Office of the Inspector General

U.S. Commodity Futures Trading Commission

Compliance with DATA Act of 2014 Readiness Review

November 29, 2016 

Report Number: 16-REV-02 
U.S. COMMODITY FUTURES TRADING COMMISSION

Three Lafayette Centre

1155 21st Street, NW, Washington, DC 20581

Telephone: (202) 418-5110

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TO: Timothy G. Massad, Chairman 

Sharon Y. Bowen, Commissioner 

J. Christopher Giancarlo, Commissioner 

Anthony C. Thompson, Executive Director 

Mary Jean Buhler, Chief Financial Officer 

FROM: Miguel A. Castillo, CPA CRMA 

Assistant Inspector General for Audits 

DATE: November 29, 2016 

SUBJECT: U.S. Commodity Futures Trading Commission Compliance with 

DATA Act of 2014 – Readiness Review in Fiscal Year (FY) 2016 

Introduction

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

May 9, 2014, required that Federal agencies report financial and payment data 

in accordance with data standards established by the Department of Treasury 

(Treasury) and the Office of Management and Budget (OMB). The DATA Act 

required agency Inspectors General (IGs) to review the readiness of the agency’s 

required program. In general, the Act requires agencies to begin reporting 

financial spending data using Treasury and OMB data standards by May 2017 

and publicly posting spending data in machine-readable formats by May 2018. 

According to the Government Accountability Office, “Full and effective 

implementation of the DATA Act will allow funds to be tracked at multiple 

points in the federal spending lifecycle.” For example, once fully implemented, 

amounts appropriated, obligated, and subsequently spent for a particular 

program activity would all be publicly available on www.USASpending.gov (or a 

successor system).2

Background

Treasury and OMB have developed 57 data definition standards and issued 

guidance to Federal agencies, including the DATA Act Implementation 

 

1 Pub. L. No. 113-101, 128 Stat. 1146 (May 9, 2014). The DATA Act amended the Federal Funding Accountability 

and Transparency Act of 2006. Pub. L. No. 109-282, 120 Stat. 1186 (Sept. 26, 2006), codified at 31 U.S.C. § 6101, 

note.

2 U.S. Government Accountability Office, DATA Act: Data Standards Established, but More Complete and Timely 

Guidance is Needed to Ensure Effective Implementation (GAO-16-261, January 2016).
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Playbook3. The “playbook” provides a high-level discussion of the vision and 

objectives of the DATA Act, followed by an eight-step agency implementation 

plan which agencies can use to develop methodologies for DATA Act 

implementation. The IGs’ readiness reviews of each Federal agency must 1) 

review statistical samples of data submitted by the agency under the DATA Act, 

and 2) report on the completeness, timeliness, quality, and accuracy of the 

sampled data and the agency’s use of the data standards. 

To fulfill our modified reporting obligation, we conducted a readiness review of 

the CFTC’s progress toward compliance with the DATA Act, and we plan to 

provide Congress with the first required report in November 2017, with 

subsequent reports following on a two year cycle, in November 2019 and 

November 2021,4 as mandated by the DATA Act. 

Objective Scope and Methodology

The objective of our readiness review was to document our understanding of 

the processes, systems, and controls which the CFTC has implemented, or plan 

to implement, to comply with the DATA Act. We reviewed the CFTC’s progress 

toward DATA Act compliance within the structure of Treasury’s eight-step 

implementation plan. Specifically, we assessed the CFTC’s progress in 

completing steps one through six, as early Treasury guidance anticipated that 

progress would be made in these six steps at the time of our review. 

We conducted our work at CFTC headquarters’ office in Washington, D.C., and 

the Department of Transportation, Federal Aviation Authority, Enterprise 

Service Center (ESC) field site in Oklahoma City, OK. between May 2016 and 

October 2016. We interviewed personnel from the CFTC DATA Act working 

group, including the Chief Financial Officer (CFO), Department of 

Transportation OIG personnel performing a readiness review of ESC, and the 

ESC working group lead. We also reviewed CFTC’s and ESC’s implementation 

plans, documents summarizing the project’s progress, and ESC timelines. 

 

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 On December 22, 2015, the chair of the Council of the Inspectors General on Integrity and Efficiency issued a 

letter memorializing this strategy for dealing with the Inspector General reporting date anomaly and communicated 

it to the Senate Committee on Homeland Security and Governmental Affairs and the House Committee on Oversight 

and Government Reform.
3

Conclusion

Under an interagency agreement, ESC is implementing the DATA Act 

requirements on behalf of CFTC and is on schedule to meet its first reporting 

deadline of May 2017. CFTC and ESC’s implementation of the DATA Act have 

followed the eight-step implementation plan from the “playbook”. ESC has a 

comprehensive technical plan for complying with the DATA Act and is working 

seamlessly with the CFTC. Those tasks that the CFTC cannot perform are 

delegated to ESC, monitored by an internal working group, and discussed 

monthly with the Chief Financial Officer/Senior Accountable Officer (SAO). (See 

Appendix A – Eight Steps for Complying with DATA Act 2014, which summarizes 

our observations of the six out of eight steps of the “playbook.”) 

We do not plan to perform additional readiness reviews of CFTC’s compliance 

with the DATA Act. As required, we will review statistical samples of the data 

and report on its completeness, timeliness, quality, and accuracy by November 

2017. Management stated that no written comments were necessary and 

therefore we are issuing this report in final. For additional information or to 

discuss our responses, please contact me at (202) 418-5084 or 

mcastillo@cftc.gov. 

Cc: 

Clark Ogilvie, Chief of Staff 

A. Roy Lavik, Inspector General 

Judith A. Ringle, Deputy Inspector General and General Counsel
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Appendix A5

Eight Steps for Complying with DATA Act 2014

1. Organize Team: Create an agency DATA Act working group including 

impacted communities and identify Senior Accountable Official. 

Status: Complete 

OIG Evaluation: CFTC has a five-member DATA Act working group of subject 

matter experts from the Financial Management Branch including a Deputy 

Accounting Officer (Lead), an Accounting Officer, a Senior Procurement 

Executive, a Budget Officer, and the Chief Financial Officer as the Senior 

Agency Officer (SAO). In addition, ESC has a DATA Act program group 

composed of a project manager and technical experts. 

2. Review Elements: Review list of DATA Act elements and participate in 

data definitions standardization.

Status: Complete 

OIG Evaluation: ESC completed its review of data elements in August 2015. 

The CFTC working group reviewed data element definitions concurrently with 

ESC and found the data elements to be consistent with current definitions. 

3. Inventory Data: Perform inventory of agency data and associated 

business processes. 

Status: Complete 

OIG Evaluation: ESC performed an inventory of agency data by identifying 

source systems for each of the 57 data elements. The CFTC working group 

relied on ESC’s work and noted that only eight of the data elements which are 

financial were required for other financial reporting tasks. 

4. Design and Strategize: Plan changes to systems and business 

processes to capture data that are complete, multilevel, and fully 

linked. 

Status: Complete 

OIG Evaluation: CFTC submitted the required agency implementation plan in 

September 2015. CFTC’s implementation plan clearly points to the work for 

ESC to perform. ESC submitted its implementation plan in August 2015 and 

updated it in July 2016. ESC’s implementation plan and more detailed project 

plan covers the topics and considers the factors that will allow ESC to fully 

 

5

 Data Act Implementation Playbook version 1.0 and OIG work performed.
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implement the DATA Act. The CFTC formally tracks ESC’s progress and reports 

progress monthly to the CFO/SAO. 

5. Prepare Data for Submission to the Broker: Implement system 

changes and extract data iteratively. 

Status: In Progress 

OIG Evaluation: CFTC is dependent on ESC implementation of necessary 

system changes. We note that ESC has not mapped data elements via a 

common identifier (Award ID) between the CFTC’s financial systems because 

ESC is waiting on the system software patches from the software developer. 

6. Test Broker Outputs and Ensure Data are Valid: Test broker outputs 

to ensure data are valid iteratively. 

Status: In Progress 

OIG Evaluation: CFTC is relying on ESC to test data validity. ESC has tested 

the broker using only sample data. As noted earlier, ESC will test CFTC 

transmitted data after software patches are installed and been available by the 

software vendor in a timely manner to accommodate ESC’s testing cycle. 

7. Update Data and Systems: Implement other system changes 

iteratively. 

Status: In Progress 

OIG Evaluation: We did not include this step in our readiness review. 

8. Submit Data: Update and refine process. 

Status: In Progress

OIG Evaluation: We did not include this step in our readiness review. 
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Source: DATA Act Implementation Playbook version 1.0
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Recipients: 

United States Senate Committee on Homeland Security & Governmental Affairs 

The Honorable Ron Johnson, Chairman 

The Honorable Tom Carper, Ranking Member 

340 Dirksen Senate Building 

Washington, DC, 20510 

202-224-4751 

Chairman Johnson staff contact – David Brewer, 

david_Brewer@HSGAC.senate.gov 

Senate HSGAC minority – Rebecca Maddox, 

Rebecca.Maddox@hsgac.senate.gov

United States House Committee on Oversight and Government Reform 

The Honorable Jason E. Chaffetz, Chairman 

The Honorable Elijah E. Cummings, Ranking Member 

2157 Rayburn House Office Building 

Washington, DC 20515 

(202) 225-5074 

House Gov’t oversight majority – Jeffrey Post, Subcommittee Deputy Staff 

Director, Subcommittee on Gov’t Operations, Committee on Oversight and 

Government Reform 

jeffrey.post@mail.house.gov 

House Gov’t oversight minority – Mark Stephenson, Legislative Director, 

Committee on Oversight and Government Reform 

Mark.Stephenson@mail.house.gov 

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 

Kimberly Proctor, Chief Clerk, U.S. Senate Committee on the Budget, 

Kimberly_Proctor@budget.senate.gov 

United States House Committee on the Budget 

The Honorable Tom Price, M.D., Chairman 

The Honorable Chris Van Hollen, Ranking Member 

207 Cannon House Office Building 

Washington, D.C. 20515 

(202) 226-7270 

Kimberly Proctor, Chief Clerk, U.S. Senate Committee on the Budget, 

Kimberly_Proctor@budget.senate.gov 
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GAO 

Reports can be electronically submitted at DATAActImplementation@gao.gov 

Treasury OIG 

Reports can be electronically submitted at DATAAct@oig.treas.gov