CFTC

2014-2018 Information Technology

Strategic Plan (ITSP) 

Office of Data and Technology (ODT)

12/22/2014
IT Strategic Plan 2014

i. Document History

Document History

Revision Date Description of Changes

0.1 August 20, 2013 Initial draft 

0.2 September 4, 2013 Revised draft

0.3 September 13, 2013 Draft version circulated w/ CFTC FY15 Budget 

Submission package and CFTC Strategic Plan 

pre-seriatim review package

0.4 October 2013 Incorporated feedback from Strategic Plan goal 

team leads

0.5 February 27, 2014 Added an executive summary

0.6 May 16, 2014 Revised based on quarterly review of IT 

Operating Plan

0.7 July 22, 2014 Updates based on FY16 budget formulation

1.0 November 21, 2014 References to CFTC Strategic Plan updated to 

reflect approved CFTC Strategic Plan

1.1 December 22, 2014 Added External Factors, revised table identifying 

alignment between IT strategic initiatives and 

CFTC goals and objectives
IT Strategic Plan 2014

ii. Table of Contents

Table of Contents

Executive Summary.........................................................................................................................iii

IT Strategic Goals, Objectives, and Initiatives.......................................................................................... iv

1 Introduction .............................................................................................................................. 1

2 IT Strategic Principles................................................................................................................ 3

3 IT Strategic Priorities................................................................................................................. 4

4 IT Strategic Factors.................................................................................................................... 6

5 IT Strategic Goals, Strategic Objectives, and Strategic Initiatives............................................ 7

Goal 1 - Deliver IT systems and services aligned with regulatory mission activities of the CFTC..... Error! 

Bookmark not defined.

Goal 2 - Facilitate availability and enhance understanding of data to improve regulatory effectiveness

................................................................................................................................................................27

Goal 3 - Provide a stable, scalable and secure IT environment and ensure continuous operations......43

Goal 4 - Manage resources to achieve CFTC priorities...........................................................................61

6 IT Strategic Plan Performance Measures................................................................................ 67

7 IT Strategic Planning Process.................................................................................................. 69

8 External Factors ...................................................................................................................... 71

9 Alignment between IT Strategic Initiatives and CFTC Goals and Objectives.......................... 72
IT Strategic Plan 2014

iii Executive Summary

Executive Summary

The 2014-2018 Information Technology Strategic Plan (ITSP) provides strategic direction for how ODT 

will support the expanded CFTC mission, improve efficiency and effectiveness, and provide reliable and 

secure IT services. 

This IT Strategic Plan was developed in partnership with CFTC stakeholders from all divisions and offices 

to ensure alignment with the CFTC Mission and the CFTC Strategic Plan. ODT and the CFTC stakeholders 

developed the plan using the following principles, priorities, and factors. 

Principles

IT strategic principles identify how IT activities will be managed:

• Alignment with the CFTC Mission and Strategic Plan 

• Leadership and communication at all levels

• Timely direction and priorities from IT leaders.

Priorities

IT strategic priorities establish preferences for selecting IT investments, in descending order of priority:

• Availability of infrastructure and services

CFTC must have reliable and high-performance IT services, including the infrastructure and 

analysis and communication tools. Without this, other IT priorities would be difficult to achieve. 

• Access to data and information

Because the CFTC must ingest, understand, and analyze data from multiple industry sources, 

ODT provides data transfer, ingest, warehousing, standards, and quality activities.

• Availability of platforms for data analysis

The expert market, financial, legal, and economic analysts in CFTC must have platforms and 

tools with which to analyze data while minimizing time, process, and resource constraints. 

• Mission- and enterprise-focused automation services

All implemented solutions, whether built or purchased (with a bias towards buying), are 

integrated with enterprise data and enterprise services.

Factors (Technical Approaches to IT Activities)

Factors are technical approaches that direct the design, implementation, and sustainment of IT services:

• Use legal entity identifiers, provide accurate, centralized source and reference data 

• Exploit publicly available, government and industry information, facilities, and data services

• Provide an enterprise-wide information and services architecture 

• Promote and adopt industry standards 

• Connect industry straight-thru processing to automated and transformed internal processes

• Use buy-or-build and total cost of ownership assessments for the best value with acceptable risk

• Manage, protect, and leverage information using automated security controls and continuous 

diagnostics to reduce risk

• Deliver solutions in short, iterative phases, using components that can be assembled with agility

• Establish and refine precise data and data quality requirements collaboratively and iteratively 

• Maintain a cadre of FTEs with industry, technical, and contract-oversight expertise to manage IT 

investments, ultimately lowering costs, reducing risks, and increasing operational flexibility
IT Strategic Plan 2014

iv Executive Summary

IT Strategic Goals, Objectives, and Initiatives

The IT Strategic Plan is organized into four goals that provide focus and define achievable outcomes. The 

twelve objectives identify general directions that lead to the outcomes identified by IT strategic goals, 

while the strategic initiatives are specific programs, projects, services, and sets of activities. 

Goal 1 - Deliver IT systems and services aligned with regulatory 

mission activities of the CFTC

A key driver of the information technology program is the delivery of technology platforms, systems, 

and services to support CFTC mission and support functions. It is a priority to meet business needs first 

by empowering users with self-service technology platforms for data analysis, then by enterprisefocused automation services. Accordingly, the self-service technology platforms, including business 

intelligence software and collaboration software, empower CFTC staff to quickly and iteratively develop 

analytical work products (e.g., surveillance reports) and share information without being hampered by a 

dependence on technologists to build solutions. If requirements are such that self-service is not practical

and packaged solutions are available in the market, then CFTC will buy, configure, and integrate the 

appropriate solutions to meet the business need. Given the unique nature of CFTC requirements, if a 

solution is not available in the marketplace then many of the same technology platforms mentioned 

previously are leveraged to build custom mission systems. 

The underlying technology services component facilitates the:

• Delivery of services to implement technology platforms and custom solutions

• Building of analytical models, reports, and systems to support specific mission requirements 

• Integration of solutions to facilitate use within and across CFTC business units.

While it is ideal to acquire ready-made solutions to meet business objectives, services are still needed to 

implement, integrate, and manage solutions. Where solutions are customized, resources are also 

required to design and develop these customizations.

Objective 1.1: Develop mission systems that contribute to the effectiveness of 

CFTC regulatory mission activities

Strategic Initiatives

1.1.1: Continuously enhance market surveillance monitoring and case management systems

1.1.2: Continuously identify and develop enhanced financial analytical tools

1.1.3: Continuously enhance data analytics platforms, data discovery and visualization platforms and 

high-performance data environment

1.1.4: Increase litigation support services

1.1.5: Continuously enhance eLaw program technology

Objective 1.2: Collaborate with the industry and divisions to automate business 

processes and data flows

Strategic Initiatives 
IT Strategic Plan 2014

v Executive Summary

1.2.1: Actively engage derivatives clearing organizations (DCOs) to identify and potentially re-use or 

extend margining and other software algorithms to meet unique Commission requirements

1.2.2: Increase integration between the National Futures Association (NFA) and CFTC systems

1.2.3: Further integrate eLaw with other CFTC systems and processes

1.2.4: Provide technical support for regulatory reporting compliance

1.2.5: Build out of proof-of-concept programs formulated by mission program staff

Objective 1.3: Provide enterprise solutions aligned with industry best practices

Strategic Initiatives 

1.3.1: Increase use of Application Programming Interfaces (APIs) and web services for regulatory data 

reporting

1.3.2: Use industry-standard tools to evaluate futures commission merchant (FCM), commodity pool 

operator (CPO), and other participant financial risk

Goal 2 - Facilitate availability and enhance understanding of data to 

improve regulatory effectiveness

The CFTC increasingly and unavoidably relies on its understanding of data to ensure that it can perform 

its regulatory and public policy functions effectively. As the markets and participants it oversees 

overwhelmingly turn electronic, engage in faster and more automated trading, and transact in products 

that are more and more complex, the CFTC increasingly needs to be a regulator that understands,

aggregates, processes, summarizes, and acts on data in a timely manner for surveillance, enforcement 

and transparency reporting. The markets and participants that CFTC regulates generate and report to 

the CFTC a large quantity of information from multiple industry sources across multiple markets. 

Increasing speed, volume, and complexity in these products and markets require the CFTC to develop an 

increasingly sophisticated ability to validate and pre-digest the reported data so that front-line 

regulatory functions such as surveillance and enforcement can more effectively use that data. In 

addition, even as the CFTC’s regulatory regime has expanded to include swaps, it needs to ensure that 

not only is the swaps oversight integrated into the existing program initiatives, but also that the existing 

program and processes are upgraded to keep up with new techniques and technologies. Thus, data 

management is an essential to all of CFTC’s regulatory initiatives and, in particular, to integrating swaps 

oversight into existing program initiatives.

Timely and effective surveillance analysis, aggregation, and risk analysis are critical to the CFTC’s ability 

to oversee the markets effectively. CFTC’s data management program has to ensure that it responds 

both broadly and specifically to address the critical regulatory needs of the Commission:

• A standards-based, robust and flexible data architecture is an essential pre-requisite and 

ensures that confidentiality, availability and integrity of the data are maintained in line with the 

Commission’s mission and federal government requirements

• A capable data standards program that provides guidance to the industry on the data reporting 

and recordkeeping aspects of CFTC’s rules and guidance that the CFTC staff can rely on for 

understanding the data reported 
IT Strategic Plan 2014

vi Executive Summary

• A robust reference data management program that ensures that key identifier and product data 

used by the CFTC staff for data reporting, analysis, aggregating and surveillance is valid, correct 

and current

• Data analysis that reviews incoming data to ensure that upfront analyses, extracts, reports, and

alerts are effective and that data quality can be measured and addressed as needed

• A data harmonization program that includes oversight of data custodial programs operated by 

the industry, such as Swap Data Repositories (SDRs), Exchanges, Swap Execution Facilities (SEFs),

Designated Clearing Organizations (DCOs) and Designated Clearing Members (DCMs). Industry 

programs must contribute to effectively supporting the Commission’s mission, result in 

acceptable data quality, and ensure that data is well-protected in terms of data integrity, 

confidentiality and security and is available on a timely basis

• An automated, responsive, robust and high-quality data ingest program that ensures that there 

is sufficient capacity to take in, validate, rectify and make available to CFTC staff the data that is 

reported and funneled to the Commission by the participants the Commission regulates

• A front-end data operations program that reviews the data that is ingested, ensures compliance 

with reporting and recordkeeping requirements, and conducts effective data audits of regulated 

entities to ensure that their policies and processes are supportive of consistent, timely and highquality reporting and recordkeeping.

Objective 2.1: Architect data to enable automated ingestion, integration, access, 

sharing, reporting and transparency

Strategic Initiatives 

2.1.1: Receive all data electronically and automate its distribution throughout the Commission using 

business process automation software (BPMS)

2.1.2: Improve data quality

Objective 2.2: Aggregate data across markets and participants to empower the 

CFTC staff to perform complex data analyses

Strategic Initiatives

2.2.1: Increase application of data standards, including Legal Entity Identifiers (LEIs) and unique product 

identifiers (UPIs)

2.2.2: Harmonize swap data repository (SDR) data

Objective 2.3: Manage information to ensure its availability to the regulatory 

mission activities and the public

Strategic Initiatives 

2.3.1: Ingest order book data from market exchanges and platforms

2.3.2: Implement a research-focused data environment

2.3.3: Implement the President’s Digital Government Strategy
IT Strategic Plan 2014

vii Executive Summary

2.3.4: Expand the use of interagency collaboration platforms

2.3.5: Continue centralized management and administrative data and systems services and support 

automation of the CFTC administrative and management processes

2.3.6: Implement an electronic records and document management system (ERDM)

2.3.7: Support publishing of aggregated swaps and futures data

Goal 3 - Provide a stable, scalable and secure IT environment and

ensure continuous operations

The Commission must continue to provide a stable, scalable and secure IT infrastructure to meet 

demand. CFTC’s IT infrastructure is the combination of hardware, software, network resources, facilities, 

and services that are common across CFTC regardless of mission, program, or project and are the 

foundation of CFTC’s IT environment. This infrastructure supports the development, testing, delivery, 

monitoring, control, and support of IT resources. 

The IT infrastructure is the foundation upon which CFTC mission specific systems are built and is the key 

enabler for delivery of systems and services. CFTC recognizes the interdependency between 

infrastructure components as well as the systems that depend upon the infrastructure. Therefore, CFTC 

carefully prioritizes, plans, and coordinates changes to the IT Infrastructure. CFTC will continue to 

enhance computing infrastructure and related resources to facilitate CFTC regulatory mission activities 

and mission support activities. Increased network, storage, and processing capacity will permit analyzing 

larger and more complex data sets and enable enhanced collaboration. A private cloud computing 

environment will enable CFTC to consolidate processing and networking services in a highly virtualized 

environment. This environment will deliver high levels of availability, redundancy, and business 

continuity, while also allowing all information to be managed and made available centrally. IT services 

that benefit all Commission staff will be sustained and enhanced to support improved effectiveness and 

productivity.

Objective 3.1: Provide stable and scalable communication, processing, and 

storage infrastructure capabilities

Strategic Initiative 3.1.1: Maintain highly available and scalable data infrastructure

Objective 3.2: Provide trusted access to systems and data

Strategic Initiatives 

3.2.1: Enhance data management tools 

3.2.2: Automate security controls and implement continuous monitoring 

3.2.3: Provide systems platform support to empower end users

Objective 3.3: Ensure technology and data availability

Strategic Initiatives 

3.3.1: Improve business continuity support

3.3.2: Improve mobile computing and mobile communication services
IT Strategic Plan 2014

viii Executive Summary

3.3.3: Improve video teleconferencing

3.3.4: Expand after-hours technical support for staff and external participants

Objective 3.4: Optimize infrastructure for management of high-volume 

information sources

Strategic Initiatives 

3.4.1: Provide access to an increasing number of data sources and increasing sample sizes of market 

data (including non-futures market data)

3.4.2: Enable infrastructure support for high performance computing

Goal 4 - Manage resources to achieve CFTC priorities

To continue supporting improved business outcomes IT management processes will continue to be 

integrated into CFTC planning and governance processes. The degree to which IT management leverages 

best practices, CFTC processes, and proven tools to achieve efficiency of operations will help define its 

success in fully supporting CFTC regulatory mission and mission support activities. 

The CFTC will expand its strategic and operational planning process to better unite the various functional 

plans including, but not limited to, financial, human capital, and information technology plans. A unified 

planning process will lead to better use of resources and facilitate effective resource governance. Most 

importantly, it will increase the Commission’s agility in responding to and adapting to external changes 

and derivatives market evolution. The Commission will supplement current planning activities and 

deliverables (strategic planning, budget formulation, budget execution, performance, human capital 

strategic, IT strategic, and IT operating) with mission division and mission support office strategic, 

operating, and performance plans. The additional level of detailed planning at the division and office 

level will increase the granularity and focus of HR and IT strategic and operating plans. More detailed 

and better focused HR and IT plans will also increase the effectiveness of division and office level 

planning. 

Collaboration and partnering will continue to ensure the alignment of business needs and IT services. 

However, IT management processes for capital planning and investment control (CPIC), strategic and 

operational planning, and IT program and project management will be adjusted to facilitate expanding 

CFTC processes. IT operating plans will continue to identify incremental, iterative projects in order to 

reduce project risk and increase flexible alignment with CFTC appropriations and budget execution. 

Transparency will be increased to support the enterprise focus of CFTC resource planning and 

governance.

Objective 4.1: Deliver expected outcomes on IT Investments

Strategic Initiatives 

4.1.1: Extensively use learning management, electronic learning, and video production

4.1.2: Achieve transparency through ODT communications and processes
IT Strategic Plan 2014

ix Executive Summary

Objective 4.2: Develop the ODT organization in alignment with the demands of 

CFTC’s regulatory mission activities

Strategic Initiative 4.2.1: Support the implementation of CFTC Governance
IT Strategic Plan 2014

1 Introduction

1. Introduction

The 2008 financial crisis and the subsequent enactment 

of the 2010 Dodd-Frank Wall Street Reform and 

Consumer Protection Act (Dodd-Frank Act) brought 

about historic change to the mission of the CFTC. The

mission has grown from ensuring the fair, open, and 

efficient functioning of the futures marketplace to 

ensuring that the Commission provides that same level 

of oversight to the complex swaps marketplace.

This more complex environment at the agency has 

made it imperative that the information technology 

program rapidly adjusts to meet the new demands in a 

fiscally prudent environment. The Commodity Futures 

Trading Commission (CFTC) 2014-2018 Information 

Technology Strategic Plan (ITSP) provides strategic 

direction for how IT will support the expanded CFTC 

mission, improve efficiency and effectiveness, and 

provide reliable and secure IT services. The CFTC ITSP 

five-year plan was developed in partnership with its 

business stakeholders to ensure we are in alignment 

with the mission priorities of the CFTC’s Strategic Plan. 

The ITSP supports the Commodity Futures Trading 

Commission Strategic Plan FY 2014–2018 and was developed in partnership with business stakeholders. The 

ITSP defines the IT strategic principles, priorities, and factors that form the basis for the IT strategic goals, 

objectives, and initiatives outlined in this document. These goals, objectives, and initiatives will drive IT 

planning, development, and operational activities.

The ITSP is built based on a framework that consists for four key components:

1. CFTC Strategic Planning Goals

2. IT Strategic Principles

3. IT Strategic Priorities

4. IT Strategic Factors.

CTFC Strategic Planning Goals come directly from the CFTC Strategic Plan and set the priorities for all 

Commission work, including but not limited to IT priorities.

IT Strategic Principles identify the management approach to delivering and sustaining IT services:

• Mission partnership, alignment, and outcomes

• Leadership and communication at all levels

• Timely direction and priority setting.

IT Strategic Principles identify how IT services will be managed and are further described in Section 2 of the 

ITSP.

IT Strategic Priorities establish the order of importance for selecting and sustaining IT investments: 

1. Availability of infrastructure and services

IT Strategic Goals:

IT strategic goals articulate clear 

outcomes for information technology to 

deliver effective CFTC mission support.

IT Strategic Principles:

IT strategic principles identify how IT 

services will be managed. 

IT Strategic Priorities:

IT strategic priorities establish high-level 

preferences for selecting IT investments.

IT Strategic Factors:

IT strategic factors are technical 

approaches that help direct the planning, 

design, implementation, and sustainment 

of IT services.
IT Strategic Plan 2014

2 Introduction

2. Access to data and information

3. Availability of platforms for data analysis

4. Mission and enterprise-focused automation services.

IT Strategic Priorities are further described in Section 3 of the ITSP.

IT Strategic Factors provide technical direction that lead to greater return on IT investments by maximizing 

value and minimizing risk. They are further described in Section 4 of the ITSP.

IT Strategic goals and objectives correlate IT strategy 

with CFTC strategy, identifying IT Strategic Initiatives 

that will be used to identify, select, and run IT projects 

each year. Each of the IT Strategic Initiatives is defined, 

its purpose and support of the CFTC Strategic Plan is 

explained, and planned focus areas for specific projects 

are identified.

To provide the most benefit, the ITSP is integrated with 

the CFTC Planning Process and is reviewed periodically 

and adjusted as needed. 

IT Strategic Objectives:

IT strategic objectives identify general 

directions that lead to the outcomes 

identified by IT strategic goals.

IT Strategic Initiatives:

IT strategic initiatives establish sets of 

activities that provide scope to IT 

operating plans and specific programs, 

projects, and services. 
IT Strategic Plan 2014

3 IT Strategic Principles

2. IT Strategic Principles 

• Mission partnership, alignment, and outcomes

• Leadership and communication at all levels

• Timely direction and priorities

Mission Partnership, Alignment and 

Outcomes

The CFTC mission is the focal point of the ITSP. The ITSP 

is an overarching mechanism that aligns IT operational 

activities with CFTC strategic priorities. Each service 

delivered will be designed, implemented, and deployed

with direct insight into why it is needed, how it adds 

value, and how it will be adopted and used by the CFTC. 

ODT and CFTC stakeholders will work collaboratively in 

the planning, implementation, and sustainment of IT 

services. During FY 2014 thru FY 2018, this collaboration 

will be especially important in refining data and data quality requirements in the post Dodd-Frank regulatory 

environment.

Alignment of the IT Strategic Goals and IT Strategic Initiatives to CFTC Goals is summarized in Section 9.

Leadership and Communication at All Levels

Every CFTC stakeholder uses IT services to accomplish the CFTC mission and must have the opportunity to 

help define how those services are provided. Each Office of Data and Technology (ODT) staff member’s role 

offers a unique organizational perspective. Effective strategy execution can be achieved only if each 

contributor in ODT understands and takes ownership of their responsibility for contribution to the CFTC 

mission. The ITSP provides a common vision that facilitates engagement by CFTC staff in the delivery of IT 

services and enables every contributor in ODT to lead the CFTC towards its mission.

Timely Direction and Priorities

IT leaders must provide timely decision making and communicate with the Commission and ODT staff to 

ensure that IT strategy is implemented successfully. This process begins with communication of the ITSP to 

validate its rationale and encourage engagement and is followed by constant communication throughout 

the lifecycle of each IT service.

The CFTC Mission:

To foster open, transparent, competitive, 

and financially sound markets; to avoid 

systemic risk; and to protect market users 

and their funds, consumers, and the 

public from fraud, manipulation, and 

abusive practices related to derivatives 

and other products that are subject to 

the Commodity Exchange Act.
IT Strategic Plan 2014

4 IT Strategic Priorities

3. IT Strategic Priorities

• Availability of infrastructure and services

• Access to data and information

• Availability of platforms for data analysis

• Mission- and enterprise-focused automation services

Given the pace of technology and structural change in 

the futures and swaps markets and continuing resource 

constraints, four IT Strategic Priorities are applied to IT 

strategic and operational planning to ensure the best 

return on the overall portfolio of CFTC IT investments. 

These IT Strategic Priorities are listed in descending 

order of priority: Availability of Infrastructure and 

Services; Access to Data and Information; Availability of 

Platforms for Data Analysis; and Mission and Enterprisefocused Automation Services.

Availability of Infrastructure and Services

The most fundamental priority is available, flexible, 

reliable, scalable, and high performance infrastructure 

and base services. The CFTC IT infrastructure includes 

hardware, software and telecommunication equipment 

as well as base services (e.g., data base management systems, email). This infrastructure supports systems 

(e.g., trade surveillance, position monitoring, or large trader reporting), as well as platforms (e.g., data 

analytics or collaboration), that empower staff to fulfill the CFTC mission. The Commission will scale and 

enhance communication, processing, storage, and platform infrastructure to meet mission requirements.

Without a stable, available, and well-functioning IT Infrastructure, other IT priorities would be difficult to 

achieve. Therefore this is the most fundamental IT priority. 

Access to Data and Information

In order to fulfill its mission, the CFTC depends heavily on its ability to quickly access and analyze large 

volumes of complex market data. A primary area of focus must be on data understanding and ingestion—

particularly because CFTC has a unique imperative to aggregate various types of data from multiple industry 

sources across multiple market segments both domestic and international. Providing this access requires 

data transfer, data ingest, data warehousing, data standards, and data quality activities.

IT initiatives that provide staff with access to data are given priority over all other investments, with the 

exception of maintaining current infrastructure and services. Precise data and data quality requirements 

developed collaboratively with staff also provide a foundation for effectively establishing platform and 

automation service requirements.

The U.S. futures and swaps markets are 

estimated at $30 trillion and $400 

trillion, respectively. By any measure, 

the markets under CFTC’s regulatory 

purview are large and economically 

significant. Given the enormity of these 

markets and the critical role they play in 

facilitating price discovery and hedging 

of risk, ensuring that these markets are 

transparent, open, and competitive is 

essential to their proper functioning and 

to help safeguard the financial stability 

of the Nation.
IT Strategic Plan 2014

5 IT Strategic Priorities

Availability of Platforms for Data Analysis

CFTC staff are expert market, financial, legal, and economic analysts that must have the ability to rapidly 

adjust their analytic activities and approaches to address changing market characteristics and economic 

conditions. Staff must be provided with platforms and tools that enable them to innovatively analyze data

while minimizing time, process, and resource constraints. Most mission-focused work is highly analytical 

and is unique to specific market conditions, timing, and other variables.

IT initiatives that provide staff with flexible self-service analytics tools for their direct use are given priority 

over initiatives that take longer to implement and need greater investment in staff time as a prerequisite to 

successful development and implementation.

Mission and Enterprise-focused Automation Services

Automation services and solutions that support a diversity of roles and activities and increase data re-use 

across the Commission and allow CFTC to leverage limited resources. Examples include Business Process 

Management Tools, Enterprise Search Capabilities, Collaboration Tools (e.g., Microsoft SharePoint), and 

Portal Technology. When considering Enterprise-Focused tools, build/buy decisions will need to be made 

with a bias to buying. All implemented solutions, whether built or purchased, are integrated with enterprise 

data and enterprise services. 
IT Strategic Plan 2014

6 IT Strategic Factors

4. IT Strategic Factors

Several factors are considered in the planning, design, implementation, and sustainment of IT services,

including the identification of goals, objectives and strategic initiatives, in order to maximize the value of 

and manage the risk of IT investments. 

Maximizing Value

• Provide accurate, centralized source and 

reference data to ensure data quality, using 

legal entity identifiers as a linchpin

• Exploit publicly available, government and 

industry-provided information, facilities and 

data services

• Provide an enterprise-wide information and 

services architecture 

• Promote and adopt industry standards 

• Connect industry straight-thru processing to 

automated and transformed internal processes

• Consider total cost of ownership and use buy or build assessments to achieve best value with 

acceptable risk.

Minimizing Risk

• Manage information as a CFTC asset that needs to be managed, protected, and leveraged.

• Protect proprietary industry, individual and sensitive government information, using automated 

security controls and continuous diagnostics to reduce risk.

• Balance business value with risk when implementing new technology and accept risk only when the 

benefit to achieving the CFTC mission outweighs evaluated risks.

• Deliver solutions collaboratively with staff in short, iterative phases using small components that can 

be assembled and reassembled with agility.

• Establish and refine precise data and data quality requirements collaboratively and iteratively with 

staff. 

• Maintain a cadre of FTE with industry, technical, and contract oversight expertise who ensure that IT 

investments are managed effectively ultimately lowering IT ownership costs, reducing the risk 

inherent in complex IT projects, and providing a pool of expertise that increases operational 

flexibility.

Changes in the marketplace are requiring 

additional investments in technology and 

data infrastructures as well as business 

processes. The complexities of adapting 

to these changes present technical, 

operational, and business process 

challenges and opportunities to the 

industry. In response to the influx of new 

types of data from new and existing 

registrants, the CFTC must build its own 

information infrastructure and analytical 

capabilities to support its responsibilities 

as a first line regulator. 
IT Strategic Plan 2014

7 IT Strategic Goals, Objectives, and Strategies

5. IT Strategic Goals, Strategic Objectives, and Strategic 

Initiatives

The IT Strategic Plan takes a view of the CFTC Strategic Plan and CFTC mission and mission support priorities 

from a technology perspective. With that view in mind, the goals, objectives and initiative described in 

Section 5 center around how technology initiatives are organized and executed. Connections to the CFTC 

Strategic Plan, CFTC Divisions/Offices, and specific Commission program areas are provided throughout this 

Section to provide a business-oriented context to a particular IT goal, objective, or initiative. These 

connections are not intended to be comprehensive in nature, but are examples of how the ITSP integrates 

with other Commission priorities. 

Wherever practical, a single IT goal, objective, or initiative will support multiple Commission priorities. 

Many, in fact, will support all Commission goals, objectives and strategies. ODT attempts to apply an 

enterprise focus to all IT initiatives, maximizing the leverage of technology investments to support the entire 

Commission.

Each IT strategic goal and strategic objective reflects the Commission’s strategic priorities. In order to bring 

the greatest benefit to the mission, Commission stakeholders and ODT staff must collaborate and partner to 

anticipate and understand business needs and align resources to the delivery of IT services. The ITSP is 

organized into four IT strategic goals that provide focus and define achievable outcomes. Twelve IT strategic 

objectives (SO) identify general directions that lead to the outcomes identified by IT strategic goals.

IT Strategic Goals

Goal 1. Deliver IT systems and services aligned with 

regulatory mission activities of the CFTC

Goal 2. Facilitate availability and enhance 

understanding of data to improve regulatory 

effectiveness

Goal 3. Provide a stable, scalable and secure IT 

environment and ensure continuous operations

Goal 4. Manage IT resources to achieve CFTC priorities.

IT Strategic Objectives 

1.1 Develop mission systems that contribute to the effectiveness of CFTC regulatory mission activities

1.2 Collaborate with the industry and divisions to automate business processes and data flows

1.3 Provide enterprise solutions aligned with industry best practices

2.1 Architect data to enable automated ingestion, integration, access, sharing, reporting and transparency

2.2 Aggregate data across markets and participants to empower the CFTC staff to perform complex data 

analyses

2.3 Manage information to ensure its availability to the core mission functions and the public

More entities, more markets and more 

products (including more complex 

products) are subject to CFTC regulation 

than ever before. The industry is 

responding quickly to the competitive 

opportunities engendered by the shifting 

regulatory landscape. Innovation in the 

industry will continue to add complexity 

in ways currently unanticipated.
IT Strategic Plan 2014

8 IT Strategic Goals, Objectives, and Strategies

3.1 Provide stable and scalable communication, processing, and storage infrastructure capabilities

3.2 Provide trusted access to systems and data

3.3 Ensure technology and data availability

3.4 Optimize infrastructure for management of high-volume information sources

4.1 Deliver expected outcomes on IT Investments

4.2 Develop the ODT organization in alignment with the demands of CFTC’s core mission functions

IT Strategic Initiatives

IT strategic initiatives decompose the IT strategic objectives and establish sets of activities that provide 

scope to IT operating plans and specific programs, projects, and services. Each IT strategic goal, objective, 

and initiative is described below. Focus Areas for Projects listed for each IT strategic initiative are examples 

of major projects that will be executed during the timeframe of the ITSP. Projects are sometimes repeated 

across multiple initiatives because they advance multiple CFTC and IT strategic objectives. The CFTC 

Strategic Plan performance goals that the IT strategic initiative contributes to are listed along with a general 

description of the contribution. Finally, the CFTC Strategic Plan goals and objectives as well as the CFTC 

divisions or offices that will benefit from the IT strategic initiative are listed. This cross reference shows the

line of sight from IT initiatives and their projects through the IT Strategic Plan to the CFTC Strategic Plan.

While the complete set of IT projects and activities performed during the course of any year are beyond the 

scope of the IT Strategic Plan, there is a linkage from the IT Operating Plan for each year to the IT Strategic 

Plan and the CFTC Strategic Plan. It is through this line of sight that Commission staff and IT staff can see 

how their collaborative efforts lead to meeting the strategic objectives and goals of the Commission.
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9 IT Strategic Goals, Objectives, and Strategies

Goal 1 – Deliver IT systems and services aligned with regulatory mission 

activities of the CFTC

A key driver of the information technology program is the delivery of technology platforms, systems, and 

services to support CFTC mission and support functions. It is a priority to meet business needs first by 

empowering users with self-service technology platforms for data analysis, then by enterprise-focused 

automation services. Accordingly, the self-service technology platforms, including business intelligence 

software and collaboration software, empower CFTC staff to quickly and iteratively develop analytical work 

products (e.g., surveillance reports) and share information without being hampered by a dependence on 

technologists to build solutions. If requirements are such that self-service is not practical and packaged

solutions are available in the market, then CFTC will buy, configure, and integrate the appropriate solutions 

to meet the business need. Given the unique nature of CFTC requirements, if a solution is not available in 

the marketplace then many of the same technology platforms mentioned previously are leveraged to build 

custom mission systems.

The underlying technology services component facilitates the:

1. Delivery of services to implement technology platforms and custom solutions

2. Building of analytical models, reports, and systems to support specific mission requirements

3. Integration of solutions to facilitate use within and across CFTC business units.

While it is ideal to acquire ready-made solutions to meet business objectives, services are still needed to 

implement, integrate, and manage solutions. Where solutions are customized, resources are also required 

to design and develop these customizations.

The Commission’s regulatory mission activities – registration; product review and assessment; examination, 

surveillance, and enforcement – are supported by economic analysis, legal analysis, data infrastructure and 

technology, international policy coordination, and management and administration functions. New IT 

services and enhancements to existing services are evaluated and planned in terms of their impact on the 

CFTC mission, either directly to regulatory mission activities or indirectly through supporting activities. 

The following IT strategic objectives are described under Goal 1:

1.1: Develop mission systems that contribute to the effectiveness of CFTC regulatory mission 

activities

1.2: Collaborate with the industry and divisions to automate business processes and data flows

1.3: Provide enterprise solutions aligned with industry best practices.

Objective 1.1: Develop mission systems that contribute to the effectiveness of CFTC 

regulatory mission activities

Development of services or implementations of commercially-available off-the-shelf solutions are focused 

on the CFTC mission, either directly to regulatory mission activities or indirectly through mission supporting 

activities. IT delivery of systems takes a buy first approach to delivering solutions, focusing custom software 

development services on requirements unique to the CFTC and relying on commercial off-the-shelf (COTS)

acquisitions to meet non-unique requirements.

The following IT Strategic Initiatives are described below:
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10 IT Strategic Goals, Objectives, and Strategies

1.1.1: Continuously enhance market surveillance monitoring and case management systems

1.1.2: Continuously identify and develop enhanced financial analytical tools

1.1.3: Continuously enhance data analytics platforms, data discovery and visualization platforms and 

high-performance data environment

1.1.4: Increase litigation support services

1.1.5: Continuously enhance eLaw program technology.

Strategic Initiative 1.1.1: Continuously enhance market surveillance monitoring and 

case management systems

Definition: In order for CFTC to provide effective market and trade practice surveillance, CFTC must monitor 

a wide range of aspects of the futures and swaps markets (e.g., price movements, individual positions, 

positions relative to limits, trading patterns and anomalies). CFTC has developed a set of specialized 

monitoring systems. These monitoring systems range from analyst driven data discovery query tools, report 

tools, scheduled monitoring tools, to alert-based tools. Wherever possible, these monitoring systems

leverage off-the-shelf technology platforms for analytics and collaboration. For example, an analytics 

platform may be made up of data discovery tools which are self-service analytical software which enables a 

business user to analyze massive amounts of data and query this data in an ad-hoc fashion. These 

monitoring tools and platforms will require enhancements to keep pace with the industry and respond to 

changes in regulatory mandates. 

Case management systems (also known as collaboration platforms or work flow systems) allow CFTC to 

effectively manage processes, organize work products and related information, track progress, and provide 

managerial reports. These case management systems generally include document management and 

workflow management components. The case management systems support the processes throughout the 

Commission though currently case management is most mature in the Division of Enforcement for tracking 

legal matters. 

Purpose: Strategic Initiative 1.1.1 is necessary to continuously enhance market and trade practice 

surveillance monitoring in order to address structural market changes and support new regulatory 

requirements (e.g., swaps) by facilitating awareness of markets through monitoring. These systems will also 

incorporate innovative surveillance approaches formulated by staff into scheduled, routinely run processes 

to free up staff to innovate and focus on unique and emerging issues.

Integrated swaps and futures positions along with integrating position ownership information with position 

control information will be a major focus area for market surveillance monitoring. Significant effort will be 

applied to understanding overall positions across instruments. Staff will integrate the information in the 

swaps database with that currently held in the Commission’s futures and options database. In so doing, 

staff will be better able to track the positions of traders for the purpose of enhancing market surveillance of 

large traders as well as enforcing position limits.

Case management technology will be enhanced continually and applied in most mission areas, including 

market surveillance and financial risk surveillance. The case management capabilities of the eLaw program 

will be expanded to an enterprise-wide capability. Automating integration between registration and review, 

market and trade practice surveillance, financial and risk surveillance, examination, and enforcement 

activities will improve workflow, increase re-use of information, improve awareness of key market 

information as well as important regulatory activity and coordination, and increase the ability of staff to 

correlate data and events.
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11 IT Strategic Goals, Objectives, and Strategies

Focus Areas for Projects: 

• Futures and Swaps Position Monitoring Development

• Position Limits System Development

• Enterprise-wide Case Management Acquisition and Implementation (distinct from Legal Matter case 

management)

• Registration System Development

• Ownership Control Reporting (OCR)

• Data Collection, Ingestion, and Analysis

• High-Performance Computing Implementation.

Strategic Plan Performance Indicator Support: The initiative will support the accomplishment of the 

following CFTC Strategic Plan Performance Indicators by increasing awareness of key market information as 

well as important regulatory activity:

• Strive to strengthen capacity to receive and expeditiously evaluate all trading data and associated 

information to identify potential violations of the CEA or Commission regulations and the timely 

response to market emergencies

• Percentage of derivatives for which trader data can be matched across CFTC datasets

• Monitor high-risk registrants including SD, MSPs, and FCMs for signs of financial stress.

Strategic Plan Strategy Support: The initiative will support the accomplishment of the following CFTC 

Strategic Plan Strategies:

• Develop and implement technology based surveillance tools to keep pace with market technology

• Monitor firms for financial stress by, among other things, reviewing monthly and annual financial 

filings, as well as notice of specific events.

Strategic Plan Goal and Objective Support:

CFTC Goal CFTC Objective Division/Office

1–4 1.1, 1.4, 2.1-2.4, 3.1, 3.2, 4.4 DCR, DMO, DOE, DSIO

Strategic Initiative 1.1.2: Continuously identify and develop enhanced financial 

analytical tools

Definition: CFTC has acquired and/or developed a set of financial analysis tools and capabilities to monitor 

risk at the firm, clearing member, clearing house, and DCM/SEF levels as well as monitor overall systemic 

risk. Financial records, including margin, collateral, financial health measures, and positions are loaded, 

tracked, outliers explored, and measured against stress tests to determine risks and financial viability of 

participants and the markets. CFTC’s systems include Stressing Positions at Risk (SPARK), Regulatory 

Statement Review Express (RSR Express), Trend Analysis, and Vault (collateral valuation). CFTC currently 

utilizes COTS products including FINCAD and MATLAB, as components on which to build enhanced risk 

management capabilities. CFTC’s financial analytical tools require significant enhancements to evaluate risk 

not just in the futures markets but must include overall participant portfolio risks when including swaps 

(e.g., interest rate swaps, credit default swaps, and commodity swaps). 

Purpose: Strategic Initiative 1.1.2 is necessary to continuously identify and develop enhanced financial 
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12 IT Strategic Goals, Objectives, and Strategies

analytical tools to support the analysis and evaluation of financial data received from registrants in order to 

monitor financial risk. This includes continuing agile development of CFTC-developed custom systems. 

Furthermore, given the complexity of margin and risk calculations associated with swaps, this initiative 

includes identifying, implementing, and integrating best-of-breed solutions used by industry participants 

whenever practical. In addition to initial system implementation, fully operationalizing Dodd-Frank will 

require residual IT changes for several years to come. 

Enhancing CFTC’s financial analysis tools is critical as the Commission will be the only financial regulator that 

will be able to aggregate and evaluate risk across all DCOs. Each DCO’s view of risk is limited to market 

participants clearing at that DCO. Many market participants will have positions at multiple DCOs in more 

than one asset class. Therefore, the Commission is enhancing its existing futures specific risk surveillance 

program to include the ability to stress test positions in swaps for market participants and DCOs. These 

software tools will need to be able to stress test both market participants and DCOs. These financial analysis 

tools will also be used as part of oversight and reviews of FCMs and swaps dealers risk management 

controls.

Additionally, the Commission is developing a system that allows for the identification and then aggregating 

of related market participants across DCOs. Additionally, tools will be enhanced to back test/evaluate 

sufficiency of all material product and portfolio margin requirements; monitor firm level variation and initial 

margin requirements across DCOs; evaluate the risk of market participants positions held at multiple FCMs 

or DCOs; and combine cleared and bilateral positions to obtain a more complete picture of a clearing firm’s 

risk

Focus Areas for Projects:

• Analytical Systems and Tools Implementation

• Data Collection, Ingestion, and Analysis.

Strategic Plan Performance Indicator Support: The initiative will support the accomplishment of the 

following CFTC Strategic Plan Performance Indicators by providing staff with financial analysis tools:

• CFTC strives to conduct back testing of DCOs’ material product and portfolio initial margin 

requirements to assess their sufficiency

• Clearing members’ ability to fund variation and initial margin requirements calculated in 

hypothetical CFTC-designed market scenarios

• Strive to aggregate cleared swaps, futures, and options positions into a comprehensive risk 

surveillance process and conduct analysis for each material market participant.

Strategic Plan Strategy Support: The initiative will support the accomplishment of the following CFTC 

Strategic Plan Strategies:

• Develop tools to back test financial resources and evaluate sufficiency of all material product and 

portfolio margin requirements

• Develop a program to monitor firm-level variation and initial margin requirements across DCOs

• Enhance the risk surveillance program to evaluate the risk of market participants positions held at 

multiple FCMs or DCOs

• Develop process to combine cleared and uncleared, bilateral positions to obtain a more complete 

picture of a clearing firm’s risk exposure

• Monitor firms for financial stress by, among other things, reviewing monthly and annual financial 

filings, as well as notice of specific events.
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13 IT Strategic Goals, Objectives, and Strategies

Strategic Plan Goal and Objective Support:

CFTC Goal CFTC Objective Division/Office

2-4 2.1, 2.4, 3.1, 3.2, 4.4 DCR, DOE, DSIO

Strategic Initiative 1.1.3: Continuously enhance data analytics platforms, data 

discovery and visualization platforms and the high-performance data environment

Definition: Data discovery and data visualization are terms to indicate self-service analytical software which 

enables a business user to analyze massive amounts of data and query this data in an ad-hoc fashion. These 

tools allow CFTC’s economists, analysts, investigators, and attorneys to go beyond the canned reports in 

custom systems. These data discovery/data visualization tools empower users to use a point-and-click 

interface to interact with graphics, query and filter data, create interactive animations, and explore data in a 

highly intuitive fashion. To further enhance the user experience, a high-performance data infrastructure 

(e.g., CFTC’s massively parallel database) allows near real time responses to queries. High-performance 

computing coupled with data discovery tools allow users to explore data in a highly efficient manner in 

order to gain insights and see patterns that would not have been previously possible.

Purpose: Strategic Initiative 1.1.3 is necessary to enable the Commission to conduct market, risk and 

economic analysis based on the most current data, using analytical tools that can be built by CFTC data 

analysts for the particular situation being analyzed. These platforms and tools empower CFTC analysts with 

futures and swaps expertise to conduct self-discovery of data and build specific work products for unique 

business situations. These platforms also enable technologists to build solutions for more routinized 

analyses.

Continuously enhancing systems and platform support technologies is a requirement in this strategic area. 

Doing so will ensure that staff is able to efficiently conduct analytics and innovate market and financial risk 

surveillance and investigative techniques that address unique CFTC requirements. The platforms must 

enable staff to instantly interact with new, large, and varied sets data and quickly assess structure, quality 

and relevance and also establish patterns, outliers, and connections with other data sets.

Focus Areas for Projects: 

• High-Performance Computing Implementation

• Data Discovery/Data Visualization Tools Implementation

• Business Intelligence 

• Dashboards and Information Summary Reports.

Strategic Plan Performance Indicator Support: The initiative will support the accomplishment of the 

following CFTC Strategic Plan Performance Indicators by making it easier for staff to interpret and 

manipulate data:

• Strive to strengthen capacity to receive and expeditiously evaluate all trading data and associated 

information to identify potential violations of the CEA or Commission regulations and the timely 

response to market emergencies

• Percentage of derivatives activity covered by regularly published Commission reports

• Publish economic research reports to inform the public about market structure of the derivatives 
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14 IT Strategic Goals, Objectives, and Strategies

markets

• Percentage of derivatives for which trader data can be matched across CFTC datasets

• CFTC strives to conduct back testing of DCOs’ material product and portfolio initial margin 

requirements to assess their sufficiency

• Clearing members’ ability to fund variation and initial margin requirements calculated in 

hypothetical CFTC-designed market scenarios

• Strive to aggregate cleared swaps, futures, and options positions into a comprehensive risk 

surveillance process and conduct analysis for each material market participant

• Monitor high-risk registrants including SD, MSPs, and FCMs for signs of financial stress

• Strengthen and ensure a coordinated approach to receiving, assessing, and referring tips, complaints 

and referrals as necessary and appropriate; if resources permit, establish a unit or office dedicated 

to this function

• Percentage of enforcement investigations completed within 18 months of opening, depending on 

the nature and scope of investigations.

Strategic Plan Strategy Support: The initiative will support the accomplishment of the following CFTC 

Strategic Plan Strategies:

• Develop and implement technology based surveillance tools to keep pace with market technology

• Publish Interactive Reports on Swap Market Activity

• Conduct economic analysis and research on market structure and transparency for derivatives

• Update eLaw technology to more effectively investigate and litigate cases and increase program 

efficiency.

Strategic Plan Goal and Objective Support:

CFTC Goal CFTC Objective Division/Office

1–4 1.1, 1.3, 1.4, 2.1, 2.4, 3.1, 3.2, 4.4 DCR, DMO, DOE, DSIO, OCE

Strategic Initiative 1.1.4: Increase litigation support services

Definition: Litigation Support refers to all activities in supporting investigators and attorneys during the 

investigation and subsequent litigation of a matter. Support includes preparing and loading documents to an 

electronic document search and retrieval database system and preparing documents for production to 

opposing counsel. Litigation support also includes obtaining electronically stored information using proven 

digital forensics procedures; providing staff experienced in using software specifically designed for the legal 

environment to assist the investigators and attorneys in the use of the software; and providing technical 

support at trial with the presentation of animation, diagrams, visuals, or other persuasive graphics used by 

attorneys to help explain complex technology, issues or situations to jury members during a trial.

Purpose: Strategic Initiative 1.1.4 is necessary to technologically support the progress on enforcement and 

administrative matters. The Commission will continue to face rising case volumes and more complex 

enforcement actions as Dodd-Frank is operationalized. Providing enforcement staff with sufficient technical 

support resources increases their opportunity to focus on investigation and litigation strategically and 

tactically and also ensures that investments in technology provide full, realized benefits. Services will be 

increased as needed to ensure that technical and logistical support is sufficient to support the number of
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15 IT Strategic Goals, Objectives, and Strategies

enforcement actions.

Focus Areas for Projects: 

• eLaw Litigation Support

Strategic Plan Performance Indicator Support: The initiative will support the accomplishment of the 

following CFTC Strategic Plan Performance Indicators by increasing resources available to DOE:

• Percent of enforcement investigations completed within 18 months of opening, depending on the 

nature and scope of investigations.

Strategic Plan Strategy Support: The initiative will support the accomplishment of the following CFTC 

Strategic Plan Strategies:

• Solicit high quality tips, complaints and referrals from CFTC divisions and offices, and self-regulatory 

organizations

• Update eLaw technology to more effectively investigate and litigate cases and increase program 

efficiency

• Obtain and provide enforcement investigative assistance to and from international authorities.

Strategic Plan Goal and Objective Support:

CFTC Goal CFTC Objective Division/Office

3, 4 3.1-3.3, 4.4 DOE

Strategic Initiative 1.1.5: Continuously enhance eLaw program technology

Definition: The eLaw Program provides the attorneys and investigators with law office software tools to 

assist in the review and management of the large volumes of data received during the course of an 

investigation and/or litigation. eLaw supports the Division of Enforcement from the preliminary investigation 

process through to the courtroom presentation, and in all phases in between. The eLaw capabilities also 

support the Commission’s Reparations, FOIA, and Whistleblower programs. The tools in the eLaw suite

include document, transcript and audio search and retrieval tools. As technology advances and provides 

increased functionality, software needs to be evaluated for implementation within the suite of software 

applications eLaw provides to the attorneys and investigators.

Purpose: Strategic Initiative 1.1.5 is necessary to continuously enhancing eLaw program technology (e.g. 

case assessment and management, document review, eDiscovery, forensics, searching, audio analytics, data 

analytics) will address rising case volumes, complex enforcement actions, and extensive use of technology 

by opposing counsel. Since litigation support requirements are not unique to the Commission, using 

Commercial Off-the-Shelf (COTS) products is ideal and the sustained investment is comparable, in relative 

terms, to that of large industry participants.

COTS products will be continually upgraded and enhanced. Data storage capacity will be increased to 

support ever increasing volumes of digital evidence and analytic support databases. Computer forensics will 

continue to be enhanced to examine new types of digital evidence in a sound manner with the aim of 

identifying, preserving, recovering, analyzing and presenting facts and opinions about the information. 
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16 IT Strategic Goals, Objectives, and Strategies

Focus Areas for Projects: 

• Case Management Implementation

• eDiscovery Solution Implementation

• Document Review Solution Implementation

• Audio Analytics Implementation

• Forensics Data Collections and Analysis

• FOIA Solution Implementation

• Courtroom Solution Implementation

Strategic Plan Performance Indicator Support: The initiative will support the accomplishment of the 

following CFTC Strategic Plan Performance Indicators by leveling the IT-playing field between staff and those 

it investigates and opposing counsel and ensuring that staff has the tools needed to work effectively with 

other regulators:

• Strengthen and ensure a coordinated approach to receiving, assessing, and referring tips, complaints 

and referrals as necessary and appropriate; if resources permit, establish a unit or office dedicated 

to this function

• Percentage of enforcement investigations completed within 18 months of opening, depending on 

the nature and scope of investigations.

Strategic Plan Strategy Support: The initiative will support the accomplishment of the following CFTC 

Strategic Plan Strategies:

• Solicit high quality tips, complaints and referrals from CFTC divisions and offices, and self-regulatory 

organizations

• Update eLaw technology to more effectively investigate and litigate cases and increase program 

efficiency

• Obtain and provide enforcement investigative assistance to and from international authorities.

Strategic Plan Goal and Objective Support:

CFTC Goal CFTC Objective Division/Office

3, 4 3.1-3.3, 4.4 DOE, OGC, OED
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17 IT Strategic Goals, Objectives, and Strategies

Objective 1.2: Collaborate with the industry and divisions to automate business 

processes and data flows

Collaboration with the divisions and the industry to automate business processes and data flows will result 

in benefits to both the CFTC and the industry. The regulated community will be able to send data to the 

CFTC using industry-wide data standards. These data standards reduce misunderstandings. CFTC benefits 

through improved data quality and reduced manual intervention. For example, the CFTC will no longer need

to interpret hand-written responses on forms faxed to CFTC. CFTC will also have audit trails of data from 

initial receipt. CFTC will also be able to leverage business processes and algorithms that have been adopted 

by the industry and therefore spend less time developing algorithms from scratch.

The following IT Strategic Initiatives are described below:

1.2.1: Actively engage DCOs to identify and potentially re-use or extend margining and other 

software algorithms to meet unique Commission requirements

1.2.2: Increase integration between NFA and CFTC systems

1.2.3: Further integrate eLaw with other CFTC systems and processes

1.2.4: Provide technical support for regulatory reporting compliance

1.2.5: Building out of proof-of-concept programs by mission program staff.

Strategic Initiative 1.2.1: Actively engage DCOs to identify and potentially re-use or 

extend margining and other software algorithms to meet unique Commission 

requirements

Definition: Margin levels are set by the industry to cover potential losses during a one to five day period for 

Futures and Swaps. Properly set margin levels ensure the integrity of the derivatives marketplace by 

ensuring that counterparties can meet their obligations. What-if analysis or stress testing can be applied to 

derivative prices to see the impact on available margin at the firm, clearing member, clearing house, and 

DCM/SEF levels as well as to monitor overall systemic risk. Margin calculations on futures have been 

handled by CME’s SPAN Risk Manager. With the inclusion of swaps (e.g., interest rate swaps, credit default 

swaps, and commodity swaps) into CFTC regulatory purview, margin and risk analysis has become 

significantly more complicated as each swap asset class requires its own risk analysis methodology. Futures 

contracts have few configurable contract terms (i.e., quantity, price, and expiration month) whereas swaps 

can have hundreds of contract terms making risk management and margining much more difficult.

Purpose: Strategic Initiative 1.2.1 is necessary to evaluate and apply multiple margining models to conduct 

oversight of financial risk. There are no COTS products or best-of-breed solutions available that fulfill all of 

CFTC’s needs and DCO models are unique and proprietary. However, collaboration with DCOs and sharing 

of information about key algorithms will result in reduced CFTC systems development efforts. 

Focus Areas for Projects: 

• IRS Risk Analysis Implementation

• CDS Risk Analysis Implementation

• Position Risk Analysis Implementation
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18 IT Strategic Goals, Objectives, and Strategies

Strategic Plan Performance Indicator Support: The initiative will support the accomplishment of the 

following CFTC Strategic Plan Performance Indicators by allowing staff to apply multiple margining 

methodologies:

• CFTC strives to conduct back testing of DCOs’ material product and portfolio initial margin 

requirements to assess their sufficiency

• Clearing members’ ability to fund variation and initial margin requirements calculated in 

hypothetical CFTC-designed market scenarios

• Strive to aggregate cleared swaps, futures, and options positions into a comprehensive risk 

surveillance process and conduct analysis for each material market participant.

Strategic Plan Strategy Support: The initiative will support the accomplishment of the following CFTC 

Strategic Plan Strategies:

• Develop tools to back test financial resources and evaluate sufficiency of all material product and 

portfolio margin requirements

• Develop a program to monitor firm-level variation and initial margin requirements across DCOs

• Enhance the risk surveillance program to evaluate the risk of market participants positions held at 

multiple FCMs or DCOs

• Develop process to combine cleared and uncleared, bilateral positions to obtain a more complete 

picture of a clearing firm’s risk exposure.

Strategic Plan Goal and Objective Support:

CFTC Goal CFTC Objective Division/Office

2, 4 2.1, 4.3 DCR

Strategic Initiative 1.2.2: Increase integration between NFA and CFTC systems

Definition: 

NFA has been delegated the responsibility for registration for a variety of organization types including FCMs, 

IBs, CPOs, CTAs, SDs, and MSPs. The Commission works with the NFA to ensure that those seeking 

registration as intermediaries meet high qualification and fitness standards through the registration process. 

CFTC staff has access to NFA’s Online Registration System (ORS), FACTS 2000 and Query System database. 

Staff runs individual queries to extract information related to specific registration-related events, 

enforcement actions, and financial requirements about the intermediaries. DSIO Inspections access NFA 

systems on a daily to weekly basis to perform investigations on financial and demographic information of 

firms. DSIO Registration Compliance performs investigations within NFA’s audit recordkeeping logs, matter 

lists, and external tracking metrics on a weekly basis. DSIO Office of Counsel use NFA systems on a weekly to 

monthly basis to research firm demographics as enrichment to the swap registration forms. The Office of 

the Chief Economist (OCE) reference NFA firm fund identifiers on a monthly basis. Increasing the integration 

of NFA data into CFTC systems will improve CFTC’s ability to oversee the Futures and Swaps markets and 

reduce the manual effort necessary in accessing NFA systems.

Purpose: Strategic Initiative 1.2.2 is necessary to increase integration between NFA and CFTC systems (e.g., 

NFA FACTS 2000 and registration systems and the CFTC RSR system) through secure data transfers and use 

of portal services will increase staff efficiency by providing faster access to comprehensive participant data.
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Processes supporting oversight of registered participants will be automated through business process 

management software (BPMS) and integration of CFTC and NFA systems through secure services and 

automated data transfers in collaboration with NFA.

Focus Areas for Projects: 

• Financial Statement Review Implementation

• Position Risk Analysis Implementation

• Data Collection Business Process Automation

• Data Engineering and Processing

Strategic Plan Performance Indicator Support: The initiative will support the accomplishment of the 

following CFTC Strategic Plan Performance Indicators reducing the amount of time needed by staff to 

correlate data:

• Conduct governance and risk management oversight reviews for SDs and FCMs

• Review CCO annual reports for SDs, MSPs, and FCMs, and provide feedback to the registrants on 

governance and compliance oversight

• Conduct limited scope reviews of SD, MSP, and FCM risk management and internal control systems 

and procedures, including controls, processes and procedures over technology risks

• Monitor high-risk registrants including SD, MSPs, and FCMs for signs of financial stress.

Strategic Plan Strategy Support: The initiative will support the accomplishment of the following CFTC 

Strategic Plan Strategies:

• Through close coordination with NFA, the Commission will review registration documentation and 

the policies and procedures being employed by SDs and MSPs to achieve compliance with the CEA 

and the Commission’s regulations and that registrants operate with an effective governance and risk 

management structure

• Conduct oversight reviews of SD and MSP risk governance and risk management framework

• Together with the DSROs, monitor the CCO annual filings of SDs, MSPs, and FCMs and, in 

coordination with the DSROs, evaluate best practices, effectiveness of the evaluations, and areas for 

follow up with specific firms where the report does not meet expectations

• Conduct limited scope reviews of the risk management and internal control systems and procedures 

of SDs and FCMs

• Monitor firms for financial stress by, among other things, reviewing monthly and annual financial 

filings, as well as notice of specific events.

Strategic Plan Goal and Objective Support:

CFTC Goal CFTC Objective Division/Office

2, 4 2.2 – 2.4, 4.4 DOE, DSIO
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20 IT Strategic Goals, Objectives, and Strategies

Strategic Initiative 1.2.3: Further integrate eLaw with other CFTC systems and 

processes

Definition: The eLaw Program provides the attorneys and investigators with litigation software tools to 

assist in the review and management of the large volumes of data received during the course of an 

investigation and/or litigation. These tools include document, transcript and audio search and retrieval 

tools. The eLaw systems have limited integration with the Commission’s surveillance and compliance tools 

and the registration data set and further integration will improve efficiency as well as provide opportunities 

for CFTC to perform unique analysis across data sets.

Purpose: Strategic Initiative 1.2.3 is necessary to enhance integration of enforcement tools and processes 

with other the work of other divisions that lead to referrals. Further integration of eLaw tools throughout 

the Commission will enable more proactive identification of high-impact enforcement leads and will support 

faster and more comprehensive exchange of information between registration, compliance, and surveillance 

activities, thereby prioritizing oversight based on risk and patterns of non-compliance. The process of 

managing referrals to the enforcement staff from other divisions will be automated and integrated.

Focus Areas for Projects: 

• Case Management Implementation

• Business Process Management Solution Implementation

• Data Engineering and Processing.

Strategic Plan Performance Indicator Support: The initiative will support the accomplishment of the 

following CFTC Strategic Plan Performance Indicators by increasing appropriate collaboration within the 

Commission:

• Strengthen and ensure a coordinated approach to receiving, assessing, and referring tips, 

complaints and referrals as necessary and appropriate; if resources permit, establish a unit or office 

dedicated to this function.

Strategic Plan Strategy Support: The initiative will support the accomplishment of the following CFTC 

Strategic Plan Strategies:

• Solicit high quality tips, complaints and referrals from CFTC divisions and offices, and self-regulatory 

organizations.

Strategic Plan Goal and Objective Support:

CFTC Goal CFTC Objective Division/Office

1-4 1.1, 2.3, 2.4, 3.1, 3.2, 4.4 DCR, DMO, DOE, DSIO

Strategic Initiative 1.2.4: Provide technical support for regulatory reporting 

compliance

Definition: CFTC currently receives a wide range of submissions as part of firms’ regulatory reporting 

compliance programs. These submissions are sent to CFTC through a variety of methods including paper, 

fax, e-mail, CFTC portal, and FTP (i.e., batch data transfer). CFTC is moving forward with a regulatory portal 
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21 IT Strategic Goals, Objectives, and Strategies

for infrequent submissions and FTP for daily large submissions. This will reduce errors caused by 

interpreting and re-keying data at CFTC and will reduce the amount of manual tasks freeing staff to perform

higher-level tasks. This approach will also require firms to correct their data before they submit it to the 

CFTC which will improve data quality while decreasing the effort to manage this data.

Purpose: Strategic Initiative 1.2.4 is necessary to improve data reporting compliance mechanisms. It will 

allow staff to conduct registrations and reviews more efficiently. Increasing integration between reporting 

compliance and surveillance activities will benefit ongoing surveillance activities. Data collections that are 

form based will appear on the CFTC regulatory portal, with edits to ensure data quality prior to submission. 

These forms will replace the forms previously received via fax or email, and be auto-populated wherever 

possible to save time for submitters in data entry. For large volume data reporting, CFTC is improving 

automation of feedback mechanisms to data submitters in order to improve data quality at the source, 

thereby reducing the amount of data quality challenges and follow up activities required by Commission 

staff. This initiative requires continual collaboration with reporting entities.

Staff will be provided with a single data management console to review and correct swaps, futures and 

options data received by the Commission; the console will automate compliance and completeness reports, 

non-compliance and data error alerts, and data change audits. Furthermore, to improve data quality and 

standardization, guidebooks for all registered entity data will be developed and data submitters will receive 

automated notifications when errors are detected or expected data is missing.

Focus Areas for Projects: 

• Data Engineering and Processing

• Data Operations and Collections.

Strategic Plan Performance Indicator Support: The initiative will support the accomplishment of the 

following CFTC Strategic Plan Performance Indicators by making it easier for industry participants to comply 

with regulations and for staff to have a comprehensive view of each participant:

• Strive for percentage of high impact contract and rule submissions received by the Commission 

through the OPERA portal

• Strive to strengthen capacity to receive and expeditiously evaluate all trading data and associated 

information to identify potential violations of the CEA or Commission regulations and the timely 

response to market emergencies

• Strive to examine compliance by exchanges with the CEA Core Principles and Commission 

regulations, prioritizing systemically important entities

• Strive to review exchange and SDR notifications and periodic status updates regarding significant 

systems disruptions and material planned changes to mission-critical systems or programs of risk 

analysis and oversight

• Percentage of derivatives for which trader data can be matched across CFTC datasets

• Strive to review DCO notifications regarding systems disruptions, material planned changes to 

mission-critical systems or programs of risk analysis and any other notifications that potentially 

impact the DCOs ability to process, clear and risk manage its business activities

• Number of SD, MSP, and FCM annual and quarterly reports reviewed and feedback provided; 

percent of swap dealer and major swap participant’s registration documentation completed

• Review CCO annual reports for SDs, MSPs, and FCMs, and provide feedback to the registrants on 

governance and compliance oversight

• Monitor high-risk registrants including SD, MSPs, and FCMs for signs of financial stress.
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22 IT Strategic Goals, Objectives, and Strategies

Strategic Plan Strategy Support: The initiative will support the accomplishment of the following CFTC 

Strategic Plan Strategies:

• Review derivatives contract terms and conditions more efficiently and effectively

• Analysis of DCM, SEF, and Foreign Boards of Trade (FBOT) registration applications and the ongoing 

oversight of DCMs, SEFs, and FBOTs.

• Review of SDR applications and the ongoing supervision of SDRs

• Through close coordination with NFA, the Commission will review registration documentation and 

the policies and procedures being employed by SDs and MSPs to achieve compliance with the CEA 

and the Commission’s regulations and that registrants operate with an effective governance and risk 

management structure

• Together with the DSROs, monitor the CCO annual filings of SDs, MSPs, and FCMs and, in 

coordination with the DSROs, evaluate best practices, effectiveness of the evaluations, and areas for 

follow up with specific firms where the report does not meet expectations

• Monitor firms for financial stress by, among other things, reviewing monthly and annual financial 

filings, as well as notice of specific events.

Strategic Plan Goal and Objective Support:

CFTC Goal CFTC Objective Division/Office

1, 2 1.1, 1.2, 2.1 – 2.4 DCR, DMO, DSIO

Strategic Initiative 1.2.5: Building out of proof-of-concept programs by mission 

program staff

Definition: The process of having surveillance staff establish requirements for the development of systems

and then have ODT develop those requirements in a waterfall approach is not rapid or agile enough for 

surveillance staff to iteratively test and apply innovative surveillance approaches. Instead, models and 

prototypes developed directly by surveillance staff that are determined to be worth executing daily or on 

some other recurring basis will be operationalized by technology staff. This approach allows surveillance 

staff to define their business requirements as they iterate through their proof of concept, and determining 

how technologists can add additional technological capabilities for solutions that have persistent value.

Purpose: Strategic Initiative 1.2.5 is necessary to enable Commission staff to have the means of working 

through the process of analyzing voluminous transaction and position data to conduct surveillance activities. 

With access to the data received by the Commission daily and the tools to create surveillance models, staff 

can innovate on new surveillance techniques that address CFTC-specific requirements. With the assistance 

of computer aided tools such as graphics and visualization software or automated anomaly detection 

models, staff will identify patterns of activity that may indicate possible violations of the CEA by one or more 

individuals. Staff will make use of newly available technologies to blend data from different data sources, 

such as futures and swaps position data, trade execution data and order data, and develop new methods to 

analyze trading within and across products and markets. Proof of concepts innovated by staff will be 

operationalized, enhanced, and adapted over time to address evolving market conditions. The results of 

these analyses will be shared across CFTC market, financial risk, and participant surveillance programs. 
IT Strategic Plan 2014

23 IT Strategic Goals, Objectives, and Strategies

Focus Areas for Projects: 

• Staff Proof-of-concept Development 

• Data Discovery/Data Visualization Tools Implementation

• Financial Statement Review Implementation

• Position Risk Analysis Implementation

• Business Process Management Software (BPMS).

Strategic Plan Performance Indicator Support: The initiative will support the accomplishment of the 

following CFTC Strategic Plan Performance Indicators by having staff rapidly develop and apply new market 

and financial surveillance techniques:

• Strive to strengthen capacity to receive and expeditiously evaluate all trading data and associated 

information to identify potential violations of the CEA or Commission regulations and the timely 

response to market emergencies

• CFTC strives to conduct back testing of DCOs’ material product and portfolio initial margin 

requirements to assess their sufficiency

• Clearing members’ ability to fund variation and initial margin requirements calculated in 

hypothetical CFTC-designed market scenarios

• Strive to aggregate cleared swaps, futures, and options positions into a comprehensive risk 

surveillance process and conduct analysis for each material market participant

• Monitor high-risk registrants including SD, MSPs, and FCMs for signs of financial stress

• Strengthen and ensure a coordinated approach to receiving, assessing, and referring tips, 

complaints and referrals as necessary and appropriate; if resources permit, establish a unit or office 

dedicated to this function.

Strategic Plan Strategy Support: The initiative will support the accomplishment of the following CFTC 

Strategic Plan Strategies:

• Develop and implement technology based surveillance tools to keep pace with market technology

• Develop tools to back test financial resources and evaluate sufficiency of all material product and 

portfolio margin requirements

• Develop a program to monitor firm-level variation and initial margin requirements across DCOs

• Enhance the risk surveillance program to evaluate the risk of market participants positions held at 

multiple FCMs or DCOs

• Develop process to combine cleared and uncleared, bilateral positions to obtain a more complete 

picture of a clearing firm’s risk exposure

• Solicit high quality tips, complaints and referrals from CFTC divisions and offices, and self-regulatory 

organizations.

Strategic Plan Goal and Objective Support:

CFTC Goal CFTC Objective Division/Office

1-4 1.1, 2.1-2.3, 3.1, 3.2, 4.4 DCR, DMO, DOE, DSIO
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24 IT Strategic Goals, Objectives, and Strategies

Objective 1.3: Provide enterprise solutions aligned with industry best practices

In order to cost-efficiently meet the business / regulatory needs at CFTC, enterprise-wide solutions are used 

whenever possible. This is in line with ODT’s IT Strategic Priority for enterprise-focused automation services. 

Enterprise-wide solutions promote re-use, information sharing, standardization of common practices, and 

collaboration. Many requirements are common across mission areas and across the industry as a whole. 

Additionally, industry best practices (e.g., data standards, portfolio margining models, web services for data 

reporting) should be utilized to reduce implementation time and implementation cost.

The following IT Strategic Initiatives are described below:

1.3.1: Increase use of Application Programming Interfaces (APIs) and web services for regulatory 

data reporting

1.3.2: Use industry-standard tools (e.g., to evaluate FCM, CPO, and other participant financial risk).

Strategic Initiative 1.3.1: Increase use of Application Programming Interfaces (APIs) 

and web services for regulatory data reporting

Definition: Common development best practices will be used to enable straight-thru processing (data 

passing directly from industry applications to the Commission without human intervention) between 

industry participants and CFTC systems wherever practical. APIs and web services provide mechanisms for 

systems at CFTC to interact with external systems (e.g., Bloomberg data services, ICE margining systems) 

minimizing the development efforts at CFTC. Additionally CFTC will use APIs and web services as a 

methodology to loosely couple systems internally (e.g., BPMS, portal). By using standardized external APIs 

and web services, ODT minimizes the effort of developing, testing and maintaining of software. By exposing 

APIs and web services to industry participants, CFTC ensures data received at the commission has already 

passed rigorous data quality checks.

Purpose: Strategic Initiative 1.3.1 is necessary to facilitate rapid development of systems and will lead to a 

reduced reporting burden for industry participants. Increasing use of publicly available and industry 

provided APIs and data services will also support more timely collection of correlated data for staff. 

Focus Areas for Projects: 

• CFTC Portal Implementation

• Participant Registration Processes and Systems

• Business Process Management Software (BPMS)

• Data Engineering and Processing.

Strategic Plan Performance Indicator Support: The initiative will support the accomplishment of the 

following CFTC Strategic Plan Performance Indicators by reducing systems development cost and time for 

the Commission and industry participants:

• Strive for percentage of high impact contract and rule submissions received by the Commission 

through the OPERA portal

• Strive to strengthen capacity to receive and expeditiously evaluate all trading data and associated 

information to identify potential violations of the CEA or Commission regulations and the timely 

response to market emergencies

• Strive to examine compliance by exchanges with the CEA Core Principles and Commission 

regulations, prioritizing systemically important entities
IT Strategic Plan 2014

25 IT Strategic Goals, Objectives, and Strategies

• Strive to review exchange and SDR notifications and periodic status updates regarding significant 

systems disruptions and material planned changes to mission-critical systems or programs of risk 

analysis and oversight

• Percentage of derivatives for which trader data can be matched across CFTC datasets

• Strive to review DCO notifications regarding systems disruptions, material planned changes to 

mission-critical systems or programs of risk analysis and any other notifications that potentially 

impact the DCOs ability to process, clear and risk manage its business activities

• Number of SD, MSP, and FCM annual and quarterly reports reviewed and feedback provided; 

percent of swap dealer and major swap participant’s registration documentation completed

• Review CCO annual reports for SDs, MSPs, and FCMs, and provide feedback to the registrants on 

governance and compliance oversight

• Monitor high-risk registrants including SD, MSPs, and FCMs for signs of financial stress.

Strategic Plan Strategy Support: The initiative will support the accomplishment of the following CFTC 

Strategic Plan Strategies:

• Review derivatives contract terms and conditions more efficiently and effectively

• Analysis of DCM, SEF, and Foreign Boards of Trade (FBOT) registration applications and the ongoing 

oversight of DCMs, SEFs, and FBOTs.

• Review of SDR applications and the ongoing supervision of SDRs

• Through close coordination with NFA, the Commission will review registration documentation and 

the policies and procedures being employed by SDs and MSPs to achieve compliance with the CEA 

and the Commission’s regulations and that registrants operate with an effective governance and risk 

management structure

• Together with the DSROs, monitor the CCO annual filings of SDs, MSPs, and FCMs and, in 

coordination with the DSROs, evaluate best practices, effectiveness of the evaluations, and areas for 

follow up with specific firms where the report does not meet expectations

• Monitor firms for financial stress by, among other things, reviewing monthly and annual financial 

filings, as well as notice of specific events.

Strategic Plan Goal and Objective Support:

CFTC Goal CFTC Objective Division/Office

1, 2 1.1, 1.2, 2.1–2.3 DCR, DMO, DSIO

Strategic Initiative 1.3.2: Use industry-standard tools (e.g., to evaluate FCM, CPO, 

and other participant financial risk)

Definition: Instead of building financial risk assessment tools from scratch, ODT will use industry-standard 

tools, thereby reducing overall development and maintenance efforts. The CFTC Strategic Plan requires the 

following strategy for Goal 2: conduct limited scope reviews of FCMs and swap dealers risk management and 

internal control systems and procedures. This initiative will ensure that Commission staff uses common 

industry tools to reduce costs.

Purpose: Strategic Initiative 1.3.2 is necessary to define and utilize, where practical, an established set of 
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26 IT Strategic Goals, Objectives, and Strategies

tools in use by FCMs, CPOs, and swap participants to evaluate their own financial risk. Best-of-breed tools 

will be identified, acquired, and implemented to enable staff to use familiar and commonly used software. 

Use of the tools will be integrated with CFTC systems and enterprise data using data services whenever 

practical to increase overall process automation and data reuse.

Focus Areas for Projects: 

• DSIO Tool Identification and Implementation

• Data Engineering and Processing.

Strategic Plan Performance Indicator Support: The initiative will support the accomplishment of the 

following CFTC Strategic Plan Performance Indicators by encouraging rapid acquisition of tools for DSIO 

staff:

• Number of SD, MSP, and FCM annual and quarterly reports reviewed and feedback provided; 

percent of swap dealer and major swap participant’s registration documentation completed

• Conduct governance and risk management oversight reviews for SDs and FCMs

• Review CCO annual reports for SDs, MSPs, and FCMs, and provide feedback to the registrants on 

governance and compliance oversight

• Conduct limited scope reviews of SD, MSP, and FCM risk management and internal control systems 

and procedures, including controls, processes and procedures over technology risks

• Monitor high-risk registrants including SD, MSPs, and FCMs for signs of financial stress.

Strategic Plan Strategy Support: The initiative will support the accomplishment of the following CFTC 

Strategic Plan Strategies:

• Conduct oversight reviews of SD and MSP risk governance and risk management framework

• Together with the DSROs, monitor the CCO annual filings of SDs, MSPs, and FCMs and, in 

coordination with the DSROs, evaluate best practices, effectiveness of the evaluations, and areas for 

follow up with specific firms where the report does not meet expectations

• Conduct limited scope reviews of the risk management and internal control systems and procedures 

of SDs and FCMs

• Monitor firms for financial stress by, among other things, reviewing monthly and annual financial

filings, as well as notice of specific events.

Strategic Plan Goal and Objective Support:

CFTC Goal CFTC Objective Division/Office

2, 4 2.4, 4.3 DSIO
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27 IT Strategic Goals, Objectives, and Strategies

Goal 2 - Facilitate availability and enhance understanding of data to 

improve regulatory effectiveness

The CFTC increasingly and unavoidably relies on its understanding of data to ensure that it can perform its 

regulatory and public policy functions effectively. As the markets and participants it oversees 

overwhelmingly turn electronic, engage in faster and more automated trading, and transact in products that 

are more and more complex, the CFTC increasingly needs to be a regulator that understands, aggregates, 

processes, summarizes, and acts on data in a timely manner for surveillance, enforcement and transparency 

reporting. The markets and participants that CFTC regulates generate and report to the CFTC a large

quantity of information from multiple industry sources across multiple markets. Increasing speed, volume,

and complexity in these products and markets require the CFTC to develop an increasingly sophisticated 

ability to validate and pre-digest the reported data so that front-line regulatory functions such as 

surveillance and enforcement can more effectively use that data. In addition, even as the CFTC’s regulatory 

regime has expanded to include swaps, it needs to ensure that not only is the swaps oversight integrated 

into the existing program initiatives, but also that the existing program and processes are upgraded ability to 

keep up with new techniques and technologies. Thus, data management is essential to all of CFTC’s 

regulatory initiatives and, in particular, to integrating swaps oversight into existing program initiatives.

Timely and effective surveillance analysis, aggregation, and risk analysis are critical to the CFTC’s ability to 

oversee the markets effectively. CFTC’s data management program has to ensure that it responds both 

broadly and specifically to address the critical regulatory needs of the Commission:

• A standards-based, responsive, robust and flexible data architecture as an essential pre-requisite

and ensures that confidentiality, availability and integrity of the data are maintained in line with the 

Commission’s mission and federal government requirements

• A capable data standards program that provides guidance to the industry on the data reporting and 

recordkeeping aspects of CFTC’s rules and guidance that the CFTC staff can rely on for

understanding the data reported 

• A robust reference data management program that ensures that key identifier and product data 

used by the CFTC staff for data reporting, analysis, aggregating and surveillance is valid, correct and 

current

• A data analysis component that reviews incoming data to ensure that upfront analyses, reviews, 

extracts, reports, and alerts are effective and that data quality can be measured, reported and 

addressed as needed

• A data harmonization program that includes oversight of data custodial programs operated by the 

industry, such as Swap Data Repositories (SDRs), Exchanges, Swap Execution Facilities (SEFs),

Designated Clearing Organizations (DCOs) and Designated Clearing Members (DCMs). Industry 

programs must contribute to effectively supporting the Commission’s mission, result in acceptable 

data quality, and ensure that data is well-protected in terms of data integrity, confidentiality and 

availability

• An automated, responsive, robust and high-quality data ingest program that ensures that there is 
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28 IT Strategic Goals, Objectives, and Strategies

sufficient capacity to take in, validate, rectify and make available to CFTC staff the data that is 

reported and transmitted to the Commission by the participants the Commission regulates

• A front-end data operations program that reviews the data that is ingested, ensures compliance 

with reporting and recordkeeping requirements, and conducts effective data audits of regulated 

entities to ensure that their policies and processes are supportive of consistent, timely and highquality reporting and recordkeeping.

The following IT Strategic Objectives are directly linked to the above components and are described under 

Goal 2:

2.1: Architect data to enable automated ingestion, integration, access, sharing, reporting and 

transparency

2.2: Aggregate data across markets and participants to empower the CFTC staff to perform complex 

data analyses

2.3: Manage information to ensure its availability to the regulatory mission activities and the public.

Objective 2.1: Architect data to enable automated ingestion, integration, access, 

sharing, reporting and transparency

One of the pre-requisites to enabling market transparency and regulatory effectiveness through reporting is 

architecting data, that is, defining what data types are being collected, their relationships, and relevant data 

standards and logically organizing data. Integration of swaps oversight into existing CFTC mission functions 

will require ODT to create an integrated enterprise data environment that supports both swaps and futures 

oversight and to define new data standards and submission requirements. Architecting data at the 

enterprise level and using a standards-based approach for data interchanges and submissions, particularly 

for information needed by regulators, will promote information integration, sharing, and re-use.

The following IT Strategic Initiatives are described below:

2.1.1: Receive all data electronically and automate its distribution throughout the Commission using 

business process automation software (BPMS)

2.1.2: Improve data quality.

Strategic Initiative 2.1.1: Receive all data electronically and automate its distribution 

throughout the Commission using business process automation software (BPMS)

Definition: Receiving all data electronically and automating the data flow within the Commission will 

improve productivity through streamlined data ingest, registrations, reviews, and reporting. It will include

automatic updating of CFTC systems and eliminating latency between industry submission of data and staff

ability to use the data. It will provide industry participants with up-to-date information about submission 

status and lead to a reduced reporting burden.

Purpose: Strategic Initiative 2.1.1 is necessary to ensure that all data will be submitted and processed 

electronically, including Ownership Control Reporting (OCR), all registrations, Large Trader Reporting (Parts 

16 and 17), aggregated SDR reporting, and Order Data submissions. Use of the CFTC Portal and 

Organizations, Product, Events, Rules and Actions (OPERA which allows organizations to make submissions 
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29 IT Strategic Goals, Objectives, and Strategies

to the Commission through the CFTC Portal) will reduce staff burdens and increase the efficiency with which 

staff conducts reviews of new or amended contracts and rule filings. Exchanges will be able to electronically 

file submissions directly with the Commission. All key mission processes will be fully automated and 

integrated with Electronic Records and Document Management (ERDM). Dashboards will provide 

transparency and management visibility into process status.

Focus Areas for Projects: 

• CFTC Regulatory Portal

• OPERA

• ERDM

• Business Process Management Software (BPMS).

Strategic Plan Performance Indicator Support: The initiative will support the accomplishment of the 

following CFTC Strategic Plan Performance Indicators by streamlining registration and review processes:

• Strive for percentage of high impact contract and rule submissions received by the Commission 

through the OPERA portal

• Strive to strengthen capacity to receive and expeditiously evaluate all trading data and associated 

information to identify potential violations of the CEA or Commission regulations and the timely 

response to market emergencies

• Strive to examine compliance by exchanges with the CEA Core Principles and Commission 

regulations, prioritizing systemically important entities

• Strive to review exchange and SDR notifications and periodic status updates regarding significant 

systems disruptions and material planned changes to mission-critical systems or programs of risk 

analysis and oversight

• Percentage of derivatives for which trader data can be matched across CFTC datasets

• Strive to review DCO notifications regarding systems disruptions, material planned changes to 

mission-critical systems or programs of risk analysis and any other notifications that potentially 

impact the DCOs ability to process, clear and risk manage its business activities

• Number of SD, MSP, and FCM annual and quarterly reports reviewed and feedback provided; 

percent of swap dealer and major swap participant’s registration documentation completed

• Review CCO annual reports for SDs, MSPs, and FCMs, and provide feedback to the registrants on 

governance and compliance oversight

• Monitor high-risk registrants including SD, MSPs, and FCMs for signs of financial stress.

Strategic Plan Strategy Support: The initiative will support the accomplishment of the following CFTC 

Strategic Plan Strategies:

• Review derivatives contract terms and conditions more efficiently and effectively

• Analysis of DCM, SEF, and Foreign Boards of Trade (FBOT) registration applications and the ongoing 

oversight of DCMs, SEFs, and FBOTs.

• Review of SDR applications and the ongoing supervision of SDRs

• Through close coordination with NFA, the Commission will review registration documentation and 

the policies and procedures being employed by SDs and MSPs to achieve compliance with the CEA 

and the Commission’s regulations and that registrants operate with an effective governance and risk 

management structure

• Together with the DSROs, monitor the CCO annual filings of SDs, MSPs, and FCMs and, in 
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30 IT Strategic Goals, Objectives, and Strategies

coordination with the DSROs, evaluate best practices, effectiveness of the evaluations, and areas for 

follow up with specific firms where the report does not meet expectations

• Monitor firms for financial stress by, among other things, reviewing monthly and annual financial 

filings, as well as notice of specific events.

Strategic Plan Goal and Objective Support:

CFTC Goal CFTC Objective Division/Office

1-3 1.1-1.4, 2.1-2.4, 3.1 DCR, DMO, DOE, DSIO

Strategic Initiative 2.1.2: Improve data quality

Definition: It is essential that the Commission proactively manage the quality of the data used to conduct 

oversight and is able to certify the accuracy and completeness of data. Data quality will be improved by 

both standards and processes. Data standards such as FIXml and FpML, which are industry standards, will 

be adopted and enhanced to ensure that reporting firms and the CFTC have a shared understanding of field 

definitions, types and values. Since most firms have already adopted these standards, this will reduce the 

effort required to move to this more flexible standard. The data loading process will be improved and fully 

implement the CFTC Regulatory Portal to eliminate manually keying and correcting forms and submissions. 

Data quality will be further improved by enhancing error detection when loading large data file submissions. 

Firms submitting data will send their data to automated data ingest systems at the CFTC that will check the 

data for errors, report error conditions, and reject records or the entire file as appropriate. This will 

incentivize firms to resolve consistent errors as they will be forced to resolve the same types of errors day 

after day. This will also reduce staff burdens by eliminating time required to key in data, review errors, 

contact firms to request corrections, and reprocess files. The Commission will also improve quality of data 

through better implementation of reporting rules, data audits, data management practices, and technology. 

The Commission will focus on enterprise reference data and will streamline processes for and increasing 

controls around ad-hoc and recurring data requests from market participants. The CFTC will implement a 

controlled unclassified information (CUI) program, additional controls for high-risk personally identifiable 

information (PII) and research data, and information security continuous monitoring. Collectively these 

activities will improve the effectiveness of both mission area and mission support analysis and decisionmaking.

Leveraging data management activities related to standards and improving quality, this initiative will 

establish ownership of and accountability for authoritative source data and implement policy and 

procedures necessary to provide transparency of management and system controls over sensitive CFTC 

information.

Purpose: Strategic Initiative 2.1.2 is necessary to ensure that data will be appropriately standardized, 

described, tagged, and harmonized to improve data quality. Improving data quality reduces rework, reduces 

the time it takes to conduct complex data analyses, and reduces systems development and maintenance 

costs. Data standards will be harmonized for all SDR data. Guidebooks and standards will be published for 

all CFR parts with data reporting requirements. Data quality standards, metrics and measures will be 

established and be reported on daily, weekly, and monthly. Data edit checks will be enhanced to reduce the 

level of incomplete data.
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31 IT Strategic Goals, Objectives, and Strategies

Focus Areas for Projects: 

• Data Standards Implementation

• Data Operations and Collection Automation

• Data request process

• Information Governance (Controlled Unclassified Information - CUI).

Strategic Plan Performance Indicator Support: The initiative will support the accomplishment of the 

following CFTC Strategic Plan Performance Indicators by reducing redundancy and rework:

• Strive to strengthen capacity to receive and expeditiously evaluate all trading data and associated 

information to identify potential violations of the CEA or Commission regulations and the timely 

response to market emergencies

• Percentage of derivatives activity covered by regularly published Commission reports

• Publish economic research reports to inform the public about market structure of the derivatives 

markets

• Percentage of derivatives for which trader data can be matched across CFTC datasets

• CFTC strives to conduct back testing of DCOs’ material product and portfolio initial margin 

requirements to assess their sufficiency

• Clearing members’ ability to fund variation and initial margin requirements calculated in 

hypothetical CFTC-designed market scenarios

• Strive to aggregate cleared swaps, futures, and options positions into a comprehensive risk 

surveillance process and conduct analysis for each material market participant

• Strengthen and ensure a coordinated approach to receiving, assessing, and referring tips, complaints 

and referrals as necessary and appropriate; if resources permit, establish a unit or office dedicated 

to this function.

Strategic Plan Strategy Support: The initiative will support the accomplishment of the following CFTC 

Strategic Plan Strategies:

• Develop and implement technology based surveillance tools to keep pace with market technology

• Develop consistent reporting of relevant swaps data

• Publish Interactive Reports on Swap Market Activity

• Conduct economic analysis and research on market structure and transparency for derivatives

• Develop tools to back test financial resources and evaluate sufficiency of all material product and 

portfolio margin requirements

• Develop a program to monitor firm-level variation and initial margin requirements across DCOs

• Enhance the risk surveillance program to evaluate the risk of market participants positions held at 

multiple FCMs or DCOs

• Develop process to combine cleared and uncleared, bilateral positions to obtain a more complete 

picture of a clearing firm’s risk exposure

• Monitor firms for financial stress by, among other things, reviewing monthly and annual financial 

filings, as well as notice of specific events

• Solicit high quality tips, complaints and referrals from CFTC divisions and offices, and self-regulatory 

organizations.
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32 IT Strategic Goals, Objectives, and Strategies

Strategic Plan Goal and Objective Support:

CFTC Goal CFTC Objective Division/Office

1-4 1.1-1.4, 2.1, 2.4, 3.1, 3.2, 4.2, 4.4 DCR, DMO, DOE, DSIO, OCE, OIA

Objective 2.2: Aggregate data across markets and participants to empower the 

CFTC staff to perform complex data analyses

The CFTC surveillance mission function is highly dependent on the ability to understand large volumes of 

data and develop sophisticated analytics to identify trends and/or outlying events that warrant further 

investigation. The first step to effective management of this information is its understanding and 

aggregation, including definition, cataloguing, correlating with other data types and evaluation at multiple 

levels. The futures and swaps markets are complex and understanding who owns or controls positions 

across the wide spectrum of markets that CFTC regulates is critical to economic analysis and investigations. 

Aggregating data across markets and participants will make this possible.

The following IT Strategic Initiatives are described below:

2.2.1: Increase application of data standards, including Legal Entity Identifiers (LEIs) and product 

identifiers (UPIs)

2.2.2: Harmonize SDR data.

Strategic Initiative 2.2.1: Increase application of data standards, including Legal 

Entity Identifiers (LEIs) and product identifiers (UPIs)

Definition: Data standards provide easier, less expensive data sharing and transfer by providing regulators 

and diverse industry participants with common terms, format, and quality standards. Consistently used 

identifiers are key part of applying data standards for the purpose of data aggregation, whether it is 

aggregation at the counterparty level, product level, or some other level. LEIs are part of a unique 

identification system for parties to financial transactions being adopted by financial markets globally. They 

are important for the CFTC to be able to cost-effectively determine the controlling and benefitting party to 

every derivatives transaction. UPIs are unique product identifiers for standardized derivatives. UPIs will 

allow the Commission to cost-effectively determine the characteristics of most derivatives transactions. 

Purpose: Strategic Initiative 2.2.1 is necessary to apply standards in support of more efficient data 

aggregation. Customer and account level aggregation across related markets is necessary to more 

comprehensively assess risk. Product, customer, and account aggregation is necessary to monitor market 

power and position limits. Comprehensive use of data standards will support more efficient aggregation at 

various levels and dimensions and will enable staff to more easily discover new approaches to correlating 

data for surveillance and economic analysis. The Commission will lead global establishment of entity, 

product and transaction data standards. A standardized guidebook and handbook for substituted 

compliance for all relevant jurisdictions will be developed. LEIs and UPIs will be extended to include futures

as well as swaps. 

Focus Areas for Projects: 

• LEI
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33 IT Strategic Goals, Objectives, and Strategies

• UPI

• Reference data catalog

• Integration of LEI and UPI with all data services and systems.

Strategic Plan Performance Indicator Support: The initiative will support the accomplishment of the 

following CFTC Strategic Plan Performance Indicators by reducing the cost and time to aggregate data and 

increase the accuracy of aggregated data:

• Strive to strengthen capacity to receive and expeditiously evaluate all trading data and associated 

information to identify potential violations of the CEA or Commission regulations and the timely 

response to market emergencies

• Percentage of derivatives activity covered by regularly published Commission reports

• Publish economic research reports to inform the public about market structure of the derivatives 

markets

• Percentage of derivatives for which trader data can be matched across CFTC datasets

• CFTC strives to conduct back testing of DCOs’ material product and portfolio initial margin 

requirements to assess their sufficiency

• Clearing members’ ability to fund variation and initial margin requirements calculated in 

hypothetical CFTC-designed market scenarios

• Strive to aggregate cleared swaps, futures, and options positions into a comprehensive risk 

surveillance process and conduct analysis for each material market participant

• Strengthen and ensure a coordinated approach to receiving, assessing, and referring tips, complaints 

and referrals as necessary and appropriate; if resources permit, establish a unit or office dedicated 

to this function.

Strategic Plan Strategy Support: The initiative will support the accomplishment of the following CFTC 

Strategic Plan Strategies:

• Develop and implement technology based surveillance tools to keep pace with market technology

• Develop consistent reporting of relevant swaps data

• Publish Interactive Reports on Swap Market Activity

• Conduct economic analysis and research on market structure and transparency for derivatives

• Develop tools to back test financial resources and evaluate sufficiency of all material product and 

portfolio margin requirements

• Develop a program to monitor firm-level variation and initial margin requirements across DCOs

• Enhance the risk surveillance program to evaluate the risk of market participants positions held at 

multiple FCMs or DCOs

• Develop process to combine cleared and uncleared, bilateral positions to obtain a more complete 

picture of a clearing firm’s risk exposure

• Monitor firms for financial stress by, among other things, reviewing monthly and annual financial 

filings, as well as notice of specific events

• Solicit high quality tips, complaints and referrals from CFTC divisions and offices, and self-regulatory 

organizations.
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34 IT Strategic Goals, Objectives, and Strategies

Strategic Plan Goal and Objective Support:

CFTC Goal CFTC Objective Division/Office

1-4 1.1, 1.3, 1.4, 2.1, 2.4, 3.1, 3.2, 4.2, 4.4 DCR, DMO, DOE, DSIO, OCE, OIA

Strategic Initiative 2.2.2: Harmonize SDR data

Definition: Swaps Data Repositories collect and maintain over-the-counter (OTC) derivative trade records. 

Though SDRs make these records available to CFTC, the data elements or even specific fields are not defined 

or reported in a similar manner. Even within an SDR, different trading firms may report data inconsistently 

(e.g., using different codes to represent trades in crude oil). Therefore it can be difficult to analyze SDR 

data. SDRs must standardize the data elements and content for the CFTC to aggregate data across SDRs.

Purpose: Strategic Initiative 2.2.2 is necessary to SDR data harmonization. Harmonized SDR data will 

support more efficient data aggregation. Though industry must have the latitude to make cost-effective 

design and implementation decisions in operationalizing SDRs, the collective set of information across SDRs 

must be consistent, transparent and usable by regulators and will require a concerted effort by all 

participants initially (as SDRs begin operating) and a sustained level of effort to integrate new products and 

accommodate market evolution.

The Commission will continue close collaboration with SDRs to identify and resolve data consistency and 

access issues, establishing best practices and common approaches whenever practical. Subsets of SDR data 

required for integration with CFTC systems will be received daily. Currently, SDRs have different validation 

models, making rules for acceptance and rejection of the submitter’s records inconsistent; receive different 

content for certain data fields; and provide different functionality within their regulatory portals. CFTC will 

identify the best capabilities of each SDR and make them requirements for others to achieve the highest 

common denominator of standardization and capability. Foreign SDRs must also have harmonized data to 

enable efficient cross-border regulation.

Focus Areas for Projects: 

• SDR compliance

• Reporting completeness and compliance

• Data Services.

Strategic Plan Performance Indicator Support: The initiative will support the accomplishment of the 

following CFTC Strategic Plan Performance Indicators by ensuring SDRs operate as intended by financial 

reform legislation and regulation:
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35 IT Strategic Goals, Objectives, and Strategies

• Strive to strengthen capacity to receive and expeditiously evaluate all trading data and associated 

information to identify potential violations of the CEA or Commission regulations and the timely 

response to market emergencies

• Percentage of derivatives activity covered by regularly published Commission reports

• Publish economic research reports to inform the public about market structure of the derivatives 

markets

• Percentage of derivatives for which trader data can be matched across CFTC datasets

• Strive to aggregate cleared swaps, futures, and options positions into a comprehensive risk 

surveillance process and conduct analysis for each material market participant

• Strengthen and ensure a coordinated approach to receiving, assessing, and referring tips, complaints 

and referrals as necessary and appropriate; if resources permit, establish a unit or office dedicated 

to this function.

Strategic Plan Strategy Support: The initiative will support the accomplishment of the following CFTC 

Strategic Plan Strategies:

• Develop and implement technology based surveillance tools to keep pace with market technology

• Develop consistent reporting of relevant swaps data

• Publish Interactive Reports on Swap Market Activity

• Conduct economic analysis and research on market structure and transparency for derivatives

• Develop process to combine cleared and uncleared, bilateral positions to obtain a more complete 

picture of a clearing firm’s risk exposure

• Monitor firms for financial stress by, among other things, reviewing monthly and annual financial 

filings, as well as notice of specific events

• Solicit high quality tips, complaints and referrals from CFTC divisions and offices, and self-regulatory 

organizations.

Strategic Plan Goal and Objective Support:

CFTC Goal CFTC Objective Division/Office

1-4 1.1, 1.3, 1.4, 2.1, 2.4, 3.1, 3.2, 4.2, 4.4 DCR, DMO, DOE, DSIO, OCE, OIA
IT Strategic Plan 2014

36 IT Strategic Goals, Objectives, and Strategies

Objective 2.3: Manage information to ensure its availability to the regulatory mission 

activities and the public

Data needs to be managed as an enterprise asset to ensure integration across multiple systems, high quality, 

identification of authoritative data sources, and availability of a consolidated data set that is the single 

source of reference for the CFTC’s operational production systems. 

The following IT Strategic Initiatives are described below:

2.3.1: Ingest order book data from market exchanges and platforms

2.3.2: Implement a research-focused data environment

2.3.3: Implement the President’s Digital Government Strategy

2.3.4: Expand the use of interagency collaboration platforms

2.3.5: Continue centralized management and administrative data and systems services and support 

automation of the CFTC administrative and management processes

2.3.6: Implement an electronic records and document management system (ERDM)

2.3.7: Support publishing of aggregated swaps and futures data.

Strategic Initiative 2.3.1: Ingest order book data from market exchanges and 

platforms

Definition: Futures market order message data, which allows surveillance staff to understand market 

behavior as it was unfolding, is not currently obtained on a regular basis. The process for requesting and 

obtaining order message data for specific timeframes or situations under surveillance is too cumbersome 

and lengthy. Furthermore, order book data can be two hundred times larger than a comparable slice of 

trade register data. Advanced tools, techniques, and storage devices are needed to process this 

information.

Purpose: Strategic Initiative 2.3.1 is necessary to perform analysis of pre-trade activity for surveillance, 

economic analysis and enforcement purposes. Ingesting of order book data from market exchanges and 

platforms will allow surveillance staff to increase the depth of surveillance. Because of the massively large 

volume of order book data it is likely that not all order data will be ingested from all regulated exchanges, 

platforms and facilities; however the capability to ingest targeted sets of data on a recurring basis or to 

quickly ingest sets of data based on specific surveillance or other initiatives is required, especially for 

oversight of automated trading activity. Dodd-Frank mandates pre-trade transparency for the swaps traded 

on SEFs. Commission rules require that DCMs and SEFs offer open and competitive centralized market 

trading for futures and swaps. To ensure compliance with these regulations, staff will gather and analyze 

trade and order book data from SEFs and DCMs. While trade data from DCMs is being reported to the 

Commission, staff will work with DCMs to collate order book data, develop a database to store this data or 

alternatively, access data from DCMs on an as-needed basis, and develop tools to analyze this data and 

integrate it with trade data. Similarly, staff will work with SEFs to develop data standards and protocols to 

collate both trade and order book data, and develop tools to analyze this data. 

Order book data will be available to staff for on-demand for targeted or recurring analysis.
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37 IT Strategic Goals, Objectives, and Strategies

Focus Areas for Projects: 

• Order Book

• Data standards

• High-Frequency trading.

Strategic Plan Performance Indicator Support: The initiative will support the accomplishment of the 

following CFTC Strategic Plan Performance Indicators by ensuring key market data is available to staff:

• Strive to strengthen capacity to receive and expeditiously evaluate all trading data and associated 

information to identify potential violations of the CEA or Commission regulations and the timely 

response to market emergencies

• Percentage of derivatives activity covered by regularly published Commission reports

• Publish economic research reports to inform the public about market structure of the derivatives 

markets

• Strengthen and ensure a coordinated approach to receiving, assessing, and referring tips, complaints 

and referrals as necessary and appropriate; if resources permit, establish a unit or office dedicated 

to this function.

Strategic Plan Strategy Support: The initiative will support the accomplishment of the following CFTC 

Strategic Plan Strategies:

• Develop and implement technology based surveillance tools to keep pace with market technology

• Conduct economic analysis and research on market structure and transparency for derivatives

Develop

• Solicit high quality tips, complaints and referrals from CFTC divisions and offices, and self-regulatory 

organizations.

Strategic Plan Goal and Objective Support:

CFTC Goal CFTC Objective Division/Office

1, 3, 4 1.1, 3.1, 3.2, 4.4 DMO, DOE, OCE

Strategic Initiative 2.3.2: Implement a research-focused data environment

Definition: Effective research requires a data environment that is supported by transparent policies and 

procedures; allows data to be used and shared with external parties without compromising privacy, 

confidential, or sensitive information; and provides researchers with flexibility in using tools and approaches 

without risk to CFTC data and IT infrastructure.

Purpose: Strategic Initiative 2.3.2 is necessary to support a research environment that allows for interagency research within a controlled environment. Implementing a research-focused data environment will 

support CFTC and inter-agency research into understanding evolving market conditions as well as continuing 

to provide appropriate market information to the public to increase market transparency. Staff will

collaborate with market structure experts from academia to strengthen its analytical capabilities and ensure 

that the state of art in terms of models and econometric techniques is being deployed. The efforts of such 

rigorous economic analysis will generate internal staff reports to inform the Commission, cost and benefit 

considerations to support Commission rulemaking, and research papers targeting publication in academic 
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38 IT Strategic Goals, Objectives, and Strategies

and practitioner journals.

The environment will include transparent management and systems controls. Hadoop and other open 

source analytic processing tools will be used in the environment.

Focus Areas for Projects:

• Information Governance.

Strategic Plan Performance Indicator Support: The initiative will support the accomplishment of the 

following CFTC Strategic Plan Performance Indicator by ensuring that market information published by the 

CFTC is relevant, accurate and can only be provided by the Commission:

• Publish economic research reports to inform the public about market structure of the derivatives 

markets.

Strategic Plan Strategy Support: The initiative will support the accomplishment of the following CFTC 

Strategic Plan Strategies:

• Conduct economic analysis and research on market structure and transparency for derivatives.

Strategic Plan Goal and Objective Support:

CFTC Goal CFTC Objective Division/Office

1, 3, 4 1.1, 1.3, 3.1, 4.3, 4.4 DMO, DOE, OCE

Strategic Initiative 2.3.3: Implement the President’s Digital Government Strategy

Definition: The President’s Digital Government Strategy aims to deliver better digital services to the 

American people. The strategy has main objectives: enable the American people and an increasingly mobile 

workforce to access high-quality digital government information and services anywhere, anytime, on any 

device; ensure that as the government adjusts to this new digital world, we seize the opportunity to procure 

and manage devices, applications, and data in smart, secure and affordable ways; unlock the power of 

government data to spur innovation across our Nation and improve the quality of services for the American 

people.

Purpose: Strategic Initiative 2.3.3 is necessary to implement the President’s digital government strategy.

This will be achieved by enhancing the usability and mobility of reports published on CFTC.gov and will 

support increased transparency of the futures and swaps markets. The Commission continues to 

incorporate many of the elements of the President’s Digital Government Strategy in the CFTC.gov public 

website. In addition to the elements already incorporated, architecting certain CFTC.gov services specifically 

for users of mobile devices and developing open APIs for datasets published on CFTC.gov would provide 

industry participants and the public with greater flexibility in accessing and using the information and would 

support efforts to boost public awareness across different audiences

Together with re-architecting services for mobile users and to include APIs, CFTC.gov will be reorganized to 

improve ease of use and to better support implementing new technology.

Focus Areas for Projects:

• CFTC.gov.
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39 IT Strategic Goals, Objectives, and Strategies

Strategic Plan Performance Indicator Support: The initiative will support the accomplishment of the 

following CFTC Strategic Plan Performance Indicators by increasing the ability of the public and industry 

participants to access and use information published by the Commission:

• Percentage of derivatives activity covered by regularly published Commission reports

• Develop a comprehensive communication strategy, geared for internal and external stakeholders, 

relating to the role of whistleblowers and the function of the Whistleblower Office.

Strategic Plan Strategy Support: The initiative will support the accomplishment of the following CFTC 

Strategic Plan Strategies: 

• Publish Interactive Reports on Swap Market Activity

• Boost public awareness of the Commission and its role in regulating financial markets

• Promote public information campaigns to enhance consumer ability to detect and avoid fraudulent 

and other abusive business practices.

Strategic Plan Goal and Objective Support:

CFTC Goal CFTC Objective Division/Office

1, 3 1.3, 3.4 DMO, DOE, OCE

Strategic Initiative 2.3.4: Expand the use of interagency collaboration platforms

Definition: CFTC Strategic Plan Goal 2 will benefit from secure, mobile-accessible platforms that support

arrangements for regulatory and enforcement cooperation and coordination; partnering with law 

enforcement agencies at the national, regional, and state levels; and obtaining and providing enforcement 

investigative assistance.

Purpose: Strategic Initiative 2.3.4 is necessary to expand the use of interagency collaboration platforms to

support enforcement and cooperative domestic and international enforcement. The Commission will 

ensure that staff has required digital credentials and supporting policy and processes to participate on 

platforms provided by other agencies. In cases where the purpose of the platform is specific to the CFTC 

mission, the Commission will establish platforms that are secure and supported by transparent management 

and system controls.

Focus Areas for Projects: 

• Secure private cloud

• Collaboration sites.

Strategic Plan Performance Indicator Support: The initiative will support the accomplishment of the 

following CFTC Strategic Plan Performance Indicators by ensuring staff ability to work effectively with other 

regulators:

• Strengthen and ensure a coordinated approach to receiving, assessing, and referring tips, complaints 

and referrals as necessary and appropriate; if resources permit, establish a unit or office dedicated 

to this function

• Percentage of enforcement investigations completed within 18 months of opening, depending on 

the nature and scope of investigations.
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40 IT Strategic Goals, Objectives, and Strategies

Strategic Plan Strategy Support: The initiative will support the accomplishment of the following CFTC 

Strategic Plan Strategies: 

• Solicit high quality tips, complaints and referrals from CFTC divisions and offices, and self-regulatory 

organizations.

Strategic Plan Goal and Objective Support:

CFTC Goal CFTC Objective Division/Office

3, 4 3.1, 3.2, 4.4 DOE

Strategic Initiative 2.3.5: Continue centralized management and administrative data 

and systems services and support automation of the CFTC administrative and 

management processes

Definition: The Commission uses services provided by other agencies for its financial management and 

human resources systems, as well as services provided by commercial providers to many federal agencies 

(e.g., travel and hiring systems). The Commission must also develop some administrative services that are 

unique to the Commission (e.g., performance management, pay adjustment, and ethics compliance). To 

reduce data redundancy, rework, and support cost-effective automation, administrative data and systems 

must continue to be centralized, replacing point solutions and isolated data stores.

Purpose: Strategic Initiative 2.3.5 is necessary to ensure that the Commission has a single authoritative 

source for administrative information about staff and mission support functions such as budget execution, 

security clearances, training, financial disclosure, workforce planning, and performance management. The 

Management and Administrative Enterprise Database (MAED), which provides centralization of 

administrative data and data services, will be sustained and used for ongoing management system 

maintenance and integration. All administrative support systems will leverage a single data source. As 

administrative support systems for any purpose (e.g., inventory management, onboarding support, and 

transit subsidy) are implemented or upgraded they will be integrated with MAED to use core data and 

services. Flexible dashboards will be developed to increase management visibility into processes. Excel 

collaboration tools will be used to supplement services provided by other agencies without systems 

development.

Focus Areas for Projects: 

• MAED

• OED automation initiatives.

Strategic Plan Performance Indicator Support: The initiative will support the accomplishment of the 

following CFTC Strategic Plan Performance Indicators by enabling administrative and management support 

activities to be conducted more efficiently:

• Implement Operational Planning across the Commission

• Improved satisfaction among CFTC staff with management programs and services

• Decrease in per employee operating costs.

Strategic Plan Strategy Support: The initiative will support the accomplishment of the following CFTC 

Strategic Plan Strategies: 
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41 IT Strategic Goals, Objectives, and Strategies

• All Employees Have the Knowledge, Tools, and Resources to Effectively and Efficiently Accomplish 

the CFTC Mission.

Strategic Plan Goal and Objective Support:

CFTC Goal CFTC Objective Division/Office

Management Objectives 5.2 OED

Strategic Initiative 2.3.6: Implement an electronic records and document 

management system (ERDM)

Definition: An ERDM will manage documents and records from creation to destruction across connecting 

business processes. Benefits include: centrally storing documents instead of in uncontrolled shared drive 

and email folders, managing emails as records, managing lawful destruction of records, integrating case 

management and business process management systems (BPMS), searching more efficiently for relevant 

documents, reducing duplicate copies, ensuring information is reliable and secure, and managing FOIA 

requests more efficiently. 

Purpose: Strategic Initiative 2.3.6 is necessary to apply technology to automate the process of collecting 

and managing CFTC documents and records. Fully deploying an electronic records and document 

management system will improve information management and security, support process automation, 

improve internal controls, and improve staff productivity. In addition to automating, all key mission 

processes via BPMS, an integrated, secure enterprise search capability that will allow simultaneous 

searching of key Commission information sources and databases will be implemented. A National Archives 

and Records Administration (NARA) compliant electronic records management will be fully deployed to 

ensure the effective and appropriate capture, retention, archival, and destruction of Commission records. 

Focus Areas for Projects:

• ERDM

• Capstone

• OPERA

• BPMS

• Information Governance including Controlled Unclassified Information (CUI).

Strategic Plan Performance Indicator Support: The initiative will support the accomplishment of the 

following CFTC Strategic Plan Performance Indicators enabling staff to collaborate more effectively and 

contribute to Commission-wide work processes more efficiently:

• Improved CFTC customer satisfaction with management programs and services

• Decrease in per employee operating costs.

Strategic Plan Strategy Support: The initiative will support the accomplishment of the following CFTC 

Strategic Plan Strategies: 

• Expand Management Support and Data and Information Technology Internal Controls, Governance, 

and Planning.

• All Employees Have the Knowledge, Tools, and Resources to Effectively and Efficiently Accomplish 
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42 IT Strategic Goals, Objectives, and Strategies

the CFTC Mission.

Strategic Plan Goal and Objective Support:

CFTC Goal CFTC Objective Division/Office

ALL 5.2 ALL

Strategic Initiative 2.3.7: Support publishing of aggregated swaps and futures data

Definition: This initiative supports continuing improvements in currently-published aggregated data and 

publishing of aggregated datasets to be defined in the future.

Purpose: Strategic Initiative 2.3.7 is necessary to support the publication of internal and external (i.e., 

public) reports in the interest of transparency. Publishing aggregated swaps and futures data supports

increased transparency of the futures and swaps markets. ODT will continue to provide and enhance data 

extraction, loading and maintenance processes; compose reports using automated analytics tools; and 

publish the reports with automated processes. The CFTC will use data collected directly from the SDRs 

under Part 45 for the swaps report. Initially such reports will cover the major swap categories and then be 

expanded to include other categories as they meet minimum activity thresholds. The Commission will 

continue to identify new sets of aggregated information that will promote transparency. 

Focus Areas for Projects: 

• CFTC.gov

• Data Analysis and Reporting

• SAS.

Strategic Plan Performance Indicator Support: The initiative will support the accomplishment of the 

following CFTC Strategic Plan Performance Indicators by ensuring that market information published by the 

CFTC is generated efficiently:

• Percentage of derivatives activity covered by regularly published Commission reports.

Strategic Plan Strategy Support: The initiative will support the accomplishment of the following CFTC 

Strategic Plan Strategies: 

• Develop consistent reporting of relevant swaps data

• Publish Interactive Reports on Swap Market Activity.

Strategic Plan Goal and Objective Support:

CFTC Goal CFTC Objective Division/Office

1 1.3 DMO, OCE
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43 IT Strategic Goals, Objectives, and Strategies

Goal 3 - Provide a stable, scalable and secure IT environment and

ensure continuous operations

As the scope of CFTC oversight increases and expands and as the markets and related data grow increasingly 

complex, the Commission must continue to provide a stable, scalable and secure IT infrastructure to meet 

demand. CFTC’s IT infrastructure is the combination of hardware, software, network resources, facilities, 

and services that are common across CFTC regardless of mission, program, or project and are the foundation 

of CFTC’s IT environment. This infrastructure supports the development, testing, delivery, monitoring, 

control, and support of IT resources. 

The IT infrastructure is the foundation upon which CFTC mission specific systems are built and is the key 

enabler for delivery of systems and services. CFTC recognizes the interdependency between infrastructure 

components as well as the systems that depend upon the infrastructure. Therefore, CFTC carefully 

prioritizes, plans, and coordinates changes to the IT Infrastructure. CFTC will continue to enhance computing 

infrastructure and related resources to facilitate CFTC regulatory mission activities and mission support 

activities. Increased network, storage, and processing capacity will permit analyzing larger and more 

complex data sets and enable enhanced collaboration. A private cloud computing environment will enable 

CFTC to consolidate processing and networking services in a highly virtualized environment. This 

environment will deliver high levels of availability, redundancy, and business continuity, while also allowing 

all information to be managed and made available centrally. IT services that benefit all Commission staff will

be sustained and enhanced to support improved effectiveness and productivity.

The following IT Strategic Objectives are described under Goal 3:

3.1: Provide stable and scalable communication, processing, and storage infrastructure capabilities

3.2: Provide trusted access to systems and data

3.3: Ensure technology and data availability

3.4: Optimize infrastructure for management of high-volume information sources.
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44 IT Strategic Goals, Objectives, and Strategies

Objective 3.1: Provide stable and scalable communication, processing, and storage 

infrastructure capabilities

Communication, processing, and storage infrastructure capabilities are fundamental to the operation of the 

Commission. The communication infrastructure consists of all the networks, routers, switches, and 

monitoring software. Providing a high-bandwidth, low-latency environment is critical to supporting CFTC 

regulatory mission activities and mission support activities. Processing infrastructure consists of all of the 

desktop and server hardware and software. The storage infrastructure includes everything from the 

desktop hard drives to the Storage Area Networks (SANs). 

CFTC is experiencing significant growth in demands on the IT infrastructure. Data volumes are increasing 

significantly as CFTC incorporates swaps data and order message data. To optimize processing efficiency, 

specialized analytic tools may require storing additional versions of data sets (e.g., data marts, data 

warehouses, and massively parallel data systems). To provide for disaster recovery, data must be 

transferred across networks to backup facilities. Processing this data requires significant server resources. 

Additionally, significant network bandwidth is required to transfer this data between regions and to backup 

sites.

The Commission must sustain existing program initiatives, providing mission operations and maintenance, as

well as providing CFTC staff with up-to-date desktop computing tools (e.g., software) necessary to be 

effective in their daily jobs. ODT needs to be able to quickly and efficiently allocate resources to meet 

business requirements. The IT infrastructure will allow dynamic provisioning of resources, providing 

resources quickly as needs arise (e.g., providing a virtual server for processing data associated with a special 

call). This scalable environment will provide the flexibility to add to resources into existing pools to scale 

storage and processing power as our needs grow.

The following IT Strategic Initiative is described below:

3.1.1: Maintain highly available and scalable data infrastructure.

Strategic Initiative 3.1.1: Maintain highly available and scalable data infrastructure

Definition: High availability infrastructure refers to a well-designed and thoroughly tested system of 

networks, servers, storage systems and other hardware that are available for access with very little 

downtime. High-availability is engineered into the infrastructure through redundant devices such as 

redundant array of independent disks (RAID), storage area networks (SANs), virtualized servers, and 

alternative computing facilities (ACFs). A scalable architecture is a set of networks, servers and storage that 

can be enlarged or configured to accommodate growth. The Commission’s IT services should leverage 

technology that makes systems highly available and ready for use at all times. The systems should be flexible 

enough to be incrementally upgraded to adapt to increased demands. 

Purpose: Strategic Initiative 3.1.1 is necessary to ensure that the CFTC IT infrastructure is designed to be 

able to change to meet the needs of the business, where CFTC can flexibly add resources within fiscal 

constraints. It is modularly expandable and designed to allow flexibility in capital expenditures in a given 

year. It allows CFTC to commoditize computing and storage resources (i.e., use standardized commodity 

hardware) that can be scaled up when necessary. Communications, processing and storage usage is 

monitored constantly and capacity planning is incorporated into IT strategic and annual operational 

planning. The hardware, software, and other components that provide communications, processing, and 
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45 IT Strategic Goals, Objectives, and Strategies

storage are continuously updated to remediate security vulnerabilities and maintain acceptable 

performance and are regularly upgraded or replaced to ensure they are cost-effective, provide acceptable 

levels of service, and can be scaled to meet CFTC demand. Computing tools used by all staff are similarly 

maintained for secure operation and up-to-date functionality.

In addition to increasing current capacities to meet demand, increasing the redundancy of communications 

infrastructure will be an area of focus. The storage environment with be expanded and enhanced as 

appropriate with technological advances. The database management system (DBMS) used for all CFTC 

systems will be upgraded. The desktop computing environment used by all staff will be transitioned to a 

virtual desktop environment that will provide better mobile access and telework functionality, reduce 

ongoing operational support costs, and provide more flexibility in meeting fluctuating staffing levels. 

Desktop computing tools will be upgraded to support increased mobile computing and secure collaboration. 

Focus Areas for Projects: 

• Internet redundancy

• SQL 2014 DBMS

• Virtual desktop initiative (VDI)

• Office 2013/365.

Strategic Plan Performance Indicator Support: The initiative will support the accomplishment of the 

following CFTC Strategic Plan Performance Indicators by ensuring that tools and services used by staff are 

available as workload increases and technology changes:

• Improved CFTC customer satisfaction with management programs and services

• Decrease in per employee operating costs.

Strategic Plan Strategy Support: The initiative will support the accomplishment of the following CFTC 

Strategic Plan Strategies: 

• All Employees Have the Knowledge, Tools, and Resources to Effectively and Efficiently Accomplish 

the CFTC Mission.

Strategic Plan Goal and Objective Support:

CFTC Goal CFTC Objective Division/Office

ALL ALL ALL
IT Strategic Plan 2014

46 IT Strategic Goals, Objectives, and Strategies

Objective 3.2: Provide trusted access to systems and data

In addition to scaling up technology capacity, the Commission must also continue to increase, automate, and 

scale information security controls in the face of evolving security threats. The Commission is charged with 

protecting sensitive information assets that are critical to overseeing the markets. Continuous monitoring is 

required to assess and mitigate risk more effectively. Also, security controls that are solely dependent on 

policy and staff compliance must be supplemented with system controls to reduce the risks to the 

Commission. CFTC will deliver a consistent approach to data security that will adequately protect 

information resources and minimize loss of productivity. 

The following IT Strategic Initiatives are described below:

3.2.1: Enhance data management tools and procedures

3.2.2: Automate security controls and implement continuous monitoring 

3.2.3: Provide systems platform support to empower end users.

Strategic Initiative 3.2.1: Enhance data management tools 

Definition: Data needs to be treated as a strategic asset that can be used as a trusted source of information 

throughout the Commission. Data needs to be managed throughout its entire lifecycle. Data management 

requires tools that facilitate defining and enforcing quality and integrity; ensuring that all IT services 

integrate with the Commission’s data architecture; defining how data is collected, labeled and stored 

through-out CFTC; and establishing, in cooperation with the divisions and offices, definition and direction on 

the use, access to and security of Commission data.

Purpose: Strategic Initiative 3.2.1 is necessary to ensure that Commission staff access to data is managed 

efficiently. Enhancing data management tools will support Commission-wide data repositories and increase 

efficiency and appropriate Commission-wide reuse of data. This initiative will improve management of

complex market data. It will also facilitate the sharing of data between enforcement and surveillance 

activities, as appropriate. The initiative will support secure collaborative research (both internal and 

external) and will support the effort to streamline reporting to the Commission. The Commission will 

expand access to and controls over regulatory and internal management data and records through the 

creation of maintainable data catalogs, standards and guide books, and implementing cross-divisional 

approval of access to enterprise data. One area of focus will be full implementation of the Forefront 

Identify Management (FIM) platform to automate the provisioning, certification and auditing, and deprovisioning of access to systems and data for CFTC staff. 

Focus Areas for Projects: 

• Data Management Tools

• Identity Management.

Strategic Plan Performance Indicator Support: The initiative will support the accomplishment of the 

following CFTC Strategic Plan Performance Indicators by ensuring that data used by staff is available and 

protected from unauthorized disclosure:

• Improved CFTC customer satisfaction with management programs and services

• Decrease in per employee operating costs.
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47 IT Strategic Goals, Objectives, and Strategies

Strategic Plan Strategy Support: The initiative will support the accomplishment of the following CFTC 

Strategic Plan Strategies: 

• Expand Management Support and Data and Information Technology Internal Controls, Governance, 

and Planning

• All Employees Have the Knowledge, Tools, and Resources to Effectively and Efficiently Accomplish 

the CFTC Mission.

Strategic Plan Goal and Objective Support:

CFTC Goal CFTC Objective Division/Office

ALL 5.2 ALL

Strategic Initiative 3.2.2: Automate security controls and implement continuous 

monitoring 

Definition: Cyber warfare and electronic espionage are at an all-time high. Financial systems and 

repositories of market data could be viewed as high value targets. Securing our nation against cyber-attacks 

has become one of the nation's highest priorities. To achieve this objective, networks, systems, and the 

operations teams that support them must vigorously defend against a variety of threats, both internal and 

external. Furthermore, for those attacks that are successful, defenses must be capable of detecting, 

thwarting, and responding to follow-on attacks on internal enterprise networks as attackers spread inside a 

compromised network. Federal agencies must monitor, detect, analyze, protect, report, and respond 

against known vulnerabilities, attacks, and exploitations and continuously test and evaluate information 

security controls and techniques to ensure that they are effectively implemented. By improving efficiency 

and reducing the likelihood of human error, greater automation of security mechanisms reduces the 

number and magnitude of potential security vulnerabilities and reduces the Commission’s risk of exposure 

to vulnerability. 

Purpose: Strategic Initiative 3.2.2 is necessary to ensure proper security mechanisms are in place to protect 

the Commission’s information and technology assets. CFTC is a custodian of confidential industry data and 

must make efforts to protect that data and prevent unauthorized disclosures. The data must be protected 

without reducing productivity and availability. This initiative will improve internal controls and reduce 

information security risk. The initiative includes enhancing security on all access points to CFTC systems 

(mobile device, BYOD, telework, desktop, external participant) to reduce the risk of compromise of CFTC 

information by outsiders. A Mobile Device Management (MDM) System will be implemented to ensure all 

data is securely controlled and all mobile devices can be managed to protect the CFTC from unauthorized 

access. A Data Loss Prevention (DLP) program will be implemented to reduce the risk of staff inadvertently 

disclosing sensitive information. A security operations center (SOC) will be fully implemented to use 

automated security controls to increase situational awareness and prevent and react rapidly to information 

security incidents. Critical controls will be automated to support continuous monitoring of information 

security risk. Legacy controls like anti-virus protection and staff internet use filtering and blocking will be 

evaluated based on emerging technology and upgraded or replaced. The capability for staff to digitally sign 

documents with authority that is valid externally will be implemented.

Focus Areas for Projects: 

• SOC
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48 IT Strategic Goals, Objectives, and Strategies

• Enhanced authentication controls

• DLP

• Mobile Device Management

• Advanced malware defense

• Automated web application security testing

• Red teaming/penetration testing

• Configuration baseline hardening and management

• Continuous diagnostics and mitigation

• External digital signature.

Strategic Plan Performance Indicator Support: The initiative will support the accomplishment of the 

following CFTC Strategic Plan Performance Indicators by ensuring staff can work effectively in an 

environment that minimizes risk to the Commission:

• Decrease in per employee operating costs.

Strategic Plan Strategy Support: The initiative will support the accomplishment of the following CFTC 

Strategic Plan Strategies: 

• Expand Management Support and Data and Information Technology Internal Controls, Governance, 

and Planning

• All Employees Have the Knowledge, Tools, and Resources to Effectively and Efficiently Accomplish 

the CFTC Mission.

Strategic Plan Goal and Objective Support:

CFTC Goal CFTC Objective Division/Office

ALL ALL ALL

Strategic Initiative 3.2.3: Provide systems platform support to empower end users

Definition: In addition to continually enhancing data analytics, data discovery and visualization, 

collaboration, and other platforms through IT strategic Initiative 1.1.3, CFTC must manage, sustain, and 

support the platforms that are the infrastructure supporting these capabilities. Additionally, ODT must 

provide technical, governance, and user support services when needed to troubleshoot and calibrate the 

technology environment.

Purpose: Strategic Initiative 3.2.3 is necessary to ensure that the Commission has a robust technology 

infrastructure and support mechanism to enable efficient, effective, and continuously available operations. 

In addition to providing platforms to empower staff to apply information technology to more effectively 

carry out CFTC regulatory mission and mission support activities, the Commission must manage those 

platforms so they are highly available, used efficiently and effectively, and used extensively. CFTC will apply 

best practices to managing platforms. The CFTC will promote a knowledge-sharing culture by promoting 

platform services and the exchange of knowledge about the effective use of platforms. Platforms will be 

managed with a strong focus on information governance to ensure compliance with the Privacy Act, Records 

Management Act, Freedom of Information Act (FOIA), and the controlled unclassified information (CUI) 
IT Strategic Plan 2014

49 IT Strategic Goals, Objectives, and Strategies

initiative.

Focus Areas for Projects: 

• Data Analytics

• Data Discovery/Data Visualization Tools

• SAS Enterprise Business Intelligence

• High Performance Computing

• SharePoint collaboration sites.

Strategic Plan Performance Indicator Support: The initiative will support the accomplishment of the 

following CFTC Strategic Plan Performance Indicators by making it easier for staff to interpret, manipulate, 

and securely share data:

• Strive to strengthen capacity to receive and expeditiously evaluate all trading data and associated 

information to identify potential violations of the CEA or Commission regulations and the timely 

response to market emergencies

• Percentage of derivatives activity covered by regularly published Commission reports

• Publish economic research reports to inform the public about market structure of the derivatives 

markets

• Percentage of derivatives for which trader data can be matched across CFTC datasets

• CFTC strives to conduct back testing of DCOs’ material product and portfolio initial margin 

requirements to assess their sufficiency

• Clearing members’ ability to fund variation and initial margin requirements calculated in 

hypothetical CFTC-designed market scenarios

• Strive to aggregate cleared swaps, futures, and options positions into a comprehensive risk 

surveillance process and conduct analysis for each material market participant

• Strengthen and ensure a coordinated approach to receiving, assessing, and referring tips, complaints 

and referrals as necessary and appropriate; if resources permit, establish a unit or office dedicated 

to this function.

• Improved CFTC customer satisfaction with management programs and services

• Decrease in per employee operating costs.

Strategic Plan Strategy Support: The initiative will support the accomplishment of the following CFTC 

Strategic Plan Strategies:
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50 IT Strategic Goals, Objectives, and Strategies

• Develop and implement technology based surveillance tools to keep pace with market technology

• Develop consistent reporting of relevant swaps data

• Publish Interactive Reports on Swap Market Activity

• Conduct economic analysis and research on market structure and transparency for derivatives

• Develop tools to back test financial resources and evaluate sufficiency of all material product and 

portfolio margin requirements

• Develop a program to monitor firm-level variation and initial margin requirements across DCOs

• Enhance the risk surveillance program to evaluate the risk of market participants positions held at 

multiple FCMs or DCOs

• Develop process to combine cleared and uncleared, bilateral positions to obtain a more complete 

picture of a clearing firm’s risk exposure

• Monitor firms for financial stress by, among other things, reviewing monthly and annual financial 

filings, as well as notice of specific events

• Solicit high quality tips, complaints and referrals from CFTC divisions and offices, and self-regulatory 

organizations.

• All Employees Have the Knowledge, Tools, and Resources to Effectively and Efficiently Accomplish 

the CFTC Mission.

Strategic Plan Goal and Objective Support:

CFTC Goal CFTC Objective Division/Office

1-4 1.1-1.4, 2.1-2-4, 3.1, 3.2, 4.4 ALL
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51 IT Strategic Goals, Objectives, and Strategies

Objective 3.3: Ensure technology and data availability

CFTC staff are more dependent than ever on IT. Technology will be more readily available through improved 

mobile computing and expanded after hours support. CFTC will also move toward a zero downtime 

architecture to perform maintenance updates without having to take systems offline and will employ 

geographically co-located infrastructure (i.e., replicated in an alternative off-site facility for disaster 

recovery) to support business continuity. Additionally, availability of teleconferencing technology will be 

expanded since CFTC staff collaborate regularly with other federal, state, and international regulators, SelfRegulatory Organizations (SROs), and industry participants.

The following IT Strategic Initiatives are described below:

3.3.1: Improve business continuity support

3.3.2: Improve mobile computing and mobile communication services

3.3.3: Improve video teleconferencing

3.3.4: Expand after-hours technical support for staff and external participants.

Strategic Initiative 3.3.1: Improve business continuity support

Definition: Protection and service availability of production data and infrastructure is a key component of 

the Commission business continuity program. Data loss or unplanned service interruption would directly 

impact the Commission’s ability to perform CFTC regulatory mission activities. 

Purpose: Strategic Initiative 3.3.1 is necessary to ensure business continuity in the event of loss of regular 

production operations. Given the importance of continuing oversight of derivatives markets to the health of 

the U.S. and global financial systems, the Commission must be fully prepared for continuity of operations

under a broad range of circumstances. This initiative builds on the recent implementation of a co-located 

alternate computing facility (ACF). To ensure consistency of day to day operations CFTC needs to have a 

safe and reliable environment for its production systems. The critically of the information the Commission 

deals with dictates the need for scalable data facilities. The server room at the DC Headquarters location will 

be de-commissioned and the ACF will be supplemented with a second, geographically co-located ACF. In 

addition to current capability to recover operations within recovery time objectives, application system 

architectures will be adjusted to further automate recovery and reconstitution processes and reduce the 

need for outages for planned maintenance. A zero downtime engineering methodology will be 

implemented for all future infrastructure enhancements. 

Focus Areas for Projects: 

• Secondary ACF

• DC Server Room Decommissioning.
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52 IT Strategic Goals, Objectives, and Strategies

Strategic Plan Performance Indicator Support: The initiative will support the accomplishment of the 

following CFTC Strategic Plan Performance Indicators by ensuring that tools and services used by staff are 

available under all operating conditions:

• Improved CFTC customer satisfaction with management programs and services.

Strategic Plan Strategy Support: The initiative will support the accomplishment of the following CFTC 

Strategic Plan Strategies:

• All Employees Have the Knowledge, Tools, and Resources to Effectively and Efficiently Accomplish 

the CFTC Mission.

Strategic Plan Goal and Objective Support:

CFTC Goal CFTC Objective Division/Office

ALL ALL ALL

Strategic Initiative 3.3.2: Improve mobile computing and mobile communication 

services

Definition: There is a growing need for people to communicate with each other and have timely access to 

information regardless of the location of the individuals or the information. The demand for wireless 

communication systems of increased sophistication and the increased use of mobile devices require flexible 

and scalable wireless services. Flexibility must include the ability to securely use a mix of CFTC-provided and

staff personal devices. Scalability must enable the Commission to adapt quickly to wireless service and 

mobile device technology changes. 

Purpose: Strategic Initiative 3.3.2 is necessary to support work outside the office. Improving mobile 

computing and mobile communication services will support increased productivity for investigators, 

auditors, and international affairs staff by ensuring availability of information and services, anytime and 

anywhere. Increased capability and advanced devices will require additional protections of the CFTC 

infrastructure and information. Mobile device management (MDM) will be implemented to enforce security 

controls and a secure, partitioned area for CFTC information, for both CFTC-provided and staff personal 

devices. Mobile wireless services will be provided by a diversified set of carriers to ensure coverage for staff 

in all geographic locations. Wireless connectivity within CFTC headquarters and regions will be provided to 

staff to increase productivity in meetings and when collaborating.

Focus Areas for Projects: 

• MDM

• Multi-carrier wireless

• HQ and regional WI-FI.
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53 IT Strategic Goals, Objectives, and Strategies

Strategic Plan Performance Indicator Support: The initiative will support the accomplishment of the 

following CFTC Strategic Plan Performance Indicators by ensuring that tools and services used by staff are 

available regardless of their geographic location:

• Strive to examine compliance by exchanges with the CEA Core Principles and Commission 

regulations, prioritizing systemically important entities

• Strive to examine compliance by exchanges and SDRs with the system safeguards and cyber security 

requirements of the CEA Core Principles and Commission regulations, prioritizing systemically 

important entities

• Strive to examine compliance by DCOs with the Core Principles, including system safeguards and 

cyber security requirements, of the CEA and Commission regulations, prioritizing systemically 

important entities

• Conduct governance and risk management oversight reviews for SDs and FCMs

• Conduct limited scope reviews of SD, MSP, and FCM risk management and internal control systems 

and procedures, including controls, processes and procedures over technology risks.

• Percentage of enforcement investigations completed within 18 months of opening, depending on 

the nature and scope of investigations

• Improved satisfaction among CFTC staff with management programs and services.

Strategic Plan Strategy Support: The initiative will support the accomplishment of the following CFTC 

Strategic Plan Strategies:

• Conduct oversight reviews of SD and MSP risk governance and risk management framework

• Conduct limited scope reviews of the risk management and internal control systems and procedures 

of SDs and FCMs

• All Employees Have the Knowledge, Tools, and Resources to Effectively and Efficiently Accomplish 

the CFTC Mission.

Strategic Plan Goal and Objective Support:

CFTC Goal CFTC Objective Division/Office

ALL ALL ALL

Strategic Initiative 3.3.3: Improve video teleconferencing

Definition: Video conferencing services are increasingly integral to conducting CFTC regulatory mission 

activities and mission support activities. Room-based, desktop, and mobile video conferencing and 

collaboration services will be seamlessly integrated. 

Purpose: Strategic Initiative 3.3.3 is necessary to visual communication to support meetings where an inperson is not possible and to support video communication with large audiences (i.e., the public via 

webcasting). Improving video teleconferencing services will increase staff productivity by adopting 

technology that is increasing video quality at reduced cost and introducing new collaboration tools and

services. Well-managed, high quality, secure, and available-on-demand teleconferencing services will 

support increased collaboration with external parties, including other federal, state, and international 

regulators, Self-Regulatory Organizations (SROs), and industry participants. Implementing internal 

conference bridging will facilitate secure video collaboration with broad support for existing and emerging 

standards, protocols, applications, devices and interoperability between unified communications (UC) 
IT Strategic Plan 2014

54 IT Strategic Goals, Objectives, and Strategies

environments at a predictable cost.

Focus Areas for Projects: 

• Mobile Video Conferencing

• Online Meeting, Desktop Sharing, and Video Teleconferencing with External Parties

• Media Streaming to Support Training Initiatives 

• In-house Bridging of Video Teleconferencing

Strategic Plan Performance Indicator Support: The initiative will support the accomplishment of the 

following CFTC Strategic Plan Performance Indicators by ensuring that staff can collaborate effectively with 

remote staff and external parties:

• Strive to examine compliance by exchanges with the CEA Core Principles and Commission 

regulations, prioritizing systemically important entities

• Strive to examine compliance by exchanges and SDRs with the system safeguards and cyber security 

requirements of the CEA Core Principles and Commission regulations, prioritizing systemically 

important entities

• Strive to examine compliance by DCOs with the Core Principles, including system safeguards and 

cyber security requirements, of the CEA and Commission regulations, prioritizing systemically 

important entities

• Conduct governance and risk management oversight reviews for SDs and FCMs

• Conduct limited scope reviews of SD, MSP, and FCM risk management and internal control systems 

and procedures, including controls, processes and procedures over technology risks.

• Percentage of enforcement investigations completed within 18 months of opening, depending on 

the nature and scope of investigations

• Improved satisfaction among CFTC staff with management programs and services.

Strategic Plan Strategy Support: The initiative will support the accomplishment of the following CFTC 

Strategic Plan Strategies:

• Conduct oversight reviews of SD and MSP risk governance and risk management framework

• Conduct limited scope reviews of the risk management and internal control systems and procedures 

of SDs and FCMs

• All Employees Have the Knowledge, Tools, and Resources to Effectively and Efficiently Accomplish 

the CFTC Mission.

Strategic Plan Goal and Objective Support:

CFTC Goal CFTC Objective Division/Office

ALL ALL ALL
IT Strategic Plan 2014

55 IT Strategic Goals, Objectives, and Strategies

Strategic Initiative 3.3.4: Expand after-hours technical support for staff and external 

participants

Definition: The DC ODT Customer Support Center currently provides support from 7:30am to 5:30pm

Eastern Time. Local support for each of the regional offices is comparable, varying slightly region to region. 

A best-effort is made to support senior staff and staff working on critical projects after those hours and on 

weekends. After hours support is not generally and readily available to all staff, requires unpredictable 

compensatory time to be incurred by Commission support staff, and is not supported by current CFTC IT 

service support contracts.

Purpose: Strategic Initiative 3.3.4 is necessary to provide continued support to staff working outside of 

normal business hours. Expanding after-hours technical support will increase the productivity of economists, 

attorneys, investigators, auditors, and international affairs staff by ensuring availability of information and 

services, anytime and anywhere. It will also improve the productivity of staff working extended hours on 

high-priority projects under tight deadlines. CFTC will structure future IT service support contracts to 

include the option for customer support after-hours and on weekends to support CFTC regulatory mission 

and mission support activities. This will be accomplished with a pool of technical resources staffing an afterhours call center to handle high priority work. In addition, the online customer self-service portal will be 

enhanced and the IT Training Program will be expanded to provide CFTC staff to allow staff to be more 

empowered after hours. Providing automated self-service capabilities to staff (e.g., password reset 

capability) will be of the highest priority for this Strategic Initiative as it will likely be the most cost effective. 

Additional non-automated after-hours technical support will be evaluated based on specific business value 

assessments.

Focus Areas for Projects: 

• After Hours Customer Support

• Online Self-Service

• IT Training.

Strategic Plan Performance Indicator Support: The initiative will support the accomplishment of the 

following CFTC Strategic Plan Performance Indicators by ensuring that tools and services used by staff are 

available outside of HQ operating hours:

• Strive to examine compliance by exchanges with the CEA Core Principles and Commission 

regulations, prioritizing systemically important entities

• Strive to examine compliance by exchanges and SDRs with the system safeguards and cyber security 

requirements of the CEA Core Principles and Commission regulations, prioritizing systemically 

important entities

• Strive to examine compliance by DCOs with the Core Principles, including system safeguards and 

cyber security requirements, of the CEA and Commission regulations, prioritizing systemically 

important entities

• Conduct governance and risk management oversight reviews for SDs and FCMs

• Conduct limited scope reviews of SD, MSP, and FCM risk management and internal control systems 

and procedures, including controls, processes and procedures over technology risks.

• Percentage of enforcement investigations completed within 18 months of opening, depending on 

the nature and scope of investigations

• Improved satisfaction among CFTC staff with management programs and services.
IT Strategic Plan 2014

56 IT Strategic Goals, Objectives, and Strategies

Strategic Plan Strategy Support: The initiative will support the accomplishment of the following CFTC 

Strategic Plan Strategies:

• Conduct oversight reviews of SD and MSP risk governance and risk management framework

• Conduct limited scope reviews of the risk management and internal control systems and procedures 

of SDs and FCMs

• All Employees Have the Knowledge, Tools, and Resources to Effectively and Efficiently Accomplish 

the CFTC Mission.

Strategic Plan Goal and Objective Support:

CFTC Goal CFTC Objective Division/Office

ALL ALL ALL
IT Strategic Plan 2014

57 IT Strategic Goals, Objectives, and Strategies

Objective 3.4: Optimize infrastructure for management of high-volume information 

sources

Increasingly complex automated surveillance strategies and analysis of very large datasets, as well as market 

reconstruction and simulation; margining, valuation, and stress testing of complex swaps; and analysis of 

high speed and algorithmic trading require high speed computing capabilities for rapid analysis of datasets.

Data communication capacity must also be increased to support connectivity to swap data repositories, 

high-volume DCMs, and increased communication with newly-regulated industry participants as well as 

other regulators. High performance disk input/output (I/O) systems, database management systems, and 

parallel processing will ensure acceptable, reliable and scalable performance for activities that require 

manipulation of very large data sets. 

The following IT Strategic Initiatives are described below:

3.4.1: Provide access to an increasing number of data sources and increasing sample sizes of market 

data (including non-futures market data)

3.4.2: Enable infrastructure support for high performance computing.

Strategic Initiative 3.4.1: Provide access to an increasing number of data sources 

and increasing sample sizes of market data (including non-futures market data)

Definition: Global markets are automated, intensively data-driven, and connected. Market regulators 

cannot operate in a vacuum. CFTC staff are increasingly requesting access to external data sources and 

services. Some of the data sources have mandated access (e.g., SDRs), some data sources are requested on 

an ad-hoc basis (e.g., special calls), and some data sources CFTC will need to be procured through contracts

(e.g., Bloomberg, Reuters or other market data). In some cases the data source is retrieved via calling an 

interactive service (e.g., sending a complex portfolio to be margined by a web service hosted by a DCM). 

Additionally, given the growth of messaging in the markets and the growing complexities of the market, 

sample sizes of data ingested or processed at CFTC will continue to grow. Even a few seconds of futures 

data can run into hundreds of thousands of rows during a major market event. 

Purpose: Strategic Initiative 3.4.1 is necessary to ensure staff have access to market data sources as needed 

to support regulatory mission activities. Providing access to an increasing number of data sources and 

increasing sample sizes of market data (including non-futures market data) will allow surveillance staff to 

broaden the scope of surveillance. Activities in markets not regulated by the Commission can be related to 

regulated trading activity and impact the risk profile of regulated participants. Additional data from external 

sources and services (e.g., margin data, delta ladders, and cash price data) are necessary for risk analysis, 

financial surveillance, risk surveillance, and enforcement matters. Dedicated high speed links to data 

repositories will be leveraged to facilitate secure data collection.

Services that consume data without requiring that it be ingested by the Commission will be favored because 

they will be quicker to implement and more cost effective. On-demand ingest by staff will be implemented 

to allow staff to quickly use new sources. Communications, storage, analytical processing applications, and 

high-performance computing will be scaled to meet demand. Secure, private cloud services will be 

implemented to ensure future scalability and to cost-effectively support largely-fluctuating ingest volumes.

Focus Areas for Projects: 

• Data Services

• Information Governance
IT Strategic Plan 2014

58 IT Strategic Goals, Objectives, and Strategies

• High-performance Computing

• Cloud Services.

Strategic Plan Performance Indicator Support: The initiative will support the accomplishment of the 

following CFTC Strategic Plan Performance Indicators by providing staff with access to relevant external 

data:

• Strive to strengthen capacity to receive and expeditiously evaluate all trading data and associated 

information to identify potential violations of the CEA or Commission regulations and the timely 

response to market emergencies

• Percentage of derivatives activity covered by regularly published Commission reports

• Publish economic research reports to inform the public about market structure of the derivatives 

markets

• Percentage of derivatives for which trader data can be matched across CFTC datasets

• CFTC strives to conduct back testing of DCOs’ material product and portfolio initial margin 

requirements to assess their sufficiency

• Clearing members’ ability to fund variation and initial margin requirements calculated in 

hypothetical CFTC-designed market scenarios

• Strive to aggregate cleared swaps, futures, and options positions into a comprehensive risk 

surveillance process and conduct analysis for each material market participant

• Strengthen and ensure a coordinated approach to receiving, assessing, and referring tips, 

complaints and referrals as necessary and appropriate; if resources permit, establish a unit or office 

dedicated to this function.

• Improved CFTC customer satisfaction with management programs and services

• Decrease in per employee operating costs.

Strategic Plan Strategy Support: The initiative will support the accomplishment of the following CFTC 

Strategic Plan Strategies:

• Develop and implement technology based surveillance tools to keep pace with market technology

• Develop consistent reporting of relevant swaps data

• Publish Interactive Reports on Swap Market Activity

• Conduct economic analysis and research on market structure and transparency for derivatives

• Develop tools to back test financial resources and evaluate sufficiency of all material product and 

portfolio margin requirements

• Develop a program to monitor firm-level variation and initial margin requirements across DCOs

• Enhance the risk surveillance program to evaluate the risk of market participants positions held at 

multiple FCMs or DCOs

• Develop process to combine cleared and uncleared, bilateral positions to obtain a more complete 

picture of a clearing firm’s risk exposure

• Monitor firms for financial stress by, among other things, reviewing monthly and annual financial 

filings, as well as notice of specific events

• Solicit high quality tips, complaints and referrals from CFTC divisions and offices, and self-regulatory 

organizations.

• All Employees Have the Knowledge, Tools, and Resources to Effectively and Efficiently Accomplish 

the CFTC Mission.

Strategic Plan Goal and Objective Support:
IT Strategic Plan 2014

59 IT Strategic Goals, Objectives, and Strategies

CFTC Goal CFTC Objective Division/Office

1-4 1.1, 2.1, 2.4, 3.1, 3.2, 4.4 DMO, DCR, DOE, DSIO, OCE

Strategic Initiative 3.4.2: Enable infrastructure support for high performance 

computing

Definition: High performance computing utilizing a massively parallel processing and storage platform will 

help process and analyze the ever growing size of market transaction data (TCR data, Order Book, Time and 

Sales). This data storage and retrieval facility must accommodate the increasing needs of the analysts who 

are using analytical tools to gain immediate access to data. Traditional relational database management 

(RDBMS) platforms are not able to sustain the ever-growing demands of the analysts and economists at the 

Commission. The high performance computing platform implemented at the Commission is required to 

conduct CFTC regulatory mission activities when analyzing massive amounts of data and has proven to 

reduce data ingest and data analytics processing times dramatically. 

Purpose: Strategic Initiative 3.4.2 is necessary to timely analysis of high volume data sets and high 

complexity data analyses. Use of high-performance computing will be extended from supporting ad-hoc, 

issue-specific analytics to being fully operationalized, supporting all Commission data ingest and analytics 

processing. This will reduce latency in data availability and allow staff to conduct analytics more quickly and 

with greater opportunity to refine and innovate analytic approaches. It will also enable the Commission to 

scale capabilities to meet the increasing size of very large datasets. High-performance computing technology 

will be used for daily and other regular analytics. The RDBMS used by the Commission will also be upgraded 

to take advantage of performance and scalability improvements. The High-availability distributed objectoriented platform (Hadoop) open-source software framework for data-intensive distributed applications will 

also be evaluated and potentially used.

Focus Areas for Projects: 

• High-Performance Computing 

• ACF

• SQL 2014 DBMS

• Hadoop

• Communications Infrastructure Bandwidth

Strategic Plan Performance Indicator Support: The initiative will support the accomplishment of the 

following CFTC Strategic Plan Performance Indicators by making it easier for staff to interpret and 

manipulate very large data sets:

• Strive to strengthen capacity to receive and expeditiously evaluate all trading data and associated 

information to identify potential violations of the CEA or Commission regulations and the timely 

response to market emergencies
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60 IT Strategic Goals, Objectives, and Strategies

• Percentage of derivatives activity covered by regularly published Commission reports

• Publish economic research reports to inform the public about market structure of the derivatives 

markets

• Percentage of derivatives for which trader data can be matched across CFTC datasets

• CFTC strives to conduct back testing of DCOs’ material product and portfolio initial margin 

requirements to assess their sufficiency

• Clearing members’ ability to fund variation and initial margin requirements calculated in 

hypothetical CFTC-designed market scenarios

• Strive to aggregate cleared swaps, futures, and options positions into a comprehensive risk 

surveillance process and conduct analysis for each material market participant

• Strengthen and ensure a coordinated approach to receiving, assessing, and referring tips, 

complaints and referrals as necessary and appropriate; if resources permit, establish a unit or office 

dedicated to this function.

• Improved CFTC customer satisfaction with management programs and services

• Decrease in per employee operating costs.

Strategic Plan Strategy Support: The initiative will support the accomplishment of the following CFTC 

Strategic Plan Strategies:

• Develop and implement technology based surveillance tools to keep pace with market technology

• Develop consistent reporting of relevant swaps data

• Publish Interactive Reports on Swap Market Activity

• Conduct economic analysis and research on market structure and transparency for derivatives

• Develop tools to back test financial resources and evaluate sufficiency of all material product and 

portfolio margin requirements

• Develop a program to monitor firm-level variation and initial margin requirements across DCOs

• Enhance the risk surveillance program to evaluate the risk of market participants positions held at 

multiple FCMs or DCOs

• Develop process to combine cleared and uncleared, bilateral positions to obtain a more complete 

picture of a clearing firm’s risk exposure

• Monitor firms for financial stress by, among other things, reviewing monthly and annual financial 

filings, as well as notice of specific events

• Solicit high quality tips, complaints and referrals from CFTC divisions and offices, and self-regulatory 

organizations.

• All Employees Have the Knowledge, Tools, and Resources to Effectively and Efficiently Accomplish 

the CFTC Mission.

Strategic Plan Goal and Objective Support:

CFTC Goal CFTC Objective Division/Office

1-4 1.1, 1.3, 2.1, 2.4, 3.1, 3.2, 4.4 DMO, DCR, DOE, DSIO, OCE
IT Strategic Plan 2014

61 IT Strategic Goals, Objectives, and Strategies

Goal 4 - Manage resources to achieve CFTC priorities

To continue supporting improved business outcomes IT management processes will continue to be 

integrated into CFTC planning and governance processes. The degree to which IT management leverages 

best practices, CFTC processes, and proven tools to achieve efficiency of operations will help define its 

success in fully supporting CFTC regulatory mission and mission support activities. 

The CFTC will expand its strategic and operational planning process to better unite the various functional 

plans including, but not limited to, financial, human capital, and information technology plans. A unified 

planning process will lead to better use of resources and facilitate effective resource governance. Most 

importantly, it will increase the Commission’s agility in responding to and adapting to external changes and 

derivatives market evolution. The Commission will supplement current planning activities and deliverables 

(strategic planning, budget formulation, budget execution, performance, human capital strategic, IT 

strategic, and IT operating) with mission division and mission support office strategic, operating, and 

performance plans. The additional level of detailed planning at the division and office level will increase the 

granularity and focus of HR and IT strategic and operating plans. More detailed and better focused HR and 

IT plans will also increase the effectiveness of division and office level planning. 

Collaboration and partnering will continue to ensure the alignment of business needs and IT services. 

However, IT management processes for capital planning and investment control (CPIC), strategic and 

operational planning, and IT program and project management will be adjusted to facilitate expanding CFTC 

processes. IT operating plans will continue to identify incremental, iterative projects in order to reduce 

project risk and increase flexible alignment with CFTC appropriations and budget execution. Transparency 

will be increased to support the enterprise focus of CFTC resource planning and governance.

The following IT Strategic Objectives are described under Goal 4:

4.1: Deliver expected outcomes on IT Investments

4.2: Develop the ODT organization in alignment with the demands of CFTC’s regulatory mission 

activities.
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62 IT Strategic Goals, Objectives, and Strategies

Objective 4.1: Deliver expected outcomes on IT Investments

ODT will increase transparency and communication in order to ensure that the right set of IT investments is 

being made to meet mission requirements, the implementation and sustainment of those investments is 

efficient, and the investments provide all intended benefits.

The following IT Strategic Initiatives are described below:

• 4.1.1: Extensively use learning management, electronic learning, and video production

• 4.1.2: Achieve transparency through ODT communications and processes:

Strategic Initiative 4.1.1: Extensively use learning management, electronic learning, 

and video production

Definition: ODT provides IT infrastructure needed by Human Resources, DOE, and other organizations to 

manage and deliver training. ODT also provides IT training that is focused on CFTC IT services and their 

application at the Commission. This IT strategic initiative highlights the fact that IT services are more 

effective when capabilities are fully understood and usage best practices are applied.

Purpose: Strategic Initiative 4.1.1 is necessary to support training as an essential Commission function 

needed to support staff efficiency and effectiveness. IT services often require training to be used to their 

fullest potential. Training is most effective when it is delivered with mission context. Maintaining the ability 

to deliver mission-focused training is important not only to deliver IT services effectively, but also to address 

competency gaps and maintain high performance in all mission functions. Extensively using learning 

management and electronic learning will improve the overall knowledge and proficiency of all staff and 

provide organizational flexibility. Video production will support enhanced internal communication as well as

increased transparency to the public. 

A multimedia production studio capability that supports the development of mission-focused training will be 

implemented. A multimedia production room will allow the Commission to produce professional grade 

videos for communications, media distribution and training purposes. The production room will allow for 

greater scalability and control over video production and post-production activities. The studio will be used 

to bring a number of benefits to the commission including: a growing need for broadcast quality media 

services in the form of announcements, presentations, meeting material and HR training, and Public 

Broadcasts. The CFTC will expand the enforcement learning program to include an on-demand Training 

Video Library to provide a wide variety of enforcement training topics in a user-friendly, on-demand format. 

Additionally, an IT training program that is focused on having the greatest impact on mission capabilities will 

be implemented. 

Focus Areas for Projects: 

• Multimedia Production Studio

• Media Streaming Server

• IT Training Program

• Onboarding Training

• Policy Training

• CFTCNet
IT Strategic Plan 2014

63 IT Strategic Goals, Objectives, and Strategies

Strategic Plan Performance Indicator Support: The initiative will support the accomplishment of the 

following CFTC Strategic Plan Performance Indicators by enabling knowledge unique to the CFTC mission to 

be provided to new staff and shared with collaborating staff:

• Establish and implement an Individual Development Plan (IDP) strategy

• Establish certification programs in executive, supervisory, and one core subject matter function

• Improved satisfaction among CFTC staff with management programs and services

• Launch long-term anti-fraud campaign.

Strategic Plan Strategy Support: The initiative will support the accomplishment of the following CFTC 

Strategic Plan Strategies:

• Further develop, strengthen, and maintain areas of expertise relevant to the CEA, as amended by 

Dodd-Frank Act, Commission regulations, and ever-changing market innovations and technologies

• Advance a training and development program that focuses employee proficiency and career 

development, and that addresses the dynamic knowledge requirements of Dodd-Frank legislation

• Boost public awareness of the Commission and its role in regulating financial markets

• Promote public information campaigns to enhance consumer ability to detect and avoid fraudulent 

and other abusive business practices

• Recruit, Develop, and Retain Highly Qualified Staff

• Increase Transparency and Communication of Commission-wide Vision, Mission, and Policies. 

• All Employees Have the Knowledge, Tools, and Resources to Effectively and Efficiently Accomplish 

the CFTC Mission.

Strategic Plan Goal and Objective Support:

CFTC Goal CFTC Objective Division/Office

3, Management Objectives 3.2, 5.1, 5.2 ALL

Strategic Initiative 4.1.2: Achieve transparency through ODT communications and 

processes

Definition: Effective communication within and between business units can more fully engage employees in 

the business of the Commission and can mobilize them to support organizational change and goals. There 

are three main methods of corporate communication that are appropriate for ODT: in person, electronic 

push, and electronic pull. In-person communications includes all-hands meetings, group meetings, hallway 

conversations, and one-on-one interviews. Electronic push includes emails and desktop alerts, while 

electronic pull means creating an online destination where employees are confident of finding the 

information they need, either on CFTCNet or on SharePoint sites.

Purpose: Strategic Initiative 4.1.2 is necessary to keep CFTC staff abreast of IT initiatives. ODT will provide 

more communication about planned, upcoming, and existing IT services to increase awareness and reinforce 

mission alignment. In order to improve internal communication, ODT will inform staff of ODT projects, 

events, and services; announce major ODT initiatives systematically; and ensure staff understand essential 

processes. To improve communication about IT services with the rest of the Commission, inform CFTC of 

ODT news, projects, and services; structure and share ODT information effectively; create technical 

documentation based on CFTC needs; and package ODT information so it is trusted. The ITSP will be 
IT Strategic Plan 2014

64 IT Strategic Goals, Objectives, and Strategies

published on CFTCNet and CFTC.gov. Annual IT operating plans will be posted on CFTCNet. Information 

about IT services published on CFTCNet will be improved and expanded. Information about IT services on 

CFTCNet will be linked to the online self-service web page to request services that must be provisioned and 

directly to services that are provided to all CFTC staff.

Focus Areas for Projects: 

• Commission-wide Planning

• IT planning

• ODT Communication Strategic Plan Activities 

Strategic Plan Performance Indicator Support: The initiative will support the accomplishment of the 

following CFTC Strategic Plan Performance Indicators by making IT services more readily accessible to staff:

• Improved satisfaction among CFTC staff with management programs and services.

Strategic Plan Strategy Support: The initiative will support the accomplishment of the following CFTC 

Strategic Plan Strategies:

• Expand Management Support and Data and Information Technology Internal Controls, Governance, 

and Planning

• All Employees Have the Knowledge, Tools, and Resources to Effectively and Efficiently Accomplish 

the CFTC Mission.

Strategic Plan Goal and Objective Support:

CFTC Goal CFTC Objective Division/Office

Management Objectives 5.1, 5.2 ALL
IT Strategic Plan 2014

65 IT Strategic Goals, Objectives, and Strategies

Objective 4.2: Develop the ODT organization in alignment with the demands of 

CFTC’s regulatory mission activities

The Office of Data and Technology (ODT) was established within the CFTC as a mission support office 

reporting directly to the Chairman because IT services and data management are integral to supporting and 

transforming CFTC regulatory mission and mission support activities. As with other CFTC divisions and 

offices, achieving expected business outcomes depends on attracting, developing and retaining experienced 

and engaged employees. Additionally, contracting for IT services and IT support services must be highly 

competitive and well-managed in order to fully leverage the innovation that industry is ready to provide. 

ODT will, along with other CFTC divisions and offices, partner with the Office of the Executive Director (OED) 

to achieve Objective 5.1 of the CFTC Strategic Plan: A High-performing, diverse, and engaged workforce. 

ODT will also develop its organization to assume a co-leadership responsibility with OED to achieve 

Objective 5.2 of the CFTC Strategic Plan: Effective stewardship of resources. Co-leadership is required

specifically with respect to the CFTC Strategic Plan strategy to “Expand Management Support and Data and 

Information Technology Internal Controls, Governance, and Planning”. Achieving CFTC Strategic Plan 

Objective 5.2 will allow CFTC regulatory mission activities to be carried out securely, efficiently, and 

transparently.

The following IT Strategic Initiative is described below:

4.2.1: Support the implementation of CFTC Governance.

Strategic Initiative 4.2.1: Support the implementation of CFTC Governance

Definition: CFTC must establish a corporate perspective when applying its finite resources or adopting 

Commission-wide policies or processes. Applying a corporate perspective enhances agency performance 

and reduces programmatic risks. Given its staffing level, the Commission must right-size IT planning 

activities and integrate them with Commission-wide planning and governance co-led by the Office of the 

Executive Director (OED) in order to make the best use of staff time. 

Purpose: Strategic Initiative 4.2.1 is necessary to ensure appropriate integration of IT planning functions 

with other Divisions and Office activities. As the CFTC continues to develop and improve its planning and 

program evaluation functions, IT planning will be tightly integrated into those functions.

The Chief Information Officer (CIO) is, along with the Executive Director (ED), a co-chair of the Resource 

Governance Board (RGB). The CIO is also, with the ED, Chief Operating Officer (COO), and Chief Counsel, on 

the steering committee of a cross-organizational program for information governance (InfoGov). The RGB is 

a critical advisory resource that serves two primary purposes—to improve internal Commission-wide 

communication and transparency and provide collaborative recommendations to senior leaders. Two-way, 

non-attributive dialog is vital to creating consistent, high quality, Commission-wide deliverables. InfoGov 

fosters a coordinated, enterprise-wide approach to the management of information throughout the 

information lifecycle -- from creation or receipt, use and maintenance to ultimate disposal. InfoGov will 

facilitate the development of policies and processes to holistically address various information-use issues 

and create accountability with respect to the handling of information. ODT will continue to develop its 

organization to improve and integrate capital planning and investment control (CPIC) and project 

management life-cycle (PMLC) with CFTC planning and governance functions, particularly the RGB and 

InfoGov. Additionally, a right-sized enterprise architecture (EA) program will be implemented to provide 

strategic and technical assessments that will inform integrated planning and governance functions. 
IT Strategic Plan 2014

66 IT Strategic Goals, Objectives, and Strategies

Focus Areas for Projects: 

• InfoGov

• RGB

• PMLC

• EA

Strategic Plan Performance Indicator Support: The initiative will support the accomplishment of the 

following CFTC Strategic Plan Performance Indicators by focusing IT investments on essential services:

• Decrease in per employee operating costs.

Strategic Plan Strategy Support: The initiative will support the accomplishment of the following CFTC 

Strategic Plan Strategies:

• Increase Transparency and Communication of Commission-wide Vision, Mission, and Policies

• Expand Management Support and Data and Information Technology Internal Controls, Governance, 

and Planning.

Strategic Plan Goal and Objective Support:

CFTC Goal CFTC Objective Division/Office

Management Objectives 5.2 ALL
IT Strategic Plan 2014

67 IT Strategic Plan Performance Measures

1 IT Strategic Plan Performance Measures

ITSP performance will be measured at the ITSP Goal level.

Goal 1 - Deliver IT systems and services aligned 

with regulatory mission activities of the CFTC 

For Goal 1, ODT will use a CFTC Strategic Plan Objective 5.2 

measure.

Indicator: Improved CFTC customer satisfaction with 

management programs and services

Target: Survey/baseline in 2015 and annual target thereafter

Timeframe: 2018

Description: Resource allocation, including financial, human, 

and information technology resources, is one of the primary services provided by mission support. The 

Office of the Executive Director (OED) and the Office of Data and Technology (ODT) will design and conduct 

a survey in FY 2015 that addresses key services provided by each office to establish a baseline. At least two 

of the services on which staff will be surveyed will be services that are integral to CFTC resource allocation 

processes. The survey will be conducted semi-annually FY 2015 – FY 2018. The staff survey will include 

questions about mission alignment of IT services.

Goal 2 - Facilitate availability and enhance understanding of data to improve 

regulatory effectiveness

Indicator: SDR Data Quality

Target: Baseline in 2015 and annual target thereafter

Timeframe: 2018

Description: In FY 2015 an objective, qualitative measure of SDR data quality will be developed. Also in FY 

2015, the measure will be applied to establish a baseline and improvement targets will be established. FY 

2015 through FY 2018 measurement will be conducted quarterly. Staff will continually, with the SDRs, 

identify root causes of insufficient quality as well as corrective actions. Staff will correlate corrective actions 

and measurement results.

Goal 3 - Provide a stable, scalable and secure IT environment to ensure continuous 

operations

Indicator: DHS FISMA Scorecard (Small Agencies)

The U.S. futures and swaps markets 

are estimated at $30 trillion and 

$250 trillion, respectively. By any 

measure, the markets under CFTC’s 

regulatory purview are large and 

economically significant. Given the 

enormity of these markets and the 

critical role they play in empowering 

legitimate, prudential, and nonspeculative hedging strategies 

ensuring that these markets are 

transparent, open, and competitive 

is essential to help safeguard the 

financial stability of the Nation.
IT Strategic Plan 2014

68 IT Strategic Plan Performance Measures

Target: Baseline in 2015 and annual target thereafter

Timeframe: 2018

Description: Given increasing external cyber security risks, the Commission will use the DHS FISMA 

Scorecard for small agencies, which is compiled annually, as an indicator for providing a secure IT 

environment. The FY 2014 annual scorecard results will be a baseline. In FY 2014 performance targets for 

improvement relative to other small agencies will be set and measured FY 2014 through FY 2018. 

Goal 4 - Manage resources to achieve CFTC priorities

Indicator: Major IT Project Budget and Schedule Performance

Target: Baseline in 2015 and annual target thereafter

Timeframe: 2018

Description: Estimated cost and schedule variance will be base lined for each major IT project. In FY 2015

an average budget and schedule variance will be calculated. Also in FY 2015, target performance 

improvements will be set for FY 2016 through FY 2018. Results will be measured quarterly FY 2015 through 

FY 2018 for in-flight projects.
IT Strategic Plan 2014

69 IT Strategic Plan Process

2 IT Strategic Planning Process

Information Technology (IT) plays a critical role in CFTC mission attainment. IT enables the Commission’s 

regulatory mission activities by delivering quick and secure information aggregation and access, analytical 

capabilities, and successful business process automation. The IT Strategic Planning is an integral part of the 

CFTC Strategic Planning Process, which establishes the long-term goals for the Commission’s core mission 

and supporting functions, including IT. The CFTC IT Strategic Plan (ITSP) ensures that IT investments are in 

direct alignment with business needs and contribute to the CFTC strategic priorities.

The ITSP high level processes provide the Office of Data and Technology (ODT) with a framework by which to 

execute the following activities: 

• Develop (Update) and Socialize IT Strategic Plan

• Implement IT Strategic Plan

• Evaluate IT Strategic Plan Implementation Progress

The objective of the ‘Develop (Update) and Socialize IT Strategic Plan’ process is to define what ODT seeks to 

accomplish in support of the CFTC Strategic Plan goals for current and future years and to identify the 

strategies ODT will use to achieve desired results.

The objective of the ‘Implement IT Strategic Plan’ process is to ensure that the planned strategies are 

executed and that, on a day-to-day basis, the IT Strategic Plan guides IT programs, projects and operational 

activities. 

Finally, the objective of the ‘Evaluate IT Strategic Plan Implementation Progress’ process is to determine -

through measurement – how well ODT is succeeding in achieving IT strategic objectives. 

Each of the ITSP High Level Processes is a part of the Commission-level Planning Process, managed by the 

Office of the Executive Director. As such, each of the ITSP High Level Processes identifies touch points with 

the Commission’s Integrated Strategic, Budget, and Operating Planning Process.

Develop (Update) and Socialize IT Strategic Plan

The ‘Develop (Update) and Socialize IT Strategic Plan’ is the process by which ODT defines the long-term IT 

goals and objectives needed to reach the CFTC’s strategic goals. In alignment with the CFTC Planning 

Process, ODT develops IT Strategic Plan once in 4 years (major revisions). Major ITSP revisions take place 

concurrently with the development of the CFTC Strategic Plan, which is triggered by the presidential election 

cycle and begins shortly after the presidential inauguration for publication generally one year following the 

inauguration with scope spanning the four years of the administration. During the major revisions, the IT 

Strategic Plan is socialized and published leveraging the CFTC Strategic and Operating Plan socialization 

process and activities. Since there are ODT-generated IT requirements and technical office requirements, 

development of the ITSP both informs and is guided by the CFTC Strategic Plan.

ODT continuously reviews its progress (see ‘Evaluate IT Strategic Plan Implementation Progress’) and 

conducts annual validations of the ITSP to evaluate if it needs to be modified so that it can remain a valid 

driver for the IT Operating Plan activities, annual CFTC and ODT operational planning, CFTC strategic plan 

adjustments, and the next major CFTC strategic planning cycle.

The development of the ITSP is based on collaboration with the other CFTC Divisions and Offices as part of 

the concurrent CFTC Strategic Planning and IT Strategic Planning processes. The ITSP is also based on 

divisional strategic and operational plans as articulated through the planning process.
IT Strategic Plan 2014

70 IT Strategic Plan Process

The depth of detail in the ITSP aligns with the detail specified in the CFTC Strategic Plan and other divisional 

plans. Operational details, project timelines, and budgets are beyond the scope of the ITSP.

Implement IT Strategic Plan

The objective of the ‘Implement IT Strategic Plan’ process is to ensure that the defined IT Strategic Goals and 

Objectives direct ODT operations and are implemented via ODT programs and projects. ODT executes the IT 

Strategic Plan by aligning projects and individual performance of ODT staff to the IT Strategic Objectives, 

which is in turn aligned with the CFTC Strategic Plan. Detailed action plans and performance measures are 

developed and tracked at the level of IT projects found in ODT’s Annual Operating Plan.

Evaluate IT Strategic Plan Implementation Progress

The objective of this process is to track and evaluate ODT’s progress in implementing the strategies 

expressed in the CFTC and IT Strategic Plans, and ultimately, in meeting business needs and supporting the 

CFTC mission. ODT continuously tracks and evaluates performance at the level of tasks, projects and 

strategic initiatives. Formal report and communication of the progress of IT strategic initiatives towards 

defined performance metrics takes place quarterly and coincides with the quarterly CPIC IT Portfolio 

evaluation meetings.
IT Strategic Plan 2014

71 IT Strategic Plan Process

3 External Factors

The CFTC must be prepared to modify or change its planned direction or level of effort if factors not within 

its control change in unanticipated ways. Some of the factors that could materially affect CFTC’s long term 

IT strategy are:

• Legislation could be enacted that adds to or reduces CFTC’s scope of regulation or ability to access 

critical information.

• Appropriations may be above or below the level requested.

• World and U.S. economies could grow or contract dramatically.

• Demand for or supply of commodities and other goods and services that affect commodity markets 

and derivatives trading could change significantly.

• Court decisions may alter prior understandings on which the Commission based workload 

projections, business processes or resource requirements.

• Information Technology capabilities could materially change, improving or hindering the 

Commission’s ability to monitor market or participant behavior or analyze transactions.

• New derivative products, processes or market participants may develop, having a positive or 

negative effect in the Commission’s ability to oversee the market.

• War or terrorist activity could disrupt the Commission’s ability to fulfill its responsibilities.

• Critical staff with hard to replace competencies could leave or be unable to work for some period of 

time. 
IT Strategic Plan 2014

72 Alignment Between the IT Strategic Initiatives and CFTC Goals and Objectives

4 Alignment between IT Strategic Initiatives and CFTC Goals and Objectives

 CFTC Goals and Objectives 

IT Strategic Goals, Objectives, Initiatives

Market Integrity and 

Transparency

1.1 Markets not readily 

susceptible to manipulation and 

other abusive practices

1.2 Effective self-regulatory 

framework

1.3 Availability of market 

information to the public and 

for use by authorities

1.4 Integrate swaps data with 

futures and options on futures 

data

Financial Integrity and Avoidance 

of Systemic Risk

2.1 Reduce the risk of 

disruptions to the system for 

clearing and settlement of 

contract obligations

2.2 Provide market participants 

with regulatory guidance

2.3 Strong governance and 

oversight of Commission 

registrants

2.4 Assess whether SDs, MSPs 

and FCMs maintain sufficient 

financial resources, risk 

management procedures, 

internal controls, and customer 

protection practices

Comprehensive Enforcement

3.1 Strengthen capacity to 

receive and expeditiously 

handle high-impact tips, 

complaints and referrals

3.2 Execute rigorous and 

thorough investigations

3.3 Effectively prosecute 

violations

3.4 Remedy past violations, 

deter future violations and 

related consumer losses

Domestic and international 

cooperation and coordination

4.1 Broad outreach on 

regulatory concerns

4.2 Sound international 

standards and practices

4.3 Provide global technical 

assistance

4.4 Robust Domestic and 

International Enforcement 

Cooperation and Coordination

1. Deliver IT systems and services aligned with regulatory 

mission activities of the CFTC

1.1 Develop mission systems that contribute to the 

effectiveness of CFTC regulatory mission activities

1.1.1 Continuously enhance market surveillance monitoring 

and case management systems



(CFTC 1.1, 1.4)



(CFTC 2.1, 2.2, 2.3, 2.4)



(CFTC 3.1, 3.2) (CFTC 4.4) 

1.1.2 Continuously identify and develop enhanced financial 

analytical tools 

(CFTC 2.1, 2.4)



(CFTC 3.1, 3.2) (CFTC 4.4) 

1.1.3 Continuously enhance data analytics platforms, data 

discovery and visualization platforms and highperformance data environment



(CFTC 1.1, 1.3, 1.4)



(CFTC 2.1, 2.4)



(CFTC 3.1, 3.2) (CFTC 4.4) 

1.1.4 Increase litigation support services 

(CFTC 3.1, 3.2, 3.3) (CFTC 4.4) 

1.1.5 Continuously enhance eLaw program technology 

(CFTC 3.1, 3.2, 3.3) (CFTC 4.4) 
IT Strategic Plan 2014

73 Alignment Between the IT Strategic Initiatives and CFTC Goals and Objectives

 CFTC Goals and Objectives 

IT Strategic Goals, Objectives, Initiatives

Market Integrity and 

Transparency

1.1 Markets not readily 

susceptible to manipulation and 

other abusive practices

1.2 Effective self-regulatory 

framework

1.3 Availability of market 

information to the public and 

for use by authorities

1.4 Integrate swaps data with 

futures and options on futures 

data

Financial Integrity and Avoidance 

of Systemic Risk

2.1 Reduce the risk of 

disruptions to the system for 

clearing and settlement of 

contract obligations

2.2 Provide market participants 

with regulatory guidance

2.3 Strong governance and 

oversight of Commission 

registrants

2.4 Assess whether SDs, MSPs 

and FCMs maintain sufficient 

financial resources, risk 

management procedures, 

internal controls, and customer 

protection practices

Comprehensive Enforcement

3.1 Strengthen capacity to 

receive and expeditiously 

handle high-impact tips, 

complaints and referrals

3.2 Execute rigorous and 

thorough investigations

3.3 Effectively prosecute 

violations

3.4 Remedy past violations, 

deter future violations and 

related consumer losses

Domestic and international 

cooperation and coordination

4.1 Broad outreach on 

regulatory concerns

4.2 Sound international 

standards and practices

4.3 Provide global technical 

assistance

4.4 Robust Domestic and 

International Enforcement 

Cooperation and Coordination

1.2 Collaborate with the industry and divisions to automate 

business processes and data flows

1.2.1 Actively engage DCOs to identify and potentially reuse or extend margining and other software algorithms to 

meet unique Commission requirements



(CFTC 2.1)



(CFTC 4.3) 

1.2.2 Increase integration between NFA and CFTC systems 

(CFTC 2.2, 2.3, 2.4)



(CFTC 4.4) 

1.2.3 Further integrate eLaw with other CFTC systems and 

processes



(CFTC 1.1) (CFTC 2.3, 2.4)



(CFTC 3.1, 3.2) (CFTC 4.4) 

1.2.4 Provide technical support for regulatory reporting 

compliance



(CFTC 1.1, 1.2) (CFTC 2.1, 2.2, 2.3, 2.4)

1.2.5 Building out of proof-of-concept programs by mission 

program staff



(CFTC 1.1) (CFTC 2.1, 2.2, 2.3)



(CFTC 3.1, 3.2) (CFTC 4.4) 

1.3 Provide enterprise solutions aligned with industry best 

practices

1.3.1 Increase use of Application Programming Interfaces 

(APIs) and web services for regulatory data reporting



(CFTC 1.1, 1.2) (CFTC 2.1, 2.2, 2.3)

1.3.2 Use industry-standard tools to evaluate FCM, CPO, 

and other participant financial risk



(CFTC 2.4)



(CFTC 4.3) 
IT Strategic Plan 2014

74 Alignment Between the IT Strategic Initiatives and CFTC Goals and Objectives

 CFTC Goals and Objectives 

IT Strategic Goals, Objectives, Initiatives

Market Integrity and 

Transparency

1.1 Markets not readily 

susceptible to manipulation and 

other abusive practices

1.2 Effective self-regulatory 

framework

1.3 Availability of market 

information to the public and 

for use by authorities

1.4 Integrate swaps data with 

futures and options on futures 

data

Financial Integrity and Avoidance 

of Systemic Risk

2.1 Reduce the risk of 

disruptions to the system for 

clearing and settlement of 

contract obligations

2.2 Provide market participants 

with regulatory guidance

2.3 Strong governance and 

oversight of Commission 

registrants

2.4 Assess whether SDs, MSPs 

and FCMs maintain sufficient 

financial resources, risk 

management procedures, 

internal controls, and customer 

protection practices

Comprehensive Enforcement

3.1 Strengthen capacity to 

receive and expeditiously 

handle high-impact tips, 

complaints and referrals

3.2 Execute rigorous and 

thorough investigations

3.3 Effectively prosecute 

violations

3.4 Remedy past violations, 

deter future violations and 

related consumer losses

Domestic and international 

cooperation and coordination

4.1 Broad outreach on 

regulatory concerns

4.2 Sound international 

standards and practices

4.3 Provide global technical 

assistance

4.4 Robust Domestic and 

International Enforcement 

Cooperation and Coordination

2. Facilitate availability and enhance understanding of data 

to improve regulatory effectiveness

2.1 Architect data to enable automated ingestion, 

integration, access, sharing, reporting and transparency

2.1.1 Receive all data electronically and automate its 

distribution throughout the Commission using business 

process automation software



(CFTC 1.1, 1.2, 1.3, 1.4) (CFTC 2.1, 2.2, 2.3, 2.4) (CFTC 3.1) 

2.1.2 Improve data quality 

(CFTC 1.1, 1.2, 1.3, 1.4) (CFTC 2.1, 2.4)



(CFTC 3.1, 3.2) (CFTC 4.2, 4.4) 

2.2 Aggregate data across markets and participants to 

empower the CFTC staff to perform complex data analyses

2.2.1 Increase application of data standards, including Legal 

Entity Identifiers (LEIs) and product identifiers



(CFTC 1.1, 1.3, 1.4) (CFTC 2.1, 2.4)



(CFTC 3.1, 3.2) (CFTC 4.2, 4.4) 

2.2.2 Harmonize SDR data 

(CFTC 1.1, 1.3, 1.4) (CFTC 2.1, 2.4)



(CFTC 3.1, 3.2) (CFTC 4.2, 4.4) 

2.3 Manage information to ensure its availability to the 

regulatory mission activities and the public

2.3.1 Ingest order book data from market exchanges and 

platforms



(CFTC 1.1) (CFTC 3.1, 3.2)



(CFTC 4.4)
IT Strategic Plan 2014

75 Alignment Between the IT Strategic Initiatives and CFTC Goals and Objectives

 CFTC Goals and Objectives 

IT Strategic Goals, Objectives, Initiatives

Market Integrity and 

Transparency

1.1 Markets not readily 

susceptible to manipulation and 

other abusive practices

1.2 Effective self-regulatory 

framework

1.3 Availability of market 

information to the public and 

for use by authorities

1.4 Integrate swaps data with 

futures and options on futures 

data

Financial Integrity and Avoidance 

of Systemic Risk

2.1 Reduce the risk of 

disruptions to the system for 

clearing and settlement of 

contract obligations

2.2 Provide market participants 

with regulatory guidance

2.3 Strong governance and 

oversight of Commission 

registrants

2.4 Assess whether SDs, MSPs 

and FCMs maintain sufficient 

financial resources, risk 

management procedures, 

internal controls, and customer 

protection practices

Comprehensive Enforcement

3.1 Strengthen capacity to 

receive and expeditiously 

handle high-impact tips, 

complaints and referrals

3.2 Execute rigorous and 

thorough investigations

3.3 Effectively prosecute 

violations

3.4 Remedy past violations, 

deter future violations and 

related consumer losses

Domestic and international 

cooperation and coordination

4.1 Broad outreach on 

regulatory concerns

4.2 Sound international 

standards and practices

4.3 Provide global technical 

assistance

4.4 Robust Domestic and 

International Enforcement 

Cooperation and Coordination

2.3.2 Implement a research-focused data environment 

(CFTC 1.1, 1.3) (CFTC 3.1)



(CFTC 4.3, 4.4)

2.3.3 Implement the president’s digital government 

strategy



(CFTC 1.3) (CFTC 3.4) 

2.3.4 Expand the use of interagency collaboration 

platforms



(CFTC 3.1, 3.2)



(CFTC 4.4)

2.3.5 Continue centralized management and administrative 

data and systems services and support automation of the 

CFTC administrative and management processes

Supports CFTC Management Objective 5.2 (Effective stewardship of resources)

2.3.6 Implement an electronic records and document 

management system



(CFTC 1.2) (CFTC 2.1, 2.2, 2.3, 2.4)

2.3.7 Support publishing of aggregated swaps and futures 

data



(CFTC 1.3) 

3. Provide a stable, scalable and secure IT environment and

ensure continuous operations

3.1 Provide stable and scalable communication, processing, 

and storage infrastructure capabilities

3.1.1 Maintain highly available and scalable data 

infrastructure



(CFTC 1.1, 1.2, 1.3, 1.4) (CFTC 2.1, 2.2, 2.3, 2.4) (CFTC 3.1, 3.2, 3.3, 3.4) (CFTC 4.1, 4.2, 4.3, 4.4) 
IT Strategic Plan 2014

76 Alignment Between the IT Strategic Initiatives and CFTC Goals and Objectives

 CFTC Goals and Objectives 

IT Strategic Goals, Objectives, Initiatives

Market Integrity and 

Transparency

1.1 Markets not readily 

susceptible to manipulation and 

other abusive practices

1.2 Effective self-regulatory 

framework

1.3 Availability of market 

information to the public and 

for use by authorities

1.4 Integrate swaps data with 

futures and options on futures 

data

Financial Integrity and Avoidance 

of Systemic Risk

2.1 Reduce the risk of 

disruptions to the system for 

clearing and settlement of 

contract obligations

2.2 Provide market participants 

with regulatory guidance

2.3 Strong governance and 

oversight of Commission 

registrants

2.4 Assess whether SDs, MSPs 

and FCMs maintain sufficient 

financial resources, risk 

management procedures, 

internal controls, and customer 

protection practices

Comprehensive Enforcement

3.1 Strengthen capacity to 

receive and expeditiously 

handle high-impact tips, 

complaints and referrals

3.2 Execute rigorous and 

thorough investigations

3.3 Effectively prosecute 

violations

3.4 Remedy past violations, 

deter future violations and 

related consumer losses

Domestic and international 

cooperation and coordination

4.1 Broad outreach on 

regulatory concerns

4.2 Sound international 

standards and practices

4.3 Provide global technical 

assistance

4.4 Robust Domestic and 

International Enforcement 

Cooperation and Coordination

3.2 Provide trusted access to systems and data

3.2.1 Enhance data management tools and procedures 

(CFTC 1.1, 1.2, 1.3, 1.4) (CFTC 2.1, 2.2, 2.3, 2.4) (CFTC 3.1, 3.2, 3.3, 3.4) (CFTC 4.1, 4.2, 4.3, 4.4) 

3.2.2 Automate security control, data loss prevention, and 

identity management tools and implement continuous 

monitoring



(CFTC 1.1, 1.2, 1.3, 1.4) (CFTC 2.1, 2.2, 2.3, 2.4) (CFTC 3.1, 3.2, 3.3, 3.4) (CFTC 4.1, 4.2, 4.3, 4.4) 

3.2.3 Provide systems platform support to empower end 

users



(CFTC 1.1, 1.2, 1.3, 1.4) (CFTC 2.1, 2.2, 2.3, 2.4) (CFTC 3.1, 3.2) (CFTC 4.4)

3.3 Ensure technology and data availability

3.3.1 Improve business continuity support 

(CFTC 1.1, 1.2, 1.3, 1.4) (CFTC 2.1, 2.2, 2.3, 2.4) (CFTC 3.1, 3.2, 3.3, 3.4) (CFTC 4.1, 4.2, 4.3, 4.4) 

3.3.2 Improve mobile computing and mobile 

communication services 



(CFTC 1.1, 1.2, 1.3, 1.4) (CFTC 2.1, 2.2, 2.3, 2.4) (CFTC 3.1, 3.2, 3.3, 3.4) (CFTC 4.1, 4.2, 4.3, 4.4) 

3.3.3 Improve video teleconferencing 

(CFTC 1.1, 1.2, 1.3, 1.4) (CFTC 2.1, 2.2, 2.3, 2.4) (CFTC 3.1, 3.2, 3.3, 3.4) (CFTC 4.1, 4.2, 4.3, 4.4) 

3.3.4 Expand after-hours technical support for staff and 

external participants



(CFTC 1.1, 1.2, 1.3, 1.4) (CFTC 2.1, 2.2, 2.3, 2.4) (CFTC 3.1, 3.2, 3.3, 3.4) (CFTC 4.1, 4.2, 4.3, 4.4) 
IT Strategic Plan 2014

77 Alignment Between the IT Strategic Initiatives and CFTC Goals and Objectives

 CFTC Goals and Objectives 

IT Strategic Goals, Objectives, Initiatives

Market Integrity and 

Transparency

1.1 Markets not readily 

susceptible to manipulation and 

other abusive practices

1.2 Effective self-regulatory 

framework

1.3 Availability of market 

information to the public and 

for use by authorities

1.4 Integrate swaps data with 

futures and options on futures 

data

Financial Integrity and Avoidance 

of Systemic Risk

2.1 Reduce the risk of 

disruptions to the system for 

clearing and settlement of 

contract obligations

2.2 Provide market participants 

with regulatory guidance

2.3 Strong governance and 

oversight of Commission 

registrants

2.4 Assess whether SDs, MSPs 

and FCMs maintain sufficient 

financial resources, risk 

management procedures, 

internal controls, and customer 

protection practices

Comprehensive Enforcement

3.1 Strengthen capacity to 

receive and expeditiously 

handle high-impact tips, 

complaints and referrals

3.2 Execute rigorous and 

thorough investigations

3.3 Effectively prosecute 

violations

3.4 Remedy past violations, 

deter future violations and 

related consumer losses

Domestic and international 

cooperation and coordination

4.1 Broad outreach on 

regulatory concerns

4.2 Sound international 

standards and practices

4.3 Provide global technical 

assistance

4.4 Robust Domestic and 

International Enforcement 

Cooperation and Coordination

3.4 Optimize infrastructure for management of high-volume 

information sources

3.4.1 Provide access to an increasing number of data 

sources and increasing sample sizes of market data 

(including non-futures market data)



(CFTC 1.1) (CFTC 2.1, 2.4) (CFTC 3.1, 3.2) (CFTC 4.4) 

3.4.2 Enable infrastructure support for high performance 

computing



(CFTC 1.1, 1.3) (CFTC 2.1, 2.4) (CFTC 3.1, 3.2) (CFTC 4.4) 
IT Strategic Plan 2014

78 Alignment Between the IT Strategic Initiatives and CFTC Goals and Objectives

 Management Objectives 

IT Strategic Goals, Objectives, Initiatives

5.1 A High-performing, 

diverse, and engaged 

workforce

5.2 Effective stewardship of 

resources

5.3 A Robust and 

Comprehensive Consumer 

Outreach Program

4.1 Deliver expected outcomes on IT Investments

 

4.1.1 Extensively use learning management, electronic learning, and 

video production

  

4.1.2 Achieve transparency through ODT communications and 

processes

 

4.2 Develop the ODT organization in alignment with the demands of 

CFTC’s core mission functions

4.2.1 Support the implementation of CFTC Governance 