Dissenting Statement by Commissioners Jill E. Sommers and Scott D. O'Malia

Fiscal Year 2012 Annual Performance Report

April 10, 2013

We respectfully dissent from the Fiscal Year 2012 Annual Performance Report. This document highlights the budgetary and staffing challenges facing the Commission in meeting its self-established priorities as part of the FY 2011-2015 Strategic Plan. To date, the Commission has met just 46 percent of its goals. It should be noted that six goals weren't even considered as part of this calculation, which if included would take the unmet goals to over 59 percent. We find these results troubling.

But even more troubling is that this report fails to outline any corrective measures that the Commission should take to ensure that these specific unmet performance measures are going to be achieved in the future. It is unclear from this document when or how the Commission will address the missed targets, if at all. Overall, the vague descriptions provide no clear direction, specificity or urgency, which indicates a complete lack of commitment to the overall performance measures.

The document does correctly point out that the Dodd-Frank Act is the reason for the lack of focus on pre-existing priorities, as staff and budgetary resources have been redirected to promulgation and implementation of rules pursuant to Dodd-Frank. In light of the expansion of its mission and the tenuous potential for additional resources, the Commission should undertake a process to revise its FY 11-15 Strategic Plan during fiscal year 2013.

Last Updated: April 10, 2013