Section 967 of the Dodd–Frank Act directed the SEC to engage an independent consultant to "conduct a broad and independent assessment of the SEC's internal operations, structure, funding, and the agency's relationship with Self-Regulating Organizations." Section 967 further states that within six months of the consultant issuing its report, and every six months thereafter for a two-year period, the SEC must issue a report to Congress describing the SEC's implementation of the regulatory and administrative recommendations contained in the consultant's report.

In March 2011, Boston Consulting Group, the firm hired by the SEC to perform this assessment, released its 263-page report providing an in-depth examination of these areas. On September 9, the SEC released its first "Report on the Implementation of SEC Organizational Reform Recommendations" to discuss its progress.

As the SEC notes in its report, BCG made wide-ranging recommendations across four main areas.

1. Reprioritizing regulatory activities. Acknowledging that the SEC is making—and will continue to need to make—difficult tradeoffs in allocating resources to highest priority needs, the study recommends that the SEC engage in a rigorous assessment to better prioritize its needs and reallocate resources accordingly.

2. Reshaping the organization. The study recommends several initiatives by which the SEC can reshape its organizational structure, roles and governance to maximize efficiency, effectiveness and collaboration and drive continuous improvement.

3. Investing in enabling infrastructure. The study concludes that significant new investment is needed in the SEC's key enabling infrastructure, specifically technology, human resources, risk management and high-priority staff skills.

4. Enhancing engagement with SROs. The study concludes that the SEC can improve both its oversight of, and engagement with, SROs.

The SEC states that it is quite early in the process of implementing any of the BCG recommendations, and has only just dipped its toe into the massive change management project that lies ahead. The agency says it has now hired its own consultant (Booz Allen & Hamilton) to help it carry out initial tasks such as dividing up all of the recommendations into separate “workstreams” and assigning each to a senior SEC staff member to analyze and plan for implementation; creating an Executive Steering Committee to "provide oversight, integration and initial decision making across all workstreams;" and other change management-ish things such as creating “Mission Advancement Program" Roadmaps.

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