Comments on Proposed SEC 2010-2015 Draft Strategic Plan

The SEC has proposed a strategic plan which sets out its mission, vision, and values, identifies four strategic goals, a set of desired outcomes associated with each strategic goal, and a list of performance measures for assessing the SEC's effectiveness in attaining its goals. We affirm the need for vigorous enforcement of securities law and offer some research based insights and performance indicators. We also acknowledge the importance of disclosure, but propose that the SEC needs to develop a disclosure framework and develop better operational indicators of quality of disclosure. It is important to appreciate the benefits of disclosure as well as its limits and potential dysfunctional consequences. We also discuss the need for an independent accounting standard setter and recommend that the SEC take a greater role in enhancing the independence of FASB. This comment was developed by American Accounting Association's Financial Accounting Standards Committee and does not represent an official position of the American Accounting Association