Office of the Inspector General

U.S. Commodity Futures Trading Commission

Review of the CFTC Travel Card Program
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U.S. COMMODITY FUTURES TRADING COMMISSION

OFFICE OF INSPECTOR GENERAL 

Three Lafayette Centre 

1155 21st Street, NW, Washington, DC 20581 

Telephone: (202) 418-5110 

TO: Anthony C. Thompson, Executive Director

Mary Jean Buhler, Chief Financial Officer

FROM: Miguel A. Castillo, CPA, CRMA

Assistant Inspector General for Auditing 

 

DATE: September 19, 2016

SUBJECT: Review of the CFTC Travel Card Program (16-REV-03)

Introduction

The Office of the Inspector General (OIG) reviewed the use of CFTC travel card holders’ 

US Bank transactions from June 1, 2015 to June 31, 2016. Our review assessed whether 

the Commodity Futures Trading Commission (CFTC) complied with its travel card 

policy. 

Travel Regulations and Policy

 

Federal travel regulations1 require employees to use their travel cards for all travelrelated expenses while on official travel unless exempted.2 CFTC policy also requires 

employees to use their government-issued travel cards3 for payment of expenses related 

to their official travel. Official travel is defined as “[t]ravel under an official travel 

authorization from an employee’s official station or other authorized point of departure 

to a temporary duty location and return from a temporary duty location, between two 

temporary duty locations, or relocation at the direction of a Federal agency.”4

Authorized uses of the travel card include:

• Cash Advances

Lodging 

Meals

Miscellaneous Expenses

•

•

•

CFTC travel card holders are billed directly by the travel card issuing bank for their 

charged official travel expenses, and are responsible for payment. Official travel 

expenses are separately reimbursed to the traveler. Any use of the travel card (including 

cash withdrawals) to pay expenses incurred for purposes other than official travel and 

travel-related activities are unauthorized. 

 

1http://www.gsa.gov/portal/content/104790

2 41 CFR § 301-51.1. 3 Individually Billed Account (IBA) credit card. 4 41 CFR § 300-3.1.
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Conclusion

CFTC’s travel card program is generally effective in minimizing non-compliance with its 

travel policy. However, adherence to current CFTC policy requiring notification to

employees and supervisors of suspected unauthorized transactions, so that the 

appropriate steps can be taken to address any misuse, would further strengthen its 

travel card program. See Appendix A for further details. 

 

Recommendation

We recommend the Office of Financial Management:

1. Follow Section VI, Review and Remedial Action, of CFTC’s travel card policy, so 

that employees and their supervisors are informed of instances of suspected noncompliance with CFTC’s travel card program.

Management Comments

Management concurred with the findings and recommendation and expressed that they 

are drafting written communications to notify (1) employees in non-compliance of travel

regulations and policy and (2) their supervisors to determine punitive actions, if 

necessary. See Appendix B for management comments in its entirety.

Evaluation of Management Comments

Management comments are responsive to findings and recommendation.

Objective, Scope, and Methodology

Our objective was to determine whether CFTC complied with its travel card policy. To 

answer our objective, we assessed whether expenses charged to CFTC-issued travel 

cards were related to official travel and represented authorized uses. To determine 

whether expenses were related to official travel, we compared travel transactions during 

January and February 2o16 to travel authorizations approved between May 2015 and 

June 2016. In this group, there were 982 total transactions with 33 anomalies. To 

determine whether expenses represented authorized uses we summarized travel 

transactions generated between June 2015 and June 2016 by merchant type to identify

potential prohibited transactions. There were only 7 anomalous transactions of 9,578 

travel card transactions under the scope of our review. 

We also conducted interviews with key personnel to gain an understanding of the travel 

card process. They provided us with a detailed presentation of the process they use to 

monitor travel transactions. 

We conducted this review using Council of the Inspectors General on Integrity and 

Efficiency (CIGIE) review (inspections) standards. CIGIE requires auditors to ensure 
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the validity and reliability of data obtained from computer-based systems if they are 

significant to the inspectors’ findings using professional judgment. We used SAS 

Enterprise to perform distribution analysis of travel card transactions and concluded 

that the data used was sufficiently reliable for our findings and conclusion.

If you have any questions, please contact me at (202) 418-5084 or Timothy Peoples, 

lead auditor, at (202) 418-5439.

Cc: Timothy G. Massad, Chairman 

Sharon Y. Bowen, Commissioner 

J. Christopher Giancarlo, Commissioner

A. Roy Lavik, Inspector General

Judith A. Ringle, Deputy Inspector General and Chief Counsel
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Appendix - A 

Finding 1 – Travel Card Transactions Without Authorization

Condition and Criteria

For the months of January and February 2016, the OIG assessed whether travel card use 

was related to authorized travel. We found 33 of 982 or 3.3% of transactions reviewed 

did not have approved travel authorizations. The value of the anomalous 33 transactions 

totaled $1,057.64 or 1% of the value of transactions reviewed. Table 1 denotes the CFTC 

reporting units with instances of non-compliance with the requirement to use the travel 

card for authorized travel.

Table 1

Cause and Effect

The system of controls for CFTC’s travel card program relies on detecting or monitoring 

instances of travel card non-compliance. The policy5 states that if charges are not 

supported by documentation, the Office of Financial Management (OFM) will inform an 

employee and their supervisor in writing. Additionally, OFM will request that the 

employee respond to the allegation by email or telephone by a certain date. For the 

instances of non-compliance we found, OFM did not communicate with employees or 

supervisors in writing. As a result, employees were able to continuously use their travel 

card for unauthorized purchases.6 We believe informing supervisors is paramount to 

creating a deterrent effect for non-compliance with CFTC’s travel card program.

 

5 CFTC Procedure: Travel Credit Card, Section VI, Review and Remedial Action. 6 For instance, during the review period, a former OIG employee used a CFTC issued travel card to charge over $240.00 for 

occasional daily parking near the employee’s workplace – clearly without a valid travel authorization. The OIG supervisor was 

informed of the misuse of the travel card after the employee’s departure. 
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Finding 2 – Non-Travel Related Transactions

Condition and Criteria

To a lesser extent, we noted instances where employees used their travel card for nontravel-related purposes, albeit while on official travel pursuant to an official travel 

authorization. Specifically, 7 of 9,578 payments made by CFTC employees were nontravel related for transactions occurring between June 2015 and June 2016. The value of 

the 7 transactions totaled $1,279.64 or less than 1% of all transactions reviewed. Table 2 

denotes the CFTC reporting units with instances of prohibited uses7 of travel cards. 

Table 2

Cause and Effect 

The system of controls for CFTC’s travel card program relies on detecting or monitoring 

instances of travel card non-compliance. The policy8 states that if charges are not 

supported by documentation, the Office of Financial Management (OFM) will inform an 

employee and their supervisor in writing. Additionally, OFM will request that the 

employee respond to the allegation by email or telephone by a certain date. For the 

instances of non-compliance we found, OFM did not communicate with employees or 

supervisors in writing. As a result, employees are able to continuously use their travel 

card for prohibited purchases. We believe informing supervisors is paramount to 

creating a deterrent effect for prohibited use of the travel card.

 

7 For instance, during the review period, a current CFTC employee used a CFTC issued travel card to charge over $1,089 for a 

property tax payment and related fee—clearly a prohibited use of the travel card. 8 CFTC Procedure: Travel Credit Card, Section VI, Review and Remedial Action.
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Appendix B – Management Comments