Under Section 967 of Dodd-Frank, the SEC was directed to hire an independent consultant “to examine the internal operations, structure, funding, and the need for comprehensive reform of the SEC, as well as the SEC’s relationship with and the reliance on self-regulatory organizations and other entities relevant to the regulation of securities and the protection of securities investors that are under the SEC’s oversight.”

On October 15, 2010, the SEC hired Boston Consulting Group to perform this study. BCG’s report is due March 14, but a draft report is now circulating and some of its preliminary findings have already been made public. As reported by Bloomberg, BCG’s study shows that the SEC presently has a “capacity gap” of 375 to 425 employees, i.e., it is about 400 employees short of what is required for it to handle its current workload. โ€œWithout sufficient human resources,” BCG stated, “the agency will be unable to complete the requirements of Dodd-Frank while maintaining its current activities.โ€