U.S. COMMODITY FUTURES TRADING COMMISSION

Office of the Inspector General 

Office of Audits 

ATTESTATION REPORT

Report Number: 17-AU-04

Compliance with DATA Act of 2014- Reporting Accuracy (FY 2017 Quarter II)
-BLANK PAGE- 
U.S. COMMODITY FUTURES TRADING COMMISSION 

OFFICE OF INSPECTOR GENERAL

Three Lafayette Centre

1155 21st Street, NW, Washington, DC 20581 

Telephone: (202) 418-5110

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.

.

TO: J. Christopher Giancarlo, Chairman 

Brian D. Quintenz, Commissioner 

Rostin Behnam, Commissioner 

FROM: Miguel A. Castillo, CPA, CRMA

DATE: October 17, 2017 

SUBJECT: Compliance with DATA Act of 2014 - Reporting Accuracy 

(FY 2017 Quarter II) 

Introduction 

We performed the agreed-upon procedures in accordance with attestation 

standards established by the American Institute of Certified Public 

Accountants and Generally Accepted Government Auditing Standards. 

The purpose of this report is to fulfill our obligation as required by the 

Digital Accountability and Transparency Act of 20141 (DATA Act) and 

guidelines issued by the Federal Audit Executive Council (FAEC)2. For FY 

2017 Quarter II, the DATA Act requires the Office of the Inspector 

General (OIG) to review a statistically valid sampling of the U.S. 

Commodity Futures Trading Commission (CFTC) spending data. In 

addition, the Act requires the OIG to submit to Congress and make 

publically available a report assessing the completeness, timeliness, 

quality, and accuracy of sampled data and the use of data standards by 

the CFTC. 

Management is responsible for data submitted in accordance with the 

DATA Act and is required to provide a corrective action plan that 

addresses any exceptions noted. Management is also responsible for its 

financial records, establishing internal controls over financial reporting, 

and compliance with applicable laws and regulations. These procedures 

were agreed to by management and the OIG, solely to evaluate the 

completeness, quality, timeliness, and accuracy of FY 2017 Quarter II 

data submitted by management. 

1P.L. 113-101, 128 Stat. 1146 (2014) 2 Inspectors General Guide to Compliance Under the DATA Act
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The sufficiency of these procedures is solely the responsibility of the 

users of this report. Consequently, we make no representation regarding 

the sufficiency of the procedures described below either for the purpose 

for which this report has been requested or for any other purpose. 

Background 

Under an interagency agreement, the Department of Transportation’s 

Enterprise Service Center (ESC) provides system support for CFTC to 

fulfill its reporting obligation under the DATA Act. ESC followed the 

eight-step implementation plan from the DATA Act Implementation 

Playbook3 for system development and published procedures4 for its use 

which includes data validations. Those tasks that the CFTC cannot 

perform are delegated to ESC, monitored, and discussed monthly with 

the Chief Financial Officer/Senior Accountable Officer. 

Scope and Methodology 

To evaluate completeness, quality, timeliness and accuracy of the FY 

2017 Quarter II, we assessed internal controls over the CFTC 

procurement cycle to determine the appropriate level of risk. In addition, 

we inspected CFTC’s Quarter II submission to evaluate data elements 

and summary transactions. We selected a statistically valid sample of 

underlying transaction data representing payments. Management 

reconciled underlying payment data to summary transactions submitted 

in order for us to test accordingly. Table 1. shows the small volume of 

CFTC payments;5 1,308 in all averaging $25,175, with none more than 

$706,911. 

Table 1 

Analysis Variable : Payment Amount (Contracts)

Mean Std. Dev Maximum Sum N N Miss

25,175.59 80,417.57 706,911.89 32,929,671.49 1,308 0

 

3 Treasury released versions 1.0 and 2.0 of the DATA Act Implementation Playbook in June 2015 and June 

2016, respectively. The Playbook is not public, but Treasury has published one-page summary, released 

versions 1.0 and 2.0 of the DATA Act Implementation Playbook in June 2015 and June 2016, respectively.

4 AMKWI-333-334-335-00032 DATA Act Bulk File Submission. 5 Does not include travel payments and purchase card transactions less than $3,500.
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As such we determined our 

sample size, 297, based FAEC’s 

formula6 for a smaller 

population. See Figure 1. 

We measured completeness in 

two ways, assessing whether 

(1) transactions that should 

have been recorded were 

recorded in the tested reporting 

period and (2) all applicable data elements required by the DATA Act 

were included. Timeliness was measured as the percentage of 

transactions reported appropriately within the period and submitted 

within 30 days of quarter end. We measured quality by considering 

utility, objectivity, and integrity of information displayed for CFTC on 

www.USAspending.gov and reviewed system support information.7

Accuracy was measured as the percentage of transactions that were 

complete and in agreement with the record systems and supporting 

documentation. 

Our findings are as follows: 

Figure 1

Procurement – Internal Controls 

A control deficiency in internal control exists when the design or 

operation of a control does not allow management or employees to 

prevent or detect and correct errors on a timely basis. A significant 

deficiency is a control deficiency or a combination of control deficiencies 

that adversely affects CFTC’s ability to initiate, authorize, record, 

process, or report financial data reliably. A material weakness is a 

significant deficiency, or combination of significant deficiencies, that 

results in more than a remote likelihood that a material error will not be 

prevented or detected. 

We assessed CFTC’s payment (spending) reporting risk “low” because FY 

2015 and FY 2016 internal control tests performed by independent 

 

6 Where the recommended sample size of 385 represents 5 percent or more of the population, we reduced the 

sample size by applying the finite correction factor 385/[1+(385/N)], where “N” represents the population size. 

Figure 2 presents the inputs associated with our simple random sample.

7 Utility refers to the usefulness of the information to the intended users. Objectivity refers to whether the 

disseminated information was being presented in an accurate, clear, complete, and unbiased manner. 

Integrity refers to the protection of information from unauthorized access or revision. 
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public accountants8 (IPA) contracted by OIG did not identify material 

control deficiencies for payments. A review of the IPA’s FY 2017 internal 

control work papers and test results also did not reveal control 

deficiencies for this matter. Further, our review of internal controls9 did 

not identify material control deficiencies for payment reporting. 

Sample Test Results 

We found transactions tested were: 

1. Complete for contracts - All contract transactions (file total 

$32,668,617.12) that should have been recorded, were recorded, 

and contained all applicable data elements10 required by the DATA 

Act. A review of error controls used by CFTC’s service provider 

revealed that initial errors were addressed prior to submission. 

Error reports did not reveal any contract payments posted in 

incorrect periods. Figure 2 shows CFTC’s Quarter II submission 

was certified as meeting DATA Act requirements by ESC and 

CFTC’s Chief Accountant. 

Figure 2 

2. Incomplete for purchase cards - As it relates to purchase card 

transactions greater than $3,500, the FY 2017 Quarter II file 

submitted by CFTC did not include any of these transactions totaling 

$339,347.68 and representing about 1% of the file submission. 

3. Clear, complete, unbiased and useful for the intended purpose of 

making CFTC’s spending data transparent on 

 

8 CFTC OIG, 2016 Financial Statement Audit Opinion (Nov. 14, 2016); CFTC OIG, 2015 Financial Statement 

Audit Opinion (Jan. 15, 2016). 9 CFTC OIG, Review of Management Assurances Over Internal Controls (June 7, 2016). 10 https://max.gov/maxportal/assets/public/offm/DataStandardsFinal.htm
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www.USAspending.gov. These attributes are defined as aspects of 

quality. See Figure 3. 

Figure 3 

4. Timely – Transaction dates were within the tested reporting period 

and CFTC submitted its data file within 30 days of the quarter’s 

end; in this case no later than April 30,2017. (See Figure 2 for 

actual submission date). 

5. Accurate for contract transactions11 – With few exceptions, 

transactions were in agreement with the record systems and 

supporting documentation. We found 6 errors from our sample of 

297 transactions. These errors were associated with immaterial 

transaction amounts. As such, we are 95% confident the number 

of errors in the population could be as low as 12 or .9% but would 

be no more than 53 or 4%. See Figure 4. 

 

11 We considered the Government Accountability Office publication Assessing Data Reliability (p.19) to 

assess accuracy for the purpose. We determined that contract data were sufficiently reliable and thus 

accurate for the purposes of this report.
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Figure 4 

Corrective Action 

1. Review purchase card transaction omissions noted; coordinate 

corrective action with ESC and reconcile prior to each submission. 

Conclusion 

We were not engaged to perform, and did not perform, an audit, the 

objective of which would be the expression of an opinion on 

management's FY 2017 Quarter II DATA Act submission. Accordingly, 

we do not express such an opinion. We did however note that CFTC’s 

Data Act submission met the objectives of quality and timeliness. While 

the submission was also accurate for contract transactions, CFTC will 

need to ensure purchase transactions greater than $3,500 are included 

for future submissions to be complete. 

This report is intended solely for the use of management of the CFTC and 

Congress and should not be used by those who have not agreed to the 
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procedures and taken responsibility for the sufficiency of the procedures 

for their purposes. 

Managements Comments 

We provided the Chief Financial Officer/Senior Accountable Officer and 

Chief Accountant a draft copy of the report. To improve DATA Act 

reporting, they agreed to work with ESC and the purchase card vendor to 

address government-wide accounting issues that would allow purchase 

card transactions to be more transparent. Management actions are 

responsive to the recommendation. 

We will publish this report on the Office of the Inspector General’s web 

page and the report will be summarized in our March 2018 Semiannual 

Report to Congress. If you have any questions, please contact me at (202) 

418-5084 or Branco Garcia, lead auditor, at (202) 418-5013. 

Cc: 

United States Senate Committee on Homeland Security and 

Governmental Affairs 

The Honorable Ron Johnson, Chairman 

The Honorable Claire McCaskill, Ranking Member 

340 Dirksen Senate Building 

Washington, DC, 20510 

(202) 224-4751 

United States House Committee on Oversight and Government Reform 

The Honorable Trey Gowdy, Chairman 

The Honorable Elijah E. Cummings, Ranking Member 

2157 Rayburn House Office Building 

Washington, DC 20515 

(202) 225-5074 

United States Senate Committee on the Budget 

The Honorable Mike Enzi, Chairman 

The Honorable Bernie Sanders, Ranking Member 

624 Dirksen Senate Office Building 

Washington, DC 20510 

(202) 224-0642 
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United States House Committee on the Budget 

The Honorable Diane Black, Chairman 

The Honorable John Yarmuth, Ranking Member 

B-234 Longworth House Office Building 

Washington, D.C. 20515 

(202) 226-7270 

U.S. Government Accountability Office 

DATAActImplementation@gao.gov 

U.S. Department of the Treasury, OIG 

DATAAct@oig.treas.gov 

Michael Gill, Chief of Staff 

Kevin Webb, Chief of Staff 

John Dunfee, Acting Special Counsel 

Anthony Thompson, Executive Director 

Mary Jean Buhler, Chief Financial Officer 

Keith Ingram, Chief Accountant 

Melissa Jurgens, Executive Secretariat 

A. Roy Lavik, Inspector General 

Judith A. Ringle, Deputy Inspector General