U.S. COMMODITY FUTURES TRADING COMMISSION 

Three Lafayette Centre 


1155 21st Street, NW, Washington, DC 20581 


Telephone: (202) 418-5110 


Facsimile: (202) 418-5522 


TO: Timothy G. Massad, Chairman 

Sharon Y. Bowen, Commissioner 

J. Christopher Giancarlo, Commissioner 

FROM: Miguel A. Castillo, Assistant Inspector General for Auditing 

DATE: January 15, 2016 

SUBJECT: 	Financial Statements Audit FY 2015: Compliance with Provisions of the 

Comptroller General of the United States; and Office of Management and 

Budget (OMB) Bulletin No. 15-02, Audit Requirements for Federal 

Financial Statements 

The Office of the Inspector General (OIG) has concluded an audit of the Commodity 

Futures Trading Commission's (CFTC) financial statements as of September 30, 2015. 

We contracted with the independent certified public accounting firm KPMG LLP 

(KPMG) to conduct this audit. The contract required KPMG to conduct and report the 

audit in accordance with U.S. generally accepted government auditing standards 

(GAGAS), U.S. generally accepted accounting principles (US GAAP), and standards 

issued by Office of Management and Budget (OMB) Bulletin No. 15-02, Audit 

Requirements for Federal Financial Statements. 

KPMG communicated a qualified opinion for the CFTC's financial position as of 

September 30, 2015 and 2014, and its net costs, changes in net position, custodial 

activity, and budgetary resources for the years then ended. Additionally, KPMG 

communicated material weaknesses in internal control over financial reporting and 

non-compliance with applicable laws and regulations. 

KPMG found that, "except for the Statement of Budgetary Resources (SBR), the 

financial statements were fairly presented, in all material respects, in conformity with 

US GAAP." Specifically, KPMG found that "the CFTC's budgetary accounting for 

recording of lease obligations [in the SBR] in prior years [FY 2005 through FY 2014] 

and in the current year is not in accordance with US GAAP." 

With regard to the recording oflease obligations, KPMG found: 

• 	 CFTC's FY 2015 and FY 2014 financial statements contained misstatements 

related to the understatement of obligations of approximately $194 million and 

$212 million, respectively, as of September 30, 2015 and 2014, which impacts a 

number of amounts on CFTC's combined statements of budgetary resources and 

related notes including financial statement captions such as Total Budgetary 
Resources, Obligations Incurred, Total Unobligated Balance, End of Year, and 

Obligated Balance, End ofYear. 

• CFfC's historical practice of entering into lease contracts and recording related 

obligations resulted in a potential violation of the Anti-Deficiency Act (ADA). 

CFrC management did not concur with these findings, and quoted unpublished 

financial reporting guidance it received from OMB staff, and stated the U.S. 

Government Accountability Office is currently reviewing the matter, with an opinion 

expected in Fiscal Year 2016. 

In addition: 

• 	 The FY 2014 balance sheet presented custodial liabilities of approximately $ 4.2 

million below the "Total Intragovernmental" caption. Custodial liabilities 

represent payables for amounts due to the U.S. Department of the Treasury upon 

collection and are considered intragovernmental liabilities. This error was 

subsequently corrected. 

• 	 During the course of preparing the 2015 Commodity Futures Trading 

Commission Customer Protection Fund (CPF) financial statements, the 

independent auditors of the CPF informed management they incorrectly 

presented in the FY 2014 Statements of Budgetary Resources $16.2 million of 

unobligated funds as "Apportioned" when this amount had not been made 

available through the apportionment process and should have been presented as 

"Unapportioned". This error was subsequently corrected. 

In reference to internal controls over financial reporting, KPMG communicated the 

CFfC's internal controls are not sufficiently designed to detect and correct material 

errors in its financial statements. In reference to compliance with laws and regulations, 

the CFfC's historical practice of entering into lease contracts and recording related 

obligations resulted in a potential violation of the Anti-Deficiency Act (ADA). KPMG 

noted CFfC lacked controls to prevent violations and were not sufficiently designed to 

prevent violations in the [two] instances [CFrC reported] for FY 2015.1 

CFrC management concurred with these additional findings. 

KPMG recommended improvements to the CFfC's internal controls over financial 

reporting and written accounting policies and procedures. KPMG also recommended 

CFfC investigate the potential violation of ADA. 

KPMG is responsible for the auditor's report dated January 15, 2016 and the conclusions 

expressed in the report. We do not express opinions on the CFfC's financial statements 

or internal control or on whetl1er the CFrC's financial management systems 

substantially complied with applicable laws and regulations over financial reporting. 

Consistent with our responsibility under the Inspector General Act, we are providing 

copies of this report to appropriate Congressional committees with CFfC oversight and 

1 These bullets are quoted from KPMG 's audit report, attached. 
appropriation responsibilities. In addition, we will post a copy ofthe report on our 

public website and remove previous financial statement audit opinions impacted by this 

audit report. The report will be published on the OIG webpage and a synopsis will be 

presented in the Semiannual Report to Congress ending March 31, 2016. Ifyou have 

any questions, please contact me at (202) 418-5084. 

cc: 

Clark Ogilvie, Chief of Staff 

Anthony Thompson, Executive Director 

Mary Jean Buhler, Chief Financial Officer 

A. Roy Lavik, Inspector General 

Judith A. Ringle, Deputy Inspector General 
KPMG LLP 

Suite 12000 

1801 K Street, NW 

Washington, DC 20006 

Independent Auditors' Report 

Chairman and Inspector General of the 

U.S. Commodity Futures Trading Commission: 

Report on the Fina ncial Statements 

We have audited the accompanying financial statements of the U.S. Commodity Futures Trading 

Commission (CFTC), which comprise the balance sheets as of September 30, 2015 and 2014, and the 

related statements of net cost, changes in net position, custodial activity, and combined statements of 

budgetary reso urces for the years then ended, and the related notes to the fi nancial statements. 

Management's Responsibility for the Financial Statements 

Management is responsible for the preparation and fa ir presentation of these financial statements in 

accordance with U.S. generally accepted accounting principles; this includes the design, implementation, 

and maintenance of internal control relevant to the preparati on and fa ir presentation of fi nancial statements 

that are free from material misstatement, whether due to fraud or error. 

Auditors ' Responsibility 

Our responsibility is to express an opinion on these financial statements based on our audits. We conducted 

our audits in accordance with auditing standards generally accepted in the United States of America; the 

standards applicable to financial audits contained in Government Auditing Standards issued by the 

Comptroller General of the United States; and Office of Management and Budget (OMB) Bulletin No. 15­

02, Audit Requirements for Federal Financial Statements. Those standards and OMB Bulletin No. 15-02 

require that we plan and perform the audit to obtain reasonable assu rance about whether the financial 

statements are free from material misstatement. 

An audit involves perfo rming procedures to obtain audit evidence about the amounts and disclosures in the 

financial statements. The procedures selected depend on the auditors' judgment, including the assessment 

of the risks of material misstatement of the fi nancial statements, whether due to fraud or error. In making 

those risk assessments, the auditor considers internal control relevant to the entity's preparation and fair 

presentation of the fi nancial statements in order to design aud it procedures that are appropriate in the 

circumstances, but not for the purpose of expressing an opinion on the effectiveness of the entity's internal 

control. Accordingly, we express no such opinion. An audit also includes eval uating the appropriateness of 

accounting policies used and the reasonableness of signi ficant accounting estimates made by management, 

as well as evaluating the overall presentation of the financial statements. 

We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our 

qualified audit opinion. 

KPMG LLP is a Delaware limited liability partnership, 

the U.S. member firm of KPMG lnlemalional Coopemtive 

\ KPMG International'), a Swiss entity. 
Basis for Qualified Opinion 

As disclosed in Note I 0 to the financial statements, CFTC is a party to multi-year lease contracts for rental 

of real estate space. U.S. 5enerally accepted accounting principles require a lease obligation to be recorded 

at the inception of the lease in the amount necessary to cover the legal and contractual obligations 

includi ng the estimated total payments expected to arise under the ful l term of the contract. CFTC has 

recorded as obligations only the annual portion of the lease payments due each year in the accompanying 

combined statements of budgetary resources. Not recording the required obligations at the inception of the 

lease resulted in an understatement of obligations of approximately $194 million and $2 12 million, 

respectively, as of September 30, 201 5 and 20 14. Accordingly, a number of amounts are misstated on 

CFTC's combined statements of budgetary resources and in the related notes for the years ended 

September 30, 201 5 and 20 14 including financial statement captions such as Total Budgetary Resources, 

Obligations Incurred, Total Unobligated Balance, End of Year, and Obligated Balance, End of Year. 

Qualified Opinion 

In our opinion, except for the effects of the matter described in the Basis for Qualified Opin ion paragraph, 

the financial statements referTed to above present fa irly, in all material respects, the financ ial position of the 

U.S. Commodi ty Futures Trading Commission as of September 30, 2015 and 2014, and its net costs, 

changes in net position, custod ial activity, and budgetary resources for the years then ended in accordance 

with U.S. generally accepted accounting pri nciples. 

Other Matters 

In our report dated November 14, 20 14, we expressed an opinion that the 20 14 financial statements fairly 

presented the financial position, net costs, changes in net position, custodial activity, and budgetary 

resources in accordance with U.S. generally accepted accounting principles. As described above, CFTC's 

budgetary accounting for recording of lease obligations in prior years and in the current year is not in 

accordance with U.S. generally accepted accounting principles. Accordingly, our present opinion on the 

201 4 financial statements, as presented herein, is different from that expressed in our previous report. 

Management has elected to reference to information on websites or other fonns of interactive data outside 

the Agency Financial Report to provide additional info rmation for the users of its fi nancial statements. 

Such information is not a required part of the basic financial statements or supplementary information 

required by the Federal Accounti ng Standards Advisory Board. The information on these websites or the 

other interactive data has not been subjected to any of our auditing procedures, and accordingly we do not 

express an opi nion or provide any assurance on it. 

Required SupplementO!y Information 

U.S. generally accepted accounting principles require that the information in the Management's Discussion 

and Analysis and Required Supplementary Information sections be presented to supplement the basic 

financial statements. Such inform ation, although not a part of the basic fi nancial statements, is required by 

the Federal Accounting Standards Advisory Board who considers it to be an essential part of fi nancial 

reporting for placing the basic financial statements in an appropriate operational, economic, or historical 

context. We have applied certain limited procedures to the required supplementary information in 

accordance with aud iting standards generally accepted in the United States of America, wh ich consisted of 

inqui ries of management about the methods of preparing the information and comparing the information 

fo r consistency with management's responses to our inqu iries, the basic financial statements, and other 

knowledge we obtained during our audits of the basic financial statements. 

2 

As described in the Basis for Qualified Opinion paragraph, CFTC did not record obligations for the 

estimated total payments expected to arise under the full term of its contracts for rental of real estate space 

in accordance with U.S. generally accepted accounting principles. Accordingly the affected balances from 

the combined statements of budgetary resources presented on a disaggregated basis in the Requi red 

Supplementary Information are a material departure from the prescribed guidelines for repo1ting budgetary 

resources. We do not express an opi nion or provide any assurance on the information because the limited 

proced ures do not provide us with sufficient evidence to express an opinion or provide any assurance. 

Other Information 

Our audits were conducted for the purpose of forming an opinion on the basic financi al statements as a 

whole. The information contained within the introducto1y sections (presented before the Management's 

Discussion and Analysis section), the Message from the Chief Fi nancial Officer, Other lnfonnation, and 

the Appendix sections is presented for purposes of additional analysis and is not a required part of the basic 

financial statements. Such information has not been subjected to the auditing proced ures applied in the 

audit of the basic financial statements, and accordingly, we do not express an opinion or provide any 

assurance on it. 

Other Reporting Required by Government Auditing Standards 

Internal Control Over Financial Reporting 

In planning and performing our audit of the financial statements as of and for the year ended September 30, 

2015, we considered the CFTC's internal control over financial reporting (internal control) to determine 

the audit procedures that are appropriate in the circumstances for the purpose of expressing our opinion on 

the fi nancial statements, but not for the purpose of expressing an opinion on the effectiveness of the 

CFTC's internal control. Accordingly, we do not express an opinion on the effectiveness of the CFTC's 

internal control. We did not test all internal controls relevant to operating objectives as broadly defined by 

the Federal Managers' Financial Integrity Act of1982. 

Our consideration of internal control was for the limited purpose described in the preceding paragraph and 

was not designed to identify all deficiencies in internal control that might be material weaknesses or 

significant deficiencies and therefore, material weaknesses or significant deficiencies may exist that have 

not been identified. However, as described in Exhibit I, we identified a deficiency in internal control that 

we consider to be a material weakness. 

A deficiency in internal control 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. A material weakness is a deficiency, or a combination of deficienc ies, in 

internal control such that there is a reasonable possibility that a material misstatement of the entity's 

financi al statements will not be prevented, or detected and corrected, on a timely basis. A significant 

deficiency is a deficiency, or a combination of defici encies, in internal control that is less severe than a 

material weakness, yet important enough to merit attention by those charged with governance. We consider 

the deficiency described in Exhibit I to be a material weakness. 

Compliance and Otlter Matters 

As part of obtaining reasonable ass urance about whether CFTC's fi nancial statements are free from 

material misstatement, we performed tests of its compliance with certain provisions of laws, regulations, 

and contracts, noncompliance with which could have a direct and material effect on the determination of 

financial statement amounts. However, providing an opinion on compliance with those provisions was not 

an objective of our audit, and accordingly, we do not express such an opinion. The results of our tests 

disclosed instances of noncompliance or other matters that are required to be reported under Government 

Auditing Standards or OMB Bulletin No. 15-02, and which are described in Exhibit 11. 

3 

CFTC's Responses to Findings 

CFTC's responses to the findings identified in our audit are described in a separate letter immediately 

fo llowing this report. CFTC's responses were not subjected to the auditing procedures appli ed in the audit 

of the financial statements and, accordingly, we express no opinion on the responses. 

Purpose ofthe Other Reporting Required by Government Auditing Standards 

The purpose of the communication described in the Other Reporting Required by Government Auditing 

Standards section is solely to describe the scope of our testing of internal control and compliance and the 

result of that testing, and not to provide an opinion on the effectiveness of CFTC's internal control or 

compliance. Accordi ngly, this communication is not suitable fo r any other purpose. 

January 15, 20 16 

4 

Exhibit I 

U.S. Commodity Futures Trading Commission 

Independent Auditors' Report 

Material Weakness 

CONDITIONS 

During Fiscal Year (FY) 2015, CFTC became aware of the following errors impacting both the FY 2014 

and FY 20 IS financial statements: 

1. 	 CFTC's accounting policy to recognize lease obligations is not in accordance with U.S. generally 

accepted accounting principles and more specifically Office of Management and Budget (OMB) 

Circular No. A-11, Preparation, Submission, and Execution ofthe Budget (OMB A-11). 

2. 	 The FY 2014 balance sheet presented custodial liabilities of approximately $4.2 million below the 

"Total Intragovernmental" caption. Custodial liabilities represent payables for amounts due to the U.S. 

Department of the Treasury (Treasury) upon collection and are considered intragovernmental 

liabilities. This error was subsequently corrected. 

3. 	 CFTC incorrectly presented in the FY 2014 statement of budgetary resources $16.2 million of 

unobligated funds as "Apportioned" when this amount had not been made available through the 

apportionment process and should have been presented as "Unapportioned". This error was 

subsequently corrected. 

CRITERIA 

Statement of Federal Financial Accounting Standards 7 (SFF AS 7), Accounting for Revenue and Other 

Financing Sources and Concepts for Reconciling Budgetary and Financial Accounting, paragraph 78 

requires "Recognition and measurement of budgetary resources should be based on budget concepts and 

definitions contained in OMB Circular A-11." 

OMB A-11, Appendix B - Budgetary Treatment of Lease-Purchases and Leases of Capital Assets 

Paragraph l(a) states: "For operating leases, budget authority is required to be obligated up front in the 

amount necessary to cover the Government's legal obligations, consistent with the requirements of the 

Antideficiency Act. This will include the estimated total payments expected to arise under the full tenn of 

the contract or, if the contract includes a cancellation clause, an amount sufficient to cover the lease 

payments for the first year plus an amount sufficient to cover the costs associated with cancellation of the 

contract." 

OMB A-11, Appendix F - Format ofSF 123, SF 133, Schedule P and SBR, Section 4 Status ofBudgetary 

Resources states: "Apportioned- Include the balances of amounts apportioned under Category A, Category 

B, and Category AB, as well as amounts apportioned by letter from OMB or by OMB bulletin." 

OMB Circular No. A-136, Financial Reporting Requirements (OMB A-136), Section II.4.3.4: 

"lntragovernmental Liabilities - These liabilities are claims against the entity by other Federal entities. 

Report intragovernmental liabilities separately from claims against the reporting entity by non-Federal 

entities." 

The Government Accountability Office's Standards for Internal Control in the Federal Government, 

"Internal control should generally be designed to assure that ongoing monitoring occurs in the course of 

nonnal operations. It is performed continually and is ingrained in the agency's operations. It includes 

5 

Exhibit I 

U.S. Commodity Futures Trading Commission 

Independent Auditors' Report 

Materia l Weakness 

regular management and supervisory activities, comparisons, reconcil iations, and other actions people take 

in pe1forming their duti es." 

The Office of Management and Budget (OMB) Circular No. A-1 23, Management's Responsibility for 

Internal Control, states, "Management is responsible for establishing and maintaining internal control to 

achieve the obj ectives of effective and effi cient operations, reliable fi nancial reporting, and compliance 

with appli cable laws and regulations." 

CAUSE 

CFTC's internal controls over financial reporting and compliance are not sufficiently designed to detect 

and correct material errors in its financial statements. Specifically: 

• 	 Condition I resulted from a lack of adeq uate control to ensure lease obligati ons are recorded in 

compliance with OMB A-11, Appendix B requirements. 

• 	 Conditions 2 and 3 resulted from a lack of sufficiently detailed review by management of the financial 

statements, or a review at a sufficient level of depth, to ensure that errors and omissions in the financial 

statements and relates notes as well as compliance with laws and regulations were detected and 

corrected in a timely manner. 

EFFECT 

• 	 Condition I related to CFTC's accounting policy for recognizing lease obligation discussed above 

resulted in the fo llowing: 

• 	 CFTC's FY 2015 and FY 2014 financial statements contained material misstatements, as descri bed 

in the Basis for Qualified Opinion paragraph of the Independent Auditors' report. 

• 	 CFTC's historical practice of entering into lease contracts and recording related obligations resulted 

in a potential violation of the Anti-Deficiency Act (ADA). 

• 	 For conditions 2 and 3, the FY 2014 financial statements were misstated by the amounts discussed 

above. 

RECOMMENDATIONS 

We recommend that management: 

(a) Improve 	its internal controls over fina ncial reporting and compliance. Specifically, we recommend 

that management perform a more detailed review of all information in the annual fi nancial report 

including financial statements, notes, and supplementary information and prepare the GAO 

accounting and financial reporting checklist. The review performed should ensure all transactions and 

classes of transactions are recorded and reported in the financial statements in accordance with U.S. 

generally accepted accounting standards. Such review should be documented and maintained. 

(b) 	Develop written accounting policies and procedures that document the basis for all accounting 

positions that are significant to the financial statements. 

(c) 	 Develop and implement adequate control to ensure lease obligations are recorded in compliance with 

OMB A-1 1, Appendix B requirements. 

(d) Update its accounting policy on the accounting for the lease obligation to be consistent with the 

guidance in OMB A-1 1, Appendix B. 

(e) 	Investigate the potential violation of ADA to make a final determination and repo1t it, as applicable. 

6 
Exhibit I 

U.S. Commodity Futures Trading Commission 

Independent Auditors' Report 

Material Weakness 

MANAGEMENT'S RESPONSE 

Management's response to the finding is presented in a separate letter immediately following this report. 

AUDITORS' RESPONSE 

Based on the Office of Management and Budget (OMB) Circular No. A-11, Preparation, Submission, and 

Execution ofthe Budget (OMB A-11), Appendix B, paragraph cited in the "CRITERIA" section above, we 

continue to believe that CFTC's accounting policy to recognize lease obligations is not in accordance with 

U.S. generally accepted accounting principles. 

7 
Exhibit II 

U.S. Commodity Futures Trading Commission 

Independent Auditors' Report 

Compliance and Other Matters 

CONDITIONS 

Reported Anti-Deficiency Act Violations: 

On July 20, 2015 CFTC reported the following violations of the Anti-deficiency Act (ADA) in accordance 

with Title 31 U.S. Code Section 1517: 

• 	 CFTC reported a violation in the amount of $3,564,752.63 related to the fiscal year 2013 transfer of 

funds from the Information Technology fund to the Salaries and Expense fund without having the 

authority under the fiscal year 2013 Appropriations Act. As disclosed in Note 14, this matter caused the 

Unapportioned balance presented in the FY 2015 Statement of Budgetary Resources to be negative. 

• 	 CFTC reported a violation pertaining to the acceptance of voluntary services from academic 

researchers from January 1, 2010 to February 7, 2013. 

Potential Anti-Deficiency Act Violation: 

CFTC is investigating a matter that may potentially represent a violation of the ADA related to the CFTC's 

historical policy of entering into lease contracts and recording related obligations. A final determination has 

not yet been made and therefore the outcome ofthis matter is not presently known. 

CRITERIA 

Title 3 I U.S. Code (U.S.C.) Section 1517 Prohibited Obligations and Expenditures states: 

(a) An 	 officer or employee of the United States Government or of the District of Columbia 

government may not make or authorize an expenditure or obligation exceeding­

(I) An apportionment; or 

(2) The amount permitted by regulations prescribed under section 1514(a) ofthis title. 

(b) 	If an officer or employee of an executive agency or of the District of Columbia government 

violates subsection (a) of this section, the head ofthe executive agency or the Mayor of the District 

of Columbia, as the case may be, shall report immediately to the President and Congress all 

relevant facts and a statement of actions taken. A copy of each report shall also be transmitted to 

the Comptroller General on the same date the report is transmitted to the President and Congress. 

CAUSE 

The controls in place at CFTC to prevent ADA violations were not sufficiently designed to prevent ADA 

violations in the instances of noncompliance noted above. 

EFFECT 

CFTC was not in compliance with the ADA related to the reported instances noted. CFTC may not be in 

compliance with the ADA related to the potential instance noted. 

8 

Exhibit II 

U.S. Commodity Futures Trading Commission 

Independent Auditors' Report 

Compliance and Other Matters 

RECOMMENDATIONS 

We recommend that management: 

(a) Complete the investigation into the potential ADA violation noted. 

(b) Develop and implement sufficient policies and procedures to prevent future ADA violations. 

MANAGEMENT'S RESPONSE 

Management's response to the finding is presented in a separate letter immediately following this report. 

9 

U.S. COMMODITY FUTURES TRADING COMMISSION 


Three Lafayette Centre 


1155 21st Street, NW, Washington, DC 20581 


Telephone: (202) 418-5089 


Facsimile: (202) 418-5414 


mbuh/er@cftc.gov 

Chief Financial Officer 

January 15, 2016 

MANAGEMENT'S RESPONSE TO INDEPENDENT AUDITOR'S REPORT 

Management's Response to the Mate1·ial Weakness: 

During Fiscal Year (FY) 2015, CFTC became aware ofthe following errors impacting both FY 2014 and 

FY 2015 financial statements: 

1. 	 CFTC's accounting policy to recognize lease obligation is not in accordance with U.S generally 

accepted accounting principles and more specificaHy Office ofManagement and Budget (OMB) 

Circular No. A-11, Preparation, Submission, and Execution of the Budget (OMB A-11). 

CFI'C Response: Management does not concur with this finding for FY 2015 because there is 

not currently an official dete11nination that the Commission has violated any regulations and, if 

so, to what extent. CFTC does not have a formal accounting policy specifically related to the 

recognition of lease obligations. CFTC's historical practice has been to obligate only the annual 

portion of lease payments due each year. On August 6, 2015, the Government Accountability 

Office (GAO) requested information on the Commission's views regarding various legal issues 

involving the CFTC's leases, including the practice ofrecording obligations arising under the 

agency's cun·ent leases for office space in Washington, D.C., Chicago, New York, and Kansas 

City. As a result of the CFTC's review, the Commission concluded that its historical practice for 

recording lease obligations may be inconsistent with OMB Circular A-11, Preparation, 

Submission and Execution ofthe Budget; 31 U.S.C. § lSOl(a)(l) (the recording statute); and 

previous GAO decisions. The GAO is currently reviewing the matter and the agency expects an 

opinion to be issued in FY 2016. As a result ofthe potential findings of the anticipated GAO 

opinion, it is reasonably possible that an unfunded obligation totaling approximately $194 million 

and $212 million as of September 30, 2015 and 2014, 1·espectively, covering all potential future 

payments agreed to under cun·ent leases, may need to be recognized on the face ofthe Statement 

ofBudgetary Resources as opposed to the Notes to the Financial Statements as historically 

repo11ed. However, the Commission has disclosed the best information it has available as ofthe 

reporting date. 

Management brought this to the attention ofKPMG in early October 2015. The Commission 

then consulted with the Office of Management and Budget to determine the best accounting and 

reporting treatment for this issue in the FY 2015 financial statements. OMB provided a written 

response dated November 20, 2015. In its response, OMB determined that a note disclosure 

would be the best course of action at this time. They fmther noted that the note disclosure would 

be in the spirit of A-11 and OMB Circular A-136, Financial Rep01ting Requirements. 
Janua1y 15, 2016 

Page2 

The guidance from OMB is provided below: 

The CFTC 's approach to disclosing an ongoing investigation into its leasing practices in the 

agency's 2015 financial statements is consistent with OMB Circulars A-11, Preparation, 

Submission, and Execution ofthe Budget, and A-136, Financial Reporting Requirements. 

It is OMB 's understanding that the CFTC anticipates a formal GA0 opinion in 2016 regarding 

its leasing practices. Concurrent with GAO 's investigation, the CFTC is conducting its own 

investigation as to whether its leasing practices constitute a violation ofthe Antideflciency Act 

(ADA) (31 USC 134/(a)). Once the CFTC concludes its investigation, the CFTC will provide a 

report to OMB describing the results, consistent with A-11. Should the GAO determination 

and/or OMB 's review ofthe CFTC report conclude that the agency made obligations exceeding 

its appropriation, the CFTC would report a violation ofthe ADA. Based on these contingencies, 

OMB concurs that a note disclosure in the CFTC 's 2015 financial statements is appropriate. 

2. 	 The FY 2014 balance sheet presented custodial liabilities ofapproximately $4.2 million below the 

"Total lntragovernmental" caption. Custodial liabilities represent payables for amounts due to the 

U.S. Department ofthe Treasury (Treasury) upon collection and are considered 


intragovernmental liabilities. This en·or was subsequently corrected. 


CFTC Response: Management concurs with this finding. As part of its regular financial 

statement review and refinement process, the Commission's accounting office identified the need 

to reclassify the custodial liabilities balance and subsequently made the correction. 

3. 	 CFTC incorrectly presented in the FY 2014 Statements of Budgetary Resources $16.2 million of 

unobligated funds as "App011ioned" when this amount had not been made available through the 

appo1tionment process and should have been presented as ~'Unappmtioned." This error was 

subsequently corrected. 

CFTC Response: Management concurs with this finding. As pm1 of its regular financial 

statement review and refinement process, the Commission's accounting office identified the need 

to correct the unobligated balance and subsequently made the correction. 

Management's Response to tile Non-Compliance Matter: 

On July 20, 2015 CFTC repo11ed the following violations of the Anti-deficiency Act (ADA) in 

accordance with Title 31 U.S. Code Section 1517: 

1. 	 CFTC repo1ted a violation in the amount of $3,564,752.63 related to the fiscal year 2013 transfer 

of funds from the Information Technology fund to the Salaries and Expense fund without having 

the authority under the fiscal year 2013 Appropriations Act. As disclosed in Note 14, this matter 

caused the Unappo11ioned balance presented in the FY 2015 Statement of Budgetary Resources to 

be negative. 

CFTC Response: Management concurs with this finding. As noted in the Commission's repo1t 

to the President and Congress, the violation pertains to a transfer of funds between two separate 

budgetary accounts that was executed by the Commission in the spring of FY 2013. The transfer 

was subsequently reversed and the Commission did not exceed its overall budget authority. The 

violation resulted from CFTC's interpretation of appropriation language that was later deemed 
January 15, 2016 

Page 3 

incorrect by the Government Accountability Office (GAO). GAO's view is set forth in a formal 

decision, Decision B-325351 - Commodity Futures Trading Commission-Fiscal Year 2013 

Transfer Authority, issued on April 25, 2014. The Commission has determined that the 

interpretation of the appropriations language contained no willful or knowing intent to violate the 

Antideficiency Act. Rather, this violation was the result of a considered interpretation of the 

appropriations language that was later deemed incorrect by GAO. The system of administrative 

controls in place at CFTC continues to operate effectively to ensure funds are expended as 

authorized and appo1tioned under normal circumstances. 

2. 	 CFTC repo1ted a violation pertaining to the acceptance of voluntary services from academic 

researchers from January 1, 2010 to February 7, 2013. 

CFTC Response: Management concurs with this finding. As noted in the Commission's report 

to the President and Congress, the Commission has instituted new policies and procedures to 

prevent a reoccurrence of this type of violation. 

3. CFTC is investigating a matter that may potentially represent a violation of the ADA related to 

the CFTC's historical policy of entering into lease contracts and recording related obligations. A 

final determination has not yet been made and therefore the outcome of this matter is not 

presently known. 

CFTC Response: Management concurs with this finding and is continuing to assess whether 

any potential ADA violations may have occurred as a result of the Commission's historical 

practices for obligating lease expenses. When the Commission entered into its four multiple-year 

leases, such as in 1994 for its Washington, D.C. office, it recorded only the annual lease 

payments each year, rather than the full multiple-year obligation in the year the lease was 

initiated. On August 6, 2015, the Govemment Accountability Office (GAO) requested 

information on the Commission's views regarding various legal issues involving the CFTC's 

leases, including the practice of recording obligations arising under the agency's cm1·ent leases 

for office space in Washington, D.C., Chicago, New York, and Kansas City. As a result of the 

CFTC's review of the GAO questions, the Commission concluded that its historical practice for 

recording lease obligations may be inconsistent with OMB Circular A-11, Preparation, 

Submission and Execution of the Budget; 31 U.S.C. § ISOJ(a)(I) (the recording statute); and 

previous GAO decisions. There is not currently an official detennination by either the agency or 

the GAO that the CFTC has violated the ADA. The CFTC plans to review GAO's decision pl'ior 

to reaching a conclusion on whether a repo11able violation ofthe ADA has occurred. Ifthe CFTC 

dete1mines that there is a violation of the ADA, the CFTC will report it as required by law. 

Sincerely, 

ff-:;/ 

~-~~- Mary 'ean Buhler 

Chief Financial Officer 

cc: Roy Lavik 
FY 2015 Agency Financial Report 

Principal Financial Statements 

Commodity Futures Trading Commission 

BALANCE SHEETS 

As of September 30, 20 l 5 and 2014 

2015 2014 

Assets 

lntragovemmental: 

Fund Balance with Treasury (Note 2) s 67,246,060 $ 47,070,343 

Investments (Note 3) 263,000,000 270,000,000 

Prepayments (Note 1J) 263,851 58,984 

Total lntragovernmental 

Custodial Receivables, Net (Note 4) 


Accounts Receivable, Net (N ote 4) 


General Property , Plant and Equipment Net (Note 5) 


Deferred Costs (Note 6) 


Prepayments (Note 1J) 


330,509,911 317,129,327 

4,696,176 4,218,788 

18,614 11,11 2 

50,358,266 54,464,549 

28,487 64,201 

2,209,608 1,653,887 

Total Assets $ 387,821 ,062 s 377,541,864 

Liabilities 

Intragovemmental: 

Accounts Payable s 387,666 $ 609, 101 

Custodial Liabilities 4,696,176 4,218,788 

FECA Liabilities (Note 9) 82,531 88,975 

Total lntragovernmental 5,166,373 4,916,864 

Accounts Payable 8,220,224 4,874,120 

Acb.Jarial FECA Liabilities (Note 9) 415,570 460,759 

Accrued Payroll 5,215,273 3,417,319 

Annual Leave 9,788,839 9,590, 172 

Deposit Fund Liabilities 179,806 134,683 

Deferred Lease Liabilities (Note 10) 25,673,457 25,961,973 

Contingent Liabilities (Note 11 ) 300,000 85,000 

Other 22,397 11,699 

Total Liabilities s 54,981,939 s 49,452,589 

Net Position 

Unexpended Appropriations - All Other Funds $ 50,997,602 $ 35,420,980 

Cumulative Results ofOperations - Funds from Dedicated Collections 267,612,410 274,315,312 

Cumulative Results of Operations - All Other Funds 14,229, 111 18,352,983 

Total Net Position 332,839,123 328,089,275 

Total Liabilities and Net Position s 387,821,062 s 377,541,864 

The accompanying notes are an integral part of these financial statements. 

85 IC FT C 

Management's Financial Other Appendix 

Discussion & Section Information 

Analysis 
FY 2015 Agency Financial Report 

Commodity Futures Trading Commission 

STATEMENTS OF NET COST 

For the Years Ended September 30, 2015 and 2014 

2015 

Net Cost by Goal (Note 16) 

Goal 1: Market Integrity and Transparency 

Gross Costs 

Less: Earned Revenue 

Net Cost of Operations - Goal One 

Goal 2: Financial Integrity andAvoidance ofSystemic Risk 

Gross Costs 

Less: Earned Revenue 

Net Cost of Operations - Goal Two 

Goal 3: Comprehensive Enforcement 

Gross Costs 

Less: Earned Revenue 

Net Cost of Operations· Goal Three 

Goal 4: Domestic and International Cooperation and Coordination 

Gross Costs 

Less: Earned Revenue 

Net Cost of Operations - Goal Four 

Grand Total 

Gross Costs 

Less: Earned Revenue 

Total Net Cost of Operations 

$ 68,337,018 

(14,516) 

$ 68,322,502 

$ 73,933,907 

(15,704) 

$ 73,918,203 

s 95,521,909 

(20,291) 

$ 95,501,618 

$ 12,068,292 

(2,563) 

$ 12,065,729 

s 249,861,126 

(53,074) 

$ 249,808,052 ~--~--

(Continued) 

86 IC FTC 

Management's Financial Other Appendix 

Discussion & Section Information 

Analysis 
FY 2015 Agency Financial Report 

Commodity Futures Trading Commission 

STATEMENTS OF NET COST (Continued) 

For the Years Ended September 30, 2015 and 2014 

2014 

Net Cost by Goal (Note 16) 

Goal 1: Market Integrity 

Gross Casis 

Less: Earned Revenue 

Net Cost of Operations - Goal One 

Goal 2: Clearing Integrity 

Gross Casis 

Less: Earned Revenue 

Net Cost of Operations - Goal Two 

Goal 3: Robust Enforcement 

Gross Casis 

Less: Earned Revenue 

Net Cost of Operations - Goal Three 

Goal 4: Cross-Border Cooperation 

Gross Casis 

Less: Earned Revenue 

Net Cost of Operations - Goal Four 

Goal 5: Organizational and Management Excellence 

Gross Casis 

Less: Earned Revenue 

Net Cost of Operations - Goal Five 

Grand Total 

Gross Casis 

Less: Earned Revenue 

Total Net Cost of Operations 

$ 56,754,452 

s 56,746,263 

(8,189) 

$ 51,970,552 

$ 51 ,963,054 

(7,498) 

$ 71,541,053 

$ 71,530,730 

(10,323) 

$ 11,742,300 

$ 11 ,740,606 

(1,694) 

$ 25,441,651 

s 25,437,980 

(3,671) 

$ 217,450,008 

$ 217,418,633 

(31,375) 

87 IC FTC 

Manageme nt's Financia l Other Appendix 

Discussion ft Section Info rmation 

Ana lysis 

The accompanying notes are an integral part of these financial statements. 
FY 2015 Agency Financial Report 

Commodity Futures Trading Commission 

STATEMENTS OF CHANGES IN NET POSITION 

For the Years Ended September 30, 2015 and 2014 

Dedicated Collections 

FY 2015 

All Other Funds Consolidated Total 

Cumulative Results of Operations: 

Beginning Balances, October 1 $ 274,315,312 s 18,352,983 s 292,668,295 

Budgetary Financing Sources 

Appropriations Used 

Nonexchange Interest Revenue (Note 3) 58, 152 

232,255,603 232,255,603 

58,152 

Other Financing Sources 

Imputed Financing Sources (Note 8) 

Total Financing Sources 58, 152 

6,667,523 

238,923,126 

6,667,523 

238,981,278 

Net Cost of Opera1ions (6,761 ,054) (243,046,998) (249,808,052) 

Net Change (6,702,902) (4,123,872) (10,826,774) 

Total Cumulative Results of Operations, September 30 s 267,612,410 s 14,229,11 1 s 281,841,521 

Unexpended Appropriations: 

Beginning Balances, October 1 s $ 35,420,980 s 35,420,980 

Budgetary Financing Sources: 

Appropriations Received 

Less: Other Adjustmenls (Rescissions, etc.) 

Appropriations Used 

Total Budgetary Financing Sources 0 

250,000,000 

(2,167,775) 

(232,255,603) 

15,576,622 

250,000,000 

(2, 167,775) 

(232,255,603) 

15,576,622 

Total Unexpended Appropriations, September 30 $ s 50,997,602 $ 50,997,602 

Net Position $ 267,612,410 s 65,226,713 s 332,839,123 

(Continued) 

88 I C FT C 

Management' s Financial Other Appendix 

Discussion & Section Information 

Analysis 
FY 2015 Agency Financial Report 

Commodity Futures Trading Commission 

STATEMENTS OF CHANGES IN NET POSITION (Continued) 

For the Years Ended September 30, 2015 and 2014 

FY 2014 

Dedicated Collections All Other Funds Consolidated Total 

Cumulative Results of Operations: 

Beginning Balances, October 1 s 99,904,291 $ 23,899,638 $ 123,803,929 

Budgetary Financing Sources 

Appropriations Used 

Nonexchange Interest Revenue (Note 3) 

Transfers· In Without Reimbursement (Note 18) 

35,630 

176,110,604 

203,363,604 203,363,604 

35,630 

176,110,604 

Other Financing Sources: 

lmpuled Financing Sources (Note 8) 

Total Financing Sources 176,146,234 

6,773,161 

210, 136,765 

6,773,161 

386,282,999 

Net Cost of Operations (1,735,213) (215,683,420) (217,418,633) 

Net Change 174,411 ,021 (5,546,655) 168,864,366 

Total Cumulative Results of Operations, September 30 s 274,315,312 $ 18,352,983 s 292,668,295 

Unexpended Appropriations: 

Beginning Balances, October 1 $ $ 25,006,039 $ 25,006,039 

Budgetary Financing Sources 

Appropriations Received 

Less: Other Adjustments (Rescissions, et.) 

Appropriations Used 

Total Budgetary Financing Sources 

215,000,000 

(1,221 ,455) 

(203,363,604) 

10,414,941 

215,000,000 

(1 ,221,455) 

(203,363,604) 

10,414,941 

Total Unexpended Appropriations, September 30 $ $ 35,420,980 $ 35,420,980 

Net Position s 274,315,312 $ 53,773,963 $ 328,089,275 

The accompanying notes are an integral part of these financial statements. 

89 IC F TC 


Management's Financial Other Appendix 

Discussion f:t Section Information 

Analysis 
Commodity Futures Trading Commission 

COMBINED STATEMENTS OF BUDGETARY RESOURCES 

For the Years Ended September 30, 2015 and 2014 

(176,466,655) 

FY 2015 Agency Financial Report 

BUDGET ARY RESOURCES 

Unobligated Balance Brought Forw ard, October 1 

Adjustment to Unobligated Balance Brought Forward, October 1 

Unobligated Balance Brought Forward, October 1, as Adjusted 

Unobligated Balance From Prior Year Budget Authority, Net 

Appropriations 

Spending Authority from Offsetting Collections 

Total Budgetary Resources 

STATUS OF BUDGET ARY RESOURCES 

Obligations Incurred (Nate 13) 

Unobligated Balance, End of Year 

Apportioned 

Unapportioned 

Total Unobligated Balance, End of Year 

Total Budgetary Resources 

CHANGE IN OBLIGATED BALANCE 

Unpaid Obligations: 

Unpaid Obligations, Brought Forward, October 1 

Obligations Incurred 

Outlays (Gross) 

Recoveries of Prior Year Unpaid Obligations 

Unpaid Obligations, End of Year 

Uncollected Payments: 

Uncollected Payments, Federal Sources, Brought Forward, October 1 

Change in Uncollected Payments, Federal Sources 

Uncollected Payments, Federal Sources, End of Year 

Memorandum Entries: 

Obligated Balance, Start of Year 

Obligated Balance, End of Year 

BUDGET AUTHORITY AND OUTLAYS, NET 

Budget Authority , Gross 

Actual Offsetting Collections 

Change in Uncollected Customer Payments from Federal Sources 

Budget Authority, Net 

Outlays, Gross 

Actual Offsetting Collections 

Outlays, Net 

Distributed Offsetting Receipts 

Agency Outlays, Net 

Recoveries of Prior Year Unpaid Obligations 

Other Changes in Unobligated Balance 

2015 2014 

$ 275,549,121 

829,170 

276,378,291 

4,061,675 

(2,167,775) 

278,272, 191 

$ 104,968,486 

104,968,486 

1,890,406 

(1,221 ,455) 

105,637,437 

s 528,502,937 

250,000,000 

230,746 

$ 496,899,396 

215,000,000 

176,261,959 

$ 258,702,003 $ 221,350,275 

$ 528 502 937 1 1

270,359,908 

(558,974) 

269,800,934 

$ 496.899.396 

13,437,561 

262, 111,560 

275,549, 121 

s 40,564,762 $ 25,798,405 

258,702,003 

(234,914, 187) 

(4,061,675) 

221,350,275 

(204,693,512) 

(1,890,406) 

60,290,903 40,564,762 

(54,225) (45,921) 

(22,435) (8,304) 

(76,660) (54,225) 

$ 40 510.537 $ 25,752,484 

$ 60,214,243 

$ 250,230,746 $ 391,261,959 


(212,554) (176,466,655) 


(22,435) (8,304) 


$ 249.9951757 $ 21417871000 

$ 234,914, 187 $ 204,693,512 

(212,554) 

234,701,633 28,226,857 

(6,767) (39,435) 

s 234,694,866 $ 28,187,422 

$ 40 510,537 

90 Ic FT c 


Management's Financial Other Appendix 

Discussion ft Section Information 

Analysis 

The accompanying notes are an integral pan of these financial statements. 
FY 2015 Agency Financial Report 

Commodity Futures Trading Commission 

STATEMENTS OF CUSTODIAL ACTIVITY 

For the Years Ended September 30, 2015 and 2014 

Revenue Activity: 

Sources of Cash Collections: 

Registration and Filing Fees 

Fines, Penalties, and Forfeib.Jres 

General Proprietary Receipts 

Total Cash Collections 

Change in Custodial Receivables 

Total ·custodial Revenue 

s 1,575,300 

s 

2015 

2,841 ,186,640 

6,767 

2,842,768,707 

477,388 

2,843,246,095 

s 2,082,325 

s 

2014 

943,104,536 

39,484 

945,226,345 

(65,525,838) 

879,700,507 

Disposition of Collections 

Amounts Transferred to: 

Department of the Treasury 

CFTC Customer Protection Fund 

Total Disposition of Collections 

Change in Custodial Liabilities 

Net Custodial Activity s 

(2,842, 768,707) 

(2,842,768,707) 

(477,388) 

s 

(769, 115,741) 

(176, 110,604) 

(945,226,345) 

65,525,838 

The accompanying notes are an integral part of these financial statements. 

91 I C F TC 


Management 's Financial Other Appendix 

Discussion & Section Information 

Analysi s 
FY 2015 Agency Financial Report 

Notes to the Financial Statements

As of and For the Fiscal Years Ended 

September 30, 2015 and 2014 

Note l. Summary of Significant Accounting Policies 

A Reporting Entity 

The Commodity Futures Trading Commission (CFTC) is an independent agency of the executive 

branch of the Federal Government. Congress created the CFTC in 1974 under the authorization of 

the Commodity Exchange Act (CEA) with the mandate to regulate commodity futu res and option 

markets in the United States. The agency's mandate was renewed and expanded under the Futures 

Trading Acts of 1978, 1982, and 1986; under the Futures Trading Practices Act of 1992; under the 

CFTC Reauthorization Act of 1995; under the Commodity Futures Modernization Act of 2000; and 

under the Dodd-Frank Act of 2010. Congress passed the Food, Conservation, and Energy Act of 

2008 (Farm Bill), which reauthorized the Commission through FY 2013. In the absence of formal 

reauthorization, CFTC has continued to operate through authorized appropriations for FY 2014 

and 2015. 

The CFTC is responsible for ensuring the economic utility of futures markets by encouraging their 

competitiveness and efficiency, ensuring their integrity, and protecting market participants against 

manipulation, abusive trade practices, and fraud. 

On July 21, 2010, the "Dodd-Frank Wall Street Reform and Consumer Protection Act" (the DoddFrank Act, or the Act) was signed into law, significantly expanding the powers and responsibilities 

of the CFTC. According to Section 748 of the Act, there is established in the Treasury of the United 

States a revolving fund known as the "Commodity Futures Trading Commission Customer 

Protection Fund" (the Fund). The Fund shall be available to the Commission, without further 

appropriation or fiscal year limitation, for a) the payment of awards to whistleblowers; and b) the 

funding of customer education initiatives designed to help customers protect themselves against 

fraud or other violations of this Act or the rules and regulations thereunder. 

B. Basis of Presentation 

The financial statements have been prepared to report the fi nancial position and results of 

operations for the CFTC, as required by the Accountability of Tax Dollars Act of 2002. They are 

presented in accordance with the form and content requirements contained in Office of 

Management and Budget (OMB) Circular No. A-136, Financial Reporting Requirements, as 

amended. 

The principal financial statements have been prepared in all material respects from the agency's 

books and records in conformity with U.S. generally accepted accounting principles (GAAP), as 

prescribed for the Federal government by the Federal Accounting Standards Advisory Board 

(FASAB). The application and methods for applying these principles are appropriate for 

92 I CFTC 

Management ' s Financial Other Appendix 

Discussion & Section Information 

Analysi s 
FY 2015 Agency Financial Report 

presenting fairly the entity's assets, liabilities, financial position, net cost of operations, changes in 

net position, budgetary resources, and custodial activities. 

The books and records of the agency served as the source of information for preparing the financial 

statements in the prescribed formats. All agency financial statements and reports used to monitor 

and control budgetary resources are prepared from the same books and records. The statements 

should be read with the understanding that they are for a component of the U.S. Government, a 

sovereign entity. 

The Balance Sheets present the financial position of the agency. The Statements of Net Cost 

present the agency's operating results; the Statements of Changes in Net Position display the 

changes in the agency's equity accounts. The Statements of Budgetary Resources present the 

sources, status, and uses of the agency's resources and follow the rules for the Budget of the United 

States Government. The Statements of Custodial Activity present the sources and disposition of 

collections for which the CITC is the fiscal agent, or custodian, for the Treasury General Fund 

Miscellaneous Receipt accounts. 

Throughout these financial statements, assets, liabilities, revenues and costs have been classified 

according to the type of entity with whom the transactions were made. Intragovernmental assets 

and liabilities are those from or to other federal entities. Intragovernmental earned revenues are 

collections or accruals of revenue from other federal entities, and intragovernmental costs are 

payments or accruals to other federal entities. The CITC does not transact business among its own 

operating units, and therefore, intra-entity eliminations were not needed. 

C. Budgetary Resources and Status 

The CITC is funded through congressionally approved appropriations. The CFTC is responsible 

for administering the salaries and expenses of the agency through the execution of these 

appropriations. 

Congress annually enacts appropriations that provide the CITC with the authority to obligate 

funds within the respective fiscal year for necessary expenses to carry out mandated program 

activities. All appropriations are subject to quarterly apportionment as well as Congressional 

restrictions. 

The CITC's budgetary resources for FY 2015 consist of: 

• 	 Unobligated balances of resources brought forward from the prior year, 

• 	 Recoveries of obligations made in prior years, and 

• 	 New resources in the form of appropriations and spending authority from offsetting 

collections. 

Unobligated balances associated with resources expiring at the end of the fiscal year remain 

available for five years after expiration only for upward adjustments of prior year obligations, after 

which they are canceled and may not be used. All unused monies related to canceled 

93 	 C F T C 

Management's Financial Othe r Appendix 

Discussion & Sectio n Information 

Ana lysis 
FY 2015 Agency Financial Report 

appropriations are returned to Treasury and the canceled authority is reported on the Statements 

ofBudgetary Resources and the Statements of Changes in Net Position. 

D. Entity and Non-Entity Assets 

Assets consist of entity and non-entity assets. Entity assets are those assets that the CFTC has 

authority to use for its operations. Non-entity assets are those held by the CFTC that are not 

available for use in its operations. Non-entity assets held by the CFTC include deposit fund 

balances, custodial fines, interest, penalties, and administrative fees receivable. 

E. Fund Balance with Treasury 

Fund Balance with Treasury is the aggregate amount of the CFTC's funds with Treasmy in general, 

receipt, revolving, and deposit fund accounts. Appropriated funds recorded in general fund 

expenditure accounts are available to pay current liabilities and finance authorized purchases. 

Revolving fund custodial collections recorded in the deposit fund and miscellaneous receipts 

accounts of the Treasmy are not available for agency use. At fiscal year-end, receipt account 

balances are returned to Treasury or transferred to the Customer Protection Fund. 

The CFTC does not maintain bank accounts of its own, has no disbursing authority, and does not 

maintain cash held outside of Treasury. Treasmy disburses funds for the agency on demand. 

Spending authority from offsetting collections is recorded in the agency's expenditure account and 

is available for agency use subject to certain limitations. 

F. Investments 

The CFTC has the authority to invest amounts deposited in the Customer Protection Fund in shortterm market-based Treasmy securities. Market-based Treasury securities are debt securities that 

the U.S. Treasury issues to Federal entities without statutorily determined interest rates. Although 

the securities are not marketable, the terms (prices and interest rates) mirror the terms of 

marketable Treasmy securities. Investments are carried at their historical cost basis which 

approximates fair value due to their short-term nature. 

Interest earned on the investments is a component of the Fund and is available to be used for 

expenses of the Customer Protection Fund. Additional details regarding Customer Protection Fund 

investments are provided in Note 3. 

G. Accounts Receivable, Net 

Accounts receivable consists of amounts owed by other federal agencies and the public to the CFTC 

and is valued net of an allowance for uncollectible amounts. The allowance is based on past 

experience in the collection of receivables and analysis of the outstanding balances. Accounts 

receivable arise from reimbursable operations, earned refunds or the Civil Monetary Sanctions 

program. 

94 IC FTC 

Management's Fi nancial Other 

Information 

Appendix 

Discussion & Section 

Analysis 
FY 2015 Agency Financial Report 

H. Gen eral Property, Plant and Equipment, Net 

Furniture, fixtures, equipment, information technology hardware and software, and leasehold 

improvements are capitalized and depreciated or amortized over their useful lives. 

The CFTC capitalizes assets annually if they have useful lives of at least two years and an individual 

value of $25,000 or more. Bulk or aggregate purchases are capitalized when the individual useful 

lives are at least two years and the purchase is a value of $25,000 or more. Property, plant and 

equipment that do not meet the capitalization criteria are expensed when acquired. Depreciation 

for equipment and amortization for software is computed on a straight-line basis using a 5-year 

life. Leasehold improvements are amortized over the remaining life of the lease. The Commission's 

assets are valued net of accumulated depreciation or amortization. 

I. Deferred Cost s 

The Commission has received lease incentives, Tenant Improvement Allowances (TIA), from the 

landlords on its operating leases. These allowances can be used for construction, asset purchases, 

or rent expense, and are classified as deferred costs on the balance sheets. These costs are 

reallocated either to leasehold improvements, equipment, or if used for rent, expensed. The TIA is 

also amortized with the deferred lease liability over the life of the lease. 

J. Prepayments 

Payments to federal and non-federal sources in advance of the receipt of goods and services are 

recorded as prepayments and recognized as expenses when the related goods and services are 

received. Intragovernmental prepayments reported on the Balance Sheet were made primarily to 

the Department of Transportation (DOT) for transit subsidy and accounting services. 

Prepayments to the public were primarily for software maintenance and subscription services. 

I<. Liabilities 

The CFTC's liabilities consist of actual and estimated amounts that are likely to be paid as a result 

of transactions covered by budgetary resources for which Congress has appropriated funds or 

funding, or are otherwise available from reimbursable transactions to pay amounts due. 

Liabilities include those covered by budgetary resources in existing legislation and those not yet 

covered by budgetary resources. The CFTC liabilities not covered by budgetary resources include: 

• 	 Intragovernmental Federal Employees' Compensation Act (FECA) liabilities, 

• 	 Annual leave benefits that will be funded by annual appropriations as leave is taken, 

• 	 Actuarial FECA liabilities, 

• 	 Custodial liabilities for custodial revenue deemed collectible but not yet collected at fiscal 

year-end, 

• 	 Contingent liabilities, 

• 	 Deposit funds, 

95 CF TC 

Management's Financial Other Appendix 

Discussion & Section Information 

Analysis 
FY 2015 Agency Financial Report 

• Deferred lease liabilities, and 

• Advances received for reimbursable se1vices yet to be provided. 

L. Accounts Payable 

Accounts payable consists plimarily of contracts for goods or services, such as operating leases, 

leasehold improvements, software development, information technology, telecommunications, and 

consulting and suppo1t services. 

M. Accrued Payroll and Benefits and Annual Leave Liability 

The accrued payroll liability represents amounts for salaries and benefits owed for the time since 

the payroll was last paid through the end of the reporting period. The annual leave liability is the 

amount owed to employees for unused annual leave as of the end of the reporting period. At the 

end of each quarter, the balance in the accrued annual leave account is adjusted to reflect current 

balances and pay rates. Sick leave and other types of non-vested leave are expensed as taken. 

The agency's employees participate in the Civil Se1vice Retirement System (CSRS) or the Federal 

Employees' Retirement System (FERS). On Janua1y 1, 1987, FERS went into effect pursuant to 

Public Law 99-335. Most employees hired after December 31, 1983, are automatically covered by 

FERS and Social Seculity. Employees hired plior to January 1, 1984, could elect to either join 

FERS and Social Security or remain in CSRS. 

For employees under FERS, the CFTC contributes an amount equal to one percent of the 

employee's basic pay to the tax deferred Thrift Savings Plan and matches employee contributions 

up to an additional four percent of pay. FERS and CSRS employees can contribute a portion of 

their gross earnings to the plan up to Internal Revenue Service (IRS) limits; however, CSRS 

employees receive no matching agency contribution. 

N. Leases 

The CFTC does not have any capital lease liabilities. The operating leases consist of commercial 

property for the CFTC's headquarters and regional offices. Lease expenses are recognized on a 

straight-line basis. 

0 . Deposit Funds 

Deposit funds are expenditure accounts used to record monies that do not belong to the Federal 

government. They are held awaiting distribution based on a legal determination or investigation. 

The CFTC Deposit Fund is used to collect and later distribute collections of moneta1y awards to the 

appropriate victims as restitution. The cash collections recorded in this fund are offset by a Deposit 

Fund liability. Activities in this fund are not fiduciary in nature because they are not legally 

enforceable against the government. 

96 IC FTC 


Management's Financial Other Appendix 

Discussion ft Section Information 

Analysis 
FY 2015 Agency Financial Report 

P. Net Position 

Net position consists of unexpended appropriations and cumulative results of operations. 

Unexpended appropriations are appropriations that have not yet been used to acquire goods and 

services or provide benefits. Appropriations are considered expended, or used, when goods and 

services have been acquired by the CFTC or benefits have been provided using the appropriation 

authority, regardless of whether monies have been paid or payables for the goods, services, or 

benefits have been established. 

Cumulative results of operations represent the excess of budgetary or other financing sources over 

expenses since inception. Cumulative results of operations are derived from the net effect of 

capitalized assets, expenses, exchange revenue, and unfunded liabilities. 

0 . Revenues 

The CFTC receives reimbursement and earns revenue for the following activities: 

• 	 Reimbursement for travel, subsistence, and related expenses from non-federal sources for 

attendance at meetings or similar functions that an employee has been authorized to 

attend in an official capacity on behalf of the Commission. 

• 	 Reimbursement for Intergovernmental Personnel Act Mobility Program assignments from 

state and local governments, institutions of higher education, and other eligible 

organizations for basic pay, supplemental pay, fringe benefits, and travel and relocation 

expenses. 

• 	 Reimbursement from non-federal sources for registration fees to cover the cost of 

expenses related to the CFTC's annual International Regulators Conference. 

R. Net Cost of Operations 

Net cost of operations is the difference between the CFTC's expenses and its earned revenue. The 

presentation of program results by strategic goals is based on the CFTC's current Strategic Plan 

established pursuant to the Government Performance and Results Act of i993. The Commission 

implemented a new strategic plan in FY 2015 with different goals; as a result, the FY 2015 and FY 

2014 net costs by strategic goal are presented separately rather than comparatively. 

The rruss10n statement of the CFTC is to protect market users and the public from fraud, 

manipulation, and abusive practices related to the sale of commodity and financial futures and 

options, and to foster open, competitive, and financially sound futures and option markets. For FY 

2015, the mission was accomplished through the following four strategic goals, each focusing on a 

vital area of regulatory responsibility: 

• 	 Goal 1: Market Integritv and Transparency - The focus of Market Integrity and 

Transparency is to recognize that derivatives markets provide a means for market users to 

97 IC FTC 

Management's Financial Other Appendix 

Discussion & Section Information 

Analysis 
FY 2015 Agency Financial Report 

offset price risks inherent in their businesses and to serve as a public price discovery 

mechanism. 

• 	 Goal 2: Financial Integrity and Avoidance of Svstemic Risk - The focus of Financial 

Integrity and Avoidance of Systemic Risk is to strive to ensure that Commission-registered 

derivatives clearing organizations (DCOs), swap dealers (SDs), major swap participants 

(MSPs), and futures commission merchants (FCMs) have the financial resources, risk 

management systems and procedures, internal controls, customer protection systems, and 

other controls necessary to meet their obligations so as to minimize the risk that the 

financial difficulty of any of these registrants, or any of their customers has systemic 

implications. 

• 	 Goal 3: Comprehensive Enforcement - Through the goal of Comprehensive Enforcement, 

the CFfC enforces the CEA and Commission regulations, and works to promote awareness 

of and compliance with these laws. 

• 	 Goal 4: Domestic and International Cooperation and Coordination - Domestic and 

International Cooperation and Coordination focuses on how the Commission interacts 

with domestic and international regulatory authorities, market participants, and others 

affected by the Commission's regulatory policies and practices. 

To advance its mission goals and obj ectives, the CFTC will achieve Commission-wide excellence by 

empowering strong, enterprise-focused leaders, maintaining a high-performing and engaged 

workforce, and ensuring effective stewardship of resources. 

For FY 2014, the mission was accomplished through the follO'\·ving five strategic goals, similar to 

the above and each focusing on a vital area of regulatory responsibility: 

• 	 Goal 1: Market Integritv - Protect the public and market participants by ensuring market 

integrity; promoting transparency, competition, and fairness; and lowering risk in the 

system, 

• 	 Goal 2: Clearing Integrity - Protect the public and market participants by ensuring the 

financial integrity of derivatives transactions, mitigation of systemic risk, and the fitness 

and soundness of intermediaries and other regish·ants, 

• 	 Goal 3: Robust Enforcement - Protect the public and market participants through a robust 

enforcement program, 

• 	 Goal 4: Cross-Border Cooperation - Enhance integrity of US markets by engaging in crossborder cooperation, promoting strong international regulatory standards, and 

encouraging ongoing convergence of laws and regulation worldwide, and 

• 	 Goal s: Organizational and Management Excellence - Promote Commission excellence 

through executive direction and leadership, organizational and individual performance 

management, and effective management of resources. 

98 JC FTC 


Management's Financial Other Appendix 

Discussion ft Section Information 

Analysis 
FY 2015 Agency Financial Report 

S. Custodial Activity 

The CFTC collects penalties and fines levied against firms for violation of laws as described in the 

Commodity Exchange Acf as codified at 7 U.S.C. § 1, et seq., and the Commodity Futures 

Modernization Act of 2000, Appendix E of P.L. 106-554, 114 Stat. 2763. Unpaid fines, penalties 

and accrued interest are reported as custodial receivables, with an associated custodial liability. 

The receivables and the liability are reduced by amounts determined to be uncollectible. Revenues 

earned and the losses from bad debts are reported to Treasury. 

Collections made by the CFTC during the year are deposited and reported into designated Treasury 

miscellaneous receipt accounts for: 

• Registration and filing fees, 

• Fines, penalties and forfeitures, and 

• General proprietary receipts. 

At fiscal year-end, custodial collections made by the CFTC are either returned to Treasury or when 

determined eligible, transferred to the Customer Protection Fund. The CFTC does not retain any 

amount for custodial activities including reimbursement of the cost of collection. 

T. Use of Management Estimates 

The preparation of the accompanying financial statements in accordance with accounting 

principles generally accepted in the United States of America requires management to make 

certain estimates and assumptions that directly affect the results of reported assets, liabilities, 

revenues, expenses, and custodial activities. Actual results could differ from these estimates. 

U. Reconciliation of Net Obligations and Net Cost of Operations 

In accordance with OMB Circular A-136, the Commission reconciles its change in budgetary 

obligations with its net cost of operations. 

V. Funds from Dedicated Collections 

The Commission's Customer Protection Fund (CPF) was established to operate a whistleblower 

program and support customer education initiatives. See Note i.A. for a description of the purpose 

of the CPF and its authority to use revenues and other financing sources. Deposits into the CPF are 

credited from monetary sanctions collected by the Commission in a covered judicial or 

administrative action where the full judgment is in excess of $1,000,000 and the collection is not 

otherwise distributed to victims of a violation of the Dodd-Frank Act or the underlying rules and 

regulations, unless the balance of the CPF at the time the monetary judgment is collected exceeds 

$100 million. No new legislation was enacted as of September 30, 2015 that significantly changed 

the purpose of the fund or redirected a material portion of the accumulated balance. 

99 IC FTC 

M A 

Management's Financial Other Appendix 

Discussion & Section Information 

Analysis 
FY 201 5 Agency Financial Report 

Note 2. Fund Balance with Treasury 

A. Reconciliation to Treasury 

There are no differences between the fund balances reflected in the CITC Balance Sheets and the 

balances in the Treasury accounts. 

B. Fund Balance with Treasury 

Fund Balance with Treasury consists of entity assets such as appropriations, reimbursements for 

services rendered, and collections of fines and penalties. Obligation of these fu nds is controlled by 

quarterly apportionments made by OMB. Work pelformecl under reimbursable agreements is 

initially financed by the annual appropriation and is subsequently reimbursed. Collections offines 

and penalties are distributed to harmed investors, returned to Treasmy, or when eligible, 

transferred to the Customer Protection Fund. 

Fund Balance with Treasury at September 30, 2015 and 2014 consisted ofthe following: 

2015 2014 

Appropriated Funds $ 61,472,593 $ 42,487,412 

Customer Protection Fund 5,593,661 4,448,248 

Deposit Fund 179,806 134,683 

TOT AL FUND BALANCE WITH TREASURY $ 67,246,060 $ 47,070,343 

C. Status of Fund Balance with Treasury 


Status of Fund Balance with Treasury at September 30, 2015 and 2014 consisted ofthe following: 


Appropriated Funds 

Unobligated Fund Balance 

Available 

Unavailable 

Obligated Balance Not Yet Disbursed 

Total Appropriated Funds 

201 5 

937, 162 

4,535,734 

55,999,697 

61 ,472,593 

s 

2014 

1,000,971 

4,592,572 

36,893,869 

42,487,412 

Customer Protection Fund 

Unobligated Fund Balance 

Available 

Obligated Balance Not Yet Disbursed 

Total Customer Protection Fund 

Deposit Fund 

TOT AL FUND BALANCE WITH TREASURY 

s 1,302,454 

$ 67,246,060 

4,291,207 

5,593,661 

179,806 

s m ,356 

s 

3,670,892 

4,448,248 

134,683 

47,070,343 

100 IC FT C 

Management's Financial Other Appendix 

Discussion & Section Information 

Analysis 
FY 2015 Agency Financial Report 

Note 3. Investments 

The CFfC invests amounts deposited in the Customer Protection Funds in overnight short-term 

Treasury securities. Treasury overnight ce1t ificates of indebtedness are issued with a stated rate of 

interest to be applied to their par amount, mature on the business day immediately following their 

issue date, are redeemed at their par amount at maturity, and have interest payable at maturity. 

The overnight certificates are Treasury securities whose interest rates or prices are determined 

based on the interest rates or prices of Treasmy-related financial instruments issued or trading in 

the market, rather than on the interest rates or prices of outstanding marketable Treasury 

secmities. The Commission may invest in other short-term or long-term Treasury securities at 

management's discretion. 

The Commission's investments as of September 30, 2015 and 2014 were $263 million and $270 

million, respectively. Interest earned as of September 30, 2015 and 2014 was $58,152 and 

$35,630, respectively. 

lntragovernmentalInvestmentsin Treasury Securities 

The Federal Government does not set aside assets to pay future claims or other expenditures 

associated with funds from dedicated collections deposited into the Customer Protection Fund. 

The dedicated cash receipts collected by the Commission as a result of monetary sanctions are 

deposited in the U.S. Treasury, which uses the cash for general Government purposes. As 

discussed above and in Note iF, the Commission invests the majority of these funds in Treasury 

securities. These Treasury securities are an asset of the Commission and a liability of the U.S. 

Treasury. Because the Commission and the U.S. Treasmy are both components of the 

Government , these assets and liabilities offset each other from the standpoint of the Government 

as a whole. For this reason, the investments presented by the Commission do not represent an 

asset or a liability in the U.S. Government-wide financial statements. 

Treasury securities provide the Commission with auth01ity to draw upon the U.S. Treasury to pay 

future claims or other expenditures. When the Commission requires redemption of these securities 

to make expenditures, the Government finances those expenditures out of accumulated cash 

balances, by raising taxes or other receipts, by borrowing from the public or repaying less debt, or 

by curtailing other expenditures. This is the same manner in which the Government finances all 

expenditures. 

10 1 IC FT C 


Management's Financial Other Appendix 

Discussion & Section Information 

Analysis 
FY 2015 Agency Financial Report 

Note 4. Accounts Receivable, Net 

Accounts receivable consist of amounts owed the CFfC by other Federal agencies and the public. 

Accounts receivable are valued at their net collectible values. Non-custodial accounts receivable 

are primarily for overpayments of expenses to other agencies, or vendors, and repayment of 

employee benefits. Historical experience has indicated that most of the non-custodial receivables 

are collectible and that there are no material uncollectible amounts. 

Custodial receivables (non-entity assets) are those for which fines and penalties have been 

assessed and levied against businesses or individuals for violations of the CEA or Commission 

regulations. Violators may be subject to a variety of sanctions including fines, injunctive orders, 

bars or suspensions, rescissions of illegal contracts, and disgorgements. 

An allowance for uncollectible accounts has been established and included in accounts receivable 

on the balance sheets. The allowance is based on past experience in the collection of accounts 

receivable and analysis of outstanding balances. Historical experience has indicated that a high 

percentage of custodial receivables prove uncollectible. Accounts are re-estimated qua1terly based 

on account reviews and the agency determination that changes to the net realizable value are 

needed. 

Accounts receivable, net consisted of the following as of September 30, 2015 and 2014: 

2015 2014 

Custodial Receivables, Net 

Civil Monetary Penalty Interest s 1,037,104 s 1,270,142 

Civil Monetary Penalties, Fines, and Administrative Fees 1,452,575, 210 1,620,550,206 

Less: Allowance for Loss on Interest (1 ,037,065) (1,270, 115) 

Less: Allowance for Loss on Penalties, Fines, and Administrative Fees (1,449,320,093) (1 ,617,905,205) 

Registration and Filing Fees 1,441,020 1,573,760 

Net Custodial Receivables $ 4,696,176 $ 4,218,788 

Other Accounts Receivable 18,614 11,112 

TOT AL ACCOUNTS RECEIVABLE, NET $ 4,714,790 $ 4,229,900 

102 IC FTC 


Management's Financial Other Appendix 

Discussion f:t Section Information 

Analysis 
FY 2015 Agency Financial Report 

Note 5. General Property, Plant and Equipment 

Property, Plant and Equipment as of September 30, 2015 and 2014 consisted of the following: 

Accumulated 

2015 Major Class Service Life and Method Cost 

Amortization/ 

Depreciation Net Book Value 

Equipment 

I TSo~are 

SOO.Vare In Development 

Leasehold lmprovemenls 

5 Years/Straight Line 

5 Years/Straight Line 

Not Applicable 

Remaining Life of Lease/Straight Line 

s 40,993,436 

s 103,270,938 

29,074,565 

2,575,619 

30,627,318 

s (28,242,099) 

s (52,912,672) 

(15,159,696) 

(9,510,8n) 

s 12,751 ,337 

s 50,358,266 

13,914,869 

2,575,619 

21 ,116,441 

2014 Major Class Service Life and Method Cost 

Accum ulated 

Amortization/ 

Depreciation Net Book Value 

Equipment 

ITSo~are 

So~are In Development 

Leasehold lmprovemenls 

5 Years/Straight Line 

5Years/Straight Line 

Not Applicable 

Remaining Life of Lease/Straight Line 

s 38,559,381 

s 96,978,171 

24,456,684 

3,836,219 

30, 125,887 

s (24,380,358) 

s (42,51 3,622) 

(10,979,125) 

(7, 154,139) 

s 14,179,023 

s 54,464,549 

13,4n,559 

3,836,219 

22,971,748 

Depreciation and amortization expense for the years ended September 30, 2015 and 2014 totaled 

$12,679,373 and $14,167,999, respectively. 

103 IC FTC 


Management' s Financial Other Appendix 

Discussion ft Section Informat ion 

Analysis 
FY 2015 Agency Financial Report 

Note 6. Deferred Costs 

The Commission receives Tenant Improvement Allowances (TIA) from its landlords. These 

allowances are used to cover the costs of building renovations, asset purchases, or rent expenses. 

The TIA is initially recorded as deferred costs on the balance sheet and is amortized with the 

deferred lease liability over the life of the lease. 

The Commission received approximately $16.2 million in TIA between FY 2010 and 2012, of which 

approximately $14-4 million has been used to fund leasehold improvements, and $i.8 million has 

been used to cover rental payments through September 30, 2015. The remaining, unused balance 

of $28 thousand is reflected as deferred costs on the balance sheet. 

Deferred Costs {TIA) 2015 2014 

Beginning Balance, October 1 

11A Received 

11A Used 

BALANCE AS OF SEPT EMBER 30 $ 28,487 

64,201 

(35,714) 

s 220,953 

$ 64,201 

(156,752) 

Note 7. Liabilities Not Covered by Budgetary Resources 

As of September 30, 2015 and 2014, the following liabilities were not covered by budgetary 

resources: 

2015 2014 

lntra;iovemmental-FECA Liabilities s 82,531 $ 88,975 

lntra;iovemmental-Cusbdial Liabilities 4,696, 176 4,218,788 

Annual Leave 9,788,839 9,500,172 

Actuarial FECA Liabilities 415,570 460,759 

Contingent Liabilities 300,CXXJ 85,CXXJ 

OefXlSrt Fund Liabilities 179,806 134,683 

Deferred Lease Liabilities 25,673,457 25,961,973 

Other 22,397 11,699 

TOTAL LIABILITIES NOT COVERED BY BUDGETARY RESOURCES $ 41 ,1ss,ns $ 40,552,049 

Liabilities not covered by budgetary resources of $41.16 million and $40.55 million represented 

74.9 and 82 percent ofthe Commission's total liabilities of $54.98 million and $49-45 million as of 

September 30, 2015 and 2014, respectively. 

In connection with the preparation of the current year financial statements, the misclassification of 

custodial liabilities was identified as an immaterial error in the FY 2014 Balance Sheet. The FY 

2014 custodial liabilities is correctly presented as an intragovernmental liability on the Balance 

Sheet presented herein. 

104 1CF TC 


Management's Financial Othe r Appe ndix 

Discussion & Section Information 

Analysis 
FY 2015 Agency Financial Report 

Note 8. Retirement Plans and Other Employee Benefits 

The CFTC imputes costs and the related financing sources for its share of retirement benefits 

accruing to its past and present employees that are in excess of the amount of contributions from 

the CFTC and its employees, which are mandated by law. The Office of Personnel Management 

(OPM), which administers federal civilian retirement programs, provides t he cost information to 

t he CFTC. The CFTC recognizes t he full cost of providing future pension and Other Retirement 

Benefits (ORB) for current employees as required by Statement of Federal Financial Accounting 

Standards (SFFAS) 5, Accounting for Liabilities ofthe Federal Government. 

Full costs include pension and ORB conttibutions paid out of the CFTC's appropriations and costs 

financed by OPM. The amount financed by OPM is recognized as an imputed financing source. 

This amount was $6,667,s23 for the year ended September 30, 2015 and $6,773,161 for the year 

ended September 30, 2014. Reporting amounts such as plan assets, accumulated plan benefits, or 

unfunded liabilities, if any, is the responsibility of OPM. 

Liabilities for future pension payments and other future payments for retired employees who 

participate in the Federal Employees Health Benefits Program and the Federal Employees Group 

Life Insurance Program are report ed by OPM rather than CFTC. 

Note 9. FECA Liabilities 

FECA provides income and medical cost protections to covered federal civilian employees injured 

on the job, to employees who have incurred work-related occupational diseases and to 

beneficiaries of employees whose deaths are attributable to job-related injmi es or occupational 

diseases. The FECA program is administered by the U.S. Department of Labor (DOL), which pays 

valid claims against the CFTC and subsequently seeks reimbursement from the CFTC for these 

paid claims. Accrued FECA liabilities represent amounts due to DOL for claims paid on behalf of 

the agency. Accrued FECA liabilities at September 30, 2015 and 2014 were $82,531 and $88,975, 

respectively. 

In addition, the Commission's actuarial FECA liability represents the liability for future workers 

compensation benefits, which includes the expected liability for death, disability, medical, and 

miscellaneous cost for approved cases. The Commission records an estimate for the FECA 

actuarial liability using the DOL's FECA model. The model considers the average amount of 

benefit payments incurred by the Commission for the past three fiscal years, multiplied by the 

medical and compensation liability to benefits paid ratio for the whole FECA program. Actuarial 

FECA liabilities at September 30, 2015 and 2014 were $415,570 and $460,759, respectively. 

105 IC FTC 


Management's Financial Other Appendix 

Discussion & Section Information 

Analysis 
FY 2015 Agency Financial Report 

Note 10. Leases 

The CFTC has operating leases in privately-owned buildings for its locations in Washington D.C., 

Chicago, New York, and Kansas City. The CFTC has no real property. Future estimated minimum 

lease payments are not accrued as liabilities and are expensed on a straight-line basis. 

As of September 30, 2015, future estimated minimum lease payments continue through FY 2025 

and are as follows: 

Fiscal Year Dollars 

2016 19,017,114 

2017 19,411 ,711 

2018 19,772,333 

2019 20, 133,393 

2020 20,507,089 

Thereafter 95,363,201 

Tota Future Minimum Lease Pay ments $ 194,204,841 

CFTC recognizes leases expenses on a straight-line basis because the Commission's lease payment 

amounts vary at negotiated times and reflect increases in rental costs, and in some cases, 

allowances or credits from landlords. Consistent with the utility of its office space, the Commission 

records deferred lease liabilities representing expense amounts in excess of payments to date. The 

deferred lease liabilities at September 30, 2015 and September 30, 2014 were $25,673,457 and 

$25,961,973 respectively. 

CFTC's historical practice has been to obligate only the annual portion of lease payments due each 

year. On August 6, 2015, the Government Accountability Office (GAO) requested information on 

the Commission's views regarding various legal issues involving the CFTC's leases, including the 

practice of recording obligations arising under the agency's current leases for office space in 

Washington, D.C., Chicago, New York, and Kansas City. As a result of the CFTC's review, the 

Commission concluded that its historical practice for recording lease obligations may be 

inconsistent with OMB Circular A-11, Preparation, Submission and Execution of the Budget; 31 

U.S.C. § 1501(a)(1) (the recording statute); and previous GAO decisions. The GAO is currently 

reviewing the matter and the agency expects an opinion to be issued in FY 2016. 

As a result of the potential findings of the anticipated GAO opinion, it is reasonably possible that 

an unfunded obligation totaling approximately $194 million and $212 million as of September 30, 

2015 and 2014 respectively, covering all potential future payments agreed to under current leases, 

will need to be recognized. 

106 IC FTC 


Manageme nt's Fina ncial Other Appe ndix 

Discussion & Section Information 

Ana lysis 
FY 2015 Agency Financial Report 

The following table describes the Commission's existing lease arrangements for buildings and 

furniture, including major asset categories by location and associated lease terms. 

BUILDINGS 

Location Lease Terms 

Washington, D.C. 

New York 

Kansas City 

Chicago 

Lease of office space from October 5, 1995, through September 30, 2025, subject to annual 

escalation amounts2 1 and including allowances for leasehold improvements and rent offsets. 

Lease of office space from November 16, 2001, through April 30, 2022, with no escalation 

clauses or option to renew. 

Lease of office space from April 1, 2011, through April 14, 2021, including allowances for 

leasehold improvements and rent offsets. 

Lease of office space from March 10, 2002, through June 30, 2022, including propo1t ionate 

share of operation expenses and taxes for premises and allowances for leasehold 

improvements and rent offsets. 

FURNITURE 

Location Lease Terms 

Washington, D.C. 

New York 

Six-month to one-year rentals of various office furniture, including desks, credenzas, chairs, 

bookcases, and lateral files, with lease terms ranging from August 10, 2014, through August 

9, 2015, to July 30, 2015, through January 2, 2016. 

One-year rentals of various office furniture, including desks, credenzas, chairs, and lateral 

files, with lease terms ranging from October 23, 2014, through October 22, 2015, to August 

21, 2015, through August 20, 2016. 

Note 11. Contingent Liabilities 

The CFTC records contingent liabilities for legal cases m which payment has been deemed 

probable and for which the amount of potential liability has been estimated, including judgments 

that have been issued against the agency and which have been appealed . In FY 2015, the 

Commission was involved in two cases where an unfavorable outcome is reasonably possible but 

the potential loss is not reasonably estimable. 

In addition, on September 29, 2015, t he Commission announced that it expects to make an award 

of approximately $300,000 to a whistleblower for providing valuable information about violations 

of the Commodity Exchange Act (CEA). While the order granting the award can be appealed until 

October 29, 2015, the Commission has recorded a liability because it has been deemed probable 

that the award will be paid. 

12 If market rent were $ 100 per square foot with a JO percent annual esca lation and a $10 operating expense base, then 98 

percent of the applicable market rent would be $98 per square foot wiU1 a 10 percent escalation and a $ JO operating base. 

107 IC FTC 

Management's Financial Ot her Appendix 

Discussion ft Sect ion Information 

Analysis 
FY 20 15 Agency Financial Report 

Note 12. Undelivered Orders 

The amount of budgetary resources obligated for undelivered orders as of September 30, 2015 and 

2014 consisted ofthe following: 

2015 2014 


UNDELIVERED ORDERS 48,941,200 $ 33,377,094 


The amount of undelivered orders represents the value of unpaid and paid obligations recorded 

during the fiscal year, and upward and downward adjustments of obligations that were originally 

recorded in a prior fiscal year. 

Note 13. Apportionment Categories of Obligations Incurred 

Category A funds are those amounts that are subject to quarterly apportionment by OMB, meaning 

that a portion of the annual appropriation is not available to the agency until apportioned for a 

particular quarter. Category B funds represent budgeta1y resources distributed by a specified time 

period, activity, project, object, or a combination of these categories. The Commission's Catego1y B 

funds represent amounts apportioned at the beginning of the fiscal year for the Commission's 

Customer Protection Fund. For the fiscal years ended September 30, 2015 and 2014, the 

Commission incurred obligations against Category A and Category B funds as follows: 

201 5 2014 

Direct 0 bligations 

Category A 

Category B - Customer Protection Fund 

Reimbursable Obligations (Category A) 

TOTAL OBLIGATIONS INCURRED S 258,702,003 

252,012,036 

6,622,259 

67,708 

$ 216,293,906 

5,042,582 

13,787 

s 221,350,275 

108 IC F T C 

Management's Financial Other Appendix 

Discussion ft Sect ion Information 

Analysis 
FY 2015 Agency Financial Report 

Note 14. Unobligated Balances 

In connection with the preparation of the current year financial statements, the Commission 

identified an immaterial error in the FY 2014 Statement of Budgetary Resources. The Unobligated 

Apportioned line item was overstated by $ 16 .2 million and the Unobligated Unapportioned line 

item was understated by $ 16.2 million. This error has no net impact to the Total Unobligated 

Balance line item. The balances of Unobligated Apportioned and Unobligated Unapportioned have 

been corrected in the FY 2 014 Statement of Budgetary Resources presented herein. 

On the FY 2 015 Statement of Budgetary Resources, the balance in Unapportioned is negative due 

to a deficiency in the 2 0 13 annual salaries and expenses fund as the result of a transfer from its 

multi-year information technology fund that was subsequently reversed. 

Note 15. Explanations of Differences between the Statement of 

Budgetary Resources and Budget of the United States Government 

The CITC had two offsetting material differences between the amounts reported in the Statement 

of Budgetary Resources and the actual amounts reported in the Budget of the U.S. Government for 

FY 2014 for the Customer Protection Fund due to a S176 .1 million recovery from the U.S. 

Department of the Treasury. This amount was paid from FY 2 0 12 collections but recognized as an 

offsetting collection in the Statement of Budgetary Resources in FY 2 014 and will not be a 

difference in FY 2015 and going forward. 

Unobligated Balance 

Brought F01Ward Spending Authorily from 

Offsetting Collections 

Total 

FY 2014 

CPF Statement ofBudgetary Resources 

FY 2014 Recovery from Treasury 

Budget of the U.S. Government 

s 98,986,699 

$ 275,096,699 

176, 110,000 

s 176, 110, 000 

s 

(176, 110,000) 

s 275,096,699 

s 275,096,699 

The Budget of the U.S. Government with actual numbers for FY 2 0 15 has not yet been published. 

The expected publish date is February 2016 . A copy of the Budget can be obtained from OMB's 

website. 

109 I C F TC 


Management's Financia l Other Appendi x 

Discussion ft Section Information 

Analysis 
FY 2015 Agency Financial Report 

Note 16. Intra-governmental Cost and Exchange Revenue by Goal 

As required by the Government Performance and Results Act of 1993, the agency's reporting has 

been aligned with the major goals presented in CFTC's Strategic Plan as reported in Note 1R. The 

Net Cost of Operations is derived from transactions between the Commission and public entities, 

as well as with other federal agencies. The details of the intragovernmental costs and revenues, as 

well as those with the public, are as follows: 

2015 

Goal 1: Market Integrity and Transparency 

lntragovernmental Gross Costs 

Less: Earned Revenue 

lntragovernmental Net Cost of Operations 

Gross Costs With the Public 

Less: Earned Revenue 

Net Cost of Operation With the Public 

Total Net Cost of Operations-Goal One 

Goal 2: Financial Integrity and Avoidance of Systemic Risk 

lntragovernmental Gross Costs 

Less: Earned Revenue 

lntragovernmental Net Costs of Operations 

Gross Costs With the Public 

Less: Earned Revenue 

Net Cost of Operations With the Public 

Total Net Cost of Operations-Goal Two 

Goal 3: Comprehensive Enforcement 

lntragovernmental Gross Costs 

Less: Earned Revenue 

lntragovernmental Net Cost of Operations 

Gross Costs With the Public 

Less: Earned Revenue 

Net Cost of Operation With the Public 

Total Net Cost of Operations-Goal Three 

$ 10,446,726 

s 10,446,726 

$ 57,890,292 

$ 57,875,776 

s 68,322,502 

(14,516) 

$ 11,302,327 

s 11,302,327 

$ 62,631,580 

s 62,615,876 

$ 73,918,203 

(15,704) 

$ 14,602,499 

s 14,602,499 

s 80,919,410 

s 80,899,119 

s 95,501,618 

(20,291) 

(Continued) 

llOICFTC 

Management's Financial Other Appendix 

Discussion & Section Information 

Ana lysis 
FY 2015 Agency Financial Report 

2015 (Continued) 

Goal 4: Domestic and International Cooperation and Coordination 

lntragovernmental Gross Costs 

Less: Earned Revenue 

lntragovernmental Net Cost of Operations 

Gross Costs With the Public 

Less: Earned Revenue 

Net Cost of Operations With the Public 

Total Net Cost of Operations-Goal Four 

Grand Total 

lntragovernmental Gross Costs 

Less: Earned Revenue 

lntragovernmental Net Cost of Operations 

Gross Costs With the Public 

Less: Earned Revenue 

Net Cost of Operations With the Public 

NET COST OF OPERATIONS 

s 1,844,888 

s 1,844,888 

$ 10,223,404 

(2,563) 

s 10,220,841 

s 12,065,729 

s 38,196,440 

s 38,196,440 

21 1,664,686 

(53,074) 

s 211,611 ,612 

$ 249,808,052 

2014 

Goal 1: Market Integrity 

lntragovernmental Gross Costs 

Less: Earned Revenue 

lntragovernmental Net Cost of Operations 

Gross Costs With the Public 

Less: Earned Revenue 

Net Cost of Operation With the Public 

Total Net Cost of Operations-Goal One 

Goal 2: Clearing Integrity 

lntragovernmental Gross Costs 

Less: Earned Revenue 

lntragovernmental Net Costs of Operations 

Gross Costs With the Public 

Less: Earned Revenue 

Net Cost of Operations With the Public 

Total Net Cost of Operations-Goal Two 

$ 8,991,682 

s 8,991,682 

$ 47,762,770 

(8,189) 

$ 47,754,581 

$ 56,746,263 

s 8,233,762 

$ 8,233,762 

s 43,736,790 

(7,498) 

$ 43,729,292 

s 51 ,963,054 

(Continued) 

lll lC FT C 

Management's Financial Othe r Appendix 

Discussion & Section Information 

Analysis 
FY 2015 Agency Financial Report 

2014 (Continued) 

Goal 3: Robust Enforcement 

lntragovernmental Gross Costs 

Less: Earned Revenue 

lntragovernmental Net Cost of Operations 

Gross Costs Wilh lhe Public 

Less: Earned Revenue 

Net Cost of Operation With the Public 

Total Net Cost of Operations-Goal Three 

Goal 4: Cross-Border Cooperation 

lntragovernmental Gross Costs 

Less: Earned Revenue 

lntragovernmental Net Cost of Operations 

Gross Costs Wilh lhe Public 

Less: Earned Revenue 

Net Cost of Operations With the Public 

Total Net Cost of Operations-Goal Four 

Goal 5: Organizational and Management Excellence 

lntragovernmental Gross Costs 

Less: Earned Revenue 

lntragovernmental Net Cost of Operations 

Gross Costs Wilh lhe Public 

Less: Earned Revenue 

Net Cost of Operations With the Public 

Total Net Cost of Operations-Goal Five 

Grand Total 

lntragovernmental Gross Costs 

Less: Earned Revenue 

lntragovernmental Net Cost of Operations 

Gross Costs Wilh lhe Public 

Less: Earned Revenue 

Net Cost of Operations With the Public 

NET COST OF OPERATIONS 

$ 11,334,342 

$ 11,334,342 

$ 60,206,711 

(10,323) 

$ 60, 196,388 

$ 71,530,730 

$ 1,860,348 

$ 1,860,348 

$ 9,881 ,952 

(1,694) 

$ 9,880,258 

$ 11,740,606 

$ 4,030,754 

$ 4,030,754 

21,410,897 

(3,671) 

$ 21,407,226 

$ 25,437,980 

$ 34,450,888 

$ 34,450,888 

182,	999, 120 

(31,375) 

$ 182,967,745 

$ 217,418,633 

112I C F T C 


Management's Financial Other Appe ndix 

Discussion & Section Information 

Analysis 
FY 2015 Agency Financial Report 

Note 17. Reconciliation of Net Obligations and Net Cost of Operations 

The schedule presented in this footnote reconciles the net obligations with the Net Cost of 

Operations. Resources Used to Finance Activities reflects the budgetary resources obligated and 

other resources used to finance the activities of the agency. Resources Used to Finance Items Not 

Part of the Net Cost of Operations adjusts total resources used to finance the activities of the entity 

to account for items that were included in net obligations and other resources but were not part of 

the Net Cost of Operations. Components Requiring or Generating Resources in Future Periods 

identifies items that are recognized as a component of the net cost of operations for the period but 

the budgetary resources (and related obligation) will not be provided (or incurred) until a 

subsequent period. Components Not Requiring or Generating Resources includes items 

recognized as part of the net cost of operations for the period but will not generate or require the 

use of resources. The Net Cost of Operations in the schedule presented in this note agrees with the 

Net Cost of Operations as reported on the Statements of Net Cost. 

RESOURCES USED TO FINANCEACTIVITIES 

Budgetary Resources Obligated 

Ot:iigations Incurred 

Less: S~ing AuthOOty frcm Offsetting Cd~tions and Recoveries 

Obligations Net of Offsetting Collections and Recoveries 

Less: 0!5etting Rocei!XS 

Net Ot:iigatioos AM- Ol!setting Rocei!XS 

Other Resources : 

Trcnsffi In mn Oisg:xgements, Fines, and Penafies 

Imp.red Finalcing Fran Costs Abslvbed b-/ Olhers 

Total Resources Used to Finance Activities 

RESOURCES USED TO FINANCE ITEMS NOT PART OF THE NET COST OF OPERATIONS 

Change in B~Resoorces Olligaled tr Gocds, Swices and Benefits Ordere:l ootnot yet Provide:! tme Adjuslments 

Resrurces that Furd ~es ze:l in Prior PericxJs 

Offiletting Recei!XS 

Nooexchalge Interest Revenue 

Resrurces that Furd fle AcquisiliCX'I ci Fixe:l Asse:s 

Total Resources Used to Finance Items Not Part of the Net Cost of Operations 

COMPONENTS OF NET COST OF OPERATIONS THAT WILL REQUIRE OR GENERATE RESOURCES IN FUTURE 

PERIODS 

Increase in Unfurde:l Liabilities 

Total Components of Net Cost of Operations that will Require or Generate Resources in Future Periods 

COMPONENTS NOT REQUIRING OR GENERATING RESOURCES 

r:Jeira:ialiCX'I and Amo1iza1ion 

(Gan)/l.oss oo Disposal 

Oillef 

Total Components of Net Cost of Operations that will Not Require or Generate Resources 

Total Components of Net Cost of Operations that will Not Require or Generate Resources in the Current Year 

Net Cost of Operations 

2015 

$ 258,702,003 $ 221,35'.l,275 

(4.~ ffiS} 

254,405,338 $ 42,984,910 

(6,767) 

s 254,300,571 s 42,945,475 

s s 176, 110,fil4 

6,667,523 

113 I CFTC 

2014 

(178,365,365) 

261,066,094 

$ (15,537, 141) 

(51,633) 

6,767 

58,152 

(9,489,542) 

(25,013,397) 

s 413,667 

s 413,667 

s 12,679,373 $ 14, 167,999 

663,649 

(1,334) 

s 13,341,688 

s 13,755,355 

249,808,052 

(39,435) 

6,773, 161 

s 225,829,240 

$ (14,032,326) 

(46,620) 

39,435 

35,Sll 

(10,569,054) 

(24,572,935) 

$ 1,647,757 

_

-

s ___

----'--'--­

--'1._64...;. 1,1_57_ 

1,065,291 

(718,719) 

14,514,571 

16,162,328 

217,418,633 

Management's Financial Other Appendix 

Discussion & Section Information 

Analysis 
FY 2015 Agency Financial Report 

Note 18 . Funds from Dedicated Collections 

Funds from dedicated collections arise from disgorgement and penalty collections and are 

transferred to the Customer Protection Fund (CPF), established by the Dodd-Frank Act. The 

collections are transferred from the custodial receipt account if they are found to be eligible before 

the end of each fiscal year. In cases where the collection has been returned to the Treasury 

Depaitment, the Commission can recover the funds directly from Treasury. The collections will 

fund the Commission's whistleblower awards program and customer education initiatives. 

The Dodd-Frank Act provides that whistleblower awards shall be paid under regulations 

prescribed by the Commission. An important prerequisite to implementation of the whistleblower 

awards program is the issuance of rules and regulations describing its scope and procedures. The 

Commission issued final rules implementing the Act on August 25, 2011. These rules became 

effective on October 2 4 , 2011. The Commission established the Whistleblower Office in FY 2012. 

Eligible collections of S176.1 million were transferred into the Customer Protection Fund as of 

September 30, 2014. No eligible collections were transferred during FY 2015 because the fund 

reached its legislative maximum dming FY 2014. The following chart presents the Fund's balance 

sheets, statements of net costs, and statements of changes in net position as of and for the years 

ended September 30, 2015 and 2014: 

Balance Sheets 2015 2014 

Fund Balance with Treasury 

Investments 

General Property, Plant and Equipment Net 

Total Assets 

Accounts Payable 

Accrued Payroll 

Contingent Liabilities 

Other 

Total Liabilties 

Cumulative Results of Operations - Funds 1i'om Dedicated Collections 

Total Net Position 

£ 5,593,661 

s 268,809,520 

s 1, 197,110 

s 267,612,410 

263,000,000 

215,859 

835,464 

55,478 

300,000 

6,168 

267,612,410 

£ 4,448,248 

s 274,448,248 

s 132,936 

s 274,315,312 

270,000,000 

109,470 

23,466 

274,315,312 

Total Liabilities and Net Position $ 268,809,520 $ 274,448,248 

11 4 CF TC 


Management's Financial Other Appendix 

Discussion & Section Information 

Ana lysis 
FY 2015 Agency Financial Report 

Statements of Net Cost 

Gross Costs 

Total Net Cost of Operations 

$ 6,761,054 

$ 6,761 ,054 

2015 

$ 1,735,213 

$ 1,735,213 

2014 

Statements of Changes in Net Position 

Beginning Cumulative Results ofOperations, October 1 $ 274,315,312 $ 99,904,291 

Nonex change Interest Revenue 

Transfers-In Without Reimbursement 

Net Cost of Operations 

Net Change 

Total Net Position, September 30 $ 267,612,410 

58,152 

(6,761, 054) 

(6,702,902) 

$ 274,315,312 

35,630 

176,1 10,604 

(1,735,213) 

174,411,021 

115 ICFTC 


Management 's Financial Other Appendix 

Discussion ft Section Information 

Analysis 
FY 2015 Agency Financia l Report 

Required Supplementary Information (Unaudited} 

Commodity Futures Trading Commission 

COMBINING STATEMENTS OF BUDGETARY RESOURCES BY MAJOR ACCOUNT 

For the Years Ended September 30, 2015 and 2014 

2015 

Customer 

Protection Fund 

Salaries and 

Expense 

Information 

Technology 

BUDGETARY RESOURCES 

Unobligated BalanceBrought Fcxward, October 1 

Adjustment b Unobligated Balance Brought FOfWard, October 1 


Unobligated Balance BroughtFcxward, October 1, as Adjusted 


Recoveries of Prior Year Unpaid Obligations 


0 lher Chaiges in Unobligated Balance 


Unobligated Balance from Prior Year Budget Aulhooty , Net 


Appropriations 


Spending Aulhooty from Offsetting Collections 


Total Budgetary Resources 

STATUS OF BUDGETARY RESOURCES 

Obligations Incurred (Nole 13) 

Unobligated Balance, End of Period 

Apportioned 

Unapportioned 

TolaJ Unobligated Balance, End of Period 

Total Budgetary Resources 

CHANGE IN OBLIGATED BALANCE 

Unpaid Obligations: 


Unpcid Obligations, Brought Forwa-d, October 1 


Obligations Incurred 


Outtays (Gross) 


Recoveries of Prior-Year Unpaid Obligations 


Unpaid Obligations, End of Period 


Uncollected Payments: 


Uncollected Payments, Federal Sources, Brought Forward. October 1 


CharY,Je in Uncollected Payments, Federal Sources 


Uncollected Payments, Federal Sources, End of Period 


Memorandum Entries: 


Obligated Balance, Slart of Period 


Obligated Balance, End of Period 

BUDGET AUTHORITY AND OUTLAYS, NET 

Budget Aulhooty, Gross 

Aclual Offsetting Collections 

CharY,Je in Uncollected Customer Payments from Federal Sources 

Budget Aulhooty, Net 

Outtays, Gross 

Aclual Offsetting Collections 

Outtays, Net 

Distributed Offsetting Receipts 

Agency Outtays, Net 

(Continued) 

116 ICF TC 

Combined 

269,001,355 s 265,726 s 5,382,040 s 275,549,121 

829, 170 829, 170 

270,730,525 265,726 5,382,040 276,378,291 

89,205 3,128,287 844, 183 4,061,675 

(2, 167, 775) (2,167,775) 

270,819,730 1,226,238 6,226,223 278,272, 191 

200,000'000 50,000,000 250,000,000 

53,908 169,223 7,615 230,746 

s 270,873,638 $ 201,395,461 $ 56,233,838 $ 528,502,937 

s 6,622,259 s 201,458,614 s 50,621,130 s 258,702,003 

264,251 ,379 560,577 5,547,952 270,359,908 

(623,730) 64,756 (558,974) 

264,251 ,379 (63, 153) 5,612,708 269,800,934 

$ 270,873,638 s 201,395,461 $ 56,233,838 $ 528,502,937 

s 3,670,892 s 25,243,753 s 11,650,117 40,564,762 

6,622,259 201,458,614 50,621 ,130 258,702,003 

(5,912,739) (188,808,978) (40, 192,470) (234,914,187) 

(89,205) (3,128,287) (844,183) (4,061,675) 

4,291,207 34,765,102 21,234,594 60,200,903 

(54,225) (54,225) 

(22,435) (22,435) 

(76,660) (76,660) 

$ 3,670,892 $ 25,189,528 $ 11,650,117 s 40,510,537 

$ 4,291,207 $ 34,688,442 $ 21,234,594 $ 60,214,243 

$ 53,908 s 200, 169,223 s 50,007,615 s 250,230,746 

(58,152) (146,787) (7,615) (212,554) 

(22,435) (22,435) 

$ (4,244) $ 200,000,001 $ 50,000,000 s 249,995,757 

s 5,912,739 s 188,808,978 s 40,192,470 234,914,187 

(58,152) (146,787) (7,615) (212,554) 

5,854,587 188,662,191 40, 184,855 234,701 ,633 

(6,767) (6,767) 

s 5,854,587 $ 188,655,424 $ 40,184,855 $ 234,694,866 

Management's Financial Other Appendix 

Discussion ft Section Information 

Ana lysis 
FY 2015 Agency Financial Report 

Commodity Futures Trading Commission 

COMBINING STATEMENTS OF BUDGETARY RESOURCES BY MAJOR ACCOUNT 

(Continued) 

For the Years Ended September 30, 20 15 and 20 14 

2014 

Customer 

Protection Fund

Salaries and 

Expense 

Information 

Technology 

BUDGETARY RESOURCES 

Unobligated Baaice Brcoght Forwa-d, October 1 

Rec(]Jeies of Prior Yea Unpcid Obligatioos 

Olher Changes in Unobligated Baance 

Unobligated Baance ran PriorYea-BudgetAumty, Net 

Apprqxialioos 

Spendif'9 Aumty ran Ofuellif'9 Cdlectioos 

Total Budgetary Resources 

STATUS OF BUDGETARY RESOURCES 

Obligafioos Incurred (Note 13) 

Unobligated Baance, End of Peiod 


Appcricoed 


unappcricoed 


Tolal Unobligated Baaice, End of Period 

Total Budgetary Resources 

CHANGE IN OBLIGATED BALANCE 

Unpaid Otligatioos: 


Unpaid Obligalioos, Brcoght Faward, Octdler 1 


Obligatioos Incurred 


Ou1ays (Gross) 


Reco.ieies of Pricr-Yea Unpaid Obligatirns 


Unpaid Obligafims, End of Period 


Uncdlected Payme1ts: 


Uncdlected Paymaits, Federa Swces, Brcoght Fawa-d, October 1 


Change in Uncdlected Payments, Federa Srurces 


Uncdlected Payments, Federa Swces, End of Period 


Memoraidum Enlries: 


Otligated Baaice, Stat ofPeriod 


Obligated Baance, End of Period 

BUDGET AUTHORITY AND OUTLAYS, NET 

Budget Aumty' Gross 

Actua Ofuetlif'9 Cdlectioos 

Change in Uncdlected Custaner Payme1ts Iran Federa Sources 

Budget Aumty, Net 

Outlays, Gross 

Aclual Ofuetlif'9 Cdlectirns 

Outlays, Net 

Distribuled Ofuellif'9 Receipts 

Agency Outlays, Net 

s 98,986,699 

24,004 

99,010,703 

175,933,234 

$ 274,943,937 

s 5,042,582 

11,00J,257 

258,901,098 

269,901,355 

$ 274,943,937 

s 333,533 

5,042,582 

(1,681 ,219) 

(24,004) 

3,670,892 

s 333,533 

s 3,670,892 

s 175,933,234 

(176,146,234) 

(213,000) 

s 1,681,219 

(176,146,234) 

(1 74,465,015) 

(174,465,015) 

s 5,131,169 s 850,618 s 104,968,486 

318,6% 1,547,706 

(6,344,455) 5,123,00J 

(894,590) 7,521,324 

180,00J,OOJ 35,00J,OOJ 

226,855 101,870 

s 179,332,265 $ 42,623,194 $ 496,899,396 

s 179,066,539 s 37,241,154 s 221,350,275 

2,178,264 259,040 

(1,912,538) 5,123,00J 

265,726 5,382,040 

$ 179,332,265 $ 42,623,194 $ 496,899,396 

s 8, 153,060 s 17,311,812 s 25,798,405 

179,066,539 37,241, 154 

(161,657,150) (41,355,143) 

(318,696) (1,547,706) 

25,243,753 11,650,117 

(45,921) 

(8,304) 

(54,225) 

$ 8,107,139 $ 17,311,812 s 25,752,484 

s 25,189,528 $ 11,650,117 s 40,510,537 

s 180,226,855 s 35,101,870 s 391 ,261,959 

(218,551) (101,870) 

(8,304) 

s 180,000,000 $ 35,000,000 $ 214,787,000 

$ 161,657,150 s 41 ,355,143 

(218,551) (101,870) 

161,438,599 41 ,253,273 

(39,435) 

$ 161,399,164 $ 41 ,253,273 $ 28,187,422 

Combined 

1,890,406 

(1 ,221,455) 

105,637,437 

215,00J,OOJ 

176,261,959 

13,437,561 

262, 111,560 

275,549,121 

221 ,350,275 

(204,693,512) 

(1,890,406) 

40,564,762 

(45,921) 

(8,304) 

(54,225) 

(176,466,655) 

(8,304) 

204,693,512 

(176,466,655) 

28,226,857 

(39,435) 

11 7 I C FT C 


Management's Financial Other Appendix 

Discussion & Section Information 

Analysis