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entitled 'SEC Operations: Implications of Alternative Funding 
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Report to Congressional Requesters:



July 2002



GAO:



SEC Operations: Implications of Alternative Funding Structures:



GAO-02-864



Contents: 



Letter:



Results in Brief:



Background:



A Range of Self-Funded Structures Exist, but Not All Meet the Act’s 

Definition of Self-Funding:



A Move to Self-Controlled Funding Would Have Implications for SEC 

Operations:



Depending on the Structure, Self-Funding Could Impact Congressional and 

OMB Oversight:



Conclusions:



Agency Comments and Our Evaluation:



Appendix I:



Scope and Methodology:



Appendix II:



Comments from the Securities and Exchange Commission:



:



Appendix III:



GAO Contacts and Staff Acknowledgments:



GAO Contacts:



Acknowledgments:



Table:



Table 1: SEC Budget Estimates and Appropriations (dollars in 
thousands):



Figures:



Figure 1: SEC Fees Collected and Appropriated Funding, 1991-2001:



1Figure 2. Federal Financial Regulatory Agencies Have Varied Missions:



Figure 3: SEC’s Budget Process:



Abbreviations:



CJS: Subcommittee on Commerce, Justice, State, and the Judiciary, 
Committee 

on Appropriations, U.S. Senate; and Subcommittee on Commerce, Justice, 

State, the Judiciary, and Related Agencies, Committee on 
Appropriations,

House of Representatives:

FCA: Farm Credit Administration:

FDIC: Federal Deposit Insurance Corporation:

FRS: Federal Reserve System:

NCUA: National Credit Union Administration:

OCC: Office of the Comptroller of the Currency:

OFHEO: Office of Federal Housing Enterprise Oversight:

OMB: Office of Management and Budget:

OTS: Office of Thrift Supervision:

SEC: Securities and Exchange Commission:



United States General Accounting Office:



Washington, DC 20548:



July 16, 2002:



Congressional Requesters:



This report responds to a mandate in the Investor and Capital Markets 

Fee Relief Act (the Act) for GAO to study the implications of 

converting the Securities and Exchange Commission (SEC) to a self-

funded basis.[Footnote 1] Although SEC is fully funded through fees it 

collects, SEC’s current funding structure differs from the Act’s 

definition of self-funding. The Act defines self-funding as an 

authorization for SEC “to deposit the receipts of its collections in 

the Treasury of the United States, or in a depository institution, but 

such deposits are not treated as Government funds or appropriated 

monies, and are available for the salaries and other expenses of the 

Commission and its employees without annual appropriation or 

apportionment.”[Footnote 2] Although SEC currently deposits its 

collected fees in the Treasury, where its deposits are treated as 

offsetting collections and not general funds of the Treasury,[Footnote 

3] it cannot deposit its fees in a depository institution, and its 

monies are annually appropriated and apportioned.[Footnote 4] In this 

report, we refer to the Act’s definition of self-funding as a self-

controlled funding structure.



Although the Act provides a specific definition for self-funding, as 

agreed with your offices, we explored a range of self-funding 

structures. Our objectives were to (1) identify the self-funding 

structures created by Congress for other financial regulators and the 

extent of control afforded to the appropriators under each; (2) 

identify the potential implications for SEC’s operations if SEC’s 

current budget structure were changed; and (3) identify the potential 

implications for congressional and executive branch oversight of SEC if 

SEC’s current budget structure were changed.



In addressing these objectives, we obtained information from SEC and 

financial service regulatory officials on their funding structures and 

the implications of these structures. We also interviewed 

representatives of other institutions that would be affected by moving 

SEC to a more self-controlled funding structure. Finally, we relied on 

existing GAO work and relevant reports. A complete description of our 

methodology can be found in appendix I.



Results in Brief:



Congress has created a range of self-funding structures for financial 

regulatory agencies that rely on fee collections, assessments, or other 

sources of funding rather than on appropriations from the Treasury’s 

general fund. The variations among these agencies can be attributed to 

how and when Congress makes the fees available to an agency and how 

much flexibility Congress gives an agency in using its collected fees 

without further legislative action. For some agencies, such as the Farm 

Credit Administration (FCA) and the Office of Federal Housing 

Enterprise Oversight (OFHEO), Congress limits the amount of assessments 

to be collected and made available through provisions in annual 

appropriations acts. Therefore, these agencies would not meet the Act’s 

definition of self-funding. In contrast, Congress provided permanent 

budget authority to the federal banking agencies--Federal Reserve 

System (FRS), Office of the Comptroller of Currency (OCC), Office of 

Thrift Supervision (OTS), Federal Deposit Insurance Corporation (FDIC), 

and National Credit Union Administration (NCUA)--allowing these 

agencies to use all the funds collected without further legislative 

action. These agencies are generally not included in the annual 

appropriations process and more closely fit the Act’s definition of 

self-funding.



Moving SEC to a more self-controlled funding structure has implications 

for SEC operations in two important areas. First, SEC would have more 

control over its own budget and funding level, which some SEC and 

industry officials believe may better enable SEC to take steps to 

address its increasing workload and some of its human capital 

challenges, such as its ability to recruit and retain quality staff. 

For example, with a more self-controlled funding structure, SEC could 

use available fee collections to increase its staff level to address a 

rising workload, or increase its budget:



in order to expand programs to recruit and retain quality staff without 

congressional or administration approval. However, others who are also 

knowledgeable about SEC’s operations questioned whether more budget 

flexibility is the best means to address SEC’s staff recruitment and 

retention issues. For example, one official believed that there are 

more efficient ways to effect a change in SEC’s budget than conversion 

to a self-controlled funding structure. A second implication for SEC’s 

operations is the resultant loss of checks and balances currently 

provided by the federal budget and appropriations processes. SEC would 

have to establish a system of budgetary controls to ensure fiscal 

restraint. Such fiscal discipline is important for agencies funded 

outside the appropriations process because they can no longer rely on 

appropriations increases during revenue shortfalls. Creating a system 

of internal controls within the budget process could prove particularly 

challenging for SEC, which lacks a comprehensive strategic planning 

process. As we found in our previous work on SEC operations, SEC had 

weaknesses in its existing budget and planning processes.[Footnote 5]



Moving SEC to a self-controlled funding structure would diminish 

congressional and executive branch oversight. Specifically, the Act’s 

self-funding definition would remove SEC from both the congressional 

appropriations process and OMB’s apportionment process. On the other 

hand, the congressional authorizing committees would maintain or else 

could choose to increase their oversight of SEC. However, if Congress 

wanted to give SEC greater budget flexibility but still maintain some 

degree of control over SEC’s funding level, it could place a variety of 

limitations on SEC’s offsetting collections. These limitations could 

include designating fees for SEC’s use but limiting amounts to those 

appropriated annually; specifying the amount of fees to be collected; 

controlling the size of SEC or a particular SEC program by limiting the 

amounts available for obligation; and specifying the purpose for which 

fees can be used. In addition, OMB could continue to be involved by 

apportioning funds by amounts, timing, program, or other methods. 

Another implication of self-controlled funding is that SEC’s offsetting 

collections would not be available to offset funding for other 

discretionary spending within the appropriations bill that funds SEC.



The purpose of this report is to identify various existing, self-

funding structures and the implications for SEC operations and 

congressional oversight if SEC’s current funding structure were 

changed. Therefore, we are making no recommendations in this report on 

whether or how to change SEC’s current funding structure. In comments 

provided on a draft of this report, SEC agreed that the report 

correctly identifies the principal consequences of moving SEC to a 

self-funded structure. However, SEC commented on several issues we 

identified that SEC would have to address were it to be given self-

funding authority.



* In response to our observation that SEC would need to adequately 

manage its annual fee collections if it were to be moved outside of the 

traditional budget process, SEC stated that its current experience in 

adjusting its fees provided it valuable experience in this area. We did 

not question SEC’s ability to adequately manage its fee collections, 

but rather we observed that SEC as required by statute relies on 

transaction-based fees, which we continue to believe generate revenues 

that are less predictable and more difficult to estimate than the 

assessments used by bank regulators to fund their operations. 



* SEC commented on our observation that SEC would have to improve its 

budget planning process and stated that as a general matter, it has 

been constrained by the current budget process and would welcome the 

opportunity under a self-funded structure to develop a more forward-

looking, strategic planning process. As stated in the report, SEC’s 

annual budget is based on the past year’s appropriations rather than on 

what is actually needed to fulfill its mission. Although this approach 

may be practical in the current context, we continue to believe that it 

would be useful for SEC to determine its staffing and resource needs to 

fulfill its mission regardless of its funding status. 



* SEC stated that our discussion of the fiscal discipline that would be 

required if SEC were given self-funding authority would benefit from an 

analysis of SEC’s experience with unobligated balances derived 

primarily from fees collected in excess of amounts used to offset its 

appropriation.[Footnote 6] However, we are not persuaded that 

additional analysis of SEC’s use of these balances would be beneficial 

to the report, because SEC does not have total control over the use of 

these unobligated funds. That is, in most cases the fiscal restraint 

provided by the current budgetary process is still a factor, because 

SEC is still subject to OMB and congressional review of its 

reprogramming proposals. In the absence of external fiscal discipline, 

we continue to believe that self-funded agencies have to establish 

systems to instill the fiscal restraint that would have been provided 

by the budget and appropriations processes. 



We have reprinted SEC’s written comments in appendix II, and we discuss 

these comments in greater detail near the end of this letter.



Background:



Congress created SEC in 1934 to administer and enforce the federal 

securities laws to protect investors and maintain the integrity of the 

securities markets. SEC’s mission is to (1) promote full and fair 

disclosure; (2) prevent and suppress fraud; (3) supervise and regulate 

the securities markets; and (4) regulate and oversee investment 

companies, investment advisers, and public utility holding companies. 

SEC works to fulfill this mission through various divisions and 

offices, among them the Office of the Executive Director, which 

formulates SEC’s budget and authorization strategies.



Congressional Oversight:



As a federal agency, SEC is subject to congressional oversight. 

Congress oversees federal agencies primarily through two distinct but 

complementary processes--authorizations and appropriations, which are 

implemented through authorizing and appropriating committees in the 

U.S. Senate and House of Representatives. The authorizing committees 

are responsible for creating a program, mandating the terms and 

conditions under which it operates, and establishing the basis for 

congressional oversight and control. SEC’s authorizing committees are 

the Senate Committee on Banking, Housing, and Urban Affairs and the 

House Committee on Financial Services. The appropriations committees 

and subcommittees are charged with assessing the need for, amount of, 

and period of availability of appropriations for agencies and programs 

under their jurisdiction. SEC’s annual appropriations are under the 

jurisdiction of the Subcommittee on Commerce, Justice, State, and the 

Judiciary, U.S. Senate Committee on Appropriations; and the 

Subcommittee on Commerce, Justice, State, the Judiciary, and Related 

Agencies, House Committee on Appropriations.[Footnote 7]



SEC Fee Collections:



To fund its operations, the federal securities laws direct SEC to 

collect fees. SEC generally collects three types of fees:



* Securities registration fees, which are required to be collected 

under Section 6(b) of the Securities Act of 1933 (the Securities Act), 

are paid when companies register with SEC new stocks and bonds for sale 

to investors. In 2001, SEC collected $987 million in Section 6(b) fees;



* Securities transaction fees, which are required to be collected under 

Section 31 of the Securities Exchange Act of 1934 (the Exchange Act) 

are paid by national securities exchanges and national securities 

associations when registered securities and security futures are sold 

on or off exchanges through any member of such an association. In 2001, 

SEC collected $1.04 billion in Section 31 fees; and:



* Fees on proxy solicitations for mergers, consolidations, 

acquisitions, or sales of a company’s assets, which are required to be 

collected under Section 14(g) of the Exchange Act, are paid by the 

person filing proxy solicitation materials for such transactions. Fees 

on the purchase of securities by an issuer of its issued securities are 

paid by the issuer under Section 13(e) of the Exchange Act. In 2001, 

SEC collected $33 million in filing fees.



SEC fees are deposited in a special SEC appropriations account to be 

used as offsetting collections. Although the fees were enacted to fund 

SEC operations, figure 1 illustrates how the amount of fees collected 

in recent years has far exceeded SEC’s appropriated budget. For 

example, in 2000, SEC collected $2.27 billion in fees, while the 

agency’s 2000 budget was $368 million. Similarly, in 2001, SEC 

collected about $2.1 billion, while its 2001 budget was $423 

million.[Footnote 8] Projected fee collections in excess of SEC’s 

appropriations are available to SEC’s appropriators to fund other 

priorities within the CJS appropriations bill.



Figure 1: SEC Fees Collected and Appropriated Funding, 

1991-2001:



[See PDF for image]



Source: SEC.



[End of figure]



SEC Fee Reductions:



Congress first addressed the issue of excess SEC fees in 1996 through 

the National Securities Markets Improvement Act of 1996, which reduced 

registration and transaction fees.[Footnote 9] However, SEC’s fee 

collection grew even higher because of subsequent increases in stock 

prices and stock trading volume. Viewing these excess fees as an 

unwarranted tax on investment and capital formation, Congress enacted 

the Investor and Capital Markets Fee Relief Act on January 16, 2002. 

The Act substantially reduces the fees collected by SEC and designates 

all such fees as offsetting collections available to fund the 

operations of the agency, to the extent provided by Congress. Prior to 

the enactment of this Act, most of the fees collected were deposited in 

the U.S. Treasury general fund as revenue. The Act also reduces the 

basic rates for transaction fees, registration fees, stock repurchase 

fees, and merger and acquisition fees, and it eliminates certain other 

filing fees. The Act includes “target offsetting collection amounts” 

for both transaction and registration fees for fiscal years 2002 

through 2011. SEC would be required to adjust the basic rates for those 

fees to make it “reasonably likely” that collections would equal the 

target amounts.



Current Funding Issues:



The Act also grants SEC the authority to pay its employees’ salaries 

and benefits at levels commensurate with those paid by the federal 

banking regulators (pay parity). For 2003, SEC currently estimates the 

additional cost of implementing pay parity to be $76 million. SEC 

anticipates that the funding to accommodate this increase will be 

provided exclusively out of the amount of fees SEC is scheduled to 

collect annually under the Act and appropriated by Congress. Although 

SEC fee collections as estimated for 2003 in the Act total $1.33 

billion, the President’s 2003 Budget request included a budget estimate 

of $466.9 million for SEC. This amount represents a $29 million, or 6.6 

percent, increase over SEC’s 2002 budget of $437.9 million but does not 

include any funding for a pay parity program in 2003. To date, Congress 

has not enacted SEC’s 2003 appropriation.



SEC’s Workload and Staffing Issues:



As reported in our SEC operations report,[Footnote 10] SEC is operating 

in an increasingly dynamic regulatory environment. Over the past 

decade, the securities markets have undergone tremendous growth and 

innovation as technological advances have increased the complexity of 

the markets and the range of products afforded to the public. Larger, 

more active, and more complex markets have produced more market 

participants, registrants, filings, examinations and inspections, 

legal interpretations, complaints, and opportunities for fraudulent 

activities. In our SEC operations report, SEC and industry officials 

agreed that SEC’s ability to fulfill its mission in such a dynamic 

environment has become increasingly strained as SEC’s growing workload 

has substantially outpaced increases in its staffing levels. 

Specifically, over the past decade, we found that staffing within SEC’s 

various oversight areas has grown between 9 and 166 percent, while 

workload measures in those areas have grown from 60 to 264 percent. 

Moreover, following the sudden and highly publicized collapse of Enron 

Corporation and other corporate failures, SEC has been under increasing 

pressure to ensure that it is equipped to adequately oversee the 

securities markets and to ensure that investors receive accurate and 

meaningful financial disclosure, an important part of SEC’s mission to 

protect investors. In addition, legislative changes such as the Gramm-

Leach-Bliley Act of 1999, the Commodity Futures Modernization Act of 

2000, and the USA Patriot Act of 2001 placed added demands on SEC’s 

limited resources. All of these changes have significant repercussions 

and pose challenges for SEC’s oversight role. In light of these 

challenges and prompted by concerns about SEC’s ability to carry out 

its mission, legislators introduced H.R. 3764 and S. 2673, both of 

which would authorize appropriations for SEC of $776 million, and H.R. 

3818, which would authorize appropriations for SEC of $876 

million.[Footnote 11] Both House bills would designate more than half 

of these amounts for the Division of Corporate Finance and the Division 

of Enforcement to increase enforcement in financial reporting cases and 

other oversight initiatives. The Senate bill designated specific 

amounts for pay parity, information technology, and additional staff 

for oversight of audit services.



A Range of Self-Funded Structures Exist, but

Not All Meet the Act’s Definition of Self-Funding:



Federal financial regulators are largely self-supporting through fee 

collections, assessments, or other funding sources, but not all of 

these self-funding options meet the Act’s definition of self-funding. 

The variation among federal agencies is attributable to how and when 

Congress makes the funds available to the agency and how much 

flexibility Congress gives the agency in using the fees or other 

funding sources it collects. At some agencies, Congress limits the 

amount of assessments collected or available for agency use. Such 

limitations are generally established by provisions in annual 

appropriations acts. For example, funding for SEC in 2002 was 

appropriated from fees collected in 2002 and prior years. In SEC’s 

case, although all the offsetting collections by definition are 

dedicated to SEC, Congress limits how much fee revenue is available. 

For example, in 2001, SEC collected about $2.1 billion in fees; 

however, Congress appropriated about $423 million for SEC’s operations. 

Therefore, almost $1.7 billion was available to the CJS subcommittees 

to offset spending for other agencies and programs under CJS 

jurisdiction.



There are other regulatory agencies, such as FCA and OFHEO, which also 

operate at this more congressionally controlled end of the self-funding 

range (see fig. 2 for a description of these two agencies’ missions as 

well as the missions of other financial services regulators). Although 

FCA and OFHEO fund their operations solely by assessments from their 

regulated entities, these agencies remain subject to the appropriations 

process. That is, Congress establishes annual limits through the 

appropriations process by approving the amount of assessments these 

agencies can collect. For example, in 2001, Congress appropriated $40 

million to FCA, which authorized FCA to collect assessments up to this 

amount as offsetting collections for 2001. Moreover, Congress limits 

the amount of assessments that FCA can obligate for administrative 

expenses. For example, in 2001, FCA’s obligation for administrative 

expenses was limited to about $38 million. Congress also establishes 

OFHEO’s budget in a similar manner.



Figure 2. Federal Financial Regulatory Agencies Have Varied 

Missions:



[See PDF for image]



Source: Financial regulatory agencies listed above.



[End of figure]



On the other hand, Congress has granted more self-controlled funding 

structures to other agencies. Some of these agencies have permanent 

indefinite appropriations, which means that these agencies can use 

whatever amount of funds are collected without any further legislative 

action. Agencies at this less congressionally controlled end of the 

range include the federal banking agencies (that is, FRS, OCC, OTS, 

FDIC, and NCUA). Unlike SEC, which is generally funded by transaction 

fees and registration-based fees and subject to annual appropriations, 

these agencies are supported almost entirely through examination or 

assessment fees on their members, deposit insurance premiums, or 

interest on asset holdings, and are not included in the annual 

congressional appropriations process. The bank regulators’ self-

funding structure most closely fits the Act’s definition of self-

funding. According to banking agency officials, they, not Congress, 

control their agencies’ budget growth and direct how their agencies 

spend their funds. Although SEC continues to be subject to annual 

appropriations, the Act moved SEC closer to having the same authority 

as the banking agencies by allowing SEC to establish the compensation 

and benefit levels of its employees.



A Move to Self-Controlled Funding Would Have Implications for SEC 

Operations:



Moving SEC to a more self-controlled funding structure has two 

important implications for SEC’s operations. First, SEC would have more 

control over its own budget and funding level, which some SEC and 

industry officials believe may better enable SEC to take steps to 

address its increasing workload and some of its human capital 

challenges, such as recruiting and retaining quality staff. However, 

others knowledgeable about SEC’s operations questioned whether more 

budget flexibility is the best means to address SEC’s recruiting and 

retention issues. Second, SEC would have an added responsibility in 

managing a more self-controlled funding structure. Self-funded agencies 

require sound fiscal control mechanisms to compensate for the removal 

of the scrutiny provided by both OMB and the appropriators, as part of 

the federal budget process. In addition, self-funded agencies require 

sound fiscal discipline to ensure revenue streams. In previous reports, 

we found weaknesses in SEC’s existing budget and planning processes.



Self-Controlled Funding Would Afford SEC More Budgetary Flexibility to 

Address Workload and Human Capital Challenges:



Some SEC officials told us that a more self-controlled funding approach 

might better enable SEC to address its increasing workload and ongoing 

human capital challenges, most notably high staff turnover and numerous 

vacancies. As mentioned previously, we reported in our SEC operations 

report that both SEC and industry officials agreed that current levels 

of human capital and budgetary resources have limited SEC’s ability to 

address many current and evolving market issues at a time when the 

collapse of Enron and other corporate failures have increased SEC’s 

workload and generated debates on reforms, which may result in 

increased responsibilities for SEC.[Footnote 12] However, others 

knowledgeable about the industry countered that while SEC may need more 

resources, there are more efficient ways to affect a change in SEC’s 

budget than conversion to a self-controlled funding basis. For example, 

within the existing structure, SEC could justify budget increases to 

its authorization and appropriation committees beyond the amount 

included in the President’s Budget.



Based on their experiences with self-funding, officials from the bank 

regulatory agencies we interviewed said that self-funding provided 

their agencies with more autonomy in formulating their budgets. They 

also said that having more control enabled them to respond more quickly 

to program needs in changing market conditions because they could 

reallocate or increase funding without having to wait for legislative 

action. SEC officials said they believed they would realize similar 

benefits in the human capital area because they would have greater 

control over their funding and would be able to respond quickly to 

changes in the market. For example, the sudden collapse of Enron 

Corporation and other corporate failures have stimulated an intense 

debate on the need for broad-based reform in such areas as financial 

reporting and accounting standards, oversight of the accounting 

profession, and corporate governance. In response to these challenges 

and proposals for regulatory changes, SEC officials requested approval 

for 100 additional staff positions dedicated to reviewing corporate 

filings, enforcing securities laws, and providing accounting guidance. 

However, under the existing structure, Congress and the executive 

branch must approve any such increases in SEC’s staffing allocation. 

Although there is general agreement on the need for these increased 

resources, SEC’s request to increase staffing in these areas is 

included in a supplemental appropriations bill that was considered in 

April 2002 but is not yet enacted, as Congress is considering issues 

unrelated to SEC’s funding needs. A more self-controlled funding 

structure would have allowed SEC to immediately implement its plan 

without the need for legislative action.



Another SEC official said that a more self-controlled funding structure 

would enable SEC to allocate resources to fund pay parity, allowing SEC 

to offer compensation packages similar to those offered by the bank 

regulators and putting SEC in a better position to attract and retain 

quality staff. SEC believes this could also help SEC stem turnover 

among its attorneys, accountants, and examiners--staff necessary to 

carry out SEC’s mission. Although the rate had decreased from 15 

percent in 2000 to 9 percent in 2001, turnover at SEC was still higher 

than the turnover rate governmentwide in 2001. As we reported 

previously, most SEC employees who responded to our survey said that 

compensation was their primary reason for leaving or thinking of 

leaving SEC.[Footnote 13] Although SEC officials acknowledged that 

turnover will always be an issue, they said that pay parity should 

enable SEC to lengthen the average tenure of attorneys and examiners. 

We previously reported that in 1999 the average tenure for attorneys 

was 2.5 years and for examiners 1.9 years. According to SEC officials, 

new employees need at least 2 years on the job to gain the knowledge 

and experience necessary to significantly contribute to SEC’s mission.



Self-Controlled Funding Would Require Fiscal Discipline:



Another implication of moving SEC to a more self-controlled funding 

structure is that it would require SEC to establish a system of 

internal controls to ensure fiscal discipline. Under SEC’s current 

funding structure, OMB and the appropriations process provide fiscal 

discipline for the agency. For example, SEC’s current annual budget 

cycle as illustrated in figure 3 begins with the preparation of an 

agencywide estimate that is based on the previous budget year’s 

appropriation. SEC then develops a conforming budget estimate based on 

OMB’s budget guidance, including a specified budget amount that OMB 

provides to SEC. After receiving OMB’s approval, SEC’s budget request 

is included in the President’s Budget that is submitted to Congress. 

Under this structure, SEC’s annual budget has been based on the 

previous year’s appropriations rather than on what may be actually 

needed to fulfill its mission. While practical, as reported in our SEC 

operations report, we found that this type of reactive approach could 

diminish SEC’s effectiveness, resulting in less effective enforcement 

and oversight. If moved to a self-controlled funding structure, not 

only would SEC have to improve its budget planning process by reviewing 

its staffing and resource needs independent of the budget process but 

the fiscal restraint provided within the federal budget process would 

be lost. Therefore, SEC would need to create its own internal control 

mechanisms and accountability structure to ensure fiscal discipline and 

budgetary restraint.



Figure 3: SEC’s Budget Process:



[See PDF for image]



Source: GAO analysis of SEC’s appropriations budget process.



[End of figure]



Bank regulatory officials said that to compensate for not being subject 

to appropriations oversight, self-funding requires discipline in both 

planning and budget processes. For example, one bank regulatory 

official said that his agency has a budget process that mirrors the 

federal budget planning process: the head of the agency reviews the 

budget estimates for each division and holds “hearings” in which each 

division must justify its budget estimate, similar to OMB’s budget 

process. Officials from NCUA, OCC, and OTS also said that their 

agencies routinely share their budgets with OMB as a courtesy.



In addition to their own internal processes, bank regulators also said 

that they experience some amount of regulatory competition and scrutiny 

from industry groups and regulated entities. These pressures provide 

incentives to the regulators to keep their operations efficient. Four 

regulators oversee the banking industry: three charter commercial 

banks, and one charters thrift institutions. Moreover, commercial banks 

have the option of changing their national charter to a state charter, 

and thrifts can opt to switch from their thrift charter to one of the 

commercial bank charters. Unlike the bank regulators, SEC is the sole 

federal regulator overseeing the U.S. securities markets, and its 

regulated entities generally have no other regulatory options if they 

want to operate in the securities markets. However, this structure does 

afford SEC a certain amount of independence from its regulated 

entities, an independence that may not be afforded to other agencies 

facing regulatory competition. Additionally, SEC’s fee payers may be 

less likely to scrutinize SEC’s budget because unlike the banking 

industry, where the burden of paying assessment fees is limited to the 

regulated entities, the securities industry distributes the 

responsibility for paying SEC’s transaction fees among all market 

participants. Therefore, in the absence of strong external pressures, a 

rigorous internal budget process and a related set of controls would be 

critical for SEC if it were to operate on a self-controlled funding 

basis.



Fiscal discipline is also important for self-controlled funding 

agencies because these agencies have no guarantee that they will be 

included in the appropriations process if they experience budget 

shortfalls. Instead, short of raising fees or assessments, some of 

these agencies, such as OCC and OTS, rely on backup sources of funding, 

such as reserves established from excess funds from previous years. 

These two agencies have established reserves to protect them during 

periods of revenue shortages. However, both agencies also have 

established internal policies that govern the appropriate use of these 

reserves. OCC and OTS officials said that their agencies now are less 

willing to use reserves during periods of revenue shortages. For 

example, the heads of these agencies have chosen to downsize and cut 

their expenses to maintain their budgets rather than use their 

reserves. Unlike the banking regulators, who have more control over the 

amount collected through assessments, SEC relies on transaction fees, 

which are less predictable and more difficult to estimate.



Finally, moving SEC to a more self-controlled funding basis would also 

increase the need for strategic planning, which also should be linked 

to the budget process. Based on our review of SEC’s strategic plan in 

our SEC operations report, we found that SEC had not engaged in a 

comprehensive strategic planning process. We found that SEC had not 

systematically utilized its strategic planning process to ensure (1) 

that resources are best used to accomplish its basic statutorily 

mandated duties, and (2) that human capital planning has identified the 

resources necessary to fulfill the full scope of its mission. Moreover, 

SEC’s annual plans lacked the detailed analysis and information needed 

to make informed workforce decisions. We found that additional 

information on (1) any excess or gaps in needed competencies within the 

agency’s various divisions and offices and (2) the relationship between 

budget requests for full-time equivalent staff years and SEC’s ability 

to meet individual strategic goals could make SEC’s budget process more 

meaningful. Introducing a meaningful strategic planning process at SEC 

could also make budget planning more proactive, rather than reactive, 

as is currently the case. SEC has begun to take steps to address these 

issues. In March 2002, SEC hired a consulting firm to work with an 

internal taskforce to perform an in-depth review of SEC’s operations, 

effectiveness, and resource needs. However, SEC officials stated that 

because the 2003 budget has already been finalized under the current 

budget process, they were concerned that even if substantive 

improvements were recommended by the internal taskforce, the earliest 

that SEC would be able to effectively react to these changes would be 

the 2004 budget cycle.



Depending on the Structure, Self-Funding Could Impact Congressional and 

OMB Oversight:



A shift in budgetary control from Congress and OMB to make SEC self-

funded as defined in the Act poses various implications for oversight 

of SEC. It could reduce the amount of direct control over SEC’s budget 

and operations, because the appropriators and OMB would no longer be 

involved in oversight. By shifting more control to SEC and its 

authorizing committees, CJS subcommittees would also lose the benefit 

of having SEC’s fees available to offset spending for other 

discretionary spending purposes. However, Congress and OMB could 

compensate for this reduction in direct control by placing other 

spending limits on SEC.



Self-Funding Lessens Direct Congressional and OMB Control:



If Congress granted SEC permanent authority to collect fees without 

further congressional action and authorized it to use whatever fees are 

collected--permanent indefinite appropriations--and posed no 

limitations, this shift to self-funding as defined by the Act would 

affect congressional oversight to a greater degree than other 

alternatives we considered. Under permanent indefinite appropriations, 

the appropriations committees generally would not be involved in 

overseeing SEC’s appropriations. However, the authorizing committees 

and other oversight committees, such as the Senate Committee on 

Governmental Affairs and House Committee on Government Reform, could 

continue to oversee SEC, since congressional oversight is not limited 

to budgetary authority and remains an important tool for:



* evaluating program administration and performance;



* making sure programs conform to congressional intent;



* ferreting out waste, fraud, and abuse;



* seeing whether programs may have outlived their usefulness;



* compelling an explanation or justification of policy; and:



* ensuring that programs and agencies are administered in a cost-

effective and efficient manner.



Shifting SEC’s budget structure to a more self-controlled model would 

also diminish the role of OMB, which establishes the framework by which 

agencies formulate their budget estimates and is responsible for 

ensuring that agency budget requests are consistent with specific 

budgetary guidelines and spending ceilings. Currently, SEC prepares its 

budget request based on guidance from OMB and submits this estimate to 

OMB for review and approval (see fig. 3). A budget hearing is 

subsequently held and, during this hearing, any policy changes or 

shifts in the SEC Chairman’s priorities are discussed. OMB then 

determines whether the proposals are consistent with the President’s 

policy goals. This part of the process is significant from an oversight 

perspective, because OMB can increase or decrease SEC’s budget request 

based on those evaluations. For example, OMB increased SEC’s budget 

request by $8.6 million in 1995. According to SEC officials, OMB 

increased SEC’s budget proposals to allow it to hire additional 

examiners. Most recently, OMB reduced SEC’s 2003 budget request by 

about $95.5 million, most of which could have been used to fund pay 

parity. According to OMB officials, they would prefer that SEC not 

implement pay parity immediately but instead come up with a mechanism 

to fund it over time.



As table 1 illustrates, SEC has limited influence over appropriations 

levels. From 1992 to 2001, OMB reduced SEC’s budget in all but 3 years. 

Likewise, the House of Representatives has voted to decrease SEC’s 

funding as presented in the President’s Budget every year. Conversely, 

the Senate has voted to restore most of the President’s Budget each 

year. Generally, the result has been appropriations lower than SEC’s 

budget request. In addition to annual appropriations, SEC has received 

supplemental appropriations or additional funding from other sources. 

For example, since 1994 SEC has received a supplemental appropriation 

or used its unobligated balances from prior years to increase its total 

funding level above its appropriation.[Footnote 14] If Congress wanted 

to give SEC greater control over its budget but still maintain some 

degree of control over SEC’s funding level, it could place a variety of 

limitations on SEC’s offsetting collections. These limitations include:



* designating fees collected for SEC’s use, but establishing limits on 

their use through annual appropriations;



* specifying the amount of fees to be collected and available for use 

in appropriations. If SEC were to collect more than that amount, 

Congress could specify that such amounts be designated to SEC, but not 

be made available without (further) congressional action;



* controlling the size of SEC or a particular program within SEC by 

limiting its obligations for specific purposes or to specific amounts; 

and:



* limiting the purposes for which fees can be used. For example, 

Congress limits the amount of FCA’s assessments that can be obligated 

for administrative expenses.



Table 1: SEC Budget Estimates and Appropriations (dollars in 

thousands):



Estimate submitted to OMB; 1992: $249,082; 1993: $260,852; 1994: 

$274,803; 1995: $297,376; 1996: $350,766; 1997: $317,294; 1998: 

$317,412; 1999: $339,098; 2000: $367,800; 2001: $430,600.



Action by OMB; 1992: -23,290; 1993: -11,091; 1994: -19,447; 1995: 

8,624; 1996: -7,844; 1997: -9,105; 1998: -; 1999: 2,000; 2000: -7,000; 

2001: -7,800.



President’s request; 1992: 225,792; 1993: 249,761; 1994: 255,356; 1995: 

306,000; 1996: 342,922; 1997: 308,189; 1998: 317,412; 1999: 341,098; 

2000: 360,800; 2001: 422,800.



Action by House of Representatives; 1992: -68,307; 1993: -92,276; 1994: 

-197,500;  1995: -9,126; 1996: -45,517; 1997: -11,168; 1998: -2,412; 

1999: -17,098; 2000: -36,800; 2001: -30,176.



Subtotal; 1992: $157,485; 1993: $157,485; 1994: $57,856; 1995: 

$296,874; 1996: $297,405; 1997: $297,021; 1998: $315,000; 1999: 

$324,000; 2000: $324,000; 2001: $392,624.



Action by the Senate; 1992: 68,307; 1993: 92,276; 1994: 197,500[A]; 

1995: 7,708; 1996: -; 1997: 9,379; 1998: 2,412; 1999: 17,098; 2000: 

46,800; 2001: 97,028.



Subtotal; 1992: $225,792; 1993: $249,761; 1994: $255,356; 1995: 

$304,582; 1996: $297,405; 1997: $306,400; 1998: $317,412; 1999: 

$341,098; 2000: $370,800; 2001: $489,652.



Action by conferees; 1992: -; 1993: 3,474; 1994: 4,961; 1995: -7,177; 

1996: -; 1997: -1,000; 1998: 2,412; 1999: -11,098; 2000: -3,000; 2001: 

-66,852.



Annual appropriation; 1992: 225,792; 1993: 253,235; 1994: 260,317; 

1995: 297,405; 1996: 297,405; 1997: 305,400; 1998: 315,000; 1999: 

330,000; 2000: 367,800; 2001: 422,800.



Supplemental appropriation; 1992: -; 1993: -; 1994: -; 1995: -; 1996: -

; 1997: -; 1998: -; 1999: 8,175; 2000: 500; 2001: -.



Sequestration[B] /; other; 1992: -; 1993: -; 1994: -; 1995: -568; 1996: 

-384; 1997: -; 1998: -; 1999: -458; 2000: -; 2001: -.



Use of prior years’ unobligated balances; 1992: -; 1992: -; 1993: 

8,833; 1994: 3,600; 1995: 3,900; 1996: 5,700; 1997: 5,100[C]; 1998: 

18,357[D]; 1999: 14,100[E]; 2000: 4,472[C].



Total funding level; 1992: $225,792; 1993: $253,235[F]; 1994: $269,150; 

1995: $300,437; 1996: $300,921; 1997: $311,100; 1998: $320,100; 1999: 

$356,074; 2000: $382,400; 2001: $427,272.



[A] Funding reduced to $57.86 million, based on an assumption that fee 

language would be later enacted in permanent legislation to provide an 

additional $197.5 million in offsetting collections, thereby funding 

SEC in full at $255.36 million.



[B] Sequestration is generally the cancellation of budgetary resources 

provided by discretionary appropriations or direct spending law.



[C] Represents spending authority for 3-year EDGAR modernization.



[D] Includes $14.5 million for 3-year EDGAR modernization and $3.86 

million from prior year recoveries.



[E] Includes $5.4 million for 3-year EDGAR modernization and $8.7 

million reprogramming.



[F] Pending possible enactment of legislation amending the Investment 

Advisors Act of 1940, SEC’s appropriation included authorization to 

collect and spend an additional $16 million in new fees for the direct 

costs of registration, inspection, and related activities. Such 

legislation was not passed in 1993.



Source: SEC 1995, 2000, and 2001 Annual Reports. GAO did not 

independently verify the accuracy of these numbers.



[End of table]



The OMB also has various ways of enforcing accountability that can 

constrain a program’s operations. For example, through the 

apportionment process OMB can control the rate of obligations by 

controlling the rate at which budget authority is made available during 

the fiscal year. Finally, a department or agency independently may 

place administrative limits on funding, such as restricting the amount 

that can be used for travel or not allowing funds to be shifted between 

items of expense. For example, an agency might prohibit a program 

manager from purchasing a computer using funds allocated, but no longer 

needed, for salaries and benefits.



Self-Funding Would Eliminate Use of SEC’s

Offsetting Collections for Other Purposes:



Another implication of self-controlled funding is that offsetting 

collections would no longer be available to offset funding for other 

discretionary spending purposes. As discussed earlier in this report, 

fees in excess of SEC’s budget are used by the appropriators to offset 

funding for other priorities in the CJS appropriations bill. Self-

controlled funding would allow SEC to dedicate the fees that it 

collects to fund its operations without further legislative action. 

Therefore, SEC’s fees would not be available to offset spending for 

other federal programs. However, regardless of whether the SEC funding 

structure changes, CJS will have less funding available for 

discretionary spending because SEC’s fees will decrease as mandated in 

the Act.



Conclusions:



The decision on whether to change SEC’s self-funding status and to what 

degree is a policy decision that resides with Congress. In deciding 

whether to move SEC to a more self-controlled funding structure, 

Congress will have to weigh the increase in flexibility afforded SEC 

against the loss in oversight provided by the appropriators and OMB. 

The increased funding flexibility would likely allow SEC to more 

readily fund certain budget priorities, such as pay parity, and to more 

quickly respond to the ever-changing securities markets. On the other 

hand, Congress and OMB would lose the ability to directly affect the 

budget and direction of the agency. In return for this added 

flexibility and control, SEC would have to develop its own system of 

fiscal controls and an accountability structure to address the loss of 

rigor and discipline provided by the federal budget and appropriations 

process.



Agency Comments and Our Evaluation:



The Chairman, SEC, provided written comments on a draft of this report 

that are reprinted in appendix II. SEC agreed that the report correctly 

identified the principal consequences of moving SEC to a self-funded 

structure. However, SEC raised several concerns with our observations 

about the issues that SEC would have to address were it to be given 

self-funding authority. Specifically, SEC commented on our observations 

in the report that SEC would need to (1) adequately manage its annual 

fee collections if it were to be moved outside of the traditional 

budget process and (2) improve its budget planning process if it were 

given self-funding authority. SEC also stated that our discussion of 

the fiscal discipline that would be required if SEC were given self-

funding authority would benefit from an analysis of SEC’s experience 

with unobligated balances derived primarily from fees collected in 

excess of amounts used to offset its appropriation.



On the first issue, regarding the need for SEC to adequately manage fee 

collections, SEC stated that the report could benefit from a more 

robust discussion of SEC’s responsibilities under the recently enacted 

Investor and Capital Markets Fee Relief Act. Among other things, this 

Act gives SEC the responsibility for adjusting fee rates on an annual 

and semi-annual basis, if necessary, to meet statutory “target 

collection amounts.” SEC stated that it had developed an adjustment 

mechanism to perform this function that has provided SEC with useful 

experience that would be beneficial if it were to move to a self-

funding structure. In our report we discussed the importance of fiscal 

discipline for self-controlled funding agencies, because these agencies 

are not guaranteed to be included in the appropriations process if they 

experience budget shortfalls. The report also recognized that the Act, 

enacted in January 2002, changed how SEC’s fees are collected and 

statutorily established target offsetting collection amounts. We did 

not question SEC’s ability to adequately manage its fee collections, 

but rather we observed that SEC as is required by statute relies on 

transaction-based fees, which we continue to believe generate revenues 

that are less predictable and more difficult to estimate than the 

assessments used by bank regulators to fund their operations.



The second issue SEC raised was our observation that SEC’s current 

budget planning process would have to be improved if it were converted 

to a self-funded basis, and it noted that “SEC’s ability to be 

proactive with respect to budget planning is constrained by the 

requirements of OMB Circular A-11, and [SEC] will continue to be 

limited…in the absence of self-funding authority.” As stated in the 

report, SEC’s annual budget is based on the past year’s appropriations 

rather than on what is actually needed to fulfill its mission. Although 

this approach may be practical in the current context, we continue to 

believe that it would be useful for SEC to determine its staffing and 

resource needs to fulfill its mission regardless of its funding status. 

Nevertheless, we are encouraged by SEC’s expressed commitment to 

improving its budget and strategic planning processes and the 

preliminary steps that are currently under way.



Finally, SEC expressed concern about the report’s discussion of SEC’s 

need for fiscal discipline, and stated that the report “would benefit 

from an analysis of the SEC’s experience with unobligated balances,” 

which according to SEC are “derived primarily from fees collected in 

excess of amounts used to offset [its] appropriation.” As illustrated 

in table 1 of the report, SEC has used these balances in several years 

during the period covered. However, we are not persuaded that 

additional analysis of SEC’s use of these balances would be beneficial 

to the report, because SEC does not have total control over the use of 

these unobligated funds. That is, in most cases the fiscal restraint 

provided by the current budgetary process is still a factor, because 

SEC is still subject to OMB and congressional review of its 

reprogramming proposals. In the absence of external fiscal discipline, 

we continue to believe that self-funded agencies have to establish 

systems to instill the fiscal restraint that would have been provided 

by the budget and appropriations processes.



We are sending copies of this report to the Chairman and Ranking 

Minority Member of the Senate Committee on Appropriations and its 

Subcommittee on Commerce, Justice, State, and the Judiciary; the 

Chairman and Ranking Minority Member, House Committee on 

Appropriations, and its Subcommittee on Commerce, Justice, State, the 

Judiciary, and Related Agencies. We will also send copies to the 

Chairman of SEC and will make copies available to others upon request. 

The report is also available at no charge on the GAO Web site at http:/

www.gao.gov.



If you or your staff have any questions regarding this report, please 

contact me or Orice M. Williams at (202) 512-8678.



Richard J. Hillman, Director

Financial Markets and Community Investment



Signed by Richard J. Hillman:



List of Requesters:



The Honorable Michael G. Oxley

Chairman

The Honorable John J. LaFalce

Ranking Minority Member

Committee on Financial Services

House of Representatives:



The Honorable Dan Burton

Chairman

The Honorable Henry A. Waxman

Ranking Minority Member

Committee on Government Reform

House of Representatives:



The Honorable Paul Sarbanes

Chairman

The Honorable Phil Gramm

Ranking Minority Member

Committee on Banking, Housing, and Urban Affairs

United States Senate:



The Honorable Joseph Lieberman

Chairman

The Honorable Fred Thompson

Ranking Minority Member

Committee on Governmental Affairs

United States Senate:



Appendix I: Scope and Methodology:



To identify the existing self-funding structures used by Congress and 

the extent of control afforded to the appropriators under each 

structure, we interviewed officials from the Securities and Exchange 

Commission (SEC), the Office of the Comptroller of the Currency (OCC), 

the Office of Thrift Supervision (OTS), and the National Credit Union 

Administration (NCUA) to obtain information on their budget structures 

and processes. Previously, we had discussed these issues with the 

Federal Deposit Insurance Corporation (FDIC) and the Federal Reserve 

System (FRS). In addition, we reviewed previous GAO work on the 

structure of other self-funded agencies, such as the Farm Credit 

Administration (FCA) and the Office of Federal Housing Enterprise 

Oversight (OFHEO). We then compared SEC’s self-funding structure to 

that of other federal financial regulators and analyzed the degree of 

control afforded to the appropriators under each structure.



To determine the implications for SEC operations and congressional and 

executive branch oversight, we interviewed SEC officials regarding the 

impact of self-funding on SEC operations. We met with the SEC Chairman 

to obtain his views on self-funding. We interviewed financial 

regulators about the impact of self-funding on their respective 

agencies, and about the challenges and benefits associated with self-

funding. We also interviewed representatives from the Senate and House 

CJS appropriations subcommittees, and officials from the Office of 

Personnel Management (OPM) and the Office of Management and Budget 

(OMB) to obtain their views on shifting budgetary control to SEC. 

Finally, we reviewed relevant GAO reports on SEC operations to identify 

existing issues.



We did our work in Washington, D.C., between February and July 2002, in 

accordance with generally accepted government auditing standards.



Appendix II: Comments from the Securities and Exchange Commission:



THE CHAIRMAN:



UNITED STATES:



SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549:



July 11, 2002:



Mr. Richard J. Hillman Director:



Financial Markets and Community Reinvestment U.S. General Accounting 

Office:



441 G Street, N.W. Washington, DC 20548:



Re:Draft Report Entitled SEC Operations: Implications of Alternative 

Funding Structures:



Dear Mr. Hillman:



Thank you for the opportunity to review and comment on the General 

Accounting Office’s draft report addressing the implications of 

converting the Securities and Exchange Commission to a self-funded 

basis. The report, as required by the Investor and Capital Markets Fee 

Relief Act, discusses the various self-funding approaches that are 

available to other federal financial regulatory agencies and assesses 

the implications of giving similar authority to the SEC.



I believe strongly that self-funding authority is important to the 

future of the SEC. This authority would greatly enhance the ability of 

the SEC, as a regulator with oversight responsibilities over critical 

aspects of our nation’s financial markets, to perform its statutory 

mission quickly, flexibly and effectively, particularly in times of 

rapidly changing conditions. In addition, in my view, the SEC is well 

suited to a self-funding structure, given that it currently collects 

fees from the securities industry that more than offset the costs of 

its operations. Moreover, I am confident that self-funding for the SEC 

can be structured in a manner that will preserve necessary 

accountability.



The report concludes that moving the SEC to a self-funding structure 

would have two primary consequences. First, the SEC would have more 

control over its own budget and funding level, which could give the SEC 

added flexibility to respond to workload challenges and market 

developments. Second, moving the SEC to a self-controlled funding 

structure could impact congressional and executive branch oversight. I 

agree that both budget flexibility and accountability must be 

considered fully in fashioning any self-funding structure for the SEC. 

The key, in my view, is to develop a structure that provides budget 

flexibility while maintaining agency accountability to Congress and the 

Office of Management and Budget. I am certain that there are ways to 

strike the right balance between these two objectives.



While I agree that the report correctly identifies the principal 

consequences of converting the SEC to a self-funded basis, I am 

concerned with some of the report’s analysis of the SEC’s ability to 

address the issues that would arise if the SEC were given self-funding 

authority. For example, the report questions the SEC’s ability to 

adequately manage annual fee collections to avoid shortfalls once the 

SEC is outside the budget process. This discussion could benefit from a 

more robust discussion of our responsibilities under the recently 

enacted Investor and Capital Markets Fee Relief Act.	The Act 

significantly alters the process by which the Commission collects fees.	

In the past, the rates of fees required to be collected by the SEC were 

set by statute.	As a result, the amount of fees collected in a given 

year varied according to market conditions. Now, the SEC has 

responsibility for adjusting fee rates on an annual and semi-annual 

basis, if necessary, to meet statutory “target offsetting collections 

amounts.” In consultation with OMB and the Congressional Budget Office, 

the SEC developed an adjustment mechanism to perform this duty. This 

mechanism is precisely the type of mechanism that would be required if 

the SEC were to move to self-funding structure.	In establishing the 

adjustment mechanism, we already have gained valuable experience in 

this area and will expand that experience with each mid-year and annual 

adjustment.



The report also notes that the SEC would need to improve its budget 

planning process if it were given self-funding authority. In support, 

the report describes the SEC’s “reactive approach” to the annual budget 

process. As a general matter, however, the SEC’s ability to be 

proactive with respect to budget planning is constrained by the 

requirements of OMB Circular A-11, and we will continue to be limited 

in the extent to which we can deviate from these requirements in the 

absence of self-funding authority. The SEC welcomes the opportunity to 

develop a more forward-looking, strategic budget process and indeed has 

become more proactive in certain areas. For example, even though the 

SEC is not covered by the requirements of the Chief Financial Officer 

Act and is limited by the lack of approved funding, the SEC supports 

the financial accountability goals of that Act and has begun to take 

the preliminary steps necessary to produce annual audited financial 

statements. I also intend to implement aggressive risk management and 

strategic planning that will affect all the agency’s programs to help 

ensure that the SEC anticipates and plans for major market changes.



The report’s discussion of the fiscal discipline that would be required 

if the SEC were given self-funding authority also would benefit from an 

analysis of the SEC’s experience with unobligated balances. Since the 

early 1990’s, the SEC has managed substantial amounts of available, 

unobligated balances derived primarily from fees collected in excess of 

amounts used to offset our appropriation. These balances have been 

applied judiciously by the agency in times of need to further our 

mission and have provided us with substantial flexibility to quickly 

respond to changes in the securities industry and our regulatory 

environment.



Our general policy has been to limit the application of these 

unobligated balances to specific, one-time purposes that require timely 

action. Recently, the SEC has used these funds to:	1) undertake our 

multi-year modernization of EDGAR, our real-time Electronic, Data 

Gathering, Analysis, and Retrieval System; 2) develop, in conjunction 

with the NASD, the Investment Advisor Registration Depository that 

electronically provides important disclosure information to the public; 

and 3) respond to the challenges that the Internet has brought to our 

enforcement program. On a more limited basis, and with the approval of 

our appropriators, we also have used a portion of these funds to add to 

our examination and inspection staff. Each of these undertakings shows 

that the SEC has the experience and ability to manage resources outside 

of the regular appropriations process. By not discussing our experience 

with these balances, I believe that the report’s description of the 

implications of moving the SEC to a self-funding basis is incomplete.



With respect to congressional and executive branch oversight, the SEC 

currently works regularly and constructively with OMB and Congress, and 

we do not foresee that a move to a self-funding structure would 

jeopardize these important relationships. While self-funding would 

require us to develop some additional internal capabilities, we would 

continue to work with both OMB and Congress to ensure their involvement 

in our annual budget, strategic planning, management, and other 

operational activities regardless of our funding structure, much as the 

banking agencies do. As a uniquely positioned regulatory agency, the 

SEC fully appreciates both its independence and responsibility to exist 

within the larger federal framework.



In closing, the SEC’s responsibilities have grown tremendously over the 

past decade as the securities industry has experienced unprecedented 

growth and change. Self-funding authority would give the SEC the 

ability to respond quickly and effectively to these dynamic changes. It 

also would provide us with a mechanism for further addressing our human 

capital challenges. As such, I believe that shifting the SEC to a self-

funded basis --much like our sister financial regulators --is a 

laudable long-term goal that is worthy of further consideration and 

congressional support.



Thank you and your staff for the courtesy of allowing us to comment on 

your draft report.



Yours Truly,



Harvey L. Pitt



Signed by Harvey L. Pitt:



[End of comments]



Appendix III: GAO Contacts and Staff Acknowledgements:



GAO Contacts:



Richard J. Hillman (202) 512-8678

Orice M. Williams (202) 512-8678:



Acknowledgments:



In addition to the persons named above, M’Baye Diagne,

Edda Emmanuelli-Perez, Denise Fantone, Edwin Lane, Barbara Roesmann, 

and Karen Tremba made key contributions to this report.



FOOTNOTES



[1] Pub. L. No. 107-123, § 10, 115 Stat. 2390 (2002).



[2] In addition, the Act states that self-funded means that “the agency 

is authorized to employ and fix the salaries and other compensation of 

its officers and employees, and such salaries and other compensation 

are paid without regard to the provisions of other laws applicable to 

officers and employees of the United States.”



[3] The Office of Management and Budget (OMB) defines offsetting 

collections as “monies that are deducted from outlays, rather than 

counted on the receipts side of the budget. They are often paid in 

return for providing goods or services.” Offsetting collections are 

typically credited to an appropriation or fund account and are 

generally made available for obligation without further legislative 

action. However, annual appropriations acts may include limitations on 

the obligation of the funds.



[4] Appropriations authorize federal agencies to incur obligations and 

make payments out of the Treasury. Apportionment is the process by 

which OMB makes amounts available to an agency for obligation by time 

periods (usually quarters), activities, projects, objects, or a 

combination thereof.



[5] U.S. General Accounting Office, SEC Operations: Increased Workload 

Creates Challenges, GAO-02-302 (Washington, D.C.: Mar. 5, 2002). This 

report will be referred to as the SEC operations report. 



[6] SEC’s funds are appropriated on a “no-year basis,” and funds that 

have not been obligated or expended by the end of the fiscal year are 

carried forward as SEC’s unobligated balances.



[7] These two subcommittees are generally abbreviated as CJS.



[8] All years are fiscal years unless otherwise noted.



[9] Pub. L. 104-290 §§ 404 & 405, 110 Stat. 34166 (1996) (codified at 

15 USC §77 f & 78ee prior to further amendments). 



[10] GAO-02-302.



[11] To date, all these bills are still pending. Representative Michael 

G. Oxley introduced H.R. 3764, which was approved by the House of 

Representatives on June 26, 2002. Representative John H. LaFalce 

introduced H.R. 3818, which has been referred to the Subcommittee on 

Capital Markets, Insurance and Government Sponsored Enterprises, House 

Committee on Financial Services. Senator Paul Sarbanes introduced 

S.2673 to the Senate Committee on Banking, Housing, and Urban Affairs.



[12] GAO-02-302.



[13] U.S. General Accounting Office, Securities and Exchange 

Commission: Human Capital Challenges Require Management Attention, 

GAO-01-947 (Washington, D.C.: Sept. 17, 2001). 



[14] Most of the unobligated balances were used to modernize EDGAR--

Electronic Data Gathering Analysis and Retrieval--a database system 

through which public companies electronically file registration 

statements, periodic reports, and other forms with SEC.



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