The two key "restructuring" components of what the SEC likes to call the Enforcement Division's "most significant reorganization since its establishment in 1972" are (1) the elimination of the branch chief position and (2) the creation of five specialized units within the division.

Much has been written here and elsewhere about the merits and potential impact of this restructuring, but at least one group has turned out to be a consistent naysayer on its significance: the union representing SEC employees.

According to an article by Zachary Goldfarb in today's Washington Post, the union insists that despite the SEC's claims that flattening its management structure will increase the resources dedicated to its investigative efforts, the actual impact of eliminating branch chiefs will be limited. That is because some of the former branch chiefs will need to be promoted to oversee other former branch chiefs who are becoming front-line investigators, the union says. In a bulletin issued in March, the union reportedly stated that it did not believe the branch chief restructuring would result in a significant increase in front-line investigators.

I'm not sure how the union's math works on this. I don't know how many branch chief slots were eliminated, but I'm going to take an educated guess that there were 75 branch chiefs. As assistant directors in the new structure are now slated to supervise six people each, that would seem to require the deployment of only around 10 of the former branch chiefs to supervise 65 newly-created investigators.

The union also downplayed the importance of the five new specialized units rolled out in January 2010 by the Enforcement Division. In the same bulletin, the union said that "[s]pecialized units are essentially a formalization and consolidation of the working group models that have existed in the Division for years." According to the Post, Enforcement Director Robert Khuzami disagrees, saying that the units are a major improvement that have "real structure, with heads and deputies who have authority. They are very much stand-alone, concrete, formalized prosecution units designed to be forward-looking."