all registered investment advisers have 
never been examined. At the same time, the population 
of registered advisers subject to SEC oversight contin-
ues to grow. To highlight, in just the last five years, 
the number of registered advisers has grown by over 
15 percent and the assets under management of these 
firms has increased by more than 40 percent. Signifi-
cant additional resources are critical to the examina-
tion program in order to improve the examination 
coverage of these entities. 

Complexity of Registrants and Markets
The securities markets continue to grow increasingly 
complex, with a proliferation of new and sophisticated 
products and services, tools, and trading strategies. 
Innovations in technology have also changed the way 
entities conduct business and investors access securities 



28   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

markets and facilitated developments in areas such as 
algorithmic trading and automated investment advice. 
More recently, the rapid growth of distributed ledger 
(i.e., blockchain) technologies and the cryptocurrency 
markets has drawn interest from both investors and 
financial services firms. At the same time, cyber threats 
in securities markets have continued to increase in both 
frequency and sophistication. These types of industry 
developments and financial innovation will continue 
to present challenges to the staff, requiring additional 
staff expertise, resources, and a program that is agile, 
responsive, and continuously improving.

Impact of Legislation and Rulemaking 
The registration of municipal advisors has added 
responsibility in recent years for hundreds of additional 
registrants with increasingly complex business lines. 
Additionally, as the Commission finalizes rules to 
create a regulatory regime for the security-based swap 
market, staff resources and additional expertise will be 
required in FY 2019 for OCIE to effectively carry out 
its expanded responsibilities.

FY 2019 Request
In light of the examination program’s limited resources 
and these existing challenges, the office is requesting 
the restoration of 24 positions in FY 2019, which it 
intends to use to address the issues identified above, 
including: filling critical staffing losses from the last 
two years that have not been restored, enhancing 
examination coverage of investment advisers, focus-
ing on critical risks impacting market participants, 
addressing new responsibilities, and implementing 
other program improvements. 

Investment Adviser/Investment Company 
Examination Program
The FY 2019 request seeks 13 restored positions to 
focus on examinations of investment advisers and 
investment companies. As stated above, the number of 
registered investment advisers and their assets under 
management has grown steadily over the years, while 
staff resources have not kept pace with the growing 
responsibilities. OCIE expects this growth to continue 

through FY 2018 and FY 2019 and estimates there  
will be approximately 20 investment advisers per  
staff member. In addition, it is anticipated that the 
population of investment advisers will be larger and 
more complex than ever. With the resources requested, 
the staff will continue efforts to improve overall 
coverage of investment advisers, including an emphasis 
on the nearly 35 percent of advisers who have never 
been examined. 

Among other things, these resources are critically 
needed to continue OCIE’s efforts of protecting retail 
investors and investors saving for retirement. Retail 
investors continue to face complex and evolving 
options when determining how to invest their money. 
Additionally, as investors are more dependent than 
ever on their own investments during retirement, 
the financial services industry is offering a broad 
array of information, advice, products, and services 
to retail investors to help them plan for, and live in, 
their retirement years. OCIE will dedicate resources 
toward examining practices that represent risks to 
retail and retirement investors, such as services offered 
from remote locations and fee structures that create 
conflicts, as well as examining for indications of 
churning, reverse churning, unsuitable recommenda-
tions, deceptive sales practices, misleading disclosure, 
and elder abuse. 

Technology Controls Program
The capital market’s use of, and dependence on, 
technology has evolved for decades, causing an increase 
in the complexity, interconnectedness, and speed of 
transactions, all of which continue to challenge market 
participants and regulators. In FY 2019, in support 
of Regulation Systems Compliance and Integrity (Reg 
SCI) to strengthen the technology infrastructure of the 
U.S. securities markets, OCIE’s Technology Controls 
Program (TCP) will continue to conduct risk-targeted 
exams of Reg SCI entities, which include self-regula-
tory organizations (SRO)(including stock and options 
exchanges, registered clearing agencies, the Financial 
Industry Regulatory Authority [FINRA], and the 
Municipal Securities Rulemaking Board [MSRB]), 



FY 2019 BUDGET REQUEST BY PROGRAM   |   29

certain alternative trading systems, disseminators of 
consolidated market data, and certain exempt clearing 
agencies. TCP will examine Reg SCI entities to evalu-
ate whether they have established, maintained, and 
enforced written policies and procedures reasonably 
designed to ensure the capacity, integrity, resiliency, 
availability, and security of their Reg SCI systems. TCP 
will also continue to examine technology focused issues 
of other registered entities, including those that may 
be new to SEC registration such as derivative markets 
participants. 

In addition, as cyber threats continue to increase in both 
frequency and sophistication at financial institutions 
and within the securities markets, OCIE and the TCP 
will also seek to enhance cybersecurity examinations 
by working with the Department of the Treasury, the 
Department of Homeland Security, the Department of 
Justice, and the intelligence community. TCP also will 
monitor market operations and track system disrup-
tions, system intrusions, and system compliance issues 
reported by Reg SCI entities. To adequately fulfill the 
above obligations, TCP would need to hire profession-
als with specialized experiences and skills. Six restored 
positions are requested to further enhance the work of 
the TCP.

Clearance and Settlement Examination Program 
Three restored positions are being requested to enhance 
the oversight of clearing agencies, security-based 
swap data repositories, and transfer agents. Focusing 
resources in this area is critical given the important 
role these entities play in ensuring the stability of 
the marketplace. In recent years, both the scope and 
number of clearing agencies required to be examined 
by the SEC have grown. Examinations of these entities 
are complex and time consuming and require particu-
lar expertise in an evolving area.

The SEC is required to conduct examinations, on at 
least an annual basis, of securities clearing agencies 
that are designated as “systemically important” and 
for which it is the supervisory agency. These examina-
tions are conducted in consultation with the Board of 

Governors of the Federal Reserve System. In addition, 
as security-based swap data repositories register with 
the SEC, additional staff will be needed to perform 
periodic examinations of these entities. The requested 
positions will help OCIE build a dedicated team of 
derivatives and clearing specialists that will be able to 
conduct cross-sector examinations of clearing agencies, 
collaborate and respond to requests for assistance from 
the Division of Trading and Markets and other regula-
tors engaged in clearance and settlement oversight,  
and enhance the NEP’s clearing and credit default 
swap/derivatives expertise.

The requested resources also will help OCIE conduct 
examinations of transfer agents, including joint 
examinations with federal banking regulators.  
Efficient transfer agent operations are critical to 
secondary securities markets. Examination efforts 
will continue to focus on transfers, record-keeping, 
safeguarding of customer information, and custody  
of shareholder funds.

Additional Significant Examination  
Program Efforts 
OCIE also requires staffing in other critical areas, 
including its Broker-Dealer and Exchange (BDX)
Program and its FINRA and Securities Industry 
Oversight (FSIO) Program. As described below, 
resources during the year will also be dedicated to 
significant program-wide efforts such as outreach 
initiatives, and risk assessment and surveillance. 

Broker-Dealer and Exchange Program. BDX continues 
to have significant responsibilities and one restored 
position is being requested in order to supplement 
existing staff and address new areas of responsibility. 
Resources in this program will be used to continue 
critical examination work related to, among others, 
broker-dealers, national securities exchanges, municipal 
advisors, the Public Company Accounting Oversight 
Board (PCAOB), and the Securities Investor Protection 
Corporation. BDX resources will also be used to cover 
several new categories of security-based swap market 
participants registering with the Commission, including 



30   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

security-based swap dealers and major security-based 
swap participants. During the year, staff will focus on 
high risk areas, including the sales and marketing of 
high risk products, with a particular emphasis on  
retail investors.

FINRA and Securities Industry Oversight Program. 

One restored position is requested to help FSIO with 
its oversight responsibilities of FINRA and MSRB. 
Oversight of FINRA is vitally important, as it is the 
primary regulator for broker-dealers. Examinations in 
FY 2019 will continue to focus on FINRA’s operations 
and regulatory programs and the quality of FINRA’s 
examinations of broker-dealers. Additionally, given the 
responsibility of MSRB to regulate municipal securities 
firms, staff will continue to examine the MSRB to 
evaluate the effectiveness of select operational and 
internal policies, procedures, and controls. 

Other Significant Initiatives. OCIE will continue to 
improve its analytic, surveillance, and risk assessment 
functions in FY 2019, leveraging data and information 
available to the exam program. As part of this work, 
the program will continue to perform preliminary risk 
analysis on thousands of entities in order to help focus 
the program’s limited resources on firms and industry 

practices posing the greatest risk to investors and  
the markets. 

In FY 2019, OCIE will continue efforts aimed at 
encouraging stronger industry compliance programs. 
These efforts include conducting OCIE’s Compliance 
Outreach programs, which provide information and 
resources for compliance personnel of registered 
entities; issuing reports and risk alerts to the public and 
industry; and speaking at conferences concerning areas 
of regulatory interest.

Developing Regulatory Technology and  
Data Analytics
As technology continues to evolve and alter the way 
entities conduct business, it is imperative that the 
examination program make appropriate investments 
to keep pace and to more effectively and efficiently 
conduct its regulatory oversight functions. Long-term 
investment and development in technology and analyt-
ical tools will be critical to the future success of the 
Commission’s oversight responsibilities. Particularly 
important in FY 2019 will be a continued focus on 
enhancing quantitative and data analytic efforts. These 
tools will provide staff with a greater ability to monitor 
for trends and emerging risks, ultimately enabling the 
staff to allocate SEC resources more effectively.

Workload Data

Activity
FY 2017
Actual

FY 2018
Estimate1

FY 2019
Request 1

Investment Adviser Examinations 2,114 2,120 2,160

Investment Company Examinations (includes administrators) 95 100 100

Broker-Dealer Examinations 325 300 300

Transfer Agent Examinations 57 45 47

Municipal Advisor Examinations 83 75 75

Market Oversight Inspections 2 115 128 128

Technology Controls Program Inspections 70 70 80

Clearing Agency Examinations 14 11 12

1	 These estimates may be impacted by a number of factors beyond the office’s control, including—but not limited to—increases in the  
complexity of firms being examined; higher than anticipated attrition rates; and the timing and amounts of the resources made available.

2	 Market oversight inspections include inspections of exchanges conducted by OCIE’s BDX group as well as programmatic inspections and  
oversight exams of FINRA conducted by OCIE’s FSIO group.



FY 2019 BUDGET REQUEST BY PROGRAM   |   31

DIVISION OF CORPORATION FINANCE

(DOLLARS IN THOUSANDS)
FY 2017
Actual

FY 2018
Annualized CR

FY 2019
Request

Full-Time Equivalents  461  433  423 

Cost:

Salaries and Benefits $	 116,144 $	 115,096 $	 113,708

Non-Personnel Expenses 31,921 29,049 36,894

Total Costs $	 148,065 $	 144,145 $	 150,601

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

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 provides interpretive assistance to companies on 
SEC rules and forms.

Rulemaking and Interpretive Advice
During FY 2019, CF will continue to assist the 
Commission, as needed, with implementing any new 
rules to further facilitate capital formation and identi-
fying any unnecessary barriers that impede capital 
formation. As part of this effort, CF will consider 

proposing amendments to modernize certain disclosure 
requirements in Regulation S-K as part of its ongoing 
Disclosure Effectiveness Initiative and implement 
recommendations resulting from the Regulation S-K 
study required by the Fixing America’s Surface Trans-
portation (FAST) Act of 2015.

FY 2019 Request
The division requests three restored positions in  
FY 2019 to meet its goals and to enhance its ongoing 
efforts to facilitate capital formation. The new positions 
would allow CF to better support the volume of 
rulemakings by increasing the number of CF staff 
members dedicated to rulemaking. For example, in 
addition to the Disclosure Effectiveness Initiative 
described above, CF will consider recommending that 
the Commission propose amendments to further facil-
itate capital formation through exempt and registered 
offerings. The division will also consider recommending 
that the Commission propose amendments to Regula-
tion S-K and Regulation S-X to modernize and stream-
line industry-specific disclosures applicable to real estate 
companies, including real estate investment trusts. The 
new positions would enable CF to fully support these 
and other rulemaking priorities. 



32   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

Workload Data

Activity
FY 2017
Actual

FY 2018
Estimate

FY 2019
Request

Review

Reporting Company Reviews 4,200 4,100 4,100

Number of New Issuer Reviews    

IPO 1933 Act 430 400 400

New 1934 Act 90 100 100

New Issuer Reviews 1 520 500 500

Total Reviews 4,720 4,600 4,600

Rulemaking and Interpretive 

General Advice and Coordination 

No-Action Letters/Interpretive Requests 95 100 100

No-Action Letters (Shareholder Proposals) 295 300 300

1	 Because of the inherent difficulty of predicting future market and economic conditions, the division assumes for planning purposes a steady level of  
transactional filings for future periods.



FY 2019 BUDGET REQUEST BY PROGRAM   |   33

DIVISION OF TRADING AND MARKETS

(DOLLARS IN THOUSANDS)
FY 2017
Actual

FY 2018
Annualized CR

FY 2019
Request

Full-Time Equivalents  263  248  250 

Cost:

Salaries and Benefits $	 66,008 $	 65,405 $	 66,611

Non-Personnel Expenses 19,161 18,303 23,212

Total Costs $	 85,169 $	 83,708 $	 89,824

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

The mission of the Division of Trading and Markets 
(TM) is to establish and maintain 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, each of which has specific functions and 
is focused on a specific part of the markets. These 
include: (i) Broker-Dealer Finance/Risk; (ii) Chief 
Counsel; (iii) Clearance and Settlement; (iv) Derivatives 
Policy and Trading Practices; and (v) Market Supervi-
sion. In addition, the division has two groups that serve 
in supporting functions: the Office of Analytics and 
Research, and the Office of the Managing Executive.

Overall, TM supervises the SROs and other major 
market participants in the U.S. securities markets, 
including 21 securities exchanges (equities and 
options), 81 alternative trading systems (ATS), over 
3,900 broker-dealers, seven active clearing agencies, 
nearly 380 transfer agents, FINRA, and various 
securities information processors.

TM is responsible for numerous separate rulemaking 
initiatives. Many of these rulemakings are focused on 
modernizing or establishing new ongoing supervisory 
and regulatory functions that will extend into FY 2019 
and beyond. These initiatives include:
•	 Development and implementation of pilot programs 

designed to test shifts in fee models; 

• Establishment of clear standards of conduct for 
broker-dealers to ensure transparency and fairness  
to investors;

• Implementation of a modernized regulatory  
framework for ATSs, enhancing transparency and  
protecting consumer information; and 

• Continuation of work related to the regulatory 
frameworks for security-based swaps and other 
derivatives products.

Ongoing work of the division includes the review of 
SRO rule proposals for consistency with the Exchange 
Act standards of investor protection, fair and orderly 
markets and market structure, and other statutory 
requirements. Additionally, staff throughout the 
division regularly responds to requests for interpretive 
guidance on existing rules to ensure compliance, as 
well as requests for exemptive and no-action relief. In 
FY 2017, TM processed 165 amendments to national 
securities exchange registrations (Form 1), registered 
13 new ATSs, and processed about 4,800 new invest-
ment product submissions (19b-4e).

FY 2019 Request
In FY 2019, TM requests 16 restored positions to 
undertake new market-related responsibilities resulting 
from ongoing or recently completed rulemakings, and 
to continue improving the agency’s market oversight 
and supervision. This includes a significantly enhanced 



34   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

focus on fixed income markets, requiring specialized 
industry expertise and staffing to support the new 
Fixed Income Market Structure Advisory Committee, 
established in early FY 2018. That committee’s work 
will initially focus on the structure and operation of the 
U.S. fixed income markets, bond market liquidity, and 
the extent to which any corporate bond market recom-
mendations might also be relevant for the municipal 
bond market. Staff will be required to fully develop, 
propose, and implement related recommendations. 

In FY 2019, the division will expand its work related 
to cybersecurity and other risks that present a threat 
to market stability. This work is required across the 
industry where this sort of risk continues to increas-
ingly become a greater concern. Such cyber risks 
have the potential to be significantly disruptive to 
U.S. markets and enhanced expertise is required to 
adequately ameliorate this risk. 

FY 2019’s work will include implementation of rule 
initiatives from FY 2018, and will incorporate lessons 
from the pilot programs underway. Building off lessons 
from the Tick Size Pilot, the division expects to further 
explore policies to enhance market structure in the 
small cap, illiquid segment of the market, to better 
encourage capital formation for smaller companies. 
Significant market structure changes may be warranted 
in this area and an additional pilot may be required to 
gather the requisite data to improve the structure of 
our markets for this segment. 

Risks and opportunities within the markets associated 
with new Financial Service Technologies (FinTech) 
is another area of division focus, requiring study 
of the flexibility of current regulatory frameworks 
and policies and application of lessons learned. As 
technology underpinning the U.S. markets evolves at a 
rapid pace, the division seeks to study the rise of such 
technologies, including new types of electronic match-
ing platforms and other secondary market tools and 
their impact on market liquidity. These studies, and 
associated pilot programs, will inform future regula-
tory considerations and initiatives. 

The division seeks to expand the agency’s depth of 
expertise in the area of market insight and analysis, 
enabling improved information sharing and issue 
spotting in support of the agency’s market threat 
detection and response capabilities. Staying current 
with market trends and developments is essential to 
the agency’s ability to remain an effective regulator. 
The requested restored positions would also help the 
division implement its new and enhanced responsibili-
ties to oversee clearing agencies and swap data repos-
itories as well as supplement staffing on existing work 
affected by the hiring freeze. 

Other restored positions would: (i) help improve 
the SEC’s analytics and reporting on broker-dealers’ 
finances, internal controls, and risk management 
practices; (ii) process an increasing number of rule 
proposals from a growing number of SROs; and (iii) 
provide interpretive guidance related to existing rules. 



FY 2019 BUDGET REQUEST BY PROGRAM   |   35

Workload Data

Activity
FY 2017
Actual

FY 2018
Estimate

FY 2019
Request

Securities Firm Supervision

SRO Proposed Rule Changes Reviewed 1 45 63 56
SEC Rulemaking, Exemptive Orders, and Interpretive and Other Actions 2 5 5
Interpretive, Exemptive, and No-Action Request Letters Closed 2 12 15 15
Reviews of Potential Enforcement Actions 1,223 1,300 1,300
Notices filed by SROs relating to Applications for Admission or Continuance as or  

with an SRO Member Notwithstanding a Statutory Disqualification 3 15 25 25
Provision of Interpretation and Guidance and Responding to General Questions 4 16,240 16,500 16,500
Tips, Complaints, and Referrals (TCR) 474 450 450
Risk Assessment of Broker-Dealers Filing Form 17-H

Firms Assessed 100 100 100
Filings Reviewed 300 300 300

Risk Supervision of Alternative Net Capital Broker-Dealers
Firms Assessed 7 7 7
Filings Reviewed 84 84 84

Risk Supervision of OTC Derivatives Dealers and Security-Based Swap Dealers
Firms Assessed 8 8 12
Filings Reviewed 96 96 144
Applications Reviewed 4 4 4

Broker-Dealers
Registrants 3,917 3,875 3,850
Registration Applications Filed 174 170 165
Registration Amendments Filed 10,835 10,800 10,750
Registrations Withdrawn or Cancelled 412 400 390
Financial Reports Filed 5,624 5,400 5,100

Security-Based Swap Dealers
Registrants — — 15
Registration Applications Filed — — 15

Major Security-Based Swap Participants
Registrants — — 2
Registration Applications Filed — — 2

Funding Portals 36 50 150 

Securities Market & Infrastructure Supervision

SRO Proposed Rule Changes and Advance Notices Reviewed 1 2,904 3,094 2,728
NMS & SRO Plan Amendments Filed 26 20 20
SEC Rulemaking, Exemptive Orders, and Interpretive and Other Actions 12 10 10

continued on next page 

1	 This data includes filings, pre-filings, and amendments reviewed.
2	 This data includes requests for which a formal response was not issued, such as items that were withdrawn, but omit routine correspondence (such as 

routine broker-dealer financial responsibility correspondence and foreign control location letters filed under Rule 15c3-3 of the Securities Exchange Act).
3	 Activity description changed from “Registered Representative Reentry Applications Filed” to better describe this data.
4	 Calls and emails received by TM staff directly from the public increased dramatically over last year. This increase was driven in large part by a move to 

allow certain registrants to file certain filings electronically, which generated significant questions and requests for assistance.



36   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

Workload Data (continued)

Activity
FY 2017
Actual

FY 2018
Estimate

FY 2019
Request

Securities Market & Infrastructure Supervision (continued)

Interpretive, Exemptive, and No-Action Request Letters Closed 38 30 30
Securities Exchanges

Registrants 21 22 23
Registration Applications Filed — 1 1
Registration Amendments Filed 165 173 180
Registrations Withdrawn or Cancelled — — —

Alternative Trading Systems
Registrants 90 98 111
Initial Operations Reports Filed 18 15 20
Initial Operations Report Amendments Filed 149 162 183
Cessations 9 7 7
Quarterly Reports 329 358 405

Security-Based Swap Execution Facilities 5

Registrants — — —
Registration Applications Filed — — —
Proposed Rule Changes Filed — — —

Clearing Agencies (Active) 6

Registrants 9 10 10
Registration Applications Filed 1 — —

Security-Based Swap Data Repositories 7

Registrants — 2 2
Registration Applications Filed 2 — —

Transfer Agents 8

Registrants 299 290 290
Registration Applications Filed 7 7 7
Registration Amendments Filed 179 175 170
Registrations Withdrawn or Cancelled 19 22 25
Annual Reports Filed 243 240 235

Large Traders
Registrants 6,269 6,557 6,857
Registration Applications Filed 589 580 580
Registration Amendments Filed 2,755 2,900 3,000
Terminated or Inactive 301 300 300
Annual Reports Filed 3,155 6,557 6,857

5	 The Commission has granted an exemption from the statutory requirement to register as a “security-based swap execution facility” to any facility that 
trades security-based swaps, pending adoption and implementation of final rules governing security-based swap execution facilities.

6	 As of December 31, 2017, it is unclear whether additional clearing agencies will seek registration in 2018.
7	 As of December 31, 2017, it is unclear whether additional security-based swap data repositories will seek registration in 2018.
8	 This data only includes SEC-registered transfer agents and omits the approximately 80 transfer agents registered with a bank regulatory agency, which 

the Commission also oversees.



FY 2019 BUDGET REQUEST BY PROGRAM   |   37

DIVISION OF INVESTMENT MANAGEMENT

(DOLLARS IN THOUSANDS)
FY 2017
Actual

FY 2018
Annualized CR

FY 2019
Request

Full-Time Equivalents                   
182 

                  
176 

                  
175 

Cost:

Salaries and Benefits $	 47,193 $	 47,254 $	 47,491

Non-Personnel Expenses 12,151 10,488 13,140

Total Costs $	 59,344 $	 57,742 $	 60,631

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

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 developing regulatory policy 
for open-end management investment companies 
(commonly known as mutual funds), exchange-traded 
funds (ETF), closed-end funds, variable insurance 
products and other investment companies, and for 
investment advisers. 

Investment companies—including mutual funds and 
ETFs—are the principal means by which middle class 
Americans invest in the capital markets. Investment 
companies provide a crucial link between U.S. house-
holds seeking an investment return on dollars saved 
for education or retirement, and U.S. corporations, 
non-profits, and national, state, and local governments 
seeking capital from the securities markets to fund 
projects that provide needed goods, services, and 
economic growth. 

Investment companies supply significant amounts of 
debt and equity capital to a variety of issuers. In terms 
of percentage of market value of outstanding securities, 
they hold: 
•	 31 percent of U.S. corporate stock
•	 19 percent of U.S. and foreign corporate bonds
•	 13 percent of U.S. Treasury and government  

agency securities
•	 23 percent of U.S. municipal securities 

As of September 2017, there were 12,616 SEC- 
registered investment advisers reporting approximately 
$71.7 trillion in regulatory assets under management. 
Approximately 51 percent of these advisers provide 
investment advice to mainstream retail investors. 
Approximately 37 percent provide investment advice 
to private funds such as hedge funds and private equity 
funds with gross assets of about $11.6 trillion. In 
addition to registered investment advisers, the SEC  
also receives reports from approximately 3,743  
exempt reporting advisers—those who are exempt 
from registering with the SEC because they are  
venture capital fund advisers or mid-sized private  
fund advisers—who report managing approximately 
$2.6 trillion in private funds.

FY 2019 Request
The SEC requests a total of seven restored positions  
for IM to implement key policy objectives. 

One new position is requested for an ETF industry 
professional. Among other responsibilities, the staff 
person would evaluate novel and complex ETF 
products, structures, trading mechanisms and index 
replication methodologies; obtain and interpret 
information resulting from dialogue with portfolio 
managers, authorized participants, index arbitrage 
traders, operations managers, personnel involved in 
physical and synthetic index replication, and other 
technical experts; and assist in targeted examinations 
that involve ETF industry participants. 



38   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

One new position is requested for a derivatives  
professional to apply sophisticated quantitative  
analysis techniques to the review of disclosure filings  
of investment companies.

Two new positions are requested to work with asset 
management industry participants to formulate policy 
recommendations with respect to issues involving the 
impact of new technologies on the investment manage-
ment and investment adviser industries, including 
issues related to cybersecurity, FinTech, and the 
emergence of roboadvice. 

One new position is requested for expertise specific 
to fixed income mutual funds and ETFs to help the 
division analyze and address market structure issues 
involving bond funds and ETFs and work with the 
Commission’s new Fixed Income Market Structure 
Advisory Committee on these matters.

One new position is requested to strengthen IM’s 
capacity to conduct ongoing analysis of data related 
to IM disclosure, regulatory, and industry engagement 
programs, and enhance IM’s ability to respond rapidly 
to market events with policy recommendations that are 
informed by sophisticated quantitative analysis. 

One new position is requested to improve oversight  
of private funds, their investment advisers, and 
business development companies (BDC). The position 
would be used to augment capacity to analyze Form PF 
data; enhance IM’s ability to respond to private fund 
adviser interpretive requests, identify policy issues, and 
recommend regulatory changes in light of changing 
conditions; and assist the division and other Commis-
sion staff in understanding the investment process used 
by BDCs.

Workload Data

Activity
FY 2017
Actual

FY 2018
Estimate

FY 2019
Request

Disclosure 

New Portfolios and Insurance Contracts Filed on Registration Statements 2,795 2,850 2,850

New Portfolio Disclosures and Insurance Contracts Reviewed 1,726 1,830 1,830

Existing Portfolios and Insurance Contracts Filed on  
Post-Effective Amendments 1, 2

34,871 33,800 33,975

Existing Portfolio Disclosures and Insurance Contracts Reviewed 2 5,492 5,233 5,237

Portfolios and Insurance Contracts Filed on Proxy Statements 1,781 1,450 1,450

Portfolios and Insurance Contracts Filed on Proxy Statements Reviewed 1,781 1,450 1,450

Annual and Periodic Reports Filed 14,511 14,400 14,475

Annual and Periodic Reports Partially Reviewed 5,009 4,800 4,825

Total Filings 53,958 52,500 52,750

Total Filings Reviewed 14,008 13,313 13,342

Percent Reviewed 26% 25% 25%

Interpretive Guidance  

Formal and Informal Requests for Guidance 1,232 1,205 1,205

Enforcement-Related Matters Reviewed 2,352 840 850

Exemptive Relief Requests Concluded 309 275 275

1	 Included in post-effective amendments are open-end, closed-end, and unit investment trust (UIT) portfolios.
2	 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. Because of their repetitive nature, amendments to UIT portfolios are generally not reviewed.



FY 2019 BUDGET REQUEST BY PROGRAM   |   39

DIVISION OF ECONOMIC AND RISK ANALYSIS

(DOLLARS IN THOUSANDS)
FY 2017
Actual

FY 2018
Annualized CR

FY 2019
Request

Full-Time Equivalents  157  147  145 

Cost:

Salaries and Benefits $	 39,919 $	 39,428 $	 39,323

Non-Personnel Expenses 28,088 32,964 35,758

Total Costs $	 68,007 $	 72,392 $	 75,081

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

The Division of Economic and Risk Analysis (DERA) 
continues to provide a powerful combination of 
sophisticated economic, financial, and legal expertise, 
and rigorous data analytic and quantitative methodol-
ogies in furtherance of the SEC’s mission. The division 
is involved across the entire range of SEC activities, 
including policy-making, rulemaking, enforcement, 
and examination. As the agency’s “think tank,” 
DERA relies on a variety of academic disciplines, 
quantitative and non-quantitative approaches, and 
knowledge of market institutions and practices to help 
the Commission approach complex matters in a fresh 
light. DERA also assists in the Commission’s efforts 
to identify, analyze, and respond to risks and trends, 
including those associated with new financial products 
and strategies. Through the range and nature of its 
activities, DERA serves the critical function of promot-
ing collaborative efforts throughout the agency and 
breaking through silos that might otherwise limit the 
impact of the agency’s institutional expertise.

The division produces high-quality, data-driven analy-
ses that address the economic issues associated with the 
regulation of the financial markets and the enforcement 
of federal securities laws. DERA’s support for the SEC 
primarily falls into four categories. 

Informing Policy-Making with Robust 
Economic Analysis and Cutting-Edge 
Research
DERA provides economic expertise for policy-making 
by analyzing the economic effects of regulations and 
other priority initiatives, and by engaging in novel 
research regarding the regulation of financial markets. 
DERA provides theoretical and data-driven economic 
analyses to support the Commission’s broad regulatory 
agenda. These analyses typically examine the need for 
regulatory action, consider potential economic effects 
by collecting and analyzing market data and evaluating 
pertinent academic literature, among other methods, 
and evaluate public comments. 

Producing Papers and Studies on  
Significant Economic Issues 
DERA produces papers and studies on significant 
economic issues that support the Commission’s 
mission. These staff-authored white papers and 
memoranda are publicly available on the DERA 
website and are often cross-referenced in Commission 
rulemakings or other policy initiatives. These papers 
showcase DERA staff’s academically rigorous research 
that aims to inform policy as it is being developed.40   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

Supporting Enforcement and  
Inspection Activities
DERA economists directly support the SEC’s enforce-
ment and litigation activities by applying economic 
methods to address agency investigations, negotiations, 
and distribution of recovered funds to harmed inves-
tors. With increasing frequency, DERA is requested 
to testify as fact and expert witnesses on behalf of the 
Commission. The fact that this expertise is resident in 
the division is extremely cost effective when compared 
to the cost associated with contracting outside 
professionals. DERA also supports agency staff with 
examination planning, including providing guidance 
on the collection and analysis of data to help promote 
risk-based examination programs.

Improving Accessibility and Usability  
of SEC Data
DERA takes innovative approaches to developing 
solutions that make market information accessible 
to internal and external audiences. Structured data 
reporting enhances access for the Commission and 
other users to key information about registrants, 
their practices, and their offerings. DERA works 
closely with agency offices and divisions to design 
data structuring approaches for required disclosures, 
and supports the SEC’s data collection and usage by 
designing taxonomies, validation rules, data quality 

assessments, and dissemination tools to facilitate 
high-quality data analyses. Once this data is ingested, 
DERA provides a variety of platforms—and continues 
to develop new ones—that allow non-technical staff to 
access and use vast quantities of market data. 

FY 2019 Request
The SEC seeks four restored positions to begin to 
address both the most critical staffing needs that have 
resulted from attrition and the continued demand for 
economic expertise from across the agency. All four 
positions would be filled with financial economists 
and will be targeted to fill essential skill gaps within 
DERA’s risk assessment and policy offices. Two of 
these financial economists are for DERA’s Office of 
Risk Assessment to address unmet customer demand 
for support and expertise in cyber/operational risk, 
structured finance, and investment advisers/asset 
management. 

The remaining two financial economists positions 
are for DERA’s policy offices to enhance the level of 
economic expertise to focus on policy and rule- 
making matters related to financial accounting and 
disclosure (including PCAOB matters) as well as  
private funds, registered investment companies, and 
investment advisers. 

Workload Data

Activity
FY 2017
Actual

FY 2018
Estimate

FY 2019
Request

Reviews of Commission Rules 1 78 80 82

Reviews of SRO and PCAOB Filings 55 57 59

Advice on Regulatory, Enforcement, and Risk Assessment Issues 3,443 3,500 3,500

Interactive Data Compliance Monitoring 8,334 7,960 7,600

Interactive Data Programs Supported 13 13 14

1	 Includes staff participation in Commission rulemaking at all stages of development as well as 10-year rule reviews required by the Regulatory Flexibility Act.



FY 2019 BUDGET REQUEST BY PROGRAM   |   41

OFFICE OF THE GENERAL COUNSEL

(DOLLARS IN THOUSANDS)
FY 2017
Actual

FY 2018
Annualized CR

FY 2019
Request

Full-Time Equivalents 141 134 131

Cost:

Salaries and Benefits $	 36,938 $	 36,647 $	 36,252

Non-Personnel Expenses 9,917 9,060 11,194

Total Costs $	 46,855 $	 45,707 $	 47,446

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

The General Counsel serves as the chief legal officer of 
the SEC and heads the Office of the General Counsel 
(OGC). OGC provides independent legal analysis and 
advice to the Chairman, Commissioners, and operating 
divisions 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 SEC 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 2019, OGC will continue to focus 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 and 
address legal challenges to rulemakings. 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. The staff 
will also continue to provide assistance and advice in 
responding to Congressional requests for information 
and documents. 



42   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

Workload Data

Activity
FY 2017
Actual

FY 2018
Estimate

FY 2019
Request

Appellate Cases 

Open Matters 174 175 175

Adjudicatory Matters

Pending Beginning of Year 67 77 70

Received 52 32 32

Completed 42 39 39

Pending End of Year 77 70 63

Legislation

Testimony 4 20 20

Correspondence with Congress and Others 91 180 180

Legislative Analysis and Technical Assistance 501 380 380

Other 91 110 110

Advisory Services

SEC Statutes 

Analysis of Enforcement Memoranda 2,225 2,200 2,200

Review of Rulemaking and Other Projects 465 600 630

Review of Articles and Speeches 358 300 300

Non-SEC Statutes 

Freedom of Information Act (FOIA) – Internal Appeals 605 620 620

Personnel Matters 245 245 245

Procurement Matters 750 760 780

Labor Matters 25 30 30

Attorney Misconduct Investigations 410 425 430

Other (Subpoenas) 51 50 50

Corporate Reorganization

Petitions Involving Public Investor Interest 54 60 60

Chapter 11 Cases: Appearances 

Filed 29 30 30

Closed 46 30 30

Chapter 11 Cases: Monitored 

Filed 25 30 30

Closed 29 25 25

Disclosure Statement Reviews 82 90 90

Disclosure Statements Commented On 60 60 60



FY 2019 BUDGET REQUEST BY PROGRAM   |   43

OTHER PROGRAM OFFICES

(DOLLARS IN THOUSANDS)
FY 2017
Actual

FY 2018
Annualized CR

FY 2019
Request

Full-Time Equivalents:

Office of the Chief Accountant  49  50  49 

Office of Investor Education and Advocacy  43  42  42 

Office of International Affairs  55  53  51 

Office of Administrative Law Judges  13  12  12 

Office of the Investor Advocate  11  11  12 

Office of Credit Ratings  44  41  41 

Office of Municipal Securities  9  10  10 

Office of the Advocate for Small Business  
Capital Formation

— 1 3

Total Full-Time Equivalents 224 220 220

Cost:

Salaries and Benefits $	 57,392 $	 57,013 $	 57,612

Non-Personnel Expenses 23,672 20,747 25,774

Total Costs $	 81,064 $	 77,761 $	 83,386

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

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

Office of the Chief Accountant: Establishes accounting 
and auditing policy and works to improve the profes-
sional performance of public company auditors to 
ensure that financial statements used for investment 
decisions are presented fairly and have credibility.

Office of Investor Education and Advocacy: Serves inves-
tors who complain to the SEC about investment fraud 
or the mishandling of their investments by securities 
professionals, ensures the views of retail investors 
inform the Commission’s regulatory policies and 
disclosure programs, and works to improve investors’ 
financial literacy. 

Office of International Affairs: Advances international 
regulatory and enforcement cooperation, promotes 
high regulatory standards worldwide, and facilitates 
technical assistance programs in foreign countries.

Office of Administrative Law Judges: Adjudicates allega-
tions of securities law violations.

Office of the Investor Advocate: Provides assistance to 
investors in resolving significant problems they may 
have with the SEC or with SROs, and identifying areas 
in which investors would benefit from changes to 
federal laws or to SEC regulations or SRO rules. 



44   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

Office of Credit Ratings: Administers the rules of the 
Commission with respect to the practices of nationally 
recognized statistical rating organizations (NRSRO) in 
determining ratings; protects the users of credit ratings; 
promotes accuracy in credit ratings issued by NRSROs; 
and ensures that such ratings are not unduly influenced 
by conflicts of interest.

Office of Municipal Securities: Administers the rules of 
the Commission with respect to the practices of munic-
ipal securities brokers and dealers, municipal advisors, 
and investors in, and issuers of, municipal securities. 
The office also coordinates with MSRB on rulemaking 
and enforcement actions.

Office of the Advocate for Small Business Capital  

Formation: Will be created by the SEC as required by 
the SEC Small Business Advocate Act (P.L. 114-284). 
Among other functions, the office will identify needs  
of small businesses and small business investors, and 
how the regulations of the Commission or SROs can  
be changed to better address those needs.



FY 2019 BUDGET REQUEST BY PROGRAM   |   45

OFFICE OF THE CHIEF ACCOUNTANT

(DOLLARS IN THOUSANDS)
FY 2017
Actual

FY 2018
Annualized CR

FY 2019
Request

Full-Time Equivalents 49 50 49

Cost:

Salaries and Benefits $	 14,427 $	 14,616 $	 14,510

Non-Personnel Expenses 3,869 3,574 4,538

Total Costs $	 18,297 $	 18,191 $	 19,048

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

The Office of the Chief Accountant (OCA) is respon-
sible for establishing and interpreting accounting 
and auditing policy to enhance the transparency and 
relevancy of financial reporting for investors. OCA 
works to improve the professional performance of 
public company auditors to ensure that financial 
statements used for investment decisions are presented 
fairly and have credibility. OCA leads the SEC’s efforts 
to oversee accounting standard-setting by the Financial 
Accounting Standards Board (FASB) and auditor 
oversight and standard-setting by the PCAOB, and to 
monitor international accounting standard-setting by 
the International Accounting Standards Board (IASB).

FY 2019 Objectives and Priorities
The Accounting Group will continue to advise on signif-
icant ongoing changes in the accounting and disclosure 
standards developed and issued by the FASB and 
IASB, such as revenue recognition, leases, and financial 
instruments. Also, the Accounting Group will continue 
to consult with companies and auditors regarding the 
application of accounting and disclosure standards, 
including the impact of the comprehensive tax reform 
from the Tax Cuts and Jobs Act of 2017.

The Professional Practice Group (PPG) will continue 
to provide expert advice related to auditing, indepen-
dence, and internal control over financial reporting. 
PPG also assists the Commission in its oversight of 
the PCAOB. PPG primarily provides this advice in 

rulemaking support, overseeing the PCAOB (includ-
ing PCAOB standard-setting), and consultations. In 
addition, PPG has been assisting in PCAOB oversight 
since its formation in the early 2000s. PCAOB 
has reached a relative steady state, but has grown 
tremendously during this time, which results in larger 
oversight activity. 

The Office of the Chief Counsel and Enforcement Liaison 

(OCCEL) will continue to assist ENF on cases involving 
accounting, auditing, and auditor independence. Based 
on the increased number and complexity of cases in 
these areas, OCCEL finds an ever increasing need to 
work with ENF teams at an earlier stage of their  
investigations. In addition, rulemaking activities in  
OCA are expected to increase. Furthermore, OCCEL 
will continue to assist with staff speeches, panel discus-
sions, and briefing statements that involve or relate to 
OCA activity. 

The International Group anticipates continuing monitor-
ing work on international accounting standards. The 
International Group is expecting that implementation 
questions associated with new major standards going 
into effect will cause it to spend additional time on 
interpretive activities. In addition, the IASB is now 
moving forward on fundamental work related to 
disclosure effectiveness, which is an area the Interna-
tional Group wants to closely monitor given the SEC’s 
existing rules and pending rulemaking efforts.



46   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

Workload Data

Activity
FY 2017
Actual

FY 2018
Estimate

FY 2019
Request

Oversight of Accounting and Auditing Standard-Setting    

U.S. Accounting Standard Setter Trustee and Board Appointments 4 5 5

U.S. Accounting Standard-Setting Projects and Interpretations 64 65 65

International Accounting Standard-Setting Projects and Interpretations 54 61 61

U.S. Auditing Oversight (PCAOB) Board Appointments — 5 —

Inspections of PCAOB Programs 1 — —

U.S. Auditing Standards and Other Rules Issued by PCAOB and  
Approved by SEC

— 3 3

International Audit/Ethics Standard-Setting Projects and Interpretations 13 13 11

    

Development of Commission Accounting and Auditing Policies    

SEC Rule Amendments and SEC Staff Announcements and Bulletins 7 12 12

International Organization of Securities Commissions (IOSCO)  
Policy Statements, Consultation Papers, and Reports

1 3 2

    

Interpretation of Accounting Standards, Policies, and Positions    

Resolution of Accounting Issues of SEC Registrants 130 140 130

Discussions of International Accounting Issues 30 49 52

    

Recommendations for Actions on the Qualification of Accountants 
to Practice Before the Commission

   

PCAOB Inspections of Audit Firms Subject to SEC Oversight 273 247 250

Auditor Independence Consultations 205 225 250

    

Supervision of the Procedures for the Commission’s Accounting 
and Auditing Enforcement Activities

   

Consultations on Potential Enforcement Investigations 311 311 311

Rule 102(e) Accountant Reinstatement Applications 26 21 21

    

Assistance with Resolving Differences on Accounting Issues 
Between Registrants and the Commission

   

	 (Included within Interpretation of Accounting Standards,  
Policies, and Positions listed above)

N/A N/A N/A

    

OCA External Outreach and Communication    

Speeches, Panel Discussions, and Meetings with Constituent Groups 143 159 159



FY 2019 BUDGET REQUEST BY PROGRAM   |   47

OFFICE OF INVESTOR EDUCATION AND ADVOCACY

(DOLLARS IN THOUSANDS)
FY 2017
Actual

FY 2018
Annualized CR

FY 2019
Request

Full-Time Equivalents 43 42 42

Cost:

Salaries and Benefits  $	 10,922     $	 10,654  $	 10,766     

Non-Personnel Expenses 8,391      5,793   7,088   

Total Costs  $	 19,313    $	 16,447  $	 17,854   

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

The Office of Investor Education and Advocacy (OIEA) 
seeks to provide individual investors with the informa-
tion they need to make sound investment decisions. 
OIEA administers two primary programs to promote this 
mission: assisting individual investors with complaints 
and inquiries about the securities markets and market 
participants, and conducting educational outreach to 
individual investors. OIEA also helps to inform Commis-
sion policy by advising the Commission and Commission 
staff on various issues from the perspective of the indi-
vidual investor, including with respect to rulemakings, 
Investor Advisory Committee recommendations, and 
through IOSCO’s Committee on Retail Investors.

Research indicates that many retail investors are not 
taking key steps to protect their money from investment 
fraud, including researching the background of an invest-
ment professional before investing. In FY 2019, OIEA 
plans to continue its “Before You Invest, Investor.gov” 
public service campaign focused on helping individuals 
protect themselves from investment fraud, including 
raising awareness about Investor.gov. 

OIEA is seeking one restored position to expand its in- 
vestor education efforts by focusing on initiatives aimed 
at increasing the number of investment professional 
background checks on Investor.gov by retail investors.

Workload Data

Activity
FY 2017
Actual

FY 2018
Estimate

FY 2019
Request

Investor Assistance 

Total Investor Assistance Matters Closed 16,756 16,000 16,000

Percentage of Investor Assistance Matters Closed Within: 

7 Days 65% 62% 62%

30 Days 94% 90% 90%

Investor Education 

Page Views on OIEA Web Pages 1 9,100,000 8,000,000 10,000,000

In-Person Investor Events 146 90 90

Number of Investor Alerts and Bulletins Issued 34 32 32

1	 OIEA implemented technical changes in FY 2016 to help users navigate SEC online investor education material more efficiently, resulting in fewer page 
views. As a result, the target for FY 2017 was changed from 37.5 million to eight million page views. 

http://investor.gov
http://investor.gov


48   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

OFFICE OF INTERNATIONAL AFFAIRS

(DOLLARS IN THOUSANDS)
FY 2017
Actual

FY 2018
Annualized CR

FY 2019
Request

Full-Time Equivalents 55 53 51

Cost:

Salaries and Benefits $	 13,198 $	 13,536 $	 13,159

Non-Personnel Expenses 3,400 3,473 4,771

Total Costs $	 16,598 $	 17,009 $	 17,930

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

The Office of International Affairs (OIA) advances the 
SEC’s mission by promoting international enforcement 
and supervisory cooperation; developing and imple-
menting strategies to further SEC policy interests in 
the regulation and oversight of cross-border securities 
activities; managing and executing the SEC’s partici-
pation in international regulatory bodies; engaging in 
regulatory dialogues with international counterparts; 
and providing technical assistance to strengthen 
partnerships with foreign authorities. 

FY 2019 Objectives and Priorities 
The Regulatory Policy Group will continue to advise 
the Chairman, Commissioners, and staff on strategies 
for advancing the Commission’s objectives in interna-
tional organizations, including the Financial Stability 
Board (FSB) and IOSCO, and to coordinate the 
Commission’s participation in these bodies; promote 
the Commission’s bilateral relationships with other 
jurisdictions and work with foreign authorities to 
address cross-border policy issues that may have an 
impact on U.S. market participants, i.e., the Markets in 
Financial Instruments Directive; and collaborate with 
other divisions and offices with respect to developing 
or operationalizing SEC rulemakings or other policy 
initiatives with cross-border elements.

The International Enforcement Cooperation Group  
will assist ENF in conducting investigations and 
enforcement proceedings with international aspects, 
including where wrongdoers, witnesses, evidence, or 
the proceeds of fraud are located abroad; advise and 
help foreign authorities with their investigations and 
litigation, e.g., where perpetrators, witnesses, evidence, 
or the proceeds of a fraud are located in the United 
States; and move forward the Commission’s policy 
objectives in the international cooperation area, includ-
ing promoting best practices and overcoming obstacles 
with respect to cross-border enforcement-related 
information sharing. Consistent with the Commission’s 
enforcement priorities, which include a focus on retail 
investors and cyber-related misconduct, the Interna-
tional Enforcement Cooperation Group will continue 
to promote initiatives to address frauds that affect 
retail investors such as cross-border pump and dump 
frauds. OIA’s International Enforcement Group will 
also assist ENF to combat cyber-enabled misconduct 
such as market manipulation schemes accomplished  
by foreign hackers and initial coin offering (ICO)- 
related frauds. 



FY 2019 BUDGET REQUEST BY PROGRAM   |   49

The Supervisory Cooperation Group plans to assist SEC 
examination staff in OCIE and OCR on cross-border 
supervisory issues; advise and help foreign regulators 
with supervisory matters involving globally-active 
regulated entities; and develop and implement 
additional cooperation memoranda of understanding 
and other supervisory cooperation arrangements with 
foreign regulatory authorities.

The Technical Assistance Group will continue to build 
capacity and strong relationships with the same foreign 
counterparts the agency relies on for assistance with 
SEC enforcement cases and overseas examinations. In 
response to requests from foreign securities authorities, 
the group will provide technical advice and training; 
review regulatory oversight regimes and suggest 
improvements; and consult on draft legislation,  
regulations, and operational processes and procedures.

Workload Data

Activity
FY 2017
Actual

FY 2018
Estimate

FY 2019
Request

SEC ENF Requests to SEC OIA for International Assistance 1 1,272 1,389 1,506

Responses to Foreign Requests for SEC Enforcement Assistance 1 599 627 655

Number of International Regulatory and Law Enforcement Officials Trained 2 1,837 1,850 1,850

SEC Requests for Supervisory Cooperation Assistance 3 169 174 179

Responses to Foreign Requests for SEC Supervisory Cooperation 
Assistance 4

153 158 163

International Regulatory Initiatives (including regulatory initiatives) 5 144 178 178

1	 OIA’s FY 2018 estimate and FY 2019 request use a linear trend analysis of actual results from the last five fiscal years in combination with FY 2018 Q1  
actual results. The FY 2018 estimate and FY 2019 request to OIA are higher than OIA’s previous submission and the FY 2018 estimate and FY 2019 
request for responses to foreign requests are lower than OIA’s previous submission as a result of such analysis.

2	 OIA’s FY 2018 and FY 2019 figures are contingent on the availability of sufficient domestic and foreign resources.
3	 OIA projects a three percent increase in the number of requests for supervisory cooperation from SEC staff, including OCIE, OCR, and TM.  

The FY 2018 estimate is higher than OIA’s previous submission because OIA used FY 2017 actual results to calculate the FY 2018 estimate.
4	 OIA projects a three percent increase in the number of foreign requests for SEC assistance in supervisory matters. The FY 2018 estimate is higher than 

OIA’s previous submission because OIA used FY 2017 actual results to calculate the FY 2018 estimate.
5	 The Regulatory Policy Unit tracks bilateral and multilateral engagements for the Chairman, Commissioners, and OIA staff that the Regulatory Policy Unit 

coordinates and supports. The Regulatory Policy Unit also supports staff throughout the agency on internal projects with international aspects and  
international projects that are not quantified in this tracking mechanism.



50   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

OFFICE OF ADMINISTRATIVE LAW JUDGES

(DOLLARS IN THOUSANDS)
FY 2017
Actual

FY 2018
Annualized CR

FY 2019
Request

Full-Time Equivalents 13 12 12

Cost:

Salaries and Benefits  $	 2,542       $	 2,472  $	 2,498 

Non-Personnel Expenses 	 648 574  709

Total Costs  $	 3,190      $	 3,046  $	 3,207     

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

The Office of Administrative Law Judges (OALJ) 
supports the SEC’s mission by conducting hearings, 
issuing initial decisions, and adjudicating ancillary 
matters in administrative proceedings. The Commis-
sion initiates an administrative proceeding by issuing 
an order instituting proceedings, which contains ENF’s 
allegations against one or more respondents. In most 
cases, an order instituting proceedings directs that a 
public hearing be held before an administrative law 
judge for the purpose of taking evidence, determining 
whether the allegations are true, and issuing an initial 
decision within a specific time period.

Administrative law judges serve as independent adjudi-
cators. Under the Administrative Procedure Act and 
the Commission’s Rules of Practice, administrative law 
judges conduct public hearings in a manner similar to 
federal bench trials, at locations throughout the United 
States. They preside at and regulate the course of these 
hearings, which may include setting filing deadlines, 
issuing subpoenas, holding prehearing conferences, 
and ruling on motions. Following the hearing and 
consideration of the parties’ post-hearing submis-
sions, the administrative law judge prepares an initial 
decision setting forth his or her factual findings and 
legal conclusions and, where appropriate, determining 
whether sanctions are warranted.

If a respondent fails to file an answer to the order insti-
tuting proceedings, appear at a conference or hearing, 
respond to a dispositive motion, or otherwise defend 
the proceeding, the administrative law judge may issue 
an initial decision finding the respondent in default and 
accepting the allegations as true. In certain proceedings, 
summary disposition, as opposed to a live hearing, may 
be used to resolve all or some of the issues. 

OALJ anticipates the Commission will institute and 
order public hearings in 200 proceedings in FY 2019. 
The exact number and specific nature of these cases 
are unknown. In FY 2018, OALJ expects to dispose of 
many of the new assignments and the 109 proceedings 
recently remanded by the Commission. See Pending 
Admin. Proc., Securities Act of 1933 Release No. 
10440, 2017 SEC LEXIS 3724 (Nov. 30, 2017),  
www.sec.gov/litigation/opinions/2017/33-10440.pdf. 

OALJ expects that with its currently allocated staff 
levels it will be capable of handling the 200 proceedings 
anticipated in FY 2019. Two hundred proceedings 
exceeds the 185 proceedings assigned in 2017, but 
is less than the number of cases assigned per year in 
2014–2016 and the number of cases anticipated in  
FY 2018.

https://www.sec.gov/litigation/opinions/2017/33-10440.pdf


FY 2019 BUDGET REQUEST BY PROGRAM   |   51

Workload Data

Activity
FY 2017
Actual

FY 2018
Estimate

FY 2019
Request

Proceedings Inventory 

Pending Disposition Beginning of Year 84 101 101

Ordered for Hearing 185 300 200

Disposed 168 300 200

Canceled Before Hearing 52 150 50

Canceled After Hearing 1 — —

Initial Decision Issued 115 150 150

Pending Disposition End of Year 101 101 101



52   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

OFFICE OF THE INVESTOR ADVOCATE

(DOLLARS IN THOUSANDS)
FY 2017
Actual

FY 2018
Annualized CR

FY 2019
Request

Full-Time Equivalents 11 11 12

Cost:

Salaries and Benefits $	 2,720 $	 2,747 $	 3,035

Non-Personnel Expenses 1,631 2,340 2,536

Total Costs $	 4,350 $	 5,087 $	 5,571

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

The mandate for the Office of the Investor Advocate 
(OIAD) is set forth in Section 4(g) of the Securities 
Exchange Act of 1934. The office is responsible for, 
among other things, identifying areas in which inves-
tors would benefit from changes to federal laws, SEC 
regulations, or the rules of SROs, and for providing 
assistance to investors in resolving significant problems 
they may have with the SEC or SROs.

Investor Advocacy 
Consistent with the requirements of Section 4(g), 
the office 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
The office is responsible for submitting two reports 
to Congress per year. 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. The 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.

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 proce-
dures and make recommendations to encourage the 
investing public and other interested persons to submit 
questions to the Investor Advocate regarding compli-
ance 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. 



FY 2019 BUDGET REQUEST BY PROGRAM   |   53

Investor Testing
OIAD uses investor testing and other outreach 
efforts, as appropriate, to gather input on rulemak-
ing initiatives and better understand investor-based 
informational needs. OIAD is currently conducting 
monthly online polls, a research project to assess 
the current state of investor awareness concerning 
the different types of financial professionals and the 
associated standards of care, and a research project 
on mutual fund fee disclosure. These research projects 
entail surveys coupled with focus groups and one-on-
one interviews. OIAD anticipates additional research 
projects will develop in FY 2019 to support the 
Commission’s rulemaking agenda. As a result, OIAD 
has an acute need for additional staff with the expertise 

and skills necessary to conduct high-quality investor 
research and analysis. The restored position requested 
in FY 2019 would provide this type of expertise  
and directly align with the Commission’s strategic  
goals by strengthening its ability to evaluate retail 
investor issues.

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.

Workload Data

Activity
FY 2017
Actual

FY 2018
Estimate

FY 2019
Request

Ombudsman 

Investor Matters 226 275 325

Investor Contacts 1,331 1,500 1,650

Outreach Events/Speeches 22 18 20

Investor Advocacy

SEC Rulemakings Reviewed 16 20 25

SRO Rulemakings Reviewed 444 450 450

Policy Recommendations  to SEC, SROs, or Congress 2 8 8

Outreach Events/Speeches 37 36 36

Investor Advisory Committee Support 

In-Person Committee Meetings 4 5 4



54   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

OFFICE OF CREDIT RATINGS

(DOLLARS IN THOUSANDS)
FY 2017
Actual

FY 2018
Annualized CR

FY 2019
Request

Full-Time Equivalents 44 41 41

Cost:

Salaries and Benefits $	 11,371 $	 10,489 $	 10,599

Non-Personnel Expenses 5,194 4,315 5,226

Total Costs $	 16,565 $	 14,804 $	 15,825

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

The Office of Credit Ratings (OCR) is charged with 
administering Commission rules with respect to the 
practices of 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 policy oversight 
of NRSROs and conducts examinations.

As required under the Dodd-Frank Act, OCR staff 
must possess knowledge of and expertise in corporate, 
municipal and structured debt finance. 

FY 2019 Request
OCR seeks to restore two securities compliance 
examiner positions. The first position would 
provide OCR with the opportunity to build out its 
senior management team in support of the office’s 
examination and monitoring responsibilities and the 
OCR-DERA Credit Ratings Analytical Data Unit.  

This unit would allow OCR to perform in-depth 
analyses of models against data sets and data feeds to 
strengthen OCR’s oversight of NRSROs. 

The second restored position would strengthen OCR’s 
examination and monitoring programs and allow 
for more detailed analyses of rating files, documents, 
methodologies, and policies and procedures. The 
examination and monitoring of NRSROs for compli-
ance with the federal securities laws and Commission 
rules would continue to account for the most signif-
icant portion of OCR’s workload in any fiscal year. 
OCR will further monitor and review registrants’ 
technological initiatives, cybersecurity governance, and 
risk assessment processes relating to access rights, data  
loss prevention, vendor management, training, and 
incident response. In addition, OCR will continue  
to evaluate and monitor credit models quantitatively 
and qualitatively, and will initiate specialized examina-
tions to conduct sweeps and targeted examinations  
as appropriate.



FY 2019 BUDGET REQUEST BY PROGRAM   |   55

Workload Data

Activity
FY 2017
Actual

FY 2018
Estimate

FY 2019
Request

Annual Examinations and Other Examination Compliance Activities 45 44 45

Studies, Reports, and Related Matters 28 31 33

Regulatory and Legislative Initiatives 8 5 8

Orders and No-Action Letters 1 5 7

Monitoring Meetings 34 36 38

Form NRSRO – Initial Applications and Annual Certifications 57 51 58

Enforcement/TCR 63 60 63

International Activities 112 114 115

Business Processes 37 39 41



56   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

OFFICE OF MUNICIPAL SECURITIES

(DOLLARS IN THOUSANDS)
FY 2017
Actual

FY 2018
Annualized CR

FY 2019
Request

Full-Time Equivalents 9 10 10

Cost:

Salaries and Benefits $	 2,211 $	 2,302 $	 2,326

Non-Personnel Expenses 540 522 634

Total Costs $	 2,750 $	 2,824 $	 2,960

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

The Office of Municipal Securities (OMS) oversees the 
$3.8 trillion municipal securities market and admin-
isters the Commission’s rules pertaining to municipal 
securities brokers and dealers, municipal advisors, 
investors in municipal securities, and municipal issuers. 
OMS also coordinates with MSRB on rulemaking and 
enforcement actions.

OMS advises the Commission on policy matters 
relating to the municipal securities market, and is 
responsible for policy development, coordination, and 
implementation of Commission initiatives to improve 
the municipal securities market. OMS provides 
technical assistance to other SEC offices and divisions, 
including OCIE and ENF. OMS is responsible for 
reviewing and processing all MSRB proposed rule 
changes on behalf of the Commission. OMS also 
regularly engages in public awareness and outreach 
activities, and closely monitors current issues in the 
municipal securities market.

In FY 2019, OMS will continue to coordinate the 
SEC’s municipal securities activities, administer SEC 
rules relating to the municipal securities market, 
oversee MSRB rulemaking, inform the Commission 
on current market issues, advise the Commission on 
policy matters relating to the municipal securities 
market, and provide technical assistance to other SEC 
offices and divisions. In addition, OMS will continue 
to lead semiannual meetings with MSRB and FINRA 
regarding the municipal securities market, as required 
by the Dodd-Frank Act; meet with MSRB and FINRA 
staff regularly to discuss rulemaking, examination, and 
enforcement activities; meet with Internal Revenue 
Service staff; and coordinate with other regulators as 
needed. OMS will also continue to work closely with 
the municipal securities industry to educate market 
participants about the federal securities laws applicable 
to the municipal securities market. 



FY 2019 BUDGET REQUEST BY PROGRAM   |   57

Workload Data

Activity
FY 2017
Actual

FY 2018
Estimate

FY 2019
Request

SRO Proposed Rule Changes Reviewed 1 9 9 12

SEC Rulemaking and Interpretive Actions 1 2 2

Interpretive, Exemptive, and No-Action Request Letters Closed 2 2 2

Reviews of Potential Enforcement Actions 22 23 23

Congressional, Governmental, Industry, and Public  
Correspondence and Inquiries 2 

580 650 650

Public Awareness and Market Outreach 28 32 32

Municipal Advisors 3

Registrants 4 651 596 606

Registration Applications Filed 43 45 50

Registration Amendments Filed 599 1,192 1,212

Registrations Withdrawn or Canceled 5 60 100 40

1  	 This data includes filings, pre-filings, and amendments reviewed.
2  	 This data combines correspondence and telephone/internet inquiries.
3  	 This data reflects the expanded responsibilities assigned to the Commission for oversight of municipal advisors (firms and sole proprietors).  

by the Dodd-Frank Act. In addition, there are approximately 3,675 Form MA-Is on file with the Commission in relation to natural persons engaged  
in municipal advisory activities.

4   These figures reflect all active MA registrations as of September 30 of the applicable fiscal year.
5  	 These figures reflect the number of registration withdrawals or cancellations effective as of September 30 of the applicable fiscal year.



58   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

OFFICE OF THE ADVOCATE FOR SMALL BUSINESS 
CAPITAL FORMATION

(DOLLARS IN THOUSANDS)
FY 2017
Actual

FY 2018
Annualized CR

FY 2019
Request

Full-Time Equivalents — 1 3

Cost:

Salaries and Benefits $	 — $	 197 $	 719

Non-Personnel Expenses — 156 273

Total Costs $	 — $	 353 $	 992

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

The SEC is in the process of establishing the Office 
of the Advocate for Small Business Capital Forma-
tion (OASB), as required by the SEC Small Business 
Advocate Act (P.L. 114-284), to help small businesses 
and investors resolve significant problems incurred 
with the SEC or SROs. OASB conducts outreach 
with small businesses and small business investors to 
solicit views on relevant capital formation issues and 
analyzes the impact of proposed regulations and rules 
on small businesses and small business investors. OASB 
also proposes changes in SEC regulations that aim to 

mitigate problems and promote the interests of small 
businesses and small business investors. In addition, 
OASB will consult with the Investor Advocate on 
issues related to small businesses and small business 
investors. 

The SEC is currently engaged in the process of hiring 
the advocate for Small Business Capital Formation, 
who will oversee this new office. In FY 2019, the  
SEC requests five additional positions to carry out  
the functions of the office.



FY 2019 BUDGET REQUEST BY PROGRAM   |   59

AGENCY DIRECTION AND ADMINISTRATIVE SUPPORT

(DOLLARS IN THOUSANDS)
FY 2017
Actual

FY 2018
Annualized CR

FY 2019
Request

Full-Time Equivalents:

Agency Direction

Office of Executive Staff  28  35  31 

Office of Public Affairs  15  21  21 

Office of the Secretary  24  25  24 

Subtotal  67  81  76 

Administrative Support

Office of the Chief Operating Officer  15  13  14 

Office of Financial Management  98  95  93 

Office of Information Technology  171  173  177 

Office of Human Resources  120  107  105 

Office of Acquisitions  57  56  55 

Office of Support Operations  100  94  92 

Office of Strategic Initiatives  15  29  29 

Office of the Ethics Counsel  18  19  19 

Office of Minority and Women Inclusion  9  9  9 

Office of Equal Employment Opportunity  14  15  15 

Subtotal  617  610  608 

Total Full-Time Equivalents  684  691  684 

Cost: 

Salaries and Benefits $	 161,993 $	 156,972 $	 156,802

Non-Personnel Expenses 52,464 53,996 65,405

Total Costs $	 214,457 $	 210,968 $	 222,207

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

This section details the SEC’s agency-wide executive 
activities, operations, and administrative functions. 

Agency Direction: Includes the Chairman and Commis-
sioners’ Offices, Office of Legislative and Intergovern-
mental Affairs (OLIA), Office of Public Affairs (OPA), 
and Office of the Secretary (OS). 

Office of the Chief Operating Officer: Provides executive 
leadership by directing the management and coordina-
tion of the SEC’s core mission support activities. 

Office of the Ethics Counsel: Administers the Commis-
sion’s Ethics Program and interprets the SEC’s Supple-
mental Ethics Rules as well as federal government-wide 
ethics laws, rules, and regulations. 

Office of Minority and Women Inclusion: Develops 
standards for all agency matters relating to diversity  
in management, employment, and business activities. 

Office of Equal Employment Opportunity: Strives to 
enhance access to employment opportunities for the 
best and brightest talent, and to foster an equitable 
work environment in which employees can perform  
the SEC’s mission.60   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

AGENCY DIRECTION

(DOLLARS IN THOUSANDS)
FY 2017
Actual

FY 2018
Annualized CR

FY 2019
Request

Full-Time Equivalents:

Office of Executive Staff  28  35  31 

Office of Public Affairs  15  21  21 

Office of the Secretary  24  25  24 

Total Full-Time Equivalents  67  81  76 

Cost: 

Salaries and Benefits $	 15,383 $	 18,858 $	 17,758

Non-Personnel Expenses 7,099 8,289 9,747

Total Costs $	 22,482 $	 27,147 $	 27,504

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

Agency Direction includes the Commissioners and  
their staff, as well as Office of Legislative and  

Intergovernmental Affairs, Office of Public Affairs,  
and Office of the Secretary.



FY 2019 BUDGET REQUEST BY PROGRAM   |   61

EXECUTIVE STAFF

(DOLLARS IN THOUSANDS)
FY 2017
Actual

FY 2018
Annualized CR

FY 2019
Request

Full-Time Equivalents 28 35 31

Cost: 

Salaries and Benefits $	 7,061 $	 8,967 $	 8,022

Non-Personnel Expenses 2,162 2,041 2,402

Total Costs $	 9,223 $	 11,008 $	 10,424

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

The Executive Staff is comprised of the Chairman, the 
Commissioners, their staff, and OLIA. 

The Chairman serves as the agency’s senior responsible 
executive, overseeing all aspects of agency opera-
tions and setting the agency’s substantive policy and 
rulemaking agenda. In addition, the Chairman 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; overseeing SROs in the securities, accounting, 
and auditing fields; and coordinating U.S. securities 
regulation with federal, state, and foreign authori-
ties. The staff in the Chairman’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 Congres-
sional 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 infor-
mation 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. 

Workload Data

Activity
FY 2017
Actual

FY 2018
Estimate

FY 2019
Request

Commission Meetings 87 91 96

Calendar Items 565 593 623

Seriatim Actions 485 509 534

Congressional Testimonies 4 6 6

Chairman’s and Congressional Correspondence 1,110 1,500 1,500



62   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

OFFICE OF PUBLIC AFFAIRS

(DOLLARS IN THOUSANDS)

FY 2017
Actual

FY 2018
Annualized CR

FY 2019
Request

Full-Time Equivalents 15 21 21

Cost:

Salaries and Benefits $	 3,395 $	 4,619 $	 4,667

Non-Personnel Expenses 1,370 2,205 2,444

Total Costs $	 4,766 $	 6,823 $	 7,111

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

The Office of Public Affairs (OPA) assists the Commis-
sion with making the work of the SEC open to the 
public, understandable to investors, and accountable 
to taxpayers. The office helps every other SEC division 
and office accomplish the agency’s mission—to protect 
investors, maintain fair, orderly, and efficient markets, 
and facilitate capital formation. 

OPA leverages technology and multimedia capabil-
ities to deliver news, data, and other information 
to inform the public and facilitate the ability of the 
public to interact with the SEC. The group maintains 
the agency’s website, SEC.gov, which is among the 
most-visited websites in the federal government. OPA 
also manages content on the SEC’s social media and 
other digital platforms using the forms and formats 

investors prefer and rely on. Additionally, OPA helps 
enhance SEC workforce efficiency, collaboration, 
and engagement by executing strategic communica-
tion initiatives and facilitating access to knowledge 
databases and systems.

OPA will continue these activities in FY 2019, includ-
ing continuous improvements and customizations 
to the SEC’s modernized intranet site that will be 
deployed in FY 2018 to fit individual staff needs and 
further enhance staff performance. In doing so, OPA 
will reduce costs and increase efficiency by working 
with SEC divisions and offices to consolidate their 
content from multiple proprietary software platforms 
to a single, unified open source platform.

Workload Data

Activity
FY 2017
Actual

FY 2018
Estimate

FY 2019
Request

News Releases and Statements 328 385 385

Email and Mobile Bulletins 4,453 4,500 4,500

Social Media Posts 1 6,892 7,500 8,000

Number of SharePoint Top-Level Sites, Web Pages, or Applications 
Created and/or Administered 2

21 15 15

Number of Internal Communications Artifacts, including Articles, 
Reminders, and Daily Emails Distributed

3,804 4,348 4,600

Website Content Updates 32,884 35,000 35,000

Number of Digital Signage Slides, Posters, and Kiosk Announcements 459 480 575

1	 Social media posts include those done by the individual divisions/offices on SEC-official accounts (10 Twitter accounts, 2 Facebook accounts, 1 Flickr 
account, 1 YouTube account, 1 Pinterest account, and 1 LinkedIn account). See www.sec.gov/opa/socialmedia

2	 Number only represents the top-level (i.e., first level/parent) sites. A total of nearly 490 subsites, pages, and/or workflows comprise these sites.

http://www.sec.gov/opa/socialmedia
www.sec.gov


FY 2019 BUDGET REQUEST BY PROGRAM   |   63

OFFICE OF THE SECRETARY

(DOLLARS IN THOUSANDS)
FY 2017
Actual

FY 2018
Annualized CR

FY 2019
Request

Full-Time Equivalents 24 25 24

Cost:

Salaries and Benefits $	 4,927 $	 5,272 $	 5,068

Non-Personnel Expenses 3,566 4,043 4,901

Total Costs $	 8,494 $	 9,316 $	 9,969

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

The Office of the Secretary (OS) reviews all doc-
uments issued by the Commission, schedules and 
coordinates Commission meetings, prepares and 
maintains records of Commission actions, and advises 
the Commission and staff about practice and proce-
dure. OS directly supports the Commission staff and 
receives and tracks filings in administrative proceed-
ings. OS is responsible for the public dissemination of 
Commission documents, such as notices, orders, and 
rulemakings and, in collaboration with OPA, manag-
ing the web content management system.

Because all enforcement actions, examination reports, 
and rulemakings flow through OS, the agency’s 
rulemaking agenda and enforcement program will 
have a significant impact on OS workload in FY 
2019. In recent years, OS has generally experienced 
significantly increased workload levels. The higher 

workload OS has experienced aligns with the agency’s 
increased enforcement actions and rulemaking activity 
during that timeframe. In addition, OS has also 
focused resources on improving operational efficiency 
and effectiveness and the development of new infor-
mation technology (IT) systems designed to replace 
legacy systems or improve the services OS provides to 
the public.

 In FY 2019, OS will continue to support Commission 
operations. OS expects that the workload directly tied 
to supporting Commission operations will remain 
steady or slightly above the workload levels OS expe-
rienced in the last few years. In FY 2019, OS will also 
continue to improve business operations and enhance 
recently implemented IT systems to further improve 
OS efficiency and effectiveness.

Workload Data

Activity
FY 2017
Actual

FY 2018
Estimate

FY 2019
Request

Releases Processed 3,412 4,500 4,700

Public Comment Letters Processed 22,000 24,000 26,000

Documents Posted on Website 5,335 5,400 5,450

Administrative Proceedings Items Processed 5,066 5,200 5,350

Service of Process – Administrative Proceedings 8,169 9,800 10,045



64   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

OFFICE OF THE CHIEF OPERATING OFFICER

(DOLLARS IN THOUSANDS)
FY 2017
Actual

FY 2018
Annualized CR

FY 2019
Request

Full-Time Equivalents:

Office of the Chief Operating Officer  15  13  14 

Office of Financial Management  98  95  93 

Office of Information Technology  171  173  177 

Office of Human Resources  120  107  105 

Office of Acquisitions  57  56  55 

Office of Support Operations  100  94  92 

Office of Strategic Initiatives  15  29  29 

Total Full-Time Equivalents  576  567  565 

Cost: 

Salaries and Benefits $	 136,952 $	 127,567 $	 128,387

Non-Personnel Expenses 41,875 42,126 51,539

Total Costs $	 178,827 $	 169,693 $	 179,926

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

The Office of the Chief Operating Officer (OCOO) 
develops, coordinates, and 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 six offices within OCOO: 
•	 Office of Financial Management (OFM) 
•	 Office of Information Technology (OIT) 
•	 Office of Human Resources (OHR) 
•	 Office of Acquisitions (OA) 
•	 Office of Support Operations (OSO) 
•	 Office of Strategic Initiatives (OSI)

OCOO in FY 2018 has also established a new chief 
risk officer position to coordinate the agency’s risk 
management functions, and a small front office staff 
who perform specialized activities and functions to 
support the SEC’s mission.



FY 2019 BUDGET REQUEST BY PROGRAM   |   65

OFFICE OF THE CHIEF OPERATING OFFICER  
(FRONT OFFICE)

(DOLLARS IN THOUSANDS)
FY 2017
Actual

FY 2018
Annualized CR

FY 2019
Request

Full-Time Equivalents 15 13 14

Cost:

Salaries and Benefits $	 3,468 $	 2,728 $	 3,016

Non-Personnel Expenses 2,038 1,392 2,821

Total Costs $	 5,506 $	 4,120 $	 5,837

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

The front office of the Office of the Chief Operating 
Officer (OCOO) oversees and coordinates the  
activities of the six component offices described in 
subsequent pages. 

Chief Risk Officer, Enterprise Risk and Internal Controls, 

and Audit Coordination and Follow-up: The OCOO 
front office will be home to the agency’s chief risk 
officer (CRO) who will coordinate the agency’s 
enterprise risk management functions, as required 
under OMB Circular A-123. The CRO will be respon-
sible for the agency’s internal controls over operations 
and coordinating the annual management assurance 
statements. 

Small Office Managing Executive Support: OCOO 
will continue to support small offices throughout the 
agency by providing administrative and management 
support to help those offices focus on their specific 
missions.

FY 2019 Request 
The OCOO requests two restored positions to further 
support establishment of the CRO and enhance risk 
management programs. Specifically, this request 
would include initiatives to expand the management 
of enterprise-wide risks such as risks identified by 
audit organizations, and enhance the agency’s internal 
control program.

Workload Data

Activity
FY 2017
Actual

FY 2018
Estimate

FY 2019
Request

Number of Audits Facilitated 35 35 35

Number of Projects and Operational Activities Supported 111 102 102



66   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

OFFICE OF FINANCIAL MANAGEMENT

(DOLLARS IN THOUSANDS)
FY 2017
Actual

FY 2018
Annualized CR

FY 2019
Request

Full-Time Equivalents 98 95 93

Cost:

Salaries and Benefits $	 21,059 $	 21,330 $	 21,035

Non-Personnel Expenses 6,016 5,789 7,001

Total Costs $	 27,074 $	 27,119 $	 28,036

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

The Office of Financial Management (OFM) is respon-
sible for the SEC’s financial and budgetary operations. 
Specifically, OFM oversees the agency’s financial 
systems; prepares financial statements and reports; 
maintains the formulation and execution of the SEC’s 
annual budget; coordinates the agency’s performance 
and cost reporting; and manages internal controls over 
financial reporting.

During FY 2019, OFM will continue to improve 
the efficiency and effectiveness of the SEC’s financial 
systems and processes as well as support the necessary 
rulemaking efforts to tag registration fee data to 
automate a highly manual review process. OFM also 
plans to continue the development and implementation 
of a Disgorgement and Penalty System. OFM has 
completed the implementation of the EDGAR Fee 
System Modernization and will continue working to 
refine the system.

Workload Data

Activity
FY 2017
Actual

FY 2018
Estimate

FY 2019
Request

Accounting and Finance 

Quarterly/Annual Financial Statements Issued 1 36 36 36

Financial Transactions Analyzed 2 7,211,022 7,200,000 7,200,000

Analysis and Reconciliation Reports Prepared 3 6,489 6,554 6,619

Planning and Budget

Number of Conference Requests Submitted in AERS 83 83 83

Percent of Reserve Fund Letters Delivered to Congress on Time  93% 100% 100%

1 	 This workload metric includes the five required financial statements—Balance Sheet, Statement of Net Cost, Statement of Changes in Net Position, 
Statement of Budgetary Resources, and the Statement of Custodial Activity—on a quarterly and annual basis (20 statements total); and the four Investor 
Protection Fund financial statements required on a quarterly and annual basis (16 statements total). This metric does not include the government-wide 
financial statements.

2 	 This workload metric captures all financial transactions processed in the financial system and analyzed by SEC staff.
3	 This workload metric accounts for all analysis and reconciliation reports prepared during the review of transactions.



FY 2019 BUDGET REQUEST BY PROGRAM   |   67

OFFICE OF INFORMATION TECHNOLOGY

(DOLLARS IN THOUSANDS)
FY 2017
Actual

FY 2018
Annualized CR

FY 2019
Request

Full-Time Equivalents 171 173 177

Cost:

Salaries and Benefits $	 40,939 $	 42,813 $	 44,301

Non-Personnel Expenses 18,700 21,818 25,410

Total Costs $	 59,639 $	 64,631 $	 69,711

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

Technology, data, and analytics are critical to the 
mission of the SEC and its ability to deliver informa-
tion to the public. The increasing size and complexity 
of the U.S. capital markets require the SEC to more 
efficiently leverage technology to streamline operations 
and increase the effectiveness of the agency’s programs. 

The Office of Information Technology (OIT) is advanc-
ing a robust cybersecurity program to strengthen the 
agency’s data management capabilities and migrate 
select applications and workloads to secure cloud 
environments. 

FY 2019 Request
In support of these efforts, the SEC is seeking an 
additional $45 million to fund critical requirements, 
including:
• Continuing the development of advanced analytics 

solutions that provide new capabilities to detect and 
expose suspicious behavior in high frequency trading 
and other complex trading areas across markets;

• Improving storage, processing, security, and manage-
ment of large volumes of data, including the agency’s 
e-Discovery program, which is approaching one 
petabyte of data;

• Modernizing the SEC’s infrastructure and computing 
environment to enhance security, improve perfor-
mance, and streamline delivery; and

• Improving the SEC’s ability to analyze fixed income 
market data. 

OIT is also focused on enhancing cybersecurity efforts 
to prevent threats, which pose risks to investors, 
financial services firms, markets, and the SEC itself. 

These efforts build on the significant progress made 
over the past several years in modernizing technology 
systems. OIT supports the Commission and staff of 
the SEC in all aspects of IT. OIT has overall manage-
ment responsibility for the Commission’s IT program, 
including application development, infrastructure 
operations and engineering, user support, IT program 
management, capital planning, security, and enterprise 
architecture. OIT operates the EDGAR system, which 
electronically receives, processes, and disseminates 
more than 500,000 financial statements and other 
corporate filings every year. OIT also maintains a 
dynamic and robust website that receives more than 18 
billion page views annually. The website provides free 
public access to the EDGAR database and contains a 
wealth of information about the Commission and the 
securities industry.

OIT is also requesting 16 additional positions to be 
applied within the areas of cybersecurity, data manage-
ment, and governance. OIT intends to expand its cloud 
and data management capabilities and enhance its 
cybersecurity posture by continuing the buildout of 
the SEC’s information security defenses and monitor-



68   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

ing capabilities to ensure the appropriate controls, 
policies, and procedures are in place to safeguard the 
Commission. The requested positions would allow 
OIT to continue focusing on service delivery to ensure 
internal business partners obtain the most value from 

technology investments. These positions would allow 
OIT to meet increasing internal and external demand 
for data with secure, efficient technology solutions that 
expand the Commission’s capability to detect fraud 
and suspicious activity.

Workload Data

Activity
FY 2017
Actual

FY 2018
Estimate

FY 2019
Request

EDGAR Filings, Disclosure, and Review 

Online Searches for EDGAR Filings (in millions) 14,899 14,933 16,389

Number of Electronic Filings Received (in millions) 1.76 1.8 1.9

Internal Process Improvements and Employee Productivity 

User Requests for Helpdesk Assistance 167,548 165,000 165,000

Amount of Network-Based Storage (Terabytes) 21,915 24,000 25,200

Network Users 6,254 6,800 6,800

Information Security and Disaster Recovery 

Percentage of Major Systems Certified and Accredited 86% 94% 94%

Technical Support – Internet and Email Inquiries 1 135 N/A N/A

Technical Support – Telephone Inquiries 1 27,581 N/A N/A

1	 Technical Support measures moved to OSI in 2018.



FY 2019 BUDGET REQUEST BY PROGRAM   |   69

OFFICE OF HUMAN RESOURCES

(DOLLARS IN THOUSANDS)
FY 2017
Actual

FY 2018
Annualized CR

FY 2019
Request

Full-Time Equivalents 120 107 105

Cost:

Salaries and Benefits $	 38,095 $	 23,513 $	 23,240

Non-Personnel Expenses 6,598 5,887 7,248

Total Costs $	 44,692 $	 29,399 $	 30,488

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

The Office of Human Resources (OHR) provides 
leadership for the strategic management of the SEC’s 
human capital in order to enhance the SEC’s perfor-
mance through effective alignment and management 
of human capital. OHR consults with management, 
administers programs, establishes policies, and ensures 
compliance with federal regulations. 

OHR develops, implements, and evaluates the 
Commission’s human capital programs and policies for 
the following areas:
•	 Recruitment, staffing, and retention
•	 Position management and classification
•	 Compensation administration
•	 Benefits counseling and processing
•	 Leadership and employee development

•	 Performance management and awards
•	 Labor relations
•	 Disability program
•	 Work-life programs
•	 Telework
•	 Employee records processing and maintenance

OHR’s FY 2019 allocation will further the strategic 
management of the SEC’s human capital by attract-
ing and retaining a diverse and talented workforce; 
administering programs to enhance employee engage-
ment and leadership development; implementing 
advanced technologies to enhance and streamline work 
processes; and establishing policies and procedures 
to ensure compliance with federal regulations and 
negotiated agreements.

Workload Data

Activity
FY 2017
Actual

FY 2018
Estimate

FY 2019
Request

AskHR Inquiries 3,183 13,564 14,000

Personnel Actions Processed 1 22,530 22,530 23,205

Recruitment Actions 118 209 212

Training Sessions Held 940 830 830

Number of Training Session Attendees 33,298 28,000 28,000

Studies, Reviews, and Policies Issued 538 547 564

1	 Comparative analysis of end Q2, FY 2017. Assumptions are very conservative and based on a fiscal outlook that includes a flat budget with limited  
hiring and normal and/or induced attrition, i.e., Voluntary Early Retirement Authority and Voluntary Separation Incentive Payments. These also account 
for personnel actions processing for regular and recurring actions associated with current employees such as career ladder promotions, career tenure 
changes, awards, etc.



70   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

OFFICE OF ACQUISITIONS

(DOLLARS IN THOUSANDS)
FY 2017
Actual

FY 2018
Annualized CR

FY 2019
Request

Full-Time Equivalents 57 56 55

Cost:

Salaries and Benefits $	 11,473 $	 12,047 $	 11,914

Non-Personnel Expenses 2,667 2,361 2,955

Total Costs $	 14,140 $	 14,408 $	 14,868

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

The Office of Acquisitions (OA) is responsible for 
procuring all goods and services—except real property 
and employee training—for the SEC. OA provides 
oversight of the Government Purchase Card (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, 
closing out contracts, and the implementation and 
enforcement of 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 the 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 with respect to numer-
ous federal programs. 

In early FY 2018, OA further strengthened internal 
controls over the contractual aspects of financial 
reporting. OA also focused on enhancements for the 
Electronic Contract File (eFile) Project, which resulted 
in improved contract administration, greater trans-
parency, and improved reporting. OA’s focal point in 
early FY 2018 was to make sure CORs received proper 
training and enforced their use of eFile. The redesign 
for the OA Customer Support SharePoint site was 
implemented, providing OA customers access to all 
documents and information required for the acquisi-
tion of supplies and services. In FY 2019, OA plans to 
continue the COR Improvement Initiative to create a 
more comprehensive COR Program that will provide 
efficient and functional control, transparency, and 
management of the COR Program across the SEC. 



FY 2019 BUDGET REQUEST BY PROGRAM   |   71

Workload Data

Activity
FY 2017
Actual

FY 2018
Estimate

FY 2019
Request

Procurement Actions (Contracts and Purchase Orders) 2,530 2,500 2,500

Total Value of Contracts with Business Funded by SEC $	 406,721,133 $	 407,000,000 $	 407,000,000

Additional Value of Interagency Agreements Obligated  
(in dollars) 

$	 24,959,993 $	 25,000,000 $	 25,000,000

GPC Cardholders Audited 115 115 115

Closeout Actions Processed 790 750 750

Dollars Recovered for Reuse (Closeouts & ULO De-Obligations) $	 35,000,000 $	 25,000,000 $	 25,000,000

CORs Managed 460 460 465

Small Business Actions Processed 1,560 1,500 1,500

Dollars Spent with Small Business $	 214,836,658 $	 210,000,000 $	 210,000,000

Percent Small Business Dollars  
(23% Federal-Wide Minimum Goal) 

56.00% 55.00% 55.00%

Multi-Agency Collaborative Actions 1,166 1,170 1,170

Multi-Agency Contract Value Awarded (in dollars) $	 289,183,630 $	 289,000,000 $	 289,000,000



72   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

OFFICE OF SUPPORT OPERATIONS

(DOLLARS IN THOUSANDS)
FY 2017
Actual

FY 2018
Annualized CR

FY 2019
Request

Full-Time Equivalents 100 94 92

Cost:

Salaries and Benefits $	 18,700 $	 18,717 $	 18,394

Non-Personnel Expenses 5,029 3,982 4,980

Total Costs $	 23,730 $	 22,699 $	 23,374

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

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 and Privacy 
Acts (FOIA), 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.

In FYs 2018 and 2019, the office will work with the 
General Services Administration (GSA) to support 
GSA’s procurement of new leases for both the SEC’s 
headquarters and its New York Regional Office. 

Workload Data

Activity
FY 2017
Actual

FY 2018
Estimate

FY 2019
Request

Records Management – Official Certifications 1,918 2,014 2,115

Records Management – Document Requests 801 841 883

FOIA Requests Carried Forward from Prior FYs 565 559 559

New FOIA/PA Requests Received 13,063 13,500 14,000

FOIA/PA Requests Completed 13,069 13,200 13,500

Security Services – Interim Suitability Determinations Made 2,616 2,050 2,050

Security Services – HSPD-12 Credentials Issued 2,499 1,730 1,800

Security Services – HSPD-12 Credential Certificates Updated 1,113 1,224 1,225

Print Production (millions of pages) 2.4 2.4 2.4



FY 2019 BUDGET REQUEST BY PROGRAM   |   73

OFFICE OF STRATEGIC INITIATIVES

(DOLLARS IN THOUSANDS)
FY 2017
Actual

FY 2018
Annualized CR

FY 2019
Request

Full-Time Equivalents 15 29 29

Cost:

Salaries and Benefits $	 3,219 $	 6,419 $	 6,487

Non-Personnel Expenses 828 898 1,125

Total Costs $	 4,046 $	 7,317 $	 7,611

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

The Office of Strategic Initiatives (OSI) provides exec-
utive-level oversight for the ongoing transformation 
of specific functions and programs to include business 
ownership of EDGAR and the respective EDGAR 
Redesign (ERD) Program initiative.

EDGAR Business Owner/Program Office
The EDGAR Program Office (EPO) provides opera-
tional support to the EDGAR business owner and is 
responsible for coordinating EDGAR issues that arise 
from filer interactions as well as providing coordina-
tion between SEC divisions/offices to resolve EDGAR- 
related issues. The EPO also serves as a business part-
ner to OIT and represents the business interests of the  
SEC’s divisions/offices in the EDGAR software devel-
opment lifecycle.

EDGAR Redesign Program
ERD is a multi-year, cross-SEC initiative to develop  
and deliver the next generation electronic disclosure 
system. This effort is aimed toward making it easier 
for registrants to fulfill their disclosure responsibilities 
through the EDGAR system, for investors to find use-
ful disclosure information, and for the SEC to manage  
the system.

Information Services and Data
OSI is responsible for managing the Commission’s 
steady-state budget and contract actions, in coordina-
tion with SEC’s OA for purchasing data and informa-
tion used in support of the SEC’s divisions and offices. 
This includes data used in analytics, electronic infor-
mation services, and physical information collections 
across the SEC. 



74   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

Workload Data

Activity
FY 2017
Actual

FY 2018
Estimate

FY 2019
Request

EDGAR Business Owner/Program Office

EDGAR Development Releases 20 12 8

EDGAR Infrastructure Releases 4 4 4

EDGAR Filer Manual Seriatim Updates 5 5 4

Technical Support – Internet and Email Inquiries 1 N/A 150 175

Assistance and Technical Support – Telephone Inquiries 1 N/A 33,000 34,122

EDGAR Form IDs Processed 53,483 55,087 56,740

Information Services    

Public Reference – Visitors 500 500 500

Library Password Management – Active Passwords 22,198 21,000 21,000

Library Acquisitions – Contracts Managed 117 114 114

Library Acquisitions – Invoices Reviewed/Paid 702 700 700

Creating New Content 293 300 310

Library Reference – Quick Reference Requests 1,983 2,000 2,000

1	 The Filer Technical Support program and corresponding workload items have been transferred to OSI from OIT, effective FY 2018. This program has been 
renamed “Filer Assistance and Technical Support” and the “Assistance and Technical Support Telephone Inquiries” workload item now consists of both 
Filer Support and Filer Technical Support telephoning functions.



FY 2019 BUDGET REQUEST BY PROGRAM   |   75

OFFICE OF THE ETHICS COUNSEL

(DOLLARS IN THOUSANDS)
FY 2017
Actual

FY 2018
Annualized CR

FY 2019
Request

Full-Time Equivalents 18 19 19

Cost:

Salaries and Benefits $	 4,257 $	 4,653 $	 4,702

Non-Personnel Expenses 911 877 1,092

Total Costs $	 5,168 $	 5,529 $	 5,794

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

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 Chairman, 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 Supplemental Ethics Rules and provides train-
ing and counseling on personal trading questions. OEC 
is also the SEC’s liaison with the United States Office of 
Government Ethics (OGE). OEC expects its workload 
and responsibilities to increase as the overall workforce 
of the SEC increases and as the number of enforcement 
matters increase in FY 2019.

In FY 2019, OEC will continue to advise and counsel 
all SEC employees and members on personal and finan-
cial conflicts of interest; post-employment restrictions; 
securities holdings and transactions of SEC employees 
and their immediate families; gifts; seeking and negoti-
ating other employment; outside activities; and financial 
disclosure. Additionally, OEC continues Commission 
memoranda reviews for potential conflicts of employees 
with complex financial holdings. Further, the office will 
strive to automate the OGE form 450 filing process, 
the 8B letter process, and plans to migrate the Personal 
Trading Compliance System to an enhanced platform. 
OEC will continue compliance testing of SEC popula-
tion data. Additionally, OEC will continue compliance 
testing agency-wide. Lastly, OEC will steadily improve 
and enhance the SEC Ethics Program to best service the 
agency and its employees.

Workload Data

Activity
FY 2017
Actual

FY 2018
Estimate

FY 2019
Request

Ethics Counseling Inquiries 8,400 9,200 9,476

Review of Public Financial Disclosure Forms 380 410 422

Commission Memoranda Reviews 1,450 1,550 1,597

Review of Confidential Financial Disclosure Forms 4,210 4,600 4,738

Clearance of 8B Requests 240 260 268

Pre-clearance of Requests for Trading 34,000 37,400 38,522

Employees Trained in Ethics 5,470 6,000 6,180

Review of SEC Forms 682 – Financial Disclosure Forms 570 620 639



76   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

OFFICE OF MINORITY AND WOMEN INCLUSION

(DOLLARS IN THOUSANDS)
FY 2017
Actual

FY 2018
Annualized CR

FY 2019
Request

Full-Time Equivalents 9 9 9

Cost:

Salaries and Benefits $	 2,088 $	 2,101 $	 2,123

Non-Personnel Expenses 1,160 1,181 1,321

Total Costs $	 3,248 $	 3,282 $	 3,444

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

The Office of Minority and Women Inclusion (OMWI) 
is responsible for all matters related to diversity in 
management, employment, and business activities 
at the SEC. The responsibilities of OMWI include 
developing standards for equal employment opportu-
nity and the diversity of the SEC’s workforce (including 
senior management); facilitating increased participa-
tion of minority-owned and women-owned businesses 
in the SEC’s programs and contracts; ensuring the 
fair inclusion of women and minorities within the 
workforce of existing contractors (and, as applicable, 
of subcontractors); and assessing the diversity policies 
and practices of entities regulated by the SEC. In accor-
dance with Title VII of the Jumpstart Our Business 
Startups (JOBS) Act, OMWI conducts outreach efforts 
to businesses owned by veterans, women, and minori-
ties to inform them about the JOBS Act and how it can 
support capital formation across our communities.

OMWI will continue to promote diversity and inclu-
sion in its core areas of workforce, business activities, 
and regulated entities. OMWI’s workforce activity 

will remain focused on development, advancement, 
and collaboration with divisions and offices that fill 
positions in FY 2019 to tailor outreach efforts. OMWI 
will continue to direct efforts toward enhancing diver-
sity at the senior levels of the SEC workforce. OMWI 
will also continue its work building the financial 
services industry and SEC “pipeline” of diverse talent 
through its own outreach and events as well as through 
partnerships, conferences, career fairs, and other events 
held by diverse professional associations, organi-
zations, and educational institutions. With regard 
to business activities, OMWI works to introduce 
minority-owned and women-owned businesses of all 
sizes to opportunities at the SEC, and will continue to 
collaborate with OA to promote access to contracting 
and sub-contracting opportunities through its extensive 
outreach and matchmaking at industry events, and via 
one-on-one meetings at SEC Vendor Outreach Days. 
Given the SEC’s focus on information technology and 
cybersecurity, OMWI anticipates emphasizing supplier 
outreach in those areas. 



FY 2019 BUDGET REQUEST BY PROGRAM   |   77

Workload Data

Activity
FY 2017
Actual

FY 2018
Estimate

FY 2019
Request

Diversity Assessments N/A 60 75

Advancing Employee Development N/A 2 2

Reporting Requirements and Data Analyses 167 110 110

Diversity and Inclusion Programs 70 65 65

Diversity and Inclusion Training 21 15 15

Roundtable or Public Meetings 5 5 5

Vendor Outreach 82 60 60

Targeted Advertisement Sources 265 80 80

Diversity Standards and Policies 4 2 2

Good Faith Effort Contract Reviews 1 99 70 75

1	 Effective FY 2017, OMWI changed the calculation methodology for Good Faith Effort (GFE) contract reviews to the number of GFE reviews conducted 
rather than the percentage of GFE reviews conducted.



78   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

OFFICE OF EQUAL EMPLOYMENT OPPORTUNITY

(DOLLARS IN THOUSANDS)
FY 2017
Actual

FY 2018
Annualized CR

FY 2019
Request

Full-Time Equivalents 14 15 15

Cost:

Salaries and Benefits $	 3,312 $	 3,793 $	 3,833

Non-Personnel Expenses 1,419 1,523 1,706

Total Costs $	 4,732 $	 5,316 $	 5,540

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

The Office of Equal Employment Opportunity 
(OEEO) strives to enhance equal access to employ-
ment opportunities for the best and brightest talent 
and foster an equitable work environment in which 
employees perform the SEC’s mission. SEC employ-
ees come from diverse backgrounds and are entitled 
to a workplace where employment decisions are 
made without regard to race, color, sex, age, religion, 
national origin, or genetic information. Like other 
demographic groups protected by statute, the law 
shields individuals with disabilities from discrimi-
nation. However, individuals with disabilities may 
lawfully receive preferential treatment, e.g., in the 
hiring process. To maintain the neutrality and impar-
tiality necessary to fulfill its responsibilities, OEEO is 
required to be independent of any other SEC office, 
and the OEEO director reports to the SEC Chairman. 
OEEO has two primary analytical functions: Compli-
ance and Barrier Analysis. 

The Compliance function applies legal principles to the 
processing and adjudication of complaints of discrim-
ination under Title VII of the Civil Rights Act, the 

Age Discrimination in Employment Act, the Reha-
bilitation and Americans with Disabilities Acts, and 
the Genetic Information Nondiscrimination Act. The 
Equal Employment Opportunity Commission enforc-
es these laws, adjudicates cases, and regulates equal 
employment opportunity programs across the federal 
government.

The Barrier Analysis function analyzes quantitative 
and qualitative data to determine whether a policy, 
practice, or procedure impedes access to employment 
opportunities for members of a protected demograph-
ic group. When OEEO identifies such an impediment, 
the office collaborates with stakeholders to identi-
fy options to eliminate the potential barrier in the 
employment lifecycle, starting with recruitment and 
ending with separation. In support of its two analyt-
ical functions, OEEO also provides opportunities to 
quickly resolve disputes, conducts mandatory train-
ing, and files required annual reports with external 
stakeholders. OEEO engages frequently with internal 
and external stakeholders to perform its functions.

Workload Data

Activity
FY 2017
Actual

FY 2018
Estimate

FY 2019
Request

Compliance 530 500 500

Reporting 8 8 8

Barrier Analysis 2,399 2,225 2,225

Mission Support 1,257 1,250 1,250



FY 2019 BUDGET REQUEST BY PROGRAM   |   79

OFFICE OF INSPECTOR GENERAL

(DOLLARS IN THOUSANDS)
FY 2017
Actual

FY 2018
Annualized CR

FY 2019
Request

Full-Time Equivalents 48 49 49

Cost:

Salaries and Benefits $	 11,357 $	 11,979 $	 12,105

Non-Personnel Expenses 3,142 3,924 4,539

Total Costs $	 14,499 $	 15,903 $	 16,644

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

The Office of Inspector General (OIG) is an indepen-
dent office that conducts audits of programs and 
operations of the SEC and investigations into allega-
tions 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 2019, the OIG will continue to focus on improv-
ing agency programs and operations through audits, 
evaluations, and reviews. The office also will enhance 
staff and agency integrity by investigating allegations 
of misconduct involving the SEC’s programs and 
operations. The OIG’s workload remains high and the 
office expects both its investigative and audit teams to 
maintain active workloads through FY 2019.

The Dodd-Frank Wall Street Reform and Consumer 
Protection Act of 2010 (Dodd-Frank Act) enacted on 
July 21, 2010, imposed significant new responsibilities 
on the SEC as a whole and, as a result, on the OIG. 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 SEC. 
During FY 2019, 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 recogniz-
ing employees who make suggestions, through the ESP, 
that result in increased work efficiency, effectiveness, 
or productivity of the SEC, or reduce waste, abuse, 
misconduct, or mismanagement, as provided for by the 
Dodd-Frank Act.

In addition, there has been continued coordination 
with other Inspector Generals (IG) 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 in FY 2019 to prepare a section of CIGFO’s80   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

annual report to Congress. 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’s OIG to conduct other 
audit or review activities on behalf of CIGFO. 

The OIG currently has 54 authorized positions. For  
FY 2019, the OIG is not requesting any additional 
positions. 

Regulatory Requirement
The Inspector General Reform Act of 1978 (as 
amended through P.L. 114-317) requires that each IG 
submit a budget estimate and request each fiscal year 
to the head of the agency to which the IG reports. 
Section 6(f)(1) requires that the request include:
• The aggregate amount of funds requested for the 

operations of the 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 FY; and

Workload Data

Activity
FY 2017
Actual

FY 2018
Estimate

FY 2019
Request

Audits/Evaluations

Pending Beginning of Year 1 4 5 4

Opened 13 12 12

Completed 12 13 12

Pending End of Year 5 4 6

•	 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 SEC submits the 
following information for the OIG’s budget estimate 
and request for FY 2019.
•	 The aggregate budget request for the operations of 

the OIG is $15,206,268.75.
•	 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. 
OIG estimates FY 2019 specialized training costs of 
$108,000. The IG certifies that the aggregate amount 
of the request satisfies all training requirements 
for the OIG for FY 2019 and also any assessment 
required to support CIGIE. 

•	 The estimated amount of the SEC OIG’s contribu-
tion to CIGIE is 0.22 percent of the budget request, 
or $33,380.35.

1	 The total FTE on the previous table represents the entire OIG organization; however, the workload data above only includes the Office of Audits. The inves-
tigative workload of the OIG is not included in the workload table because it would be inappropriate to speculate on the number of investigations the OIG 
would need to conduct during a given time period.



Other Information
Risks, Internal Controls, and Management Challenges................................................................83

Cross-Agency Collaboration...........................................................................................................................87

Evidence Building....................................................................................................................................................91

Links to Other Information and Resources............................................................................................92





OTHER INFORMATION   |   83

RISKS, INTERNAL CONTROLS, AND 
MANAGEMENT CHALLENGES

As the markets, products, and participants that 
the SEC oversees and regulates increase in size and 
complexity, the agency’s mandate to protect investors, 
maintain fair, orderly, and efficient markets, and facil-
itate capital formation becomes more challenging. To 
maximize the use of the SEC’s resources to fulfill this 
mission, the agency continually strives to allocate its 
time and funds toward the highest and best uses. The 
SEC must always reevaluate its operations to identify 
emerging risks and ensure the agency’s resources are 
deployed to most efficiently address agency priorities. 

Risk Management
The Office of the Chief Operating Officer will be 
home to the agency’s first-ever chief risk officer 
(CRO), slated to be hired in FY 2018. The CRO’s 
responsibilities include coordinating the agency’s 
enterprise risk management functions, as required 
under OMB Circular A-123. The enterprise risk 
management program assists the agency in achieving 
its strategic and operational objectives by providing 
an enterprise-wide, strategically aligned, systematic, 
and structured methodology for managing the agency’s 
most significant risks and challenges. The CRO will 
be a key member of the Risk Management Oversight 
Committee and provides governance and oversight of 
the SEC’s enterprise risk management program. This 
committee oversees the development and implemen-
tation of strategic and programmatic risk policies, 
frameworks, and methodologies, and also produces 
and maintains the agency’s risk profile. In FY 2019, 
the SEC will continue to focus on its enterprise risk 
management practices and work to integrate enterprise 
risk management with our strategic goals, performance 
metrics, and our internal control environment, as well 
as support risk-informed decision-making.

Management Assessments of  
Internal Challenges
The SEC remains committed to maintaining strong 
internal controls. Internal control is an integral 
component of effective agency management, providing 
reasonable assurance that the following objectives 
are being achieved: effectiveness and efficiency of 
operations, reliability of reporting, and compliance 
with laws and regulations. The Federal Managers’ 
Financial Integrity Act of 1982 (FMFIA) establishes 
management’s responsibility to assess and report on 
internal accounting and administrative controls. Such 
controls include program, operational, and admin-
istrative areas, as well as accounting and financial 
management. The FMFIA requires federal agencies to 
establish controls that reasonably ensure obligations 
and costs are in compliance with applicable law; funds, 
property, and other assets are safeguarded against 
waste, loss, unauthorized use, or misappropriation; 
and revenues and expenditures are properly recorded 
and accounted for to maintain accountability over the 
assets. The FMFIA also requires agencies to annually 
assess whether financial management systems conform 
to related requirements (FMFIA § 4).

Section 963 of the Dodd-Frank Wall Street Reform 
and Consumer Protection Act of 2010 (Dodd-Frank 
Act) describes the responsibility of SEC management 
to establish and maintain adequate internal controls 
and procedures for financial reporting. This section 
requires an annual financial controls audit, a Govern-
ment Accountability Office (GAO) audit of the SEC’s 
assessment of the effectiveness of internal control, and 
internal controls attestations by the Chairman and the 
chief financial officer (CFO). 



84   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

The assurance statements are based on reports from 
each division director and office head on the effec-
tiveness of their controls. These statements are based 
on self-assessments and internal reviews supported 
by control testing, as well as recommendations for 
improvement from audits, investigations, and reviews 
conducted internally by the SEC’s Office of Inspector 
General (OIG) and GAO. In evaluating internal 
controls, the SEC also considers other sources of 
information, which include, but are not limited to,  
the following:
•	 An entity-level control assessment;
•	 Internal management reviews, self-assessments, and 

tests of internal controls;
•	 Management’s personal knowledge gained from 

daily operations;
•	 Reports from GAO and the OIG;
•	 Reviews of financial management systems;
•	 Reports pursuant to the Federal Information  

Security Management Act (FISMA) and  
OMB Circular A-130, Management of Federal 
Information Resources;

• Reports and other information from Congress or 
agencies such as the OMB, the Office of Personnel 
Management (OPM), or the General Services Admin-
istration (GSA) reflecting the adequacy of internal 
controls; and

• Additional reviews relating to a division or office’s 
operations.

The SEC’s annual assessment of internal controls, 
based on these sources, 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 2017 AFR provides a summary of the 
most serious management and performance challenges 
facing the SEC, as identified by the OIG in the Other 
Information section. The AFR also details the actions 
currently being taken to address these challenges.

The table on the next page describes how the resources 
requested for FY 2019 will help address the challenges 
identified by the Inspector General.

www.sec.gov


OTHER INFORMATION   |   85

Management Challenge 
Identified by the 
Inspector General

How the FY 2019 Budget Addresses the Challenge

Regulatory Oversight The SEC must continue to find ways to use its limited resources to keep pace with changes in the size 
and complexity of the securities markets and the market participants the SEC oversees and regulates, 
absent additional funding increases.

The Office of Compliance Inspections and Examinations (OCIE) has worked to increase its examination 
coverage of investment advisers, including re-allocating staff and enhancing its use of advanced quantitative 
techniques, and continues to seek new ways to increase its efficiency while strengthening internal controls. 

The SEC continues to recognize the need to maximize technology to better identify risks, uncover frauds, 
sift through large volumes of data, inform policy-making, and streamline operations. Key information 
technology (IT) initiatives include the following:
• 	Expanding data analytics tools;
•	 Improving examinations through risk assessment and surveillance tools;
• 	Enhancing systems that support the enforcement program;
• 	Improving access and usefulness of information available to the public through the Electronic Data 

Gathering, Analysis, and Retrieval (EDGAR) system; and
• 	Investing in further business process automation and enhancements.

Information Security To ensure an effective information security program, the SEC is increasing investments in information 
security to address the ability to monitor and avoid advanced persistent threats, and to improve 
risk management and monitoring. The SEC is conducting an ongoing assessment of the agency’s 
cybersecurity risk profile and preparedness, including: (1) the formation of a senior-level cybersecurity 
working group to coordinate information sharing; (2) risk and threat monitoring; (3) incident response 
and other cross-divisional and interagency efforts; and (4) an assessment of reporting and escalation 
procedures. Each of these efforts is moving forward and, as is the nature of matters of this type, will 
require substantial time and effort to complete. Chairman Clayton’s October 4, 2017, testimony before 
the House Financial Services Committee, available at www.sec.gov/news/testimony/testimony-
examining-secs-agenda-operation-and-budget, provides a detailed overview of the agency’s ongoing 
efforts to strengthen and uplift its cybersecurity risk profile.

In FY 2018, the SEC is conducting reviews of agency systems, assessing the types of data the SEC 
keeps and the related security systems, processes, and controls. The agency is also working to enhance 
escalation protocols for cybersecurity incidents in order to enable greater agency-wide visibility and 
understanding of potential cyber vulnerabilities and attacks.

Acquisition 
Management

In FY 2019, the Office of Acquisitions (OA) will continue working on a variety of fronts to further 
promote effective contract management by improving communications between Contracting Officers 
and Contracting Officer Representatives; conducting annual reviews of contract files to make sure 
they contain the appropriate documentation; and improving reporting. In parallel, OA and the Office of 
Information Technology are addressing each of the particular OIG recommendations related to the data 
center and EDGAR contracts.

continued on next page 

http://www.sec.gov/news/testimony/testimony-examining-secs-agenda-operation-and-budget
http://www.sec.gov/news/testimony/testimony-examining-secs-agenda-operation-and-budget


86   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

Management Challenge 
Identified by the 
Inspector General

How the FY 2019 Budget Addresses the Challenge (continued)

Human Capital 
Management

During FY 2016, the SEC released a Human Capital Strategic Plan to align the agency’s human capital 
with the achievement of its mission, goals, and objectives. The agency also released an SEC Strategic 
Workforce Plan, which provides an overview of the current workforce; identifies critical workforce 
competencies for SEC mission-critical occupations; and identifies perceived workforce competency 
gaps from supervisors/managers. The Office of Human Resources (OHR) will conduct periodic reviews  
to assess whether the plan aligns with current agency workforce and succession planning efforts. 

The SEC also took several actions during the year to strengthen workforce planning and performance 
management. In FY 2017, the SEC conducted a training needs assessment for staff within OHR and 
plans to conduct a competency assessment in FY 2018 for other key occupations not previously 
assessed.

In FY 2019, the Office of Minority and Women Inclusion (OMWI) will continue to work with all divisions 
and offices, SEC senior leadership, the agency’s Diversity Council, the Office of Equal Employment 
Opportunity, and OHR to promote diversity in the agency’s workforce and cultivate an inclusive work 
environment. The SEC will continue to implement existing initiatives and explore new strategies 
for improving gender, racial, and ethnic diversity in SEC mission-critical occupations and senior 
management positions. Further, OMWI will continue to work with OA to build on the agency’s success in 
advancing the agency’s supplier diversity goals.

OMWI will also continue to conduct post-award reviews of agency contractors to determine compliance 
with the SEC’s Contract Standard for Contractor Workforce Inclusion.



OTHER INFORMATION   |   87

CROSS-AGENCY COLLABORATION

The SEC values its many partnerships with other  
federal agencies, financial regulators, foreign govern-
ments, and SEC divisions and offices. 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 for it to meet its strategic goals. Some examples 
of collaboration efforts taking place at the SEC during  
FY 2017–2019 are highlighted below. 

Strategic Goal 1  
To establish an effective regulatory environment, 
several SEC divisions and offices regularly  
collaborate with both internal and external partners. 

For example, the SEC participates in international 
regulatory organizations such as the Financial Stability 
Board (FSB), which promotes international financial 
stability by coordinating national financial authorities 
and international standard-setting bodies as they work 
toward developing strong regulatory, supervisory and 
other financial sector policies. The FSB fosters a level 
playing field by encouraging coherent implementation 
of these policies across sectors and jurisdictions. The 
SEC also participates in the International Organization 
of Securities Commissions (IOSCO), the international 
body that brings together the world’s securities regula-
tors. The SEC works with foreign securities regulators 
from over 30 countries to develop international 
guidance, recommendations and standards, and assesses 
the implementation of financial market reforms and 
their ramifications for U.S. investors. The Office of 
International Affairs (OIA) also represents the SEC in 
the Joint U.S.-EU Financial Regulatory Forum/U.S.-EU 
Financial Services Committee, and the US-India 
Financial Regulatory Dialogue, where regulatory and 
economic issues are discussed with foreign counterparts.

To enhance credit rating agency oversight, the SEC’s 
Office of Credit Ratings (OCR) meets with interna-
tional regulators in the Supervisory General Colleges 
for Credit Rating Agencies, where topics that are 
relevant to the industry such as business strategy, 
compliance and risk management, cybersecurity, and 
technology matters are addressed. OCR also shares 
information and examination findings with the inter-
national regulators of the three largest, globally-active 
credit rating agencies to further strengthen regulatory 
oversight of nationally recognized statistical rating 
organizations. 
 
Strategic Goal 2 
To foster and enforce compliance with the federal 
securities laws, the SEC works closely with other 
agencies and foreign governments. 

Oversight of broker-dealers is in many ways a coordi-
nated effort with the Financial Industry Regulatory 
Authority (FINRA). The SEC and FINRA work 
together on matters of mutual interest with respect to 
regulated entities and securities offerings. The SEC’s 
Office of Compliance Inspections and Examinations 
(OCIE) and FINRA have regular contact to discuss 
strategic initiatives, examination coordination, risk 
assessment efforts, rulemaking issues, industry risks, 
etc. This type of coordination is ultimately intended 
to make oversight of broker-dealers more effective 
and efficient and to improve compliance within the 
industry. As an example, the two agencies coordinate 
to formally present Compliance Outreach Seminars. 
The SEC also participates in semi-annual meetings with 
FINRA to discuss topics relating to financial reporting 
of broker-dealers. OCIE also makes a number of 
referrals for further investigation to other regulators 
and law enforcement as well as informational referrals 
throughout the year.



88   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

The Division of Enforcement (ENF) collaborates 
with a number of law enforcement entities to enforce 
compliance with securities laws. For example, ENF, 
the U.S. Department of Justice (DOJ), and the 94 U.S. 
Attorneys’ Offices frequently collaborate on individual 
cases and broad sweeps or task forces through access 
grants to their respective investigative files. ENF also 
collaborates with the Federal Bureau of Investigation 
(FBI) on individual matters and through a Memoran-
dum of Understanding to embed, on a full-time basis, 
several agents and intelligence analysts from the FBI’s 
Economic Crimes Unit into the division’s Office of 
Market Intelligence (OMI) for the purpose of informa-
tion sharing and leveraging each other’s resources  
and expertise.

ENF also collaborates with other federal agencies, 
routinely exchanging tips, complaints, and referrals 
(received by OMI), and sharing information and 
intelligence. ENF primarily collaborates in this regard 
with the DOJ, the 94 U.S. Attorneys’ Offices, and the 
FBI, but also collaborates with other federal and state 
agencies including, among others, the Consumer Finan-
cial Protection Bureau (CFPB), the Commodity Futures 
Trading Commission (CFTC), the Department of 
Education, the Department of Labor, the Federal Trade 
Commission (FTC), the Internal Revenue Service, the 
Financial Crimes Enforcement Network (FinCEN), and 
the Office of the Comptroller of the Currency (OCC).

To promote international cooperation among securities 
regulators in their respective investigations and cases, 
the SEC’s Office of International Affairs (OIA) and 
ENF often support the SEC’s law enforcement and 
regulatory counterparts abroad. This collaboration 
includes, for example, requests from ENF for inter-
national assistance and requests for assistance from 
foreign regulatory and law enforcement authorities. 
In addition, each year ENF participates in the SEC’s 
Annual International Enforcement Institute, where 
ENF staff share important information about enforce-
ment-related issues. OIA also collaborates with the 

DOJ and foreign law enforcement agencies on inves-
tigations of possible violations of U.S. securities laws 
where international issues exist.

The work performed by the SEC’s Division of  
Investment Management (IM) and Division of Trading 
and Markets (TM) further supports the SEC’s goal 
to enforce compliance with securities laws. IM, for 
example, routinely shares information with the DOJ, 
CFTC, Federal Reserve Board (FRB), Swiss securities 
regulator, UK securities regulator, and the New York 
Deparment of Financial Services in connection with 
various enforcement actions resulting in injunctive 
actions or criminal convictions against financial 
services entities that implicate provisions of the Invest-
ment Company Act of 1940. In addition, IM and  
TM frequently collaborate with FinCEN on various 
matters relating to anti-money laundering. IM staff 
and their colleagues provided technical guidance 
and comment to the U.S. responses to the Financial 
Action Task Force’s Anti-Money Laundering techni-
cal compliance criteria, Treasury’s national money 
laundering and terrorist financing risk assessments, and 
FinCEN’s consideration of rules that would subject 
investment advisers to certain anti-money laundering 
requirements.

Strategic Goal 3 
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 collabora-
tion activities with other regulators, federal agencies, 
and committees to make information accessible to 
investors. For example, 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 Ameri-



OTHER INFORMATION   |   89

cans for life-long financial success. Jump$tart partners 
include, among others, FDIC, FRB, FTC, FINRA, 
GSA, OCC, North American Securities Administrators 
Association (NASAA), and the U.S. Department of 
Agriculture. 
	
The SEC also collaborates with external partners to 
protect the financial wellbeing of American seniors. 
The SEC works closely with the Elder Justice Inter-
agency 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 the groups of the SEC’s 
initiatives to protect older Americans from invest-
ment fraud and abusive sales practices. Furthermore, 
through the Outsmarting Investing Fraud program, 
OIEA staff conducts educational programs with the 
FINRA Investor Education Foundation, state securities 
regulators, and AARP on how to identify common 
persuasion techniques used by con artists. 

OIEA also participates on behalf of 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 
over 20 additional federal agencies. The Commission 
was tasked to develop a national financial education 
website (MyMoney.gov) and a national strategy on 
financial education. 

An attorney in OIEA’s Office of Chief Counsel and the 
assistant director of OIEA’s Office of Investor Educa-
tion have also been coordinating with various special 
emphasis groups regarding outreach efforts to inves-
tors. These groups include the Asian Pacific American 
Committee, the Caribbean American Heritage 

Committee, and the Hispanic and Latino Opportunity, 
Leadership, and Advocacy Committee. 

Strategic Goal 4
To enhance the Commission’s performance 
through effective alignment and management 
of human, information, and financial capital, the 
Commission’s administrative offices often work 
collaboratively with other agencies. 

Below are just a few examples of activities in which the 
SEC participates to help further enhance the effective-
ness of core operations.

The Office of Human Resources (OHR) participates 
in quarterly discussions with the FDIC, CFTC, 
Federal Housing Finance Administration, OCC, 
National Credit Union Association, and Farm Credit 
Administration to benchmark benefits and work-life 
program offerings among the Financial Institutions 
Reform, Recovery, and Enforcement Act of 1989 
(FIRREA) agencies. The shared goal is to benchmark 
program areas, share information about their human 
capital management practices, and explore best 
practices. OHR and these organizations participate in 
a bi-annual survey to benchmark compensation and 
benefits programs. The survey is conducted by a third 
party with the SEC compensation team managing the 
contract and internal agency agreements. OHR also 
partakes in the Enterprise Data & Analytics Commu-
nity of Practice, a collaboration effort sponsored by the 
SEC, GSA, NASAA, OCC, and the U.S. Department of 
Veterans Affairs to share human capital analytics and 
data visualization best practices.

The Office of 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 of practice 
group of attorneys representing federal agencies 
in employment law matters. Participants regularly 
schedule speakers from across the federal government 

http://MyMoney.gov


90   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

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 exten-
sively with the Department of Homeland Security 
(DHS) and OMB on the security of agency systems. As 
one example, the SEC has been taking advantage of 
government-wide DHS offerings meant to help assess 
and bolster agency information security programs.

The Office of Strategic Initiatives helps the SEC gain 
efficiencies by participating in the Information Services 
(Library) collaboration effort with an emphasis on 
fostering relationships with peer FSOC libraries 
to develop a forum for discussing common issues, 

including licensing terms, data sharing, and library 
infrastructure needs. Participants include the Senate, 
Georgetown University Law Library, Law Library of 
Congress, Jones Day, Crowell & Moring, Finnegan, 
and FSOC libraries. By meeting with peer and other 
external libraries, the SEC is able to discuss best 
practices and develop benchmarking metrics. 

The Office of Support Operations (OSO) works closely 
with GSA to consolidate SEC’s real estate portfolio 
nationwide. Since 2011, OSO has identified and 
pursued eight opportunities representing an estimated 
annual rent savings of up to $15.9 million by 2021 
primarily by exiting leases and rightsizing rentable 
square feet requirements upon existing lease expirations. 



OTHER INFORMATION   |   91

EVIDENCE BUILDING

Internal and external evaluations play a significant role 
in monitoring and improving SEC program perfor-
mance. 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 
2017, there were seven GAO reports and 11 Office of 
Inspector General reports related to agency operations. 
Beyond this, examples of reviews and evaluations  
that the agency has initiated and plans to continue  
are listed below.
•	 The agency will continue to advance broad-based 

reviews of core agency programs. For example, the 
Division of Trading and Markets also continues to 
work with staff at other applicable regulators to 
explore ways to improve price transparency and 
address potential regulatory gaps in the government 
securities markets.

•	 Through customer satisfaction surveys and other 
research, the Office of Investor Education and 
Advocacy and the Office of the Investor Advocate 
will seek additional information regarding the 
behavior of individual investors, the type of infor-
mation they need and use when making investment 
decisions, and the usefulness of SEC’s investor 
education programs and materials.

•	 In 2017, the SEC initiated an assessment of the 
agency’s internal cybersecurity risk profile and 
approach to cybersecurity from a regulatory and 
oversight perspective.

•	 The SEC reviews performance goal data on a 
quarterly basis. Each quarter, the SEC’s performance 
improvement office reviews the status of perfor-
mance 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 OMB 
and Performance Improvement Council recommen-
dations for frequent data-driven reviews.

•	 The agency tracks the number of SEC staff partici-
pants in mission-focused training and development 
programs and will report on specific items through 
the use of post-course evaluations to assess the 
impact and results of this training on a five-point 
scale. In FY 2016, the agency began offering more 
virtual training to enhance the accessibility of 
real-time training and reduce costs associated with 
classroom-based training.



92   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

LINKS TO ADDITIONAL INFORMATION AND 
RESOURCES 
Reference URL

Strategic Plan for 2014–2018  www.sec.gov/about/sec-strategic-plan-2014-2018.pdf

FY 2017 Agency Financial Report www.sec.gov/files/sec-2017-agency-financial-report.pdf  

Prior Year Congressional Budget Justifications www.sec.gov/reports

Investor.gov  www.investor.gov

Office of the Whistleblower www.sec.gov/whistleblower 

Enforcement Actions  www.sec.gov/spotlight/enf-actions-fc.shtml

Laws that Govern the Securities Industry www.sec.gov/about/laws.shtml

Glossary of Terms and Acronyms www.sec.gov/fast-answers

http://www.sec.gov/about/sec-strategic-plan-2014-2018.pdf
http://www.sec.gov/files/sec-2017-agency-financial-report.pdf
http://www.sec.gov/reports
http://www.investor.gov
http://www.sec.gov/fast-answers


FY 2017 Annual 
Performance Report 
(APR) and FY 2019 
Annual Performance 
Plan (APP)
A Reader’s Guide to the SEC’s Performance Information..........................................................95

FY 2017 APR and FY 2019 APP Summary...............................................................................................95

Performance Summary by Strategic Goal and Strategic Objective...................................96

Strategic Goal 1:	 Establish and Maintain an Effective  

	 Regulatory Environment...................................................................................................96

Strategic Goal 2:	 Foster and Enforce Compliance with the  

	 Federal Securities Laws..................................................................................................103

Strategic Goal 3:	 Facilitate Access to the Information Investors  

	 Need to Make Informed Investment Decisions............................................114

Strategic Goal 4:	 Enhance the Commission’s Performance through  

	 Effective Alignment and Management of Human,  

	 Information, and Financial Capital............................................................................119





FY 2017 ANNUAL PERFORMANCE REPORT AND FY 2019 ANNUAL PERFORMANCE PLAN   |   95

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 five years that 
will be published in 2018 for public comment. 

The chapters included within this section comprise 
the agency’s FY 2017 APR and FY 2019 APP and 
explain how the SEC uses resources to achieve each of 
its four strategic goals. These strategic goals, strategic 
objectives, and performance goals and indicators were 
developed as part of the Strategic Plan process for  
FY 2014–2018. 

Strategic Goal Summary: Reviews the purpose of each 
strategic goal and provides additional information to 
identify the resources allocated toward achieving the goal.

Strategic Objective: Describes the SEC’s strategic objec-
tives that are used to gauge the agency’s performance as 
related to each strategic goal.

Performance Goals and Indicators: Presents the perfor-
mance goals and performance indicators by objective, 
comparing planned and actual performance levels for FY 
2017. Four years of historical data is provided for perfor-
mance goals and performance indicators where available.

FY 2017 APR AND FY 2019 APP SUMMARY

The SEC focuses its resources on: (1) establishing  
and maintaining an effective regulatory environment; 
(2) fostering and enforcing compliance with the federal
securities laws; (3) facilitating access to the information
investors need to make informed investment decisions;
and (4) enhancing the agency’s performance through
effective alignment and management of human,
information, and financial capital. In FY 2017, total
SEC obligations were $1.651 billion1 in support of
4,616 total full-time equivalents (FTE). Of 53 total
performance targets, the agency met or exceeded 49
and did not meet four.

The budget request for FY 2019 totals $1.683 billion,2 
an increase of about $32 million relative to the agency’s 
FY 2017 obligations of $1.651 billion. The FY 2019 

budget request funds 4,457 FTEs, a decrease of about  
159 FTEs and 46 positions compared to the FY 2017 level.

FY 2017 Performance Results Summary Table

Goal 1 Goal 2 Goal 3 Goal 4
Exceeded/Met
Not Met

10 10

2

12

17

2

1	 This figure excludes use of budget authority to liquidate prior obligations for deficient leases.
2	 This amount is the sum of $1.658 billion in new budget authority and $0.025 billion projected to come from de-obligations of prior fiscal years’ actions.



96   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

PERFORMANCE SUMMARY BY STRATEGIC 
GOAL AND STRATEGIC OBJECTIVE

STRATEGIC GOAL 1: Establish and 
Maintain an Effective Regulatory 
Environment

The SEC believes that its rules and regulations should 
be drafted to enable market participants to clearly 
understand their obligations under the federal securities 
laws and to conduct their activities in compliance with 
law. The SEC aims to promulgate rules that are clearly 
written, easily understood, and tailored toward specific 
ends. In addition, the agency recognizes that regular 
reviews of our regulations and rulemaking processes 
are necessary to confirm that intended results are being 
achieved. When properly crafted, these rules serve to 
further the agency’s mission and allow for accurate and 
reliable information to be made available to investors. 

In FY 2017, the agency met or exceeded all 10 perfor-
mance targets in Strategic Goal 1. The SEC devotes 
a large share of resources to responding to no-action 

letters and interpretive and other requests from regulat-
ed entities, public companies, and other outside parties. 
The agency is committed to increasing the response time 
to such requests. 

In FY 2019, the agency is requesting a total of $170.5 
million and 463 FTEs toward achieving results in 
establishing an effective regulatory environment. Inves-
tor protection, market stability, and capital formation 
remain central to the SEC’s rulemaking agenda. 

Strategic Objective 1.1: The SEC establishes and main-
tains a regulatory environment that promotes high- 
quality disclosure, financial reporting, and governance, 
and that prevents abusive practices by registrants,  
financial intermediaries, and other market participants.

Goal Leader(s): Director, Division of Trading and 
Markets; Director, Division of Corporation Finance; 
Director, Division of Investment Management 

PERFORMANCE INDICATOR (PROCESS) 1.1.1 
Number of investor testing research projects

Description: This metric tracks the number of research initiatives used to gather feedback from investors on the usefulness of 
disclosures and other input on SEC rulemaking.

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017 
Actual

Number of projects 2 0 0 0 0 1

Responsible Division/Office: Office of the Investor Advocate

Data Source: Microsoft Office Suite Tools



FY 2017 ANNUAL PERFORMANCE REPORT AND FY 2019 ANNUAL PERFORMANCE PLAN   |   97

Strategic Objective 1.2: The SEC promotes capital  
markets that operate in a fair, efficient, transparent,  
and competitive manner, fostering capital formation 
and useful innovation.

Goal Leader(s): Director, Division of Trading  
and Markets; Director, Division of Corporation Finance

PERFORMANCE GOAL 1.2.1 
Time to complete SEC review of SRO rules that are subject to SEC approval

Description: The SEC reviews SRO rule proposals for consistency with the Exchange Act standards of investor protection, fair and 
orderly operation of the markets and market structure, as well as other statutory requirements. This metric gauges the timeliness of 
those reviews.

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017 

Plan
FY 2017 
Actual

FY 2018 
Estimate

FY 2019 
Estimate

Within 45 days 75% 74% 75% 63% 60% 60% 64% 60% 60%

Target: Exceeded

Analysis: During FY 2017, the SEC approved or disapproved 302 SRO rule changes filed pursuant to Section 19(b)(2) of the Exchange 
Act. Of the 302 filings, 64 percent were approved or disapproved within the 45-day standard for publication, which exceeds the 60 
percent target established. 

Responsible Division/Office: Division of Trading and Markets

Data Source: SRO Rule Tracking System (SRTS)

PERFORMANCE INDICATOR (PROCESS) 1.2.1 
Percentage of SRO rule filings that are submitted for immediate effectiveness

Description: This indicator gauges the proportion of SRO rule proposals that can be submitted for immediate effectiveness without 
Commission approval.

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017 
Actual

Percentage 72% 78% 72% 78% 77% 69%

Responsible Division/Office: Division of Trading and Markets

Data Source: SRO Rule Tracking System (SRTS)



98   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

PERFORMANCE INDICATOR (PROCESS) 1.2.2 
Percentage of transaction dollars settled on time each year

Description: This indicator measures the efficiency of the U.S. clearance and settlement system for equity securities.

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017 
Actual

Percentage 99% 98% 99% 99% 99% 99%

Responsible Division/Office: Division of Trading and Markets

Data Source: Depository Trust & Clearing Corporation and NYSE Technologies

PERFORMANCE INDICATOR (PROCESS) 1.2.3 
Percentage of market outages at SROs and electronic communications networks (ECN)  

that are corrected within targeted timeframes 1

Description: Market outages reflect problems in the systems’ underlying the securities markets that could have an adverse effect on 
the markets’ ability to function as required. The SEC assesses the reliability and resiliency of these systems to minimize the number and 
duration of outages. This metric gauges how quickly outages are resolved so that market activity can resume.

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017 
Actual

Within 2 hours 71% 80% 80% 63% 41% 49%

Within 4 hours 89% 86% 85% 77% 54% 58%

Within 24 hours 100% 98% 96% 96% 71% 83%

Responsible Division/Office: Office of Compliance Inspections and Examinations 

Data Source: Reporting pursuant to Regulation SCI

1	 Performance data reported for this measure from FY 2011–FY 2015 was reported under the agency’s voluntary Automation Review Policy program (ARP). 
During FY 2016, Regulation SCI went into effect, effectively replacing this voluntary program. Under the old ARP program, entities reported on outages, but 
under Regulation SCI, entities are now being asked to report “disruptions.” Disruptions are a broader list of events that may have resulted in longer periods 
of event duration. In addition, there is a greater breadth of events being reported, as there has been a significant increase in the number of entities now 
being required to report. 



FY 2017 ANNUAL PERFORMANCE REPORT AND FY 2019 ANNUAL PERFORMANCE PLAN   |   99

Strategic Objective 1.3: The SEC adopts and adminis-
ters regulations and rules that are informed by robust 
economic analysis and public comment and that enable 
market participants to understand clearly their obliga-
tions under the securities laws.

Goal Leader(s): Director, Division of Trading and 
Markets; Director, Division of Corporation Finance; 
Director, Division of Investment Management; Director, 
Division of Economic and Risk Analysis

PERFORMANCE GOAL 1.3.1 
Length of time to respond to written requests for no-action letters (NAL),  

exemptive applications, and written interpretive requests

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 such requests for guidance, when provided, are generally available to the public, 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 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017  

Plan
FY 2017 
Actual

FY 2018 
Estimate

FY 2019 
Estimate

Division of Trading and Markets: No-action letters, exemptive applications, and written interpretive requests (combined figure)

Percentage within required  
timeframe

89% 93% 83% 88% 81% 80% 86% 80% 80%

Target: Exceeded

Analysis: TM exceeded the established target for FY 2017. Its target is based on a fixed deadline for responses to written requests 
for no-action letters, exemptive applications, and written interpretive requests (collectively, “requests”). Some requests are extremely 
complex and require extensive consideration and consultation both within and outside TM. TM’s approach has been to allow these 
requests the thorough consideration they demand, even when that means the request is not closed within the targeted timeframe, so 
that nuance and detail can be properly considered. 

Responsible Division/Office: Division of Trading and Markets

Data Source: TM Request Tracking Log

Division of Investment Management

No-action letters and interpretive 
requests

100% 100% 100% 100% 97% 80% 97% 80% 80%

Exemptive applications 100% 99% 99% 100% 100% 80% 100% 80% 80%

Target: No-action letters and interpretive requests – Exceeded; Exemptive applications – Exceeded

Analysis: IM continues to exceed its target of issuing initial comments on no-action letters and exemptive applications within 120 
days. IM has been 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 Investment Management

Data Source: CCO Tracker 

Division of Corporation Finance

No-action letters and interpretive 
requests 

98% 98% 97% 94% 93% 90% 98% 90% 90%

Shareholder proposals 100% 100% 100% 100% 100% 100% 100% 100% 100%

Target: No-action letters and interpretive requests – Exceeded; Shareholder proposals – Met

Analysis: CF achieved its target of responding to 100 percent of shareholder proposal requests prior to the company’s proxy filing date. 
CF surpassed its FY 2017 target by providing initial comments on no-action letters within 30 days for 98 percent of requests.

Responsible Division/Office: Division of Corporation Finance

Data Source: Division No-Action Letter database and Division Shareholder Proposal database100   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

PERFORMANCE GOAL 1.3.2 
Timeliness of responses to requests for informal guidance received by the  

Trading and Markets dedicated hotline or email box

Description: The Division of Trading and Markets maintains a dedicated phone line and an email account to provide market participants 
with avenues to request information and informal guidance regarding the Exchange Act and rules thereunder. This metric reflects the 
timeliness of the staff’s responses to these requests.

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017 

Plan
FY 2017 
Actual

FY 2018 
Estimate

FY 2019 
Estimate

Respond to or refer inquiries 
within 2 weeks

Prior-year data  
not available

99% 98% 99% 95% 98% 95% 95%

Target: Exceeded

Analysis: TM surpassed its FY 2017 target by responding to or referring inquiries within 2 weeks for 98 percent of inquiries. 

Responsible Division/Office: Division of Trading and Markets

Data Source: Division of Trading and Markets’ Office of Interpretation and Guidance Log

PERFORMANCE INDICATOR (CONTEXTUAL) 1.3.1 
Number of published economic reports

Description: This indicator gauges the number of economic reports that staff of the Division of Economic and Risk Analysis publishes 
annually on the SEC’s website.

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017 
Actual

Number of reports
Prior-year data  
not available

23 15 29 33 43

Responsible Division/Office: Division of Economic and Risk Analysis

Data Source: SEC.gov

PERFORMANCE INDICATOR (PROCESS) 1.3.2 
Number of amendments to national securities exchange registrations (Form 1)

Description: This indicator provides information about the volume of material filed with the SEC that involves amendments to  
exchange registrations.

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017 
Actual

Number of amendments
Prior-year data  
not available

117 161 160 165

Responsible Division/Office: Division of Trading and Markets

Data Source: Form 1 Amendments List 



FY 2017 ANNUAL PERFORMANCE REPORT AND FY 2019 ANNUAL PERFORMANCE PLAN   |   101

PERFORMANCE INDICATOR (PROCESS) 1.3.3 
Number of Alternative Trading System registrations (Form ATS)

Description: This indicator provides information about the volume of material filed with the SEC that involves filings related to ATS 
registrations.

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017 
Actual

Number of registrations
Prior-year data  
not available

12 9 6 16

Responsible Division/Office: Division of Trading and Markets

Data Source: ATS Events List

PERFORMANCE INDICATOR (PROCESS) 1.3.4 
Number of new investment product submissions

Description: This indicator provides information about the volume of material filed with the SEC that involves new product submissions 
pursuant to Rule 19b-4(e) of the Exchange Act.

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017 
Actual

Number of submissions
Prior-year data  
not available

2,047 2,285 4,635 4,855

Responsible Division/Office: Division of Trading and Markets

Data Source: 19b-4(e) Log     



102   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

Strategic Objective 1.4: The SEC engages with a multi-
tude of stakeholders to inform and enhance regulatory 
activities domestically and internationally.

Goal Leader(s): Director, Office of International Affairs

PERFORMANCE GOAL 1.4.1 
Supervisory cooperation requests from foreign authorities for SEC assistance and SEC requests for 

assistance on supervisory cooperation from foreign authorities

Description: The SEC makes requests to foreign authorities for supervisory cooperation assistance and responds to such requests 
from foreign regulators through both formal mechanisms, such as supervisory memoranda of understanding, and on an ad hoc basis.

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017 

Plan
FY 2017 
Actual

FY 2018 
Estimate

FY 2019 
Estimate

Supervisory cooperation  
requests from foreign  
authorities

Prior-year 
data not 
available

25 117 113 148 152 153 158 163

SEC requests for assistance  
on supervisory cooperation 
from foreign authorities

Prior-year 
data not 
available

118 96 135 135 139 169 174 179

Target: Supervisory cooperation requests from foreign authorities – Exceeded; SEC requests for assistance on supervisory cooperation 
from foreign authorities – Exceeded

Analysis: The actual SEC results in FY 2017 exceeded the estimate by approximately 22 percent. 

Responsible Division/Office: Office of International Affairs

Data Source: International Program Oversight Database and Business Objects Reports

PERFORMANCE GOAL 1.4.2 
Number of non-U.S. regulators trained

Description: This metric shows the reach of the SEC’s technical assistance programs for regulators around the world. The SEC 
conducts these training sessions to assist countries in developing and maintaining robust protections for investors and promoting cross-
border enforcement and supervisory assistance.

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017 

Plan
FY 2017 
Actual

FY 2018 
Estimate

FY 2019 
Estimate

Number of non-U.S. regulators 1,785 1,716 2,382 1,666 2,145 1,800 1,837 1,850 1,850

Target: Exceeded

Analysis: The actual results for FY 2017 exceeded the performance target.

Responsible Division/Office: Office of International Affairs

Data Source: International Program Oversight Database and Business Objects Reports



FY 2017 ANNUAL PERFORMANCE REPORT AND FY 2019 ANNUAL PERFORMANCE PLAN   |   103

	STRATEGIC GOAL 2: Foster and  
Enforce Compliance with Federal 
Securities Laws

Fostering compliance with federal securities laws is 
interwoven through all of the SEC’s programs and is 
central to fulfilling the critical mission of the agency. 
Through disclosure reviews and examinations of bro-
ker-dealers, investment advisers, self-regulatory organi-
zations (SRO), and other market participants, the SEC 
seeks both to detect violations of the securities laws and 
rules, and to foster strong compliance and risk man-
agement practices within these firms and organizations. 
The SEC’s enforcement program also investigates and 
prosecutes violations of the law with the aim of holding 
wrongdoers accountable, returning funds to harmed 
investors whenever possible, and building deterrence 

against future violations. In FY 2017, the agency met 
or exceeded 10 and did not meet two performance 
targets in Strategic Goal 2. For FY 2019, the agency is 
requesting a total of $987.2 million and 2,678 FTEs for 
Goal 2. These resources will allow the SEC to expand 
the reach of the examination program and address the 
growing number and complexity of registered firms. 
Additionally, the Commission will be able to take 
prompt action to halt misconduct, sanction wrongdoers 
effectively, and return funds to harmed investors. 

Strategic Objective 2.1: The SEC fosters compliance 
with the federal securities laws.

Goal Leader(s): Director, Office of Compliance 
Inspections and Examinations

PERFORMANCE GOAL 2.1.1 
Number of industry outreach and education programs targeted to areas 

identified as raising particular compliance risks

Description: Targeted communication with industry participants on topics shaping the examination program is intended to enhance 
compliance practices and prevent violations before they occur. This metric identifies the number of major outreach efforts conducted, 
including the SEC’s national and regional compliance outreach events, published risk alerts, and other educational programs and 
initiatives.

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017 

Plan
FY 2017 
Actual

FY 2018 
Estimate

FY 2019 
Estimate

Number of major 
outreach efforts

12 15 63 129 158 100 128 100 100

Target: Exceeded

Analysis: The SEC seeks to encourage a strong culture of ethical behavior and decision-making at organizations and promote 
compliance with federal securities laws. As part of its efforts to promote compliance within the industry, OCIE conducted more than 
125 outreach and educational programs events during the year, including Compliance Outreach seminars and various other outreach 
initiatives with registrants, regulators, and industry groups. As part of this work, the program also issued six National Risk Alerts, 
presented at SEC Speaks, and published other significant materials during the year. In addition, staff from throughout the program 
participated in a number of other outreach efforts, including speaking at more than a hundred industry conferences and related 
engagements that are not reflected in the above numbers. 

Responsible Division/Office: Office of Compliance Inspections and Examinations

Data Source: Internal tracking, although many of the events noted above are referenced on the SEC’s website



104   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

PERFORMANCE GOAL 2.1.2 
Percentage of firms receiving deficiency letters that take corrective  

action in response to all exam findings

Description: At the conclusion of examinations, the staff communicates identified deficiencies to registrants in the form of a deficiency 
letter. Registrants are then given a chance to respond to staff findings and often take action to remedy any problems and potential risks, 
including monetary compensation to clients and enhancements to disclosures, policies, and procedures. Most often, registrants respond 
that they have corrected the deficiencies and implemented measures to prevent recurrence.

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017 

Plan
FY 2017 
Actual

FY 2018 
Estimate

FY 2019 
Estimate

Percentage 92% 86% 89% 90% 88% 89% 91% 90% 90%

Target: Exceeded

Analysis: The SEC works to enforce and foster compliance with federal securities laws through its examination program. During 
examinations in FY 2017, the staff identified a number of areas where firms appeared not to be in compliance with federal securities 
laws. In response to deficiency letters that were sent to firms by the staff, the vast majority of registrants have continued to assert 
that they are taking corrective action in response to the staff’s findings. This measure continues to show that registrants are using 
examination results to improve operations and compliance with federal securities laws.

Responsible Division/Office: Office of Compliance Inspections and Examinations

Data Source: Tracking and Reporting Exam National Documentation System (TRENDS)



FY 2017 ANNUAL PERFORMANCE REPORT AND FY 2019 ANNUAL PERFORMANCE PLAN   |   105

Strategic Objective 2.2: The SEC promptly detects and 
deters violations of the federal securities laws.

Goal Leader(s): Director, Office of Compliance Inspec-
tions and Examinations

PERFORMANCE GOAL 2.2.1 
Percentage of investment advisers, investment companies,  

and broker-dealers examined during the year

Description: This metric indicates the number of registrants examined by the SEC or an 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, limited-scope special inspections to probe emerging risk areas, and oversight examinations of broker-dealers to test 
compliance and the quality of examinations by FINRA.

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017 

Plan
FY 2017 
Actual

FY 2018 
Estimate

FY 2019 
Estimate

Investment advisers 8% 9% 10% 10% 11% 13% 15% 15% 15%

Investment companies 12% 11% 10% 15% 17% 10% 11% 11% 11%

Broker-dealers 49% 46% 49% 51% 50% 48% 48% 48% 48%

Target: Investment advisers – Exceeded; Investment companies – Exceeded; Broker-dealers – Met

Analysis: Building and maintaining examination coverage of the industry helps the Commission promptly detect violations of federal 
securities laws and promote compliance with such laws. During FY 2017, the examination program met or exceeded its coverage 
targets. The program focused particular efforts in the investment adviser space and was able to improve coverage beyond targeted 
levels. In addition to conducting examinations, the staff continued to exert considerable time and attention during the year on  
enhancing its risk assessment efforts to ensure that the program is spending its limited time and resources on those activities and  
firms presenting the highest risk. Further, program resources were also allocated during the past year to other critical activities intended 
to improve the long-term performance of the program, including industry outreach initiatives, rulemaking projects, and other program 
improvement efforts. 

Responsible Division/Office: Office of Compliance Inspections and Examinations

Data Source: Tracking and Reporting Exam National Documentation System (TRENDS) (IA, IC, and BD SEC data) and SRO Databases 
(BD SRO Data)

PERFORMANCE GOAL 2.2.2 
Percentage of compliance exams that are timely concluded in accordance with the  

Office of Compliance Inspections and Examinations’ (OCIE) statutory deadline

Description: The staff conducts examinations each year of registered entities, including investment advisers, investment company 
complexes, transfer agents, and broker-dealers. The staff strives to complete its examinations and communicate findings in the most 
efficient and effective manner and within its statutory deadline. This metric reflects the percentage of examinations concluded within the 
statutory deadline.

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017 

Plan
FY 2017 
Actual

FY 2018 
Estimate

FY 2019 
Estimate

Percentage
Prior-year data 
not available

100% 100% 100% 100% 100% 100% 100% 100%

Target: Met

Analysis: The staff’s goal is to identify and communicate potential issues to firms to ensure that compliance problems and issues are 
corrected quickly. During FY 2017, 100 percent of completed examinations were done within OCIE’s statutory deadline. Overall, this 
performance goal helps the SEC ensure that deficiencies are promptly resolved by firms. 

Responsible Division/Office: Office of Compliance Inspections and Examinations

Data Source: Tracking and Reporting Exam National Documentation System (TRENDS) 



106   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

PERFORMANCE GOAL 2.2.3 
Number of joint exams, information sharing agreements, and  

formal meetings with other regulators

Description: The SEC attempts to coordinate and collaborate with other regulators on areas of mutual interest. This helps to ensure 
that all regulators are informed of ongoing risks and issues related to broad market practices as well as specific entities of mutual 
interest. This cooperation is critical to the exam program to ensure that certain higher risk firms and activities are addressed in the most 
efficient and effective manner. This metric tracks critical cooperation activities that are occurring between the SEC’s exam program and 
other regulators.

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017 

Plan
FY 2017 
Actual

FY 2018 
Estimate

FY 2019 
Estimate

Number of joint exams, active  
sharing agreements, and  
formal meetings

Prior-year data  
not available

391 442 445 375 376 350 350

Target: Exceeded

Analysis: The exam program continued to conduct joint/coordinated exams and held hundreds of meetings with other regulators, which 
has proved an effective method of overseeing entities and issues that cross jurisdictional lines. The program also maintained a number of 
sharing agreements with these regulators to help ensure that information could be shared in an appropriate and timely manner.

Responsible Division/Office: Office of Compliance Inspections and Examinations

Data Source: Tracking and Reporting Exam National Documentation System (TRENDS) 

PERFORMANCE INDICATOR (CONTEXTUAL) 2.2.1 
Percentage of exams that identify deficiencies, the percentage that result in a “significant finding,”  

and the percentage referred to the Division of Enforcement

Description: Examiners find a wide range of deficiencies during examinations. Some of the deficiencies are more technical in nature, 
such as failing to include all information that is required to be in a record. However, other deficiencies may cause harm to customers 
or clients of a firm, have a high potential to cause harm, or reflect recidivist misconduct. The latter deficiencies are among those 
categorized as “significant.” This indicator identifies the percentage of exams that identified deficiencies, that resulted in significant 
deficiency findings, and that were referred to Enforcement.

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017 
Actual

Percentage that identify deficiencies 80% 80% 76% 77% 72% 72%

Percentage that result in a “significant finding” 42% 35% 30% 31% 27% 20%

Percentage referred to the Division of Enforcement
Prior-year data  
not available

13% 12% 11% 9% 7%

Responsible Division/Office: Office of Compliance Inspections and Examinations

Data Source: Tracking and Reporting Exam National Documentation System (TRENDS)     



FY 2017 ANNUAL PERFORMANCE REPORT AND FY 2019 ANNUAL PERFORMANCE PLAN   |   107

PERFORMANCE INDICATOR (OUTPUT) 2.2.2 
Number of cause exams that result from tips, complaints, and referrals

Description: Analysis of a tip can support the request for a cause exam. This indicator would identify the number of SEC cause exams 
that result from tips collected through outreach efforts.

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017 
Actual

Number of cause exams
Prior-year data  
not available

222 149 173 191 177

Responsible Division/Office: Office of Compliance Inspections and Examinations

Data Source: Tracking and Reporting Exam National Documentation System (TRENDS)     

PERFORMANCE INDICATOR (OUTPUT) 2.2.3 
Number of rulemaking initiatives assisted by the National Exam Program 

Description: The examination program interacts with registrants on a regular basis, and this work provides critical feedback toward 
ensuring effective and practical rulemaking and policy efforts. This indicator tracks how frequently the examination program assists with 
rulemaking initiatives.

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017 
Actual

Number of rulemaking initiatives assisted by the NEP
Prior-year data  
not available

30 26 24 16

Responsible Division/Office: Office of Compliance Inspections and Examinations

Data Source: Internal tracking   

PERFORMANCE INDICATOR (OUTPUT) 2.2.4 
Number of investigations or inquiries originating from a tip or complaint 

Description: Analysis of a tip or complaint can result in the need for further enforcement investigation. The indicator identifies the 
volume of SEC investigations that result from tips and complaints received by the SEC.

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017 
Actual

Number of investigations 296 289 291 325 336 307

Responsible Division/Office: Division of Enforcement

Data Source: HUB case management and tracking system for the Division of Enforcement   



108   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

PERFORMANCE INDICATOR (OUTPUT) 2.2.5 
SEC investigations in which requests for access to information were granted by the SEC to other authorities, 

such as SROs or other state, federal, and foreign enforcement authorities 

Description: The SEC works closely with other regulators and authorities. This measure identifies the number of investigations in which 
the SEC granted one or more authorities access to information concerning an investigation during the fiscal year. This may include 
requests for access to SEC investigative files concerning investigations that the SEC continues to pursue, as well as those in which the 
SEC has completed its investigation.

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017 
Actual

Number of investigations 515 504 501 498 496 505

Responsible Division/Office: Division of Enforcement

Data Source: HUB case management and tracking system for the Division of Enforcement  

PERFORMANCE INDICATOR (OUTPUT) 2.2.6 
Requests from foreign authorities for SEC assistance and SEC requests for assistance from foreign 

authorities 

Description: Each year, the SEC makes hundreds of requests for enforcement assistance to foreign regulators, while responding 
to hundreds of such requests from other nations. To facilitate this type of assistance, and encourage other countries to enact laws 
necessary to allow regulators to cooperate with their foreign counterparts, the SEC has entered into bilateral information sharing 
arrangements, as well as the Multilateral Memorandum of Understanding, an information sharing arrangement negotiated through the 
International Organization of Securities Commissions (IOSCO). 

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017 
Actual

Number of requests from foreign authorities 450 508 541 531 636 599

Number of SEC requests 718 717 966 929 1,027 1,272

Responsible Division/Office: Office of International Affairs

Data Source: International Program Oversight Database and Business Objects reports  



FY 2017 ANNUAL PERFORMANCE REPORT AND FY 2019 ANNUAL PERFORMANCE PLAN   |   109

Strategic Objective 2.3: The SEC prosecutes violations 
of federal securities laws and holds violators account-
able through appropriate sanctions and remedies. 

Goal Leader(s): Director, Division of Enforcement

PERFORMANCE GOAL 2.3.1 
Percentage of enforcement actions in which the Commission  

obtained relief on one or more claims

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.

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017 

Plan
FY 2017 
Actual

FY 2018 
Estimate

FY 2019 
Estimate

Percentage 89% 93% 94% 95% 97% 92% 94% 92% 92%

Target: Exceeded

Analysis: In addition to securing victories in specific cases through litigation and trial, the SEC’s litigation efforts also help the SEC 
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 of the SEC’s mission. 

Responsible Division/Office: Division of Enforcement

Data Source: HUB case management and tracking system for the Division of Enforcement

PERFORMANCE GOAL 2.3.2 
Percentage of first enforcement actions filed within two years of the opening of an investigation

Description: This metric concerns the pace of investigations that lead to the filing of enforcement actions. Specifically, this metric 
captures the rate at which the first enforcement action arising out of an investigation was filed within two years of the opening of the 
investigation. If the investigation was preceded by a matter under inquiry, the metric draws on the date of the opening of the matter 
under inquiry. In conducting investigations, the Enforcement program continually strives to balance the need for complete, effective, and 
fair investigations with the need to file enforcement actions in as timely a manner as possible.

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017 

Plan
FY 2017 
Actual

FY 2018 
Estimate

FY 2019 
Estimate

Percentage 63% 58% 64% 58% 53% 65% 52% 65% 65%

Target: Not Met

Analysis: In FY 2017, the percentage of first enforcement actions filed within two years of the opening of the matter under inquiry (MUI) 
or investigation was 52 percent, which is a decrease compared to the FY 2016 result (53 percent). While timeliness in filing actions can 
be influenced by a number of factors, it is important because it can enhance the action’s deterrent impact. 

Plan for Improving Program Performance: To address the issue of timeliness in investigations, the division is taking measures that 
include emphasizing expediency in quarterly case reviews, promoting best practices regarding efficiencies in various phases of the 
investigative process, leveraging data analytics capabilities, and conducting training on tools that expedite investigations.

Responsible Division/Office: Division of Enforcement

Data Source: HUB case management and tracking system for the Division of Enforcement



110   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

PERFORMANCE GOAL 2.3.3 
Average months between opening a matter under inquiry or an  

investigation and commencing an enforcement action

Description: This metric captures the average number of months between the opening of an investigation and the filing of the first 
enforcement action arising out of that investigation. If the investigation was preceded by a matter under inquiry, the metric draws on  
the date of opening of the matter under inquiry. In conducting investigations, the enforcement program continually strives to balance  
the need for complete, effective, and fair investigations with the need to file enforcement actions in as timely a manner as possible.  
While not all investigations result in the filing of enforcement actions, this metric provides information concerning the pace of 
investigations that do lead to such actions and supplements the previous goal, which measures the percentage of first enforcement 
actions filed within two years.

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017 

Plan
FY 2017 
Actual

FY 2018 
Estimate

FY 2019 
Estimate

Months 21 21 21 24 24 20 24 20 20

Target: Not Met

Analysis: In FY 2017, the average number of months between opening a matter under inquiry (MUI) or investigation and commencing 
an enforcement action was 24 months, which was the same as FY 2016. Timeliness in filing actions is important because it can enhance 
the action’s deterrent impact. At the same time, many of the division’s cases are complex and can take extended periods of time to 
develop successfully. 

Plan for Improving Program Performance: To address the issue of timeliness in investigations, the division is taking measures that 
include emphasizing expediency in quarterly case reviews, promoting best practices regarding efficiencies in various phases of the 
investigative process, leveraging data analytics capabilities, and conducting training on tools that expedite investigations.

Responsible Division/Office: Division of Enforcement

Data Source: HUB case management and tracking system for the Division of Enforcement

PERFORMANCE GOAL 2.3.4 
Percentage of debts where either a payment has been made or a collection activity  

has been initiated within 180 days of the due date of the debt

Description: The SEC can seek a wide range of remedies for failure to comply with the securities laws. These remedies include civil 
monetary penalties and disgorgement. When the remedies are imposed by the SEC or the federal district court, payments must be 
made by a certain date. This metric identifies the percentage of debts where debtors have made payments, or the SEC has initiated a 
collection activity within 180 days of the due date. Such collection activities include, among other things, demand letters, negotiation of 
payment plans, enforcing the payment of the debt through the courts, or other judicial remedies.

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017 

Plan
FY 2017 
Actual

FY 2018 
Estimate

FY 2019 
Estimate

Percentage 92% 95% 92% 95% 96% 92% 99% 92% 92%

Target: Exceeded

Analysis: The division has successfully integrated all collections functions within the Office of Collections and, as a result, exceeded  
the target for this performance measure. 

Responsible Division/Office: Division of Enforcement

Data Source: DELPHI, HUB case management and tracking system for the Division of Enforcement



FY 2017 ANNUAL PERFORMANCE REPORT AND FY 2019 ANNUAL PERFORMANCE PLAN   |   111

PERFORMANCE GOAL 2.3.5 
Percentage of Fair Fund and disgorgement fund plans that have distributed 80 percent of the available 

funds for distribution within twenty-four (24) months of the approval of the distribution plan

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 twenty-four (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.

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017 

Plan
FY 2017 
Actual

FY 2018 
Estimate

FY 2019 
Estimate

Percentage 80% 73% 81% 96% 93% 80% 96% 80% 80%

Target: Exceeded

Analysis: In FY 2017, the division exceeded the target by 16 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 the function 
and implementing various process improvements. 

Responsible Division/Office: Division of Enforcement

Data Source: HUB case management and tracking system for the Division of Enforcement

PERFORMANCE INDICATOR (CONTEXTUAL) 2.3.1 
Percentage of filed enforcement actions reflecting characteristics that present  

enhanced risk to investors and markets, as measured by the nature of the  
investigation, conduct, parties and impact 

Description: This indicator assesses the quality of the cases filed by the Division of Enforcement. The indicator focuses on cases 
filed by the SEC that involve factors reflecting enhanced risk to investors and markets. Such cases may involve: (i) those identified 
through risk analytics and cross-disciplinary initiatives to reveal difficult-to-detect or early stage misconduct, thus minimizing investor 
loss and preventing the spread of unlawful conduct and practices; (ii) particularly egregious or widespread misconduct and investor 
harm; (iii) vulnerable victims; (iv) a high degree of scienter; (v) involvement of individuals occupying substantial positions of authority, or 
having fiduciary obligations or other special responsibilities to investors; (vi) involvement of recidivists; (vii) high amount of investor loss 
prevented; (viii) misconduct that is difficult to detect due to the complexity of products, transactions, and practices; (ix) use of innovative 
investigative or analytical techniques; (x) effective coordination with other law enforcement partners; and/or (xi) whether the matter 
involves markets, transactions, or practices identified as an enforcement priority, or that advances the programmatic priorities of other 
SEC Divisions or Offices.

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017 
Actual

Percentage
Prior-year data  
not available

62% 58% 57% 44%

Responsible Division/Office: Division of Enforcement

Data Source: Qualitative Index Spreadsheet  



112   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

PERFORMANCE INDICATOR (CONTEXTUAL) 2.3.2 
Total amount distributed within the fiscal year, and the number of Fair Funds  

from which those distributions came 

Description: In its enforcement actions, the SEC may seek to return funds to harmed investors through disgorgement of ill-gotten 
gains or through the Fair Funds provision of the Sarbanes-Oxley Act. This provision permits the SEC to combine amounts paid as 
penalties with disgorged funds, or to create a Fair Fund from penalties only, to reduce losses to injured parties. This reflects the SEC’s 
efforts to return funds to injured investors. This indicator identifies the total amount distributed within the fiscal year, and the number of 
Fair Funds from which those distributions came. This indicator may increase or decrease in dollar amount and number of distribution 
funds based on the number of SEC enforcement actions brought involving distributions, amounts ordered and paid in those actions, 
and other factors. Due to the variation in reporting timelines established for each individual distribution, reported amounts are based 
on the agency’s best available information. Reported amounts do not include those funds distributed through receiverships. 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 Commission’s own expenses.

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017 
Actual

Amount distributed (in millions) $815 $251 $424 $158 $140 $1,073

Number of Fair Funds 31 22 28 34 35 32

Responsible Division/Office: Division of Enforcement

Data Source: HUB case management and tracking system for the Division of Enforcement Distributions Management System 

PERFORMANCE INDICATOR (OUTPUT) 2.3.3 
Percent of enforcement actions filed that arose out of national priority investigations 

Description: The Division of Enforcement conducts many enforcement actions each year that can be characterized as high impact and 
of national priority. High impact or national priority investigations include investigations that are significant for one or more of the following 
reasons—the matter: (i) presents an opportunity to send a particularly strong and effective message of deterrence, including with 
respect to markets, products, and transactions that are newly developing or that are long established but by their nature present limited 
opportunities to detect wrongdoing and thus to deter misconduct; (ii) involves particularly egregious or extensive misconduct; (iii) involves 
potentially widespread and extensive harm to investors; (iv) involves misconduct by persons occupying positions of substantial authority 
or responsibility, or who owe fiduciary or other enhanced duties and obligations to a broad group of investors or others; (v) involves 
potential wrongdoing as prohibited under newly-enacted legislation or regulatory rules; (vi) concerns potential misconduct that occurred 
in connection with products, markets, transactions, or practices that pose particularly significant risks for investors or a systemically 
important sector of the market; (vii) involves a substantial number of potential victims and/or particularly vulnerable victims; (viii) involves 
products, markets, transactions, or practices that the Enforcement Division has identified as priority areas; and/or (ix) provides an 
opportunity to pursue priority interests shared by other law enforcement agencies on a coordinated basis.

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017 
Actual

Percentage 20% 15% 16% 25% 27% 19%

Responsible Division/Office: Division of Enforcement

Data Source: HUB case management and tracking system for the Division of Enforcement 



FY 2017 ANNUAL PERFORMANCE REPORT AND FY 2019 ANNUAL PERFORMANCE PLAN   |   113

PERFORMANCE INDICATOR (CONTEXTUAL) 2.3.4 
Criminal actions related to conduct under investigation by the SEC 

Description: In some instances, conduct may involve both civil and criminal violations and may be investigated by both the SEC and the 
criminal authorities. This indicator identifies the number of criminal actions that are related to conduct under investigation by the SEC.

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017 
Actual

Number of criminal investigations 126 126 127 134 109 128

Responsible Division/Office: Division of Enforcement

Data Source: HUB case management and tracking system for the Division of Enforcement 

PERFORMANCE INDICATOR (CONTEXTUAL) 2.3.5 
Disgorgement and penalties ordered and the amounts collected 

Description: In addition to other types of relief, the SEC may seek orders requiring parties to disgorge any money obtained through 
wrongdoing. The SEC is also empowered to seek civil penalties for violations of the securities laws. In some cases, the SEC will seek 
to obtain large monetary sanctions, even in instances where the prospect of collecting on a judgment is slight. The rationale for seeking 
monetary relief in these circumstances is that such relief, even when likely uncollectible, might become collectible in the future based 
on the defendant’s changed circumstances, and also because such relief can serve to deter others from violating the securities laws. 
Where appropriate, the SEC has sought to return disgorged funds to harmed investors. Funds not returned to investors are sent to the 
Treasury or the Investor Protection Fund established pursuant to Section 21F(g) of the Securities Exchange Act of 1934. This indicator 
lists disgorgement and penalties ordered as a result of SEC cases in each fiscal year and the amounts collected in those actions as of 
the end of FY 2015. The indicator for collected amounts could change over time based on various factors.

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017 
Actual

Ordered amounts (in millions) $3,104 $3,424 $4,166 $4,195 $4,082 $3,789

Collected amounts (in millions) $1,236 $2,334 $2,580 $2,408 $2,656 $1,873 

Responsible Division/Office: Division of Enforcement

Data Source: DELPHI



114   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

	 Strategic Goal 3: Facilitate Access 
to the Information Investors Need to 
Make Informed Investment Decisions 

A strong economy and a vibrant securities market rely 
on investor confidence and the widespread availability 
of relevant information about those securities. The SEC 
promotes informed investment decisions through two 
main approaches. The first is to require that investors 
have accurate, adequate, and timely public access to 
disclosure materials that are easily understood and ana-
lyzed. The second is to implement a variety of investor 
education initiatives aimed at giving investors a better 

understanding of the operations of the nation’s securi-
ties markets. In FY 2017, the agency exceeded all 12 
performance targets in Strategic Goal 3. For FY 2019, 
the SEC is requesting a total of $210.6 million and 571 
FTEs toward achieving results in Strategic Goal 3.

Strategic Objective 3.1: The SEC works to ensure that 
investors have access to high-quality disclosure materi-
als that facilitate informed investment decision-making. 

Goal Leader(s): Director, Division of Corporation 
Finance; Director, Division of Investment Management 

PERFORMANCE GOAL 3.1.1 
Percentage of public companies and investment companies with disclosures reviewed each year

Description: The Sarbanes-Oxley Act requires that the SEC review, at least once every three years, the disclosures of all companies 
and investment company portfolios reporting under the Exchange Act. These reviews help improve the information available to investors 
and may identify possible violations of the federal securities laws. This metric gauges the number of public companies and investment 
companies reviewed each year.

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017 

Plan
FY 2017 
Actual

FY 2018 
Estimate

FY 2019 
Estimate

Division of Corporation Finance

Corporations 48% 52% 52% 51% 56% 33% 56% 33% 33%

Target: Exceeded

Analysis: CF exceeded its planned level of companies reviewed in FY 2017. 

Responsible Division/Office: Division of Corporation Finance

Data Source: Electronic Data Gathering, Analysis, and Retrieval (EDGAR) System, Filing Activity Tracking System (FACTS)

Division of Investment Management

Investment company portfolios 36% 34% 35% 35% 36% 33% 35% 33% 33%

Target: Exceeded

Analysis: Consistent with Section 408 of the Sarbanes Oxley-Act of 2002, IM strives to review disclosures made by certain public 
issuers, including issuers’ financial statements, no less frequently than once every three years. The targeted number of annual reviews 
assumes that IM meets this goal. 

Responsible Division/Office: Division of Investment Management

Data Source: Microsoft Office Suite Tools        



FY 2017 ANNUAL PERFORMANCE REPORT AND FY 2019 ANNUAL PERFORMANCE PLAN   |   115

PERFORMANCE GOAL 3.1.2 
Time to issue initial comments on Securities Act filings

Description: The target of 30 days or less has become a de facto industry standard for the maximum time to receive initial comments.

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017 

Plan
FY 2017 
Actual

FY 2018 
Estimate

FY 2019 
Estimate

Days 24.9 25.6 25.8 26.0 25.5 <30.0 25.4 <30.0 <30.0

Target: Exceeded

Analysis: CF achieved its goal of having a response time for initial comments of less than 30 days. 

Responsible Division/Office: Division of Corporation Finance

Data Source: Division of Corporation Finance Management Dashboards        

PERFORMANCE GOAL 3.1.3 
Percentage of investment company disclosure reviews for which initial  

comments are completed within timeliness goals

Description: For initial registration statements, the SEC’s goal is to issue initial comments within 30 days after they are filed (60 days for 
registration statements of insurance product separate accounts and related mutual funds). The SEC also aims to comment on post-
effective amendments within 45 days, and on preliminary proxy statements within 10 days after they are filed.

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017 

Plan
FY 2017 
Actual

FY 2018 
Estimate

FY 2019 
Estimate

Initial registration statements 96% 98% 98% 98% 98% 85% 100% 85% 85%

Post-effective amendments 95% 99% 99% 98% 100% 90% 99% 90% 90%

Preliminary proxy statements 100% 98% 99% 98% 99% 99% 100% 99% 99%

Target: Initial registration statements – Exceeded; Post-effective amendments – Exceeded; Preliminary proxy statements – Exceeded

Analysis: IM strives to review all significant disclosures made by registrants in Commission filings under the Investment Company Act, 
including initial registration statements and post-effective amendments with material changes. IM may limit the scope of a review, through 
selective review procedures, to a review of only the disclosure in a filing that has not been previously reviewed. During periods of increased 
filings, IM is able to handle the increased workload largely through the use of such selective review procedures. IM generally does not set 
a target for the number of filings that are reviewed in a fiscal year because IM does not dictate the number of filings that registrants make. 
Instead, other factors, such as registrant business decisions or the implementation of new disclosure requirements, typically drive whether 
investment companies make filings and the type of filings that they make. IM sets targets for the timeliness of reviews. 

Responsible Division/Office: Division of Investment Management

Data Source: Electronic Data Gathering, Analysis, and Retrieval (EDGAR) System       



116   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

PERFORMANCE INDICATOR (CONTEXTUAL) 3.1.1 
Total digital audience including website, social media, and mobile media 

Description: Digital media has become the dominant channel for investors seeking to access information. These statistics will help 
evaluate the extent to which investors are turning to the SEC, identify the channels they use, and quantify the amount of information  
they receive.

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017 
Actual

SEC.gov page views (in billions)
Prior-year data 
not available

3.72 4.49 6.37 7.90 18.40

Social media followers 236,700 258,733 308,261 382,702 399,086 434,908

Total email/mobile subscriptions 631,839 740,318 799,055 982,817 1,051,625 1,395,591

Total email bulletins sent (in millions) 33.44 40.85 47.01 56.45 57.64 43.6

Total mobile bulletins sent 150,303 238,815 366,032 461,753 614,325 554,548

Responsible Division/Office: Office of Public Affairs

Data Source: Akamai Technologies, Google Analytics, GovDelivery, Hootsuite, social media channels

Strategic Objective 3.2: The SEC works to understand 
investor needs and educate investors so they are better 
prepared to make informed investment decisions. 

Goal Leader(s): Director, Office of Investor  
Education and Advocacy

PERFORMANCE GOAL 3.2.1 
Number of page views of online investor education content, and number of in-person events,  

including those with specifically targeted communities and organizations

Description: The Office of Investor Education and Advocacy (OIEA) initiates investor education campaigns on key strategies for 
making informed investment decisions, including publicizing online resources for researching investment professionals and investments, 
understanding fees, and identifying fraud. OIEA staff also participates in in-person events for investors, both general and those targeted 
toward specific investors, such as seniors, service members, and other affinity groups. This metric tracks page views of SEC online investor 
education materials and the number of investor events in which OIEA staff participated. 

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017 

Plan
FY 2017 
Actual

FY 2018 
Estimate

FY 2019 
Estimate

Number of page views  
(in millions)

Prior-year data 
not available

12.1 22.2 23.6 23.7 8.0 9.1 8.0 10.0

Number of in-person 
events

Prior-year data 
not available

52 51 71 112 80 146 90 90

Target: Number of page views – Exceeded; Number of in-person events – Exceeded

Analysis: The public’s use of Investor.gov and investor education materials on SEC.gov exceeded the SEC’s performance target, with 
particular interest in the calculators, tools, and resources for checking the background of investment professionals. OIEA participated in 
70 events focused on military personnel and their families as part of the SEC’s Military Financial Literacy Campaign, helping it exceed its 
target for in-person events. 

Responsible Division/Office: Office of Investor Education and Advocacy

Data Source: Google Analytics, Microsoft Office Suite Tools         



FY 2017 ANNUAL PERFORMANCE REPORT AND FY 2019 ANNUAL PERFORMANCE PLAN   |   117

PERFORMANCE GOAL 3.2.2 
Timeliness of responses to investor contacts

Description: OIEA serves the tens of thousands of investors each year who contact the SEC with investment-related complaints and 
questions. The staff aims to close out as many new investor assistance matters as possible within seven to thirty business days. 

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017 

Plan
FY 2017 
Actual

FY 2018 
Estimate

FY 2019 
Estimate

Closed within 7 days 54% 62% 62% 65% 64% 62% 65% 62% 62%

Closed within 30 days 93% 93% 92% 93% 92% 90% 94% 90% 90%

Target: Closed within 7 days – Exceeded; Closed within 30 days – Exceeded

Analysis: OIEA continued to focus its efforts on identifying and referring key investor assistance matters to the agency’s Tips, 
Complaints, and Referrals (TCR) system and exceeded its 7-day and 30-day targets for FY 2017.

Responsible Division/Office: Office of Investor Education and Advocacy

Data Source: Internal log using IRIS data

PERFORMANCE GOAL 3.2.3 
Customer satisfaction rating of OIEA’s online investor education resources

Description: This metric gauges the effectiveness, helpfulness, and usability of OIEA’s online investor education resources. 

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017  

Plan
FY 2017 
Actual

FY 2018 
Estimate

FY 2019 
Estimate

Satisfaction index
Prior-year data 
not available

81 83 84 83
Benchmark for 

federal government 
websites (73)

82 TBD TBD 

Target: Exceeded

Analysis: Investor.gov’s customer satisfaction score (82) continued to exceed the federal government benchmark (73) due in part to site 
refinements based on feedback from Investor.gov visitors. 

Responsible Division/Office: Office of Investor Education and Advocacy

Data Source: ForeSee results online portal



118   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

PERFORMANCE GOAL 3.2.4 
Number of new investor education materials designed specifically to help  

investors protect themselves from fraud 

Description: Through OIEA—and often in conjunction with other organizations, the staff issues Investor Alerts and other forms of 
educational materials that inform investors about different permutations of fraud, new investment products, and other topical issues. This 
metric measures the number of new investor education materials issued by OIEA. 

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017 

Plan
FY 2017 
Actual

FY 2018 
Estimate

FY 2019 
Estimate

Number of education materials 24 26 28 31 32 32 34 32 32

Target: Exceeded

Analysis: In FY 2017, OIEA published 34 investor alerts and bulletins to meet its goal, many of which were focused on warning investors 
about possible fraudulent schemes. 

Responsible Division/Office: Office of Investor Education and Advocacy

Data Source: SEC.gov and Investor.gov

PERFORMANCE INDICATOR (PROCESS) 3.2.1 
Number of investor testing research projects 

Description: This metric tracks the number of research initiatives used to gather feedback from investors regarding the usefulness of 
disclosures and other input on SEC rulemaking.

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017 
Actual

Number of projects 2 0 0 0 0 1

Responsible Division/Office: Office of the Investor Advocate

Data Source: Microsoft Office Suite Tools

PERFORMANCE INDICATOR (PROCESS) 3.2.2 
Number of sets of recommendations prepared by the investor advisory committee 

Description: This indicator tracks the recommendations from the Investor Advisory Committee regarding investors’ perspectives  
and priorities.

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017  
Actual

Number of sets of recommendations 0 4 4 4 4 0

Responsible Division/Office: Office of the Investor Advocate

Data Source: SEC.gov



FY 2017 ANNUAL PERFORMANCE REPORT AND FY 2019 ANNUAL PERFORMANCE PLAN   |   119

	Strategic Goal 4: Enhance the 
Commission’s Performance through 
Effective Alignment and Management 
of Human, Information, and Financial 
Capital

The investing public and the securities markets are best 
served by an efficient, well-managed, and agile SEC. 
The Office of the Chief Operating Officer (OCOO) 
and its six operational offices—the Office of Support 
Operations (OSO), the Office of Financial Manage-
ment (OFM), the Office of Human Resources (OHR), 
the Office of Strategic Initiatives (OSI), the Office 
of Acquisitions (OA), and the Office of Information 
Technology (OIT)—will focus on providing organiza-
tional and infrastructure improvements necessary to 
advance the Commission’s mission. The SEC is also 
extremely mindful of its responsibility to maximize the 

impact of public funds. In FY 2017, the agency met or 
exceeded 17 and did not meet two performance targets 
in Strategic Goal 4. During FY 2019, the agency 
will continue to focus on recruiting, developing, and 
retaining high-performing staff with current market 
expertise. Furthermore, the SEC will continue to 
strengthen internal controls. The agency is requesting 
a total of $274.9 million and 745 FTEs in FY 2019 to 
achieve results in Strategic Goal 4.

Strategic Objective 4.1: The SEC promotes a results- 
oriented work environment that attracts, engages,  
and retains a technically proficient and diverse work-
force, including leaders who provide motivation and 
strategic direction.

Goal Leader(s): Director, Office of Human Resources; 
Director, Office of Minority and Women Inclusion

PERFORMANCE GOAL 4.1.1 
Turnover 

Description: When employee morale and engagement are high, high-performing employees tend to remain in the organization. Although 
turnover can fluctuate based on a variety of factors, the SEC aims to keep its turnover rate relatively low, below eight percent per year.

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017 

Plan
FY 2017 
Actual

FY 2018 
Estimate

FY 2019 
Estimate

Percentage turnover 6.58% 6.58% 5.60% 6.20% 3.61% <8.00% 4.61% <8.00% <8.00%

Target: Met

Analysis: The agency’s results were within target. The two main sources of attrition in FY 2017 were employees leaving the SEC for 
private sector employment (approximately 45 percent of SEC losses) or retiring (approximately 40 percent of SEC losses). 

Responsible Division/Office: Office of Human Resources

Data Source: Interior Business Center120   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

PERFORMANCE GOAL 4.1.2 
Expanding staff expertise 

Description: Internal training and hiring programs are designed to help the agency recruit and develop a diverse and qualified staff with 
the key skills, industry knowledge, and expertise to support the SEC mission. In particular, there is a need to train examiners, attorneys, 
economists, and other experts for subject matter expertise relevant to the marketplace and investment and trading practices. This metric 
tracks whether certain areas requiring significant training are being addressed. The agency will track the number of SEC staff participants in 
mission-focused training and development programs and will report on specific items through the use of post-course evaluations to assess 
the impact and results of this training on a five-point scale.

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017 

Plan
FY 2017 
Actual

FY 2018 
Estimate

FY 2019 
Estimate

Mission-focused training attendance
Prior-year data  
not available

16,270 17,093 17,273 16,000 26,252 16,000 16,000

Post-course evaluations of mission- 
focused training

Prior-year data  
not available

4.14 4.24 4.33 4.30 4.32 4.30 4.30

Target: Mission-focused training attendance – Exceeded; Post-course evaluations of mission-focused training – Exceeded

Analysis: The metric tracks instructor led training, for which the agency’s results exceeded the target goal for FY 2017 by 64 percent. 
Beginning in FY 2016 and continuing in FY 2017, the agency also began offering more training virtually to enhance the accessibility of 
real-time training and reduce costs associated with classroom-based training. During FY 2017, the agency had over 55,000 instances of 
virtual training, an increase of approximately 12,000 instances. 

Responsible Division/Office: Office of Human Resources

Data Source: Course Attendance Identified in LEAP (Instructor-led courses only) and End of Course Evaluation Report Summary 
provided by Metrics that Matter 

PERFORMANCE GOAL 4.1.3 
Number of diversity-related partnerships/alliances 

Description: Increased numbers of diversity-related partnerships or alliances with professional associations and educational organizations 
provides additional opportunities to educate students about the SEC’s work and to recruit career professionals from all segments of society. 
The SEC will track the number of partnerships and/or alliances with diverse professional associations and educational organizations. 

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017 

Plan
FY 2017 
Actual

FY 2018 
Estimate

FY 2019 
Estimate

Number of partnerships/alliances 12 13 18 18 18 20 20 20 20

Target: Met

Analysis: In FY 2017, OMWI met the performance target of 20. The office established 2 new partnerships during the fiscal year and 
intends to maintain 20 partnerships moving forward. 

Responsible Division/Office: Office of Minority and Women Inclusion

Data Source: Office of Minority and Women Inclusion Internal Records and Section 342 of DFA



FY 2017 ANNUAL PERFORMANCE REPORT AND FY 2019 ANNUAL PERFORMANCE PLAN   |   121

PERFORMANCE GOAL 4.1.4 
Survey rankings  

Description: Annual and other rankings, together with other metrics and indicators of federal government agencies will be used as one 
kind of metric to determine the SEC’s overall success in improving employee morale and employee engagement.

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017 

Plan
FY 2017 
Actual

FY 2018 
Estimate

FY 2019 
Estimate

Best Places to Work ranking
Ranked  

#19
Ranked 

#15
Ranked 

#14
Ranked 

#10
Ranked 

#6
Ranked 

#5
Ranked 

#5
Ranked 

#5
Ranked 

#5 

Average of employee engagement 
and global satisfaction index

Prior-year data 
not available

61% 66% 68% 75% 75% 77% 80% 81%

Target: Best Places to Work ranking – Met; Average of satisfaction index – Exceeded

Analysis: In 2017, the SEC moved up one spot and now ranks #5 in the mid-size agency category. 

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 OPM and Average of Employee Engagement and Global Satisfaction Index from OPM EVS

PERFORMANCE GOAL 4.1.5 
Bench strength1  

Description: To maintain mission effectiveness, it is essential that attrition in the leadership ranks is quickly addressed by having a highly-
qualified and diverse pool of internal candidates ready to assume those critical roles. This metric is calculated as an average ratio of the 
number of qualified internal candidates for key leadership positions. 

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017 

Plan
FY 2017 
Actual

FY 2018 
Estimate

FY 2019 
Estimate

Percentage
Prior-year data  
not available

68% 149% 266% 280% 366% 300% 300%

Target: Exceeded

Analysis: The agency has recently placed a greater emphasis on focused leadership development cohort programs such as Aspiring 
Leaders and Leadership Development for our SK-14, SK-15, SK-16, and SK-17 employees. This increases our bench strength while 
developing cross-group collaboration. 

Responsible Division/Office: Office of Human Resources

Data Source: Course Attendance Identified in LEAP (Instructor-led courses only) and End of Course Evaluation Report Summary 
provided by Metrics that Matter 

1   	Percentage equals the number of SK 14–17 staff with significant leadership development divided by the number of senior officer positions typically filled  
by internal staff.



122   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

Strategic Objective 4.2: The SEC encourages a collab-
orative environment across divisions and offices and 
leverages technology and data to fulfill its mission more 
effectively and efficiently. 

Goal Leader(s): Director, Office of Information  
Technology 

PERFORMANCE GOAL 4.2.1 
Ensure SEC’s systems and applications are available 

Description: The SEC aims to enhance its computing infrastructure to eliminate downtime if systems at one site fail, among other 
objectives. This metric will capture the percentage of systems and applications that can fail over within 8 hours.

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017 

Plan
FY 2017 
Actual

FY 2018 
Estimate

FY 2019 
Estimate

Percentage of servers virtualized 79% 93% 95% 95% 95% 95% 91% 95% 95%

Percentage fail over within 8 hours Prior-year data  
not available

100% 100% 100% 100% 100% 100% 100%

Target: Percentage of servers virtualized – Not Met; Percentage fail over within 8 hours – Met

Analysis: OIT continues to leverage virtualization technologies for the SEC’s computing infrastructure. Virtual servers are considered the 
standard for all server builds. Dedicated physical server use requires CIO approval and remained under 5 percent. 

Responsible Division/Office: Office of Information Technology

Data Source: OIT Network Operations Center (NOC) – automated network monitoring tools

PERFORMANCE GOAL 4.2.2 
Equip the SEC with an enhanced technology infrastructure to support enterprise infrastructure

Description: The SEC aims to promote collaboration and information sharing across the enterprise. To improve efficiency and knowledge 
management, the SEC will consolidate and centralize its collaborative technologies to a commonly used enterprise set by 2020. This metric 
will measure the percentage of the SEC’s offices and divisions that utilize centralized enterprise collaboration solutions.

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017 

Plan
FY 2017 
Actual

FY 2018 
Estimate

FY 2019 
Estimate

Number of enterprise solutions 25% 30% 35% 40% 45% 45% 45% 45% 45%

Target: Met

Analysis: Enterprise solutions are leveraged across SEC offices and divisions, but higher percentages for this metric will require 
consolidation of related capabilities within the office and divisions. 

Responsible Division/Office: Office of Information Technology

Data Source: Approved software applications list



FY 2017 ANNUAL PERFORMANCE REPORT AND FY 2019 ANNUAL PERFORMANCE PLAN   |   123

PERFORMANCE GOAL 4.2.3 
Expand the SEC’s video teleconferencing (VTC) capabilities to support  

an increasing geographically dispersed workforce

Description: The SEC seeks to develop a state of the art video teleconference solution that allows users to conduct a video/
teleconference meeting between HQ, regional offices, and multiple endpoints simultaneously; collaborate and share presentation materials; 
and use VoIP technology to host video teleconferences from their offices/workspaces with other SEC users or conference rooms. This 
metric will measure the average “uptime” or availability of all VTC systems.

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017 

Plan
FY 2017 
Actual

FY 2018 
Estimate

FY 2019 
Estimate

Availability rate for  
VTC solutions

Prior-year data  
not available

80.00% 99.99% 99.99% 99.99% 99.99% 99.99% 99.99% 99.99%

Target: Met

Analysis: VTC services are leveraged across the SEC. Their high availability is attributed to the SEC’s investments in better technology, 
documented procedures, and training. 

Responsible Division/Office: Office of Information Technology

Data Source: Telecommunications monitoring system

PERFORMANCE GOAL 4.2.4 
Pursue continuous technology cost reductions and efficiencies

Description: Recent technology enhancements—e.g., data center consolidation, virtualization, and maintenance contract reductions—are 
producing technical efficiencies and cost savings. This metric will measure the amount of these costs savings.

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017 

Plan
FY 2017 
Actual

FY 2018 
Estimate

FY 2019 
Estimate

Percent reduction in opera-
tional run cost leveraging 
technology and process 
efficiencies

Prior-year 
data not 
available

18.70% 1.00% 1.00% 1.00% 1.00% 1.00% 1.00% 1.00%

Target: Met

Analysis: OIT has implemented a strategic initiative, the Steady State Cost Reduction Plan, to review all Steady State project costs. 
This plan has both short- and long-term objectives as well as business impact assessments. This effort is SEC-wide, with a focus on 
leveraging market data to capture significant improvements during contract negotiations. 

Responsible Division/Office: Office of Information Technology

Data Source: OIT Network Operations Center (NOC)



124   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

PERFORMANCE GOAL 4.2.5 
Enhance the SEC’s enterprise data warehouse infrastructure and performance

Description: The Enterprise Data Warehouse (EDW) infrastructure will enable the provisioning of data to Commission staff for search and 
analysis through a virtual data warehouse platform. This metric will measure the availability of EDW and data sources.

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017 

Plan
FY 2017 
Actual

FY 2018 
Estimate

FY 2019 
Estimate

Availability rate for the EDW 
infrastructure components  
in production

Prior-year data  
not available

99% 99% 99% 99% 99% 99% 99%

Target: Met

Analysis: EDW services are leveraged across the SEC. Availability is attributed to the use of redundant clustered servers, improved 
procedures, and training. 

Responsible Division/Office: Office of Information Technology

Data Source: OIT Network Operations Center (NOC) – automated network monitoring tools

Strategic Objective 4.3: The SEC maximizes the use 
of agency resources by continually improving agency 
operations and bolstering internal controls. 

Goal Leader(s): Chief Financial Officer; Chief  
Operating Officer

PERFORMANCE GOAL 4.3.1 
Financial audit results

Description: Under the Accountability of Taxpayer Dollars Act of 2002, the agency is required to meet all proprietary and budgetary 
accounting guidelines for federal agencies and to undergo annual audits. The SEC’s audits are conducted by the Government 
Accountability Office.

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017 

Plan
FY 2017 
Actual

FY 2018 
Estimate

FY 2019 
Estimate

Unqualified opinion Yes Yes Yes Yes Yes Yes Yes Yes Yes

Material weakness 0 0 0 0 0 0 0 0 0

Significant deficiency 2 1 1 0 0 0 0 0 0

Target: Unqualified opinion – Met; Material weakness – Met; Significant deficiency – Met

Analysis: In FY 2017, the Government Accountability Office (GAO) released an unmodified opinion on SEC’s financial statements and 
internal controls over financial reporting in which no significant issues were identified. This sustained achievement underscores SEC’s 
commitment to sound financial management and our high standards of accountability, transparency, and ethics. 

Responsible Division/Office: Office of Financial Management

Data Source: GAO’s Independent Auditor’s Report in the FY 2017 SEC Agency Financial Report



FY 2017 ANNUAL PERFORMANCE REPORT AND FY 2019 ANNUAL PERFORMANCE PLAN   |   125

PERFORMANCE GOAL 4.3.2 
Assurance statement on internal control over operations

Description: In accordance with OMB A-123 and Section 961 of the Dodd-Frank Act, the SEC conducts an annual assessment of 
the effectiveness of internal controls. The SEC will continue to develop its Operational Risk program and enhance cross-organizational 
processes to support all division and office management assurance statements. Success is measured by the quality of risk and control 
assessments and management self-identification and resolution of improvement opportunities.

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017 

Plan
FY 2017 
Actual

FY 2018 
Estimate

FY 2019 
Estimate

Unmodified opinion Yes Yes Yes Yes Yes Yes No Yes Yes

Material weakness 0 0 0 0 0 0 1 0 0

Target: Unmodified opinion – Not Met; Material weakness – Exceeded

Analysis: For FY 2017, the SEC did not provide an unmodified opinion on its internal control over operations. A material weakness 
related to cybersecurity risks was identified. 

Plan for Improving Program Performance: The SEC is proactively working to address and mitigate these deficiencies in FY 2018, 
which includes taking steps to improve communication and escalation protocols and enhance the information security of the Electronic 
Data Gathering, Analysis, and Retrieval (EDGAR) system.

Responsible Division/Office: Office of the Chief Operating Officer

Data Source: SEC Financial Audit Report

PERFORMANCE GOAL 4.3.3 
Timely completion of corrective action on Office of Inspector General (OIG)  

and the GAO audit recommendations

Description: Timely completion of audit recommendations is an important SEC priority. This metric measures how well the Commission is 
doing in completing corrective action on OIG audit recommendations within established timeframes.

Fiscal Year FY 2012 FY 2013 FY 2014 FY 2015 FY 2016
FY 2017 

Plan
FY 2017 
Actual

FY 2018 
Estimate

FY 2019 
Estimate

OIG recommendations  
completed in less than  
one year

Prior-year data 
not available

78% 76% 74% 67% 75% 86% 75% 75%

Target: Exceeded

Analysis: In FY 2017, the SEC completed 86 percent of corrective actions on OIG and GAO audit recommendations on time. 

Responsible Division/Office: Office of the Chief Operating Officer

Data Source: Audit Management System (Archer) 



Appendices

Appendix A: Divisions and Offices............................................................................................................. 129

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

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





APPENDICES  |   129

APPENDIX A: DIVISIONS AND OFFICES

Headquarters
DIVISION OF CORPORATION FINANCE

William Hinman, Director
(202) 551-3100

DIVISION OF ECONOMIC AND RISK ANALYSIS

Jeffrey Harris, Director
(202) 551-6600

DIVISION OF ENFORCEMENT

Stephanie Avakian, Co-Director
Steven Peikin, Co-Director 
(202) 551-4500

DIVISION OF INVESTMENT MANAGEMENT

Dalia Blass, Director
(202) 551-6720

DIVISION OF TRADING AND MARKETS

Brett Redfearn, Director  
(202) 551-5500

OFFICE OF ACQUISITIONS

Vance Cathell, Director 
(202) 551-7300

OFFICE OF ADMINISTRATIVE LAW JUDGES

Brenda P. Murray, Chief Administrative Law Judge 
(202) 551-6030

OFFICE OF THE CHIEF ACCOUNTANT

Wesley Bricker, Chief Accountant
(202) 551-5300

OFFICE OF THE CHIEF OPERATING OFFICER

Kenneth A. Johnson, Chief Operating Officer
(202) 551-2200

OFFICE OF COMPLIANCE INSPECTIONS  
AND EXAMINATIONS 
Peter Driscoll, Director
(202) 551-6200

OFFICE OF CREDIT RATINGS

Jessica Kane, Acting Director 
(212) 336-9080

OFFICE OF EQUAL EMPLOYMENT OPPORTUNITY

Peter Henry, Acting Director
(202) 551-6040

OFFICE OF THE ETHICS COUNSEL

Shira Pavis Minton, Ethics Counsel/ 
Designated Agency Ethics Official
(202) 551-5170

OFFICE OF FINANCIAL MANAGEMENT

Caryn Kauffman, Acting Chief Financial Officer 
(202) 551-7840

OFFICE OF THE GENERAL COUNSEL

Robert Stebbins, General Counsel 
(202) 551-5100

OFFICE OF HUMAN RESOURCES

Lacey Dingman, Chief Human Capital Officer 
(202) 551-7500

OFFICE OF INFORMATION TECHNOLOGY

Pamela Dyson, Director/Chief Information Officer 
(202) 551-8800

OFFICE OF INSPECTOR GENERAL

Carl W. Hoecker, Inspector General 
(202) 551-6061



130   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

OFFICE OF INTERNATIONAL AFFAIRS

Paul A. Leder, Director
(202) 551-6690

OFFICE OF THE INVESTOR ADVOCATE

Rick Fleming, Investor Advocate 
(202) 551-3302

OFFICE OF INVESTOR EDUCATION AND 

ADVOCACY

Lori Schock, Director
(202) 551-6500

OFFICE OF LEGISLATIVE AND  

INTERGOVERNMENTAL AFFAIRS 

Bryan Wood, Director
(202) 551-2010

OFFICE OF MINORITY AND  

WOMEN INCLUSION 

Pamela A. Gibbs, Director 
(202) 551-6046

OFFICE OF MUNICIPAL SECURITIES

Rebecca Olsen, Acting Director 
(202) 551-5680

OFFICE OF PUBLIC AFFAIRS

John Nester, Director 
(202) 551-4120

OFFICE OF THE SECRETARY

Brent Fields, Secretary 
(202) 551-5400

OFFICE OF STRATEGIC INITIATIVES

Mark Ambrose, Director
(202) 551-8600

OFFICE OF SUPPORT OPERATIONS

Barry Walters, Director/Chief FOIA Officer
(202) 551-8400

Note:	 As required by the SEC Small Business Advocate Act, the agency created the Office of the Advocate for Small Business  
Capital Formation in FY 2017. This office will be staffed in FY 2018. 



APPENDICES  |   131

Regional Offices
ATLANTA REGIONAL OFFICE

Richard Best, Regional Director 
950 East Paces Ferry Road NE, Suite 900
Atlanta, GA 30326
(404) 842-7600
email: [email protected]

BOSTON REGIONAL OFFICE

Paul Levenson, Regional Director 
33 Arch Street, 24th Floor
Boston, MA 02110
(617) 573-8900
email: [email protected]

CHICAGO REGIONAL OFFICE

Robert J. Burson, Acting Regional Director
Jane E. Jarcho, Acting Regional Director 
175 W. Jackson Boulevard, Suite 900 
Chicago, IL 60604
(312) 353-7390
email: [email protected]

DENVER REGIONAL OFFICE

Julie K. Lutz, Regional Director 
1961 Stout Street, Suite 1700 
Denver, CO 80294
(303) 844-1000
email: [email protected]

FORT WORTH REGIONAL OFFICE

Shamoil Shipchandler, Regional Director
Burnett Plaza
801 Cherry Street
Suite 1900, Unit 18 
Fort Worth, TX 76102 
(817) 978-3821 
email: [email protected]

LOS ANGELES REGIONAL OFFICE

Michele Wein Layne, Regional Director 
444 South Flower Street, Suite 900 
Los Angeles, CA 90071
(323) 965-3998
email: [email protected]

MIAMI REGIONAL OFFICE

Eric I. Bustillo, Regional Director 
801 Brickell Avenue, Suite 1800 
Miami, FL 33131
(305) 982-6300
email: [email protected]

NEW YORK REGIONAL OFFICE

Marc P. Berger, Regional Director 
Brookfield Place
200 Vesey Street, Suite 400
New York, NY 10281
(212) 336-1100
email: [email protected]

PHILADELPHIA REGIONAL OFFICE

G. Jeffrey Boujoukos, Regional Director 
One Penn Center
1617 John F. Kennedy Boulevard 
Suite 520
Philadelphia, PA 19103
(215) 597-3100
email: [email protected]

SALT LAKE REGIONAL OFFICE

Dan Wadley, Acting Regional Director 
351 S. West Temple Street
Suite 6.100
Salt Lake City, UT 84101
(801) 524-5796
email: [email protected]

SAN FRANCISCO REGIONAL OFFICE

Jina L. Choi, Regional Director
44 Montgomery Street, Suite 2800 
San Francisco, CA 94104
(415) 705-2500
email: [email protected]



132   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

APPENDIX B: VERIFICATION AND 
VALIDATION OF PERFORMANCE DATA

The SEC’s programs require accurate data to properly 
assess program performance and make good manage-
ment 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 performance 
procedures documentation. Data validation follows 
the data verification process in an effort to ensure that 
performance data are 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 perfor-

mance goal calculations; and 
•	 The sources of the underlying data elements.

(3)	 The divisions and offices calculate and report 
the performance goals to the Office of Financial 
Management, and the performance goals are 
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 C: SEC’S RESPONSES TO 
GOVERNMENT ACCOUNTABILITY OFFICE 
REPORTS

This appendix provides the SEC’s responses to Government Accountability Office (GAO) reports that 
included recommendations for the agency head.

The following are examples of letters that were sent to each appropriate committee.



134   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

GAO Report: “Telecommunications: Agencies Need to Apply Transition Planning Practices to 
Reduce Potential Delays and Added Costs” (GAO-17-464, dated September 21, 2017)



APPENDICES  |   135

GAO Report: “Telecommunications: Agencies Need to Apply Transition Planning Practices to 
Reduce Potential Delays and Added Costs” (GAO-17-464, dated September 21, 2017) (continued)



136   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

GAO Report: “Telecommunications: Agencies Need to Apply Transition Planning Practices to 
Reduce Potential Delays and Added Costs” (GAO-17-464, dated September 21, 2017) (continued)



APPENDICES  |   137

GAO Report: “Telecommunications: Agencies Need to Apply Transition Planning Practices 
to Reduce Potential Delays and Added Costs” (GAO-17-464, dated September 21, 2017)



138   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

GAO Report: “Telecommunications: Agencies Need to Apply Transition Planning Practices to 
Reduce Potential Delays and Added Costs” (GAO-17-464, dated September 21, 2017) (continued)



APPENDICES  |   139

GAO Report: “Telecommunications: Agencies Need to Apply Transition Planning Practices to 
Reduce Potential Delays and Added Costs” (GAO-17-464, dated September 21, 2017) (continued)



140   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

GAO Report: “Telecommunications: Agencies Need to Apply Transition Planning Practices 
to Reduce Potential Delays and Added Costs” (GAO-17-464, dated September 21, 2017)APPENDICES  |   141

GAO Report: “Telecommunications: Agencies Need to Apply Transition Planning Practices to 
Reduce Potential Delays and Added Costs” (GAO-17-464, dated September 21, 2017) (continued)



142   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

GAO Report: “Telecommunications: Agencies Need to Apply Transition Planning Practices to 
Reduce Potential Delays and Added Costs” (GAO-17-464, dated September 21, 2017) (continued)



APPENDICES  |   143

GAO Report: “Telecommunications: Agencies Need to Apply Transition Planning Practices to 
Reduce Potential Delays and Added Costs” (GAO-17-464, dated September 21, 2017)



144   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

GAO Report: “Telecommunications: Agencies Need to Apply Transition Planning Practices to 
Reduce Potential Delays and Added Costs” (GAO-17-464, dated September 21, 2017) (continued)



APPENDICES  |   145

GAO Report: “Telecommunications: Agencies Need to Apply Transition Planning Practices to 
Reduce Potential Delays and Added Costs” (GAO-17-464, dated September 21, 2017) (continued)



146   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

GAO Reports: “Information Security: SEC Improved Control of Financial Systems but 
Needs to Take Additional Actions” (GAO-17-469 and GAO-17-429SU, dated July 27, 2017)



APPENDICES  |   147

GAO Reports: “Information Security: SEC Improved Control of Financial Systems but Needs to 
Take Additional Actions” (GAO-17-469 and GAO-17-429SU, dated July 27, 2017) (continued)



148   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

GAO Reports: “Information Security: SEC Improved Control of Financial Systems but Needs to 
Take Additional Actions” (GAO-17-469 and GAO-17-429SU, dated July 27, 2017)



APPENDICES  |   149

GAO Reports: “Information Security: SEC Improved Control of Financial Systems but Needs to 
Take Additional Actions” (GAO-17-469 and GAO-17-429SU, dated July 27, 2017) (continued)



150   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

GAO Report: "Federal Telework: Additional Controls Could Strengthen Telework Program 
Compliance and Data Reporting” (GAO-17-247, dated March 20, 2017)



APPENDICES  |   151

GAO Report: "Federal Telework: Additional Controls Could Strengthen Telework Program 
Compliance and Data Reporting” (GAO-17-247, dated March 20, 2017) (continued)



152   |   FY 2019 CONGRESSIONAL BUDGET JUSTIFICATION

GAO Report: "Federal Telework: Additional Controls Could Strengthen Telework Program 
Compliance and Data Reporting” (GAO-17-247, dated March 20, 2017)



APPENDICES  |   153

GAO Report: "Federal Telework: Additional Controls Could Strengthen Telework Program 
Compliance and Data Reporting” (GAO-17-247, dated March 20, 2017) (continued)



The SEC’s FY 2019 Congressional Budget 
Justification/Annual Performance Plan and 

FY 2017 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 

[email protected].

mailto:[email protected]


U.S. Securities and 

Exchange Commission 

100 F Street NE

Washington, DC 20549

www.sec.gov

www.sec.gov