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GAO-15-387R 1 (2015-04-30)

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G      A       O        U.S. GOVERNMENT ACCOUNTABILITY OFFICE
441 G St. N.W.
Washington, DC 20548



April 30, 2015

The Honorable Mary Jo White
Chair
U.S. Securities and Exchange Commission

Management Report: Improvements Needed in SEC's Internal Controls and Accounting
Procedures

Dear Ms. White:

On November 17, 2014, we issued our report containing our opinion on the U.S. Securities and
Exchange Commission's (SEC) and its Investor Protection Fund's (IPF)1 fiscal years 2014 and
2013 financial statements.2 The November 2014 report also included (1) our evaluation of
SEC's compliance with selected provisions of applicable laws, regulations, contracts, and grant
agreements during fiscal year 2014 and (2) our opinion on the effectiveness of SEC's internal
control over financial reporting as of September 30, 2014, including discussion of a significant
deficiency in SEC's internal control over financial reporting resulting from continuing and new
deficiencies in its accounting for disgorgement and penalty transactions.3

The purpose of this report is to (1) present additional information regarding the significant
deficiency we identified in our November 2014 financial audit report, along with related
recommendations; (2) communicate other less significant deficiencies we identified in SEC's
internal controls during our fiscal year 2014 audit, along with our related recommended
corrective actions; and (3) provide the status of our prior recommendations reported as new or
open in our May 12, 2014, management report to the SEC (see enc. 1).4




1IPF was established in 2010 to fund the activities of SEC's whistleblower award program and the SEC Office of
Inspector General suggestion program for SEC employees. Dodd-Frank Wall Street Reform and Consumer
Protection Act, Pub. L. No. 111-203, § 922, 124 Stat. 1376, 1841 (2010) (codified at 15 U.S.C. § 78u-6(g)(2)). IPF is a
separate fund reported on within SEC's financial statements, and its financial statements present a segment of SEC
financial activity. Accordingly, IPF's financial transactions are also included in SEC's financial statements.
2GAO, Financial Audit. Securities and Exchange Commission's Fiscal Years 2014 and 2013 Financial Statements,
GAO-15-166R (Washington, D.C.: Nov. 17, 2014).
3A significant deficiency is a deficiency, or a combination of deficiencies, in internal control that is less severe than a
material weakness, yet important enough to merit attention by those charges with governance. A material weakness
is a deficiency, or combination of deficiencies, in internal control, such that there is a reasonable possibility that a
material misstatement of the entity's financial statements will not be prevented, or detected and corrected, on a timely
basis. A control deficiency exists when the design or operation of a control does not allow management or
employees, in the normal course of performing their assigned functions, to prevent, or detect and correct,
misstatements on a timely basis.
4GAO, Management Report.- Improvements Needed in SEC's Internal Controls and Accounting Procedures, GAO-1 4-
416R (Washington, D.C.: May 12, 2014).


GAO-1 5-387R SEC Management Report


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