Document Location: 

FY 2016 Annual 

Performance Report 

 & 

FY 2018 Annual 

Performance Plan 

May 2017

CFTC
Commodity Futures Trading Commission

May 23, 2017 Page 2 of 25 

Table of Contents

Strategic Framework ................................................................................................................ 3

Summary of Performance........................................................................................................ 4

Goal One: Market Integrity and Transparency .................................................................................... 5

Goal Two: Financial Integrity and Avoidance of Systemic Risk ....................................................... 8

Goal Three: Comprehensive Enforcement........................................................................................12

Goal Four: Broad Outreach on Regulatory Concerns .....................................................................15

Management Objectives.......................................................................................................................18

Completeness and Reliability of Performance Data .........................................................................21

Program Evaluations ............................................................................................................................21

Appendix A: FY 2016 Enforcement Actions ..........................................................................22

Appendix B: Indicators Discontinued in FY 2016 .................................................................24
Commodity Futures Trading Commission

May 23, 2017 Page 3 of 25 

Strategic Framework

Below is an overview of the Commission’s mission statement and strategic goals. The results in the 

following pages demonstrate progress on strategic objectives and performance indicators in support of 

the strategic goals and CFTC mission from the FY 2014–2018 Strategic Plan: 

Mission Statement 

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. 

Strategic Goals 

 Strategic Goal One – Market Integrity and Transparency 

 Strategic Goal Two – Financial Integrity and Avoidance of Systemic Risk 

 Strategic Goal Three – Comprehensive Enforcement 

 Strategic Goal Four – Domestic and International Cooperation and Coordination 

 Management Objectives 

About This Report – The combined FY 2016 Annual Performance Report and FY 2018 Annual 

Performance Plan (APR/APP) provides an overview of the CFTC’s performance results relative to its 

mission. The report is organized by strategic goal, strategic objective and performance indicator. This 

report is available at: http://www.cftc.gov/About/CFTCReports/index.htm

Performance Analysis – In the FY 2014-2018 Strategic Plan, the CFTC established a series of new 

performance indicators, some were still in draft status when published and needed testing during FY 

2016. These are “baseline” performance indicators. Baselined indicators do not have targets until 

testing is complete. Other indicators have results designated as having either ‘Met’ or ‘Not Met’ its 

target. 

Key Activity/Program Ends – When a key activity/program has achieved its long-term target, there 

are no targets for upcoming years and the indicator is moved to Appendix B: Indicators Discontinued in 

FY 2016.

Reporting History/Trending – Six performance indicators continued from the previous strategic plan, 

and subsequently have longer result trends in the indicator tables below. The CFTC began tracking 38 

new performance indicators in FY 2015 for a total of 44. During FY 2016, The CFTC reviewed all 

indicators and determined that seven should be discontinued (see Appendix B). Therefore, the CFTC 

finished the year reporting on 37 indicators. 

Reporting Year – Unless otherwise noted, the reporting period for this report is from October 1, 2015 

through September 30, 2016 (called FY 2016 or ‘the year’). 

Management Challenges – The Inspector General’s Assessment of the Most Serious Management 

Challenges Facing the CFTC and CFTC Management’s Response to the Inspector General’s Assessment

are included in the Commission’s FY 2016 Annual Financial Report: 

http://www.cftc.gov/idc/groups/public/@aboutcftc/documents/file/2016afr.pdf. 
Commodity Futures Trading Commission

May 23, 2017 Page 4 of 25 

Summary of Performance

19

12

1 

5 

FY 2016 Performance Summary 

Met

Not Met

Baseline

Contextual

Met: The activity/program 

fully met or exceeded the 

terms of its target(s) 

during the fiscal year. 

Not-Met: The program/ 

activity did not achieve the 

terms of its target(s) 

during the fiscal year. 

Baseline: Indicators that 

have not been finalized. 

Contextual: Indicators 

that do not have targets or 

have been discontinued. 

Overall results for the Commission’s performance indicators are depicted in the following table:

FY 2016 Met Not Met Baseline Contextual

Goal 1 4 4 0 0

Goal 2 8 3 0 0

Goal 3 2 2 0 0

Goal 4 1 0 0 5

Management 

Objectives

3 4 1 0

Subtotal 19 12 1 5

Total 37
Commodity Futures Trading Commission

May 23, 2017 Page 5 of 25 

Met: The activity/ 

program fully met or 

exceeded the terms of its 

target(s) during the fiscal 

year. 

Not Met: The program/ 

activity did not achieve the 

terms of its target(s) during 

the fiscal year. 

Baseline: Indicators that 

have not been finalized. 

Contextual: Indicators that 

do not have targets or 

have been discontinued. 

Goal One: Market Integrity and Transparency

 

Objective 1.1: Markets not readily susceptible to manipulation and other abusive practices 

Performance Indicator 1.1.a

Strive for percentage of high impact contract and rule submissions received by the Commission through the OPERA portal.

Description: This indicator captures the efficiency with which staff can receive and process exchange submissions related to 

contracts and rules. Through the portal, exchanges are able to electronically file submissions directly with the Commission. 

The portal will then automatically route submissions to relevant staff without the need for staff to input certain data elements 

into its systems.

Fiscal Year FY 2015 Actual FY 2016 Plan FY 2016 Actual FY 2017 Target FY 2018 Estimate

Nearly 96% 100% 99% 100% 100%

Target: Not Met.

Responsible Division/Office: DMO

Performance Indicator 1.1.b

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.

Description: The Commission routinely examines data to uncover violations of the CEA or Commission regulations with respect 

to manipulation, compliance abuses and other violations, and reviews the data for significant market events or situations. In 

the case of a market emergency or event, the CFTC communicates with exchanges and market participants. In some situations 

staff may work with the exchanges and participants to resolve potentially disruptive conduct to maintain order and market 

integrity.

The Commission has developed several automated procedures that can be used by surveillance staff to identify potential 

violations, and is in the early stages of a multi-year effort to develop analytic tools for use in the harmonization of data and to 

improve processes to evaluate trading data.

Fiscal Year FY 2016 Plan FY 2016 Actual FY 2017 Target FY 2018 Estimate

N/A No reporting 20% 50%

Target: Not Met

Responsible Division/Office: DMO & ODT
Commodity Futures Trading Commission

May 23, 2017 Page 6 of 25 

Objective 1.2: Establishment of an effective self-regulatory framework 

Performance Indicator 1.2.a

Examine compliance by exchanges with the CEA Core Principles and Commission regulations, prioritizing systemically important 

entities.

Description: Using both risk-based and Core Principles-based approaches, the Commission conducts comprehensive 

examinations of selected compliance programs at the exchange and swap data repositories, and publishes examinations reports 

when deficiencies are identified. Exchanges are notified, and CFTC staff monitor their remediation efforts.

Fiscal 

Year

FY 2015 Actual FY 2016 Plan FY 2016 Actual FY 2017 Target FY 2018 Estimate

Baseline Year –

Commission 

completed four rule 

enforcement reviews

(RERs) 1and completed 

on-site interviews for 

3 1/2 of four

additional RERs

Four DCM Rule 

Enforcement 

Reviews 

complete, and 

three DCM RERs 

initiated

One DCM Rule 

Enforcement 

Review complete 

and two RERs 

initiated

Complete four DCM RERs, 

initiate two formal DCM 

RERs and three informal 

(i.e., reach out to DCMs to 

discuss compliance 

programs); 

and one SEF horizontal 

RER.

Complete four DCM 

RERs, 

initiate three DCM 

RERs, complete one 

SEF RER, and initiate 

two SEF RERs.

Target: Not Met

Responsible Division/Office: DMO

Performance Indicator 1.2.b

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.

Description: The Commission reviews 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 to determine

need for further DMO review or action. Notifications range from informal e-mails to formal incident reports.

Fiscal Year FY 2015 Actual FY 2016 Plan FY 2016 Actual FY 2017 Target FY 2018 Estimate

Baseline year –

Commission 

reviewed 100% of 

notifications and 

updates during the 

fiscal year.

100% review 100% review 100% 100%

Target: Met

Responsible Division/Office: DMO 

Performance Indicator 1.2.c

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.

Description: Using both risk-based and Core Principles-based approaches, the Commission conducts comprehensive 

examinations of system safeguards and cyber security programs at exchanges and SDRs, and prepares examinations reports 

when deficiencies are identified. Commission staff notify Exchanges and SDRs, and staff monitor their remediation efforts.

Fiscal Year FY 2015 Actual FY 2016 Plan FY 2016 Actual FY 2017 Target FY 2018 Estimate

Baseline Year –

Commission 

completed SSEs for 

five systemically 

important entities. 

Conduct five 

System Safeguard 

Examinations (SSEs)

Five on-site 

reviews for SSEs

conducted

Conduct seven 

system SSEs, 

including swap 

execution facilities 

(SEFs)

Conduct eight SSEs, 

including SEFs

Target: Met

Responsible Division/Office: DMO

 

1

 Revised to four Rule Enforcement Reviews (RER) from 2015 APR figure of one RER. 
Commodity Futures Trading Commission

May 23, 2017 Page 7 of 25 

Objective 1.3: Availability of market information to the public and for use by authorities

Performance Indicator 1.3.a

Percentage of derivatives activity covered by regularly published Commission reports.

Description: In addition to regular reports on activity in the futures and options on futures markets, the Commission plans to 

begin publishing regular reports of activity in the swaps market to bring greater public transparency to this market. Initially, 

these reports will cover the major swap categories and then be expanded to include other categories as they meet minimum 

activity thresholds. These reports provide a measure of public transparency into derivatives market activity for those markets 

where minimum activity and participation levels have been attained.

Fiscal 

Year

FY 2012 FY 2013 FY 2014 FY 2015 

Actual

FY 2016 

Plan

FY 2016 

Actual

FY 2017 

Target

FY 2018 

Estimate

100% 70% 75% 90% 98% 98% 98% 98%

Target: Met 

Responsible Division/Office: OCE

Performance Indicator 1.3.b

Publish economic research reports to inform the public about market structure of the derivatives markets.

Description: These reports will be based on empirical research into the market microstructure of futures, options on futures, 

and swaps markets. The indicator provides a measure of economic analyses designed to inform both the public and the 

academic community of various developments in these markets, including their ongoing evolution within the context of 

electronic trading technologies and regulations.

Fiscal Year FY 2015 Actual FY 2016 Plan FY 2016 Actual FY 2017 Target FY 2018 Estimate

Four reports Three reports Five reports Three reports Three reports

Target: Met

Responsible Division/Office: OCE

Objective 1.4: Integrate futures and options positions and transactions data 

Performance Indicator 1.4.a

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

Description: This activity serves as a measure of regulatory and public transparency into trader derivative activity. It captures 

the percentage of futures trading volume where the traders have been matched to their large trader end-of-day futures 

positions. For purposes of increasing market transparency, it is critical for CFTC staff to be able to match the position and 

trading activity across the major databases used by the Commission—i.e., large trader positions, futures and options on futures 

transactions.

Fiscal Year FY 2015 Actual FY 2016 Plan FY 2016 Actual FY 2017 Target FY 2018 Estimate

Baseline year –

Commission made 

limited progress because 

CFTC is waiting for 

Ownership and Control 

Reporting to begin. 

10% See analysis above 40% 80%

Target: Not Met

Responsible Division/Office: DMO & ODT
Commodity Futures Trading Commission

May 23, 2017 Page 8 of 25 

8 

3 

Goal 2 Performance 

Summary 

Met

Not Met

Baseline

Contextual

Met: The activity/program fully met or 

exceeded the terms of its target(s) during 

the fiscal year. 

Not Met: The program/activity did not 

achieve the terms of its target(s) during 

the fiscal year. 

Baseline: Indicators that have not been 

finalized. 

Contextual: Indicators that do not have 

targets or have been discontinued. 

Goal Two: Financial Integrity and Avoidance of Systemic Risk

Objective 2.1: Avoid disruptions to the system for clearing and settlement of contract 

obligations 

Performance Indicator 2.1.a

CFTC strives to conduct back testing of DCOs’ material product and portfolio initial margin requirements to assess their 

sufficiency.

Description: To measure the sufficiency of margin requirements, the Commission back tests the profit or loss of a given product 

or portfolio against the margin requirement for the applicable liquidation period. The defaulting firm’s margin contributions 

are the first financial resource used to cover the financial impact of a clearing member default. To the extent margin can cover 

the financial impact of the default, the DCO will not have to use its own resources to cover the balance.

Fiscal 

Year

FY 2015 Actual FY 2016 Plan FY 2016 Actual FY 2017 Target FY 2018 Estimate

Conducted back testing 

of products and 

portfolios of two DCOs

Conduct back testing of 

products and portfolios 

of three DCOs

Five DCOs Five DCOs Five DCOs

Target: Met 

Responsible Division/Office: DCR

Performance Indicator 2.1.b

CFTC develops and calculates clearing members’ ability to fund variation and initial margin requirements using hypothetical 

market scenarios.

Description: The Commission’s objective is to enhance existing programs to evaluate aggregate clearing member financial 

resources against possible calls for variation payments at all DCOs in which a firm is a clearing member. Failing to make a 

variation margin payment is one of the ways in which a firm can default to the DCO. Firm variation margin payments likely will 

increase as more swaps are cleared. The Commission gathers information as to the type and level of financial resources 

available to clearing members to meet variation margin payments. 

Fiscal 

Year

FY 2015 Actual FY 2016 Plan FY 2016 Actual FY 2017 Target FY 2018 Estimate

Assessed 10% of 

clearing members

Assess 21% of 

clearing members

Assessed 10 clearing 

members (approx. 25% of 

overall clearing members)

24 27

Target: Met

Responsible Division/Office: DCR
Commodity Futures Trading Commission

May 23, 2017 Page 9 of 25 

Performance Indicator 2.1.c

Aggregate cleared swaps, futures, and options positions into a comprehensive risk surveillance process and conduct analysis for 

each material market participant.

Description: The Commission has a comprehensive program in place to aggregate and conduct risk surveillance of market 

participants’ futures and options positions. The Commission is developing procedures to aggregate swap positions across 

multiple DCOs and the asset classes for which such DCOs offer clearing services. Upon the development of such procedures, 

the Commission will be in a position to aggregate the risk of market participants that trade futures, swaps, and options and 

conduct risk surveillance for that aggregate portfolio.

Fiscal 

Year

FY 2015 Actual FY 2016 Plan FY 2016 Actual FY 2017 Target FY 2018 Estimate

CFTC aggregated the 

risk of 25 interest 

rate swap (IRS) and 

interest rate (IR) 

futures accounts.

Aggregate risk of 

market participants’ 

interest rate swap &

interest rate (IR) 

futures to get full IR 

exposure. Number of 

market participants is 

TBD for FY 2016.

16 CFTC 

aggregated the 

risk of 16

interest rate 

swap (IRS) and 

interest rate 

(IR) futures 

accounts.

CFTC will aggregate 

risk of market 

participants' IRS and 

IR futures to get full 

IR exposure. Success 

of activities during FY 

2016 will determine 

FY 2017 target.

By end of 2018,

CFTC will be 

aggregating risk of 

all customer and 

house IR and IRS 

exposure.

Target: Not Met 

Responsible Division/Office: DCR

Performance Indicator 2.1.d

Review Derivatives Clearing Organization (DCO) notifications regarding: hardware or software disruptions, cyber security events 

or threat events, activation of the DCOs’ business continuity or disaster recovery plans, significant planned changes to missioncritical systems, planned changes to the DCOs’ programs of risk analysis, and other notifications that potentially impact or could 

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

Description: Review DCO notifications regarding any:







hardware or software malfunction, cyber security incident, or targeted threat that materially impairs, or creates a significant 

likelihood of material impairment, of automated system operation, reliability, security, or capacity

activation of the DCO’s BC/DR plan, and 

material planned changes to DCO’s automated systems that are likely to have a significant impact on the reliability, security, 

or adequate scalable capacity of such systems, or programs of risk analysis and oversight. 

The Commission will design these reviews to evaluate the adequacy of the proposed corrective action to address systems 

disruptions and review plans for changes to systems or programs of risk analysis.

Fiscal 

Year

FY 2015 Actual FY 2016 Plan FY 2016 Actual FY 2017 Target FY 2018 Estimate

Filings reviewed 

within 

appropriate 

timeframe, 75% 

of the time.

Conduct high-level 

reviews of significant 

disruptions within 2-5 

business days, 85% 

of the time.

Conduct reviews of 

non-significant 

disruptions within 30 

calendar days, 85% of 

the time.

 Reviewed 93% of 

material 

notifications 

within 2-5 

business days. 

 80% of nonmaterial 

notifications 

reviewed within 

30 days.

 Conduct high-level 

reviews of 

significant 

disruptions within 

2-5 business days, 

85% of the time.

 Conduct reviews 

of non-significant 

disruptions within 

30 calendar days, 

80% of the time.

 Conduct highlevel reviews of 

significant 

disruptions within 

2-5 business days, 

85% of the time.

 Conduct reviews 

of non-significant 

disruptions within 

30 calendar days, 

80% of the time.

Target: Not Met

Responsible Division/Office: DCR
Commodity Futures Trading Commission

May 23, 2017 Page 10 of 25 

Performance Indicator 2.1.e.1

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. 

Description: The Commission conducts comprehensive, risk-based examinations of systemically important DCOs (SIDCOs) 

regarding compliance with the Core Principles of the CEA and Commission regulations. Identify issues that may impact the 

DCOs ability to control and monitor its risks, present the issues to DCO management and monitor remediation efforts to rectify 

the issues. 

Fiscal 

Year

FY 

2011

FY 

2012

FY 

2013

FY 2014 FY 2015 FY 2016 Plan FY 2016 

Actual

FY 2017 

Target

FY 2018 

Estimate

75% 50% 100% 100% 100% On an annual 

basis, examine

100% of SIDCOs

100% 100% 100%

Target: Met

Responsible Division/Office: DCR

Performance Indicator 2.1.e.2

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.

Description: The Commission conducts comprehensive risk-based examinations of non-systemically important DCOs regarding

compliance with the Core Principles of the CEA and Commission regulations. Identify issues that may impact the DCOs ability to 

control and monitor its risks, present the issues to DCO management and monitor remediation efforts to rectify the issues. 

There were 10 such DCOs in FY 2015. Completion of examinations allows the Commission to see if a DCO is in compliance with 

the Core Principles, which gives CFTC staff the opportunity to identify any areas of non-compliance and allows the DCO to 

correct any areas of non-compliance. 

Fiscal 

Year

FY 2011 FY 2012 FY 2013 FY 2014 FY 2015 FY 2016 Plan FY 2016 

Actual

FY 2017 

Target

FY 2018 

Estimate

44% 30% 23% 0% 30% Conduct 

examinations 

of 40% of all 

other DCOs

Completed 

fieldwork 

for four 

exams.

40% 40%

Target: Not Met

Responsible Division/Office: DCR

Objective 2.2: Provide market participants with timely guidance 

Performance Indicator 2.2.a.2

Percent of swap dealer and major swap participants registration documentation completed.

Description: The NFA reviews the registration applications of SDs and MSPs to determine whether the registrants have 

included adequate policies and procedures in accordance with applicable regulation. CFTC measures its success for this 

indicator by the guidance the Commission provides to the NFA on substantive new regulatory areas relevant to registration 

applications. This definition was updated to reflect that the NFA currently is the designated self-regulatory organization 

responsible for regulating SDs and MSPs registered with the Commission.

Fiscal Year FY 2015 Actual FY 2016 Plan FY 2016 Actual FY 2017 Target FY 2018

Estimate

71% - Commission worked 

with NFA to develop NFA’s 

capacity to review swap 

dealer applications 

effectively. 

Provide guidance for 

90% of the SD and MSP 

application review 

program.

100% Activity Complete Activity 

Complete

Target: Met

Responsible Division/Office: DSIO
Commodity Futures Trading Commission

May 23, 2017 Page 11 of 25 

Objective 2.3: Strong governance and oversight by financial registrants 

Performance Indicator 2.3.a.1

Conduct oversight reviews of Swap Dealers (SDs).

Description: Relying upon a risk-based and regulatory compliance oversight approach, the Commission will conduct targeted 

reviews and examinations of SDs in key areas, such as cybersecurity policies, with the National Futures Association (NFA) 

conducting regular direct examinations of SDs.

Fiscal Year FY 2015 Actual FY 2016 Plan FY 2016 Actual FY 2017 Target FY 2018 Estimate

Three SDs 30 SDs 49 SDs 30 SDs 30 SDs

Target: Met

Responsible Division/Office: DSIO

Performance Indicator 2.3.a.2

Conduct oversight reviews of Futures Commission Merchants (FCMs).

Description: Relying upon a risk-based and regulatory compliance oversight approach, the Commission will conduct targeted 

reviews and examinations of FCMs in key areas, such as cybersecurity policies, with the DSROs conducting regular direct 

examinations of FCMs.

Fiscal Year FY 2015 Actual FY 2016 Plan FY 2016 Actual FY 2017 Target FY 2018 Estimate

Zero FCMs 30 FCMs 55 FCMs 30 FCMs 30 FCMs

Target: Met

Responsible Division/Office: DSIO

Performance Indicator 2.3.b

Review Chief Compliance Officer (CCO) annual reports for Swap Dealers (SDs), Major Swap Participants (MSPs), and Futures 

Commission Merchants (FCMs), and provide feedback to the registrants on governance and compliance oversight.

Description: The Commission will review the CCO annual report filings of the SDs, MSPs, and FCMs and evaluate governance 

and compliance best practices, effectiveness of the evaluations, and areas for follow up with specific firms where the report is 

not up to expectations.

Fiscal Year FY 2015 Actual FY 2016 Plan FY 2016 Actual FY 2017 Target FY 2018 Estimate

49% Review 50% of CCO 

annual reports for SDs, 

MSPs, and FCMs.

96% 60% 75%

Target: Met

Responsible Division/Office: DSIO

Objective 2.4: Market participants maintain sufficient financial resources, risk management 

procedures, and customer protection practices 

Performance Indicator 2.4.b

Monitor high-risk registrants focusing on Futures Commission Merchants for signs of financial stress. 

Description: The Commission will monitor registrant firms for financial stress by, reviewing notices and monthly and/or annual 

financial filings, among other things. High-risk firms are identified as such through indicators developed by the Staff which 

consider such attributes as capital, liquidity, ratio of excess segregated to secure collateral, CPA firm, leverage ratios, etc.

Fiscal Year FY 2015 Actual FY 2016 Plan FY 2016 Actual FY 2017 Target FY 2018 Estimate

100% Monitor 100% of highrisk firms for signs of 

financial stress, with 

focus on FCMs.

100% 100% 100%

Target: Met

Responsible Division/Office: DSIO
Commodity Futures Trading Commission

May 23, 2017 Page 12 of 25 

Goal Three: Comprehensive Enforcement 

 

3 

1 

Goal 3 Performance Summary 

Met

Not Met

Baseline

Contextual

Met: The activity/program 

fully met or exceeded the 

terms of its target(s) 

during the fiscal year. 

Not Met: The 

program/activity did not 

achieve the terms of its 

target(s) during the fiscal 

year. 

Baseline: Indicators that 

have not been finalized. 

Contextual: Indicators that 

do not have targets or 

have been discontinued. 

Objective 3.1: Strengthen capacity to receive and expeditiously handle high-impact tips, 

complaints and referrals 

Performance Indicator 3.1.a.1

Strengthen and ensure a coordinated approach to receiving, assessing, and referring tips, complaints and referrals as necessary 

and appropriate; establish a unit or office dedicated to this function.

Description: The Commission will evaluate and refine the current processes and mechanisms, if necessary, for handling leads 

from all sources to increase the effectiveness and efficiencies of those processes and mechanisms. This indicator reflects the 

need of the Commission to enhance its capability to receive, analyze and process tips, complaints and referrals, and focuses in 

particular on the preliminary analysis which informs the Commission’s decision whether to devote more resources to a full 

investigation. The Commission created the Litigation, Intake and Triage Unit during 2015 to perform an initial review of tips, 

complaints, and leads (TCLs), so that only those with merit would be forwarded on to the investigative teams for preliminary

investigation (PI). The current indicator is now a combination of the time the investigative teams and the Litigation, Intake and 

Triage Unit spend analyzing the merits of a TCL.

Fiscal 

Year

FY 2015 Actual FY 2016 Plan FY 2016 Actual FY 2017 Target FY 2018 Estimate

 20-hour average 

time to review 

tips met

 Average review / 

referral time for TCLs 

is 18 hours. 

 60% of referrals lead 

to an investigation.

 78% of referrals 

were converted 

by teams within 

18 hours.

 80% of referrals 

lead to an 

investigation.

Developing new 

indicators to 

demonstrate 

improved

performance of 

handling tips, 

complaints, and 

referrals.

Developing new 

indicators to 

demonstrate 

improved 

performance of 

handling tips, 

complaints, and 

referrals.

Target: Met

Responsible Division/Office: DOE
Commodity Futures Trading Commission

May 23, 2017 Page 13 of 25 

Performance Indicator 3.1.b.1

Develop a comprehensive communication strategy, geared for internal and external stakeholders, relating to the role of 

whistleblowers and the function of the Whistleblower Office (WBO).

Description: The Commission will develop and provide training to new Enforcement Division and contractor new hires. 

This indicator reflects the need of the WBO to communicate effectively to internal audiences. Internal communication allows 

the WBO staff to train and inform the Commission staff about the WBO, the relevant law surrounding the role of 

whistleblowers, and the unique and protected nature of whistleblower identifying information. Internal communication also 

informs the WBO staff about external persons to whom they need to direct their message.

Fiscal 

Year

FY 2015 Actual FY 2016 Plan FY 2016 Actual FY 2017 Target FY 2018 Estimate

Completed 

training for 28 

new Division of 

Enforcement 

staff, including 

training 13 

newly hired 

division 

contractors.





Develop/provide 

annual training to 

new hires/staff.

Provide live, inperson training to 

staff in home office 

and regions.

Provided 

individualized 

training to over 20 

employees in home 

office and regions. 

 Provide annual training 

to new hires and staff. 

Provide live, in-person 

training to staff in home 

office and regions.

 Draft best practices 

guide for the DOE when 

working with the WBO 

in investigations, 

litigation, and 

administrative 

proceedings.





Provide annual 

training to new 

hires and staff. 

Conduct 

individualized 

training for staff 

assigned to 

whistleblower 

matters on asneeded basis. 

Target: Met

Responsible Division/Office: DOE

Performance Indicator 3.1.b.2

Develop a comprehensive communication strategy, geared for internal and external stakeholders, relating to the role of 

whistleblowers and the function of the Whistleblower Office.

Description: The Commission will participate in five annual public forums and trade shows annually, including the national 

Futures Industry Association Conference. This indicator reflects the need of the WBO to communicate effectively to external 

audiences. Outreach is an essential part of the program. The WBO will send the message that the program is in place and 

emphasize in its message the rewards and protections offered by Section 23 of the CEA and the Commission regulations. 

Whistleblowers provide the Commission with the opportunity to receive timely information relating to potential violations of 

the CEA that may not otherwise be available. 

Fiscal 

Year

FY 2015 Actual FY 2016 Plan FY 2016 Actual FY 2017 Target FY 2018 Estimate

Participated in 

12 public 

forums and 

trade shows 





Participate in 12 

annual public 

forums and trade 

shows. 

Create new 

website for 

Whistleblower 

office.





Participated in 18 

annual public 

forums and trade 

shows. 

Launched new 

website for 

whistleblower

office.





Participate in 15 

annual public 

forums and trade 

shows. 

Update new 

website to make it 

more effective tool 

for communicating 

with external 

stakeholders.





Participate in 15 

annual public 

forums and trade 

shows. 

Update frequently 

asked questions on 

whistleblower 

website, as 

necessary, to 

address new 

issues.

Target: Met

Responsible Division/Office: DOE
Commodity Futures Trading Commission

May 23, 2017 Page 14 of 25 

Objective 3.2: Execute rigorous and thorough investigations

Performance Indicator 3.2.a

Percentage of enforcement investigations completed within 18 months of opening, depending on the nature and scope of 

investigations. 

Description: This indicator identifies, for all investigations closed within the preceding 18 months, the percentage of such 

investigations that the Commission closed within 18 months of their opening. In conducting investigations, the enforcement 

program endeavors to complete effective and fair investigations in a timely manner, depending upon the nature and scope of 

the investigations and resources available. 

Fiscal 

Year

FY 2011 FY 2012 FY 2013 FY 2014 FY 2015 

Actual

FY 2016 

Plan

FY 2016 

Actual

FY 2017 

Target

FY 2018 

Estimate

81% 69% 62% 23% 75% 75% 71% 75% Developing 

new indicators 

to demonstrate 

improved 

performance of 

rigorous and 

thorough 

investigations.

Target: Not Met 

Responsible Division/Office: DOE
Commodity Futures Trading Commission

May 23, 2017 Page 15 of 25 

Goal Four: Broad Outreach on Regulatory Concerns

Met: The activity/program fully 

met or exceeded the terms of its 

target(s) during the fiscal year. 

Not Met: The program/activity 

did not achieve the terms of its 

target(s) during the fiscal year. 

Baseline: Indicators that have not 

been finalized. 

Contextual: Indicators that do not 

have targets or have been 

discontinued. 

Objective 4.1: Broad outreach on regulatory concerns

Performance Indicator 4.1.a

Number and types of opportunities that have been provided for the exchange of views between the Commission and other 

domestic and international regulators.

Description: The Commission will attend conferences and meetings, such as Commission advisory committee meetings, 

research seminars, international regulator conferences, and briefings for Congressional staff and other government officials. 

Activities also include meetings with SEC, U.S. Federal Reserve System, U.S. Department of the Treasury, as well as participation 

in country dialogues under auspices of the Treasury Department.

Fiscal Year FY 2015 Actual FY 2016 Plan FY 2016 Actual FY 2017 Target FY 2018 Estimate

Contextual indicator

– no annual target

Contextual 

indicator – no 

annual target

Contextual 

indicator – no 

annual target

Contextual 

indicator – no 

annual target

Contextual 

indicator – no 

annual target

Target: Contextual indicator – no annual target

Responsible Division/Office: OIA

Performance Indicator 4.1.b

Number and types of opportunities that have been provided for the exchange of views between the Commission and the 

public.

Description: Number and types of opportunities that have been provided for the exchange of views between the Commission 

and the public. CFTC regulatory policies and interests advanced through meetings/conferences/seminars with the public.

Fiscal Year FY 2015 Actual FY 2016 Plan FY 2016 Actual FY 2017 Target FY 2018 Estimate

Contextual indicator –

no annual target

Contextual 

indicator – no 

annual target

Contextual 

indicator – no 

annual target

Contextual 

indicator – no 

annual target

Contextual 

indicator – no 

annual target

Target: Contextual indicator – no annual target

Responsible Division/Office: OIA
Commodity Futures Trading Commission

May 23, 2017 Page 16 of 25 

Objective 4.2: Sound international standards and practices

Performance Indicator 4.2.a

Number and types of projects that have been initiated and/or completed within international regulatory and standard setting 

groups that promote the CFTC’s regulatory policies.

Description: The Commission will participate in projects with standard-setting organizations such as the International 

Organization of Securities Commissions (IOSCO). 

Fiscal Year FY 2015 Actual FY 2016 Plan FY 2016 Actual FY 2017 Target FY 2018 Estimate

Contextual 

indicator – no 

annual target

Contextual indicator –

no annual target

Contextual indicator

– no annual target

Contextual 

indicator – no 

annual target

Contextual 

indicator – no 

annual target

Target: Contextual indicator – no annual target

Responsible Division/Office: OIA

Performance Indicator 4.2.b

Number of regulatory cooperation and coordination arrangements negotiated with international regulatory authorities to 

facilitate high-quality derivatives regulation worldwide and the CFTC’s supervision of markets and entities that are global in 

nature. 

Description: The Commission will negotiate memoranda of Understanding (MOUs) and other arrangements (e.g. letters setting 

out respective cooperation efforts) that are needed in connection with oversight of international registered Swap Dealers and 

Central Counterparties. 

Fiscal Year FY 2015 Actual FY 2016 Plan FY 2016 Actual FY 2017 Target FY 2018 Estimate

See FY 2015 APR for 

list of arrangements 

signed that year

Contextual indicator: no

annual targets. 

Commission will track 

and record these 

arrangements, as they 

occur.

See below N/A N/A

Target: Contextual indicator – no annual target

Responsible Division/Office: OIA

Objective 4.3: Provide global technical assistance 

Performance Indicator 4.3.a

Number of non-U.S. regulators trained.

Description: The Commission provides technical assistance to international authorities by training non-U.S. regulators each 

year. 

Fiscal 

Year

FY 2011 FY 2012 FY 2013 FY 2014 FY 2015 

Actual

FY 2016 

Plan

FY 2016 

Actual

FY 2017 

Target

FY 2018 

Estimate

225 nonU.S. 

regulators 

trained

414 401 260 150 Contextual 

indicator –

no annual 

target

113 Contextual 

indicator –

no annual 

target

Contextual 

indicator –

no annual 

target

Target: Contextual indicator – no annual target

Responsible Division/Office: OIA 
Commodity Futures Trading Commission

May 23, 2017 Page 17 of 25 

Objective 4.4: Robust Domestic and International Enforcement Cooperation and 

Coordination 

Performance Indicator 4.4.a

Leverage the impact of its enforcement program through coordination with Self-Regulatory Organizations (SROs) and active 

participation in domestic and international cooperative enforcement efforts.

Description: This indicator reflects the Commission’s continued participation in regular meetings with the SROs and with 

domestic and international cooperative partners. The Commission’s enforcement program regularly meets with the SROs to 

discuss matters of common interest; including investigations, enforcement actions, and the sanctioning of violative conduct. 

The Commission’s enforcement program also works cooperatively with both domestic and international authorities to 

maximize its ability to detect, deter, and bring sanctions against wrongdoers involving U.S. markets, registrants, and customers. 

Fiscal 

Year

FY 2015 Actual FY 2016 Plan FY 2016 Actual FY 2017 Target FY 2018

Estimate

Participated in 11 

domestic and 

international 

cooperative 

meetings, task 

forces, etc.

Participate in seven 

domestic and 

international 

cooperative 

enforcement 

meetings, task forces, 

etc.

Participated in more 

than two dozen 

domestic/international 

cooperative 

enforcement meetings

Participate in 10 

domestic and 

international 

cooperative 

enforcement 

meetings, task forces, 

etc.

Contextual 

indicator – no 

annual target

Target: Met

Responsible Division/Office: DOE 
Commodity Futures Trading Commission

May 23, 2017 Page 18 of 25 

Management Objectives 

 

3 

4 

1 

Management Objectives 

Performance Summary 

Met

Not Met

Baseline

Contextual

Met: The activity/program 

fully met or exceeded the 

terms of its target(s) 

during the fiscal year. 

Not Met: The 

program/activity did not 

achieve the terms of its 

target(s) during the fiscal 

year. 

Baseline: Indicators that 

have not been finalized. 

Contextual: Indicators 

that do not have targets or 

have been discontinued. 

Objective 5.1: A High-performing, diverse, and engaged workforce

Performance Indicator 5.1.a

Implement operational planning across the Commission.

Description: Design, develop, and implement annual division/office operational plans based on the CFTC Strategic Plan. 

Operational plans ensure strategic goals and objectives are achieved through approved and coordinated tactical goals and 

objectives.

Fiscal Year FY 2015 Actual FY 2016 Plan FY 2016 Actual FY 2017 Target FY 2018 Estimate

Commission 

developed budget 

strategy documents 

that Chairman used to 

make strategic 

resource decisions

TBD Two divisions have 

fully functioning 

operational plans 

with active internal 

processes in place to 

track priorities and 

key projects

Develop strategic 

plan that will 

facilitate annual 

division and office 

operating plans

Develop annual 

operating plans for 

four divisions and 

offices

Target: Not Met

Responsible Division/Office: OED
Commodity Futures Trading Commission

May 23, 2017 Page 19 of 25 

Performance Indicator 5.1.b

Implement performance management plans for executives

Description: Design, develop, and implement an enhanced performance management program to gain transparency, 

accountability, credibility, and to properly reward performance. The program will establish performance standards, help to 

properly identify goals, and hold senior staff accountable for performance results.

Fiscal Year FY 2016 Plan FY 2016 Actual FY 2017 Target FY 2018 Estimate

40% No reporting Pilot aligning strategic or 

operating goals with executive 

performance assessments for the 

2017-2018 Performance Year. 

Pilot to include executives from 

more than one CFTC division.

Align strategic and operating 

goals for the FY 2018-2022 

CFTC Strategic Plan to 

executive performance 

assessments.

Target: Not Met 

Responsible Division/Office: OED

Performance Indicator 5.1.c

Establish and implement an Individual Development Plan (IDP) strategy.

Description: As the nature of CFTC positions changes as a result of new regulatory requirements, supervisors must anticipate 

what skills will be needed to implement the new requirements, and to take steps to build those competencies and knowledge 

in the workforce. To that end, supervisors will discuss development and training goals with employees during quarterly 

progress reviews.

Fiscal Year FY 2015 Actual FY 2016 Plan FY 2016 Actual FY 2017 Target FY 2018 Estimate

Baseline year –

CFTC completed 

baseline activities 

and projects –

approximately 10 

percent of 

Commission 

employees have 

IDPs. 

Increase baseline 

percentage to 15% of 

Commission 

employees have 

IDPs, and establish 

and launch IDP 

marketing and 

educational 

campaign

Over 15% of 

Commission 

employees in have 

Individual 

Development 

Plans in place

Expand IDP 

marketing and 

educational 

campaign and 

increase 

Commission 

employees with 

IDPs to 20%

Ensure that 80% of 

new employees 

complete, as 

appropriate, an IDP 

within 6 months of 

onboarding to the 

Commission. Integrate 

CFTC Learning 

Management System 

with IDP process.

Target: Met

Responsible Division/Office: OED

Performance Indicator 5.1.d

Establish certification programs in executive, supervisory, and one core subject matter function.

Description: Develop and establish certification programs to ensure that employees at all levels have the most up-to-date tools 

and competencies. For example, an executive certification program is critical for leadership positions, a supervisory 

certification program is vital for effective human capital management, and swaps certification is essential for carrying out the 

mission of the CFTC.

Fiscal 

Year

FY 2015 Actual FY 2016 Plan FY 2016 Actual FY 2017 Target FY 2018 Estimate

80% of planned FY 

2015 activities 

completed

Design, develop 

and vet curriculum 

framework for all 

three certification 

programs

Finalized a draft 

curriculum that 

addresses every 

level of derivatives 

education

Begin to deploy a 

curriculum, in a learning 

management system, for 

supervisory and 

executive certification.

Finalize a swaps 

certification 

program.

Target: Not Met

Responsible Division/Office: OED
Commodity Futures Trading Commission

May 23, 2017 Page 20 of 25 

Performance Indicator 5.1.e

Increase Employee Viewpoint Survey scores to achieve and maintain a ranking of Top 10 in the Best Places to Work (small 

agency category).

Description: Annually identify areas of greatest need and focus on enhancing or implementing programs, campaigns, or 

policies that will contribute to increasing those scores.

Fiscal 

Year

FY 2011 FY 

2012

FY 

2013

FY 

2014

FY 2015 

Actual

FY 2016 

Plan

FY 2016 

Actual

FY 2017 

Target

FY 2018 

Estimate

8 (ranking 

in small 

agency 

category 

of Best 

Places to 

Work)

12th 24th 27th 60% 

employee 

engagement 

index (EEI) 

score 25 

(CFTC 

ranking)

62% 

employee 

engagement 

index (EEI) 

score

65% 

employee 

engagement 

index (EEI) 

score

66% 

employee 

engagement 

index (EEI)

score

67% 

employee 

engagement 

index (EEI) 

score

Target: Met

Responsible Division/Office: OED

Objective 5.2: Effective stewardship of resources

Performance Indicator 5.2.a

Improved CFTC customer satisfaction with management programs and services.

Description: Resource allocation, including financial, human, and information technology resources, is one of the primary 

services provided by mission support. Design and conduct a survey in FY 2016 that addresses key services provided by each 

office to establish a baseline. 

Fiscal 

Year

FY 2015 Actual FY 2016 Plan FY 2016 Actual FY 2017 Target FY 2018 Estimate

Commission 

identified 

programs and 

services that will 

be evaluated.

Implement CFTC 

customer survey to 

address programs 

and services 

identified in FY 

2015.

Created two draft 

customer satisfaction 

surveys: operations 

and technology/help 

desk. Received initial 

approvals by end of 

fiscal year.

Deploy two customer 

surveys: Satisfaction with 

IT help desk, and 

satisfaction with 

Commission’s support 

operations. Establish 

targets for 1% annual 

improvement, based on 

each survey’s results.

Targeted 1% 

increase from 

each survey’s FY 

2017 results.

Target: Not Met

Responsible Division/Office: ODT/OED

Objective 5.3: A Robust and Comprehensive Consumer Outreach Program

Performance Indicator 5.3.b

Finalize and monitor campaign success measures.

Description: The Commission surveys investors who report checking the background of financial professionals with a 

government source, a belief that government sources will help reduce instances of fraud, and awareness of the signs of fraud. 

The Commission plans to conduct annual surveys to determine any changes in investor sentiments. 

Fiscal 

Year

FY 2015 Actual FY 2016 Plan FY 2016 Actual FY 2017 Target FY 2018 Estimate

At outset of 

campaign, CFTC 

had one annual 

survey indicator, 

which has since 

been dropped.

Reach/Awareness/

Engagement all 

have – established 

and functioning

sub-measures

144% of annual 

targets for reach, 

awareness, and 

engagement.

6% of user visits to 

smartcheck.gov result 

in a “check” action to 

research a financial 

professional or firm

Develop indicators to 

reflect priorities of

new CFTC leadership 

to be published in 

the FY 2018-2022 

CFTC Strategic Plan

Target: Baseline

Responsible Division/Office: OED
Commodity Futures Trading Commission

May 23, 2017 Page 21 of 25 

Completeness and Reliability of Performance Data

The Commission understands the importance of the completeness and reliability of performance 

information. The CFTC views this process as an evolutionary one, with improvements developing as 

budget, time, and expertise will allow. While developing the 2014-2018 Strategic Plan, the CFTC 

developed a performance indicator dictionary for internal control and continuity. The performance 

indicator dictionary: 

 Further defines the performance indicators; 

 Describes offices of primary and secondary responsibility; 

 Provides detailed justifications explaining how the performance indicators measure progress 

towards the overall strategic objectives; 

 Lists all data sources; 

 Provides verification and validation of data and data sources; and 

 Provides detailed methodologies on how to build the performance indicators. 

Program Evaluations 

The Office of the Inspector General (OIG) conducts and supervises audits and investigations of programs 

and operations of the CFTC and recommends policies to promote economy, efficiency, and effectiveness 

in CFTC programs and operations and to prevent and detect fraud and abuse. The OIG’s assessment is 

located in the Other Accompanying Information section of the FY 2015 Agency Financial Report (AFR) 

and on the Commission website at 

http://www.cftc.gov/ucm/groups/public/@aboutcftc/documents/file/2015afr.pdf 
Commodity Futures Trading Commission

May 23, 2017 Page 22 of 25 

Appendix A: FY 2016 Enforcement Actions

Manipulation, 

Attempted 

Manipulation, False 

Reporting, 

Disruptive Trading

CFTC v. Oystacher and 3Red Trading, Case No. 1:15-cv-09196 (Filed 10/19/15 N.D.Ill.)

In re Total Gas & Power North America, Inc., CFTC Docket No. 16-03 (Filed 12/07/15)

In re Citibank, N.A., CFTC Docket No. 16-16 (Filed 5/25/2016)

In re Citibank, N.A.; Citibank Japan Ltd; and Citigroup Global Markets Japan Ltd., CFTC Docket No. 

16-17 (Filed 5/25/2016)

Protection of 

Customer Funds and 

Financial Integrity 

In re BNP Paribas Securities Corp., CFTC Docket No. 16-01 (Filed 10/20/15)

In re Cunningham Commodities, CFTC Docket No. 16-15 (Filed 5/9/2016)

In re Barclays Capital, Inc., CFTC Docket No. 16-25 (Filed 8/4/2016)

CFTC v. FXCM, Case No. 1:16-cv-06551 (Filed 8/18/16 S.D. N.Y.)

In re Advantage Futures LLC, CFTC Docket No. 16-29 (Filed 9/21/2016)

In re JP Morgan Chase Bank, N.A., CFTC Docket No. 16-05 (Filed 12/18/15)

CFTC v. Kevin Davis, Case No. 5:16-cv-00032 (Filed 01/15/16 D. Okla.)

In re IBFX, Inc., CFTC Docket No. 16-08 (Filed 3/14/16)

Retail Fraud CFTC v. Rico Cox, Case No. 0:16-cv-60226-WJZ (Filed 2/4/16 S.D. Fla.)

CFTC v. Jody Dupont, Case No. 8:16-cv-03258-TMC (filed 9/29/16 D. S.C.)

CFTC v. Vision Financial Services LLC, Case No. 0:16-cv-60297 (Filed 2/16/16 S.D. Fla.)

CFTC v. Vault Options, Ltd., Case No. 1:16-cv-01881 (Filed 2/2/2016 N.D. Ill.)

In re Equinox, CFTC Docket No. 16-09 (Filed 3/16/16)

CFTC v. All City Investments, LLC, Case No. 1:16-cv-07372 (Filed 9/21/16 S.D. N.Y.)

CFTC v. Tracy/Treyton/Trayton/Trey/Tray/T.L. Thomas/Marbury Advisors, Case No. 1:16-cv-00226 

(Filed 3/22/16 M.D. N.C.)

CFTC v. FTS Financial Inc., Case No. 1:16-cv-07513 (Filed 9/26/16 S.D. N.Y.)

In re Atlantas Group, Inc., CFTC Docket No. 16-23 (Filed 7/14/2016)

CFTC v. Jeffrey Slemmer, Case No. 9:16-cv-80867 (Filed 5/31/2016 S.D. Fla.)

CFTC v. David Bryant, Case No. 1:15-cv-10816 (Filed 12/02/15 N.D. Ill.)

CFTC v. Ryan S. Magee, Case No. 2:16-cv-00186-LA (Filed 2/18/16 E.D. Wis.)

CFTC v. Hendrix A. Van Beuningen, Case No. 16-cv-978-TCB (Filed 3/29/2016 N.D. Ga.)

In re Brian Hinman, CFTC Docket No. 16-13 (Filed 4/12/2016)

In re Galileo Trading, LLC, CFTC Docket No. 16-14 (Filed 4/12/2016)

CFTC v. Haena Park, Case No. 1:16-cv-04120 (Filed 6/2/2016 S.D. N.Y.)

CFTC v. Alvin Guy Wilkinson, Case No. 16-cv-06734 (Filed 6/28/2016 N.D. Ill.)

In re QuantX Capital LLC, CFTC Docket No. 16-24 (Filed 8/3/2016)

CFTC v. Frank J. Collins, Case No. 8:16-cv-01461 (Filed 8/8/16, C.D. Cal.)

In re Einstein Exchange Group Inc., CFTC Docket No. 16-26 (Filed 8/22/16)

In re: RNS Holdings LP, CFTC Docket No. 16-28 (Filed 9/20/2016)

CFTC v. Alcibiades Cifuentes, Case No. 2:16-cv-06167 (filed 9/10/16 D. N.J.)

CFTC v. Gregory L. Gramalegui, Case No. 1:15-cv-02313 (Filed 10/19/15 D. Colo.)

CFTC v. Intelligent Trades, LLC, Case 8:16-cv-00020 (Filed 01/07/16 C.D. Cal.)
Commodity Futures Trading Commission

May 23, 2017 Page 23 of 25 

CFTC v. Trademasters, USA, LLC, Case No. 16-cv-01938-GMN-NJK (Filed 8/15/2016 D. Nev.)

CFTC v. Kimball Parker, Case No. 2:16-cv-00983 (Filed 9/21/16 C.D. Utah)

In re Advanced Trading Workshop, Inc., CFTC Docket No. 16-31 (Filed 9/27/2016)

In re Aden Rusfeldt, CFTC Docket No. 16-35 (Filed 9/29/2016)

In re Sharpe Signa, LLC, CFTC Docket No. 16-04, (Filed 12/07/15)

CFTC v. Joseph Dufresne, Case No. 2:16-cv-07358 (filed 9/30/16 C.D. Cal.)

Illegal Off-Exchange 

Offering of OffExchange Contracts, 

Failure to Register

In re BFXNA Inc. d/b/a BITFINIX, CFTC Docket No. 16-19 (Filed 6/2/2016)

In re Otkritie Capital International, Ltd., CFTC Docket No. 16-06 (Filed 01/13/16)

In re Angus Partners, LLC dba Angus Energy, CFTC Docket No. 16-36 (Filed 9/29/2016)

CFTC v. Oakmont Financial Inc., Case No. 9:16-cv-80055 (Filed 01/12/16 S.D. Fla.)

CFTC v. North American Asset Management, Case No. 0:16-cv-JEM (Filed 1/15/16 S.D. Fla.)

In re Cypress Wealth Management Group, Inc., CFTC Docket No. 16-18 (Filed 5/26/2016)

CFTC vs. K.B. Concepts Group, LLC dba Apex Asset Advisors, LLC, Case No. 1:16-cv-24022 (Filed 

9/20/2016 S.D. Fla.)

CFTC v. IB Capital FX, Case No. 1:15-cv-01022-LY (Filed 11/9/15 W.D. Tex.)

Other Trade Practice In re Credit Suisse International, CFTC Docket No. 16-10 (Filed 3/22/16)

In re Michael Pucciarelli, CFTC Docket No. 16-12 (Filed 4/5/2016)

In re: JSC VTB Bank, CFTC Docket No. 16-27 (Filed 9/19/2016)

In re SG Americas Securities as successor to Newedge USA, CFTC Docket No. 16-33 (Filed 

9/28/2016)

Misappropriation of 

Material, Non 

Public, Confidential 

Information, 

Employee 

Misconduct against 

their Employers

CFTC v. Fan Wang, Case No. 1:16-cv-06961 (Filed 9/7/16 S.D. N.Y.)

CFTC v. Thomas Lindstrom, Case No. 1:16-cv-09334 (Filed 9/29/16 N.D. Ill.)

In re Arya Motazedi, CFTC Docket No. 16-02 (Filed 12/02/15)

In re Jon P. Ruggles, CFTC Docket No. 16-34 (Filed 9/29/2016)

Reporting, 

Recordkeeping

In re CHS, Inc., CFTC Docket No. 16-07 (Filed 3/08/16)

In re JP Morgan Ventures Energy, CFTC Docket No. 16-11 (Filed 3/23/16) 

In re Barclays Bank PLC, CFTC Docket No. 16-20 (Filed 7/6/2016)

In re Golden Agri International Pte Ltd., CFTC Docket No. 16-21 (Filed 7/11/2016)

In re Agrocorp International Pte Ltd., CFTC Docket No. 16-22 (Filed 7/11/2016)

CFTC v. Deutsche Bank, AG, Case No. 16-cv-6544 (Filed 8/18/2016 S.D. N.Y.) 

In re Wells Fargo Bank, NA, CFTC Docket No. 16-32 (Filed 9/27/2016)

In re Barclays Bank PLC, CFTC Docket No. 16-30 (Filed 9/22/2016)

CFTC v. eFloorTrade, LLC, Case No. 1:16-cv-07544 (Filed 9/27/16 S.D. N.Y.)

Statutory 

Disqualification

In re Steven A. Cohen, CFTC Docket No. SD 16-01 (Filed 8/16/16)

The CFTC’s Enforcement Press Releases provide a description of the filed cases 

http://www.cftc.gov/PressRoom/PressReleases/EnforcementPressReleases/index.htm. FY 2016

enforcement results are highlighted at http://www.cftc.gov/PressRoom/PressReleases/pr7488-16. 
Commodity Futures Trading Commission

May 23, 2017 Page 24 of 25 

Appendix B: Indicators Discontinued in FY 2016 

Division Indicator FY 2016 

Target

FY 2016 

Result

Met/Not 

Met

Why not Included?

DSIO 2.2. a.1 – Review 

and provide 

feedback as 

appropriate on SD 

and MSP riskexposure reports.

N/A N/A Discontinued This indicator had no reporting 

during FY 2015 because of the 

significant challenges 

encountered in gathering reliable 

and comprehensive data. The 

Commission discontinued the 

indicator at the end of FY 2015.

DSIO 2.2.a.3 – Percent of 

substantive industry 

issues addressed in 

a timely manner.

180 days N/A Discontinued The CFTC’s original, planned 

outcome was that, by providing 

timely responses, the CFTC would 

enhance registrant understanding 

and compliance with applicable 

CEA and Commission regulations. 

During FY 2016, the Commission 

determined that the indicator 

itself contains fundamental flaws 

that cannot be effectively 

remediated. As a result, the CFTC 

has discontinued the indicator.

DSIO 2.4.a – Conduct 

limited scope 

reviews of Swap 

Dealers (SDs), Major 

Swap Participants 

(MSPs), and Futures 

Commission 

Merchants (FCMs) 

risk management 

and internal control 

systems and 

procedures, 

including controls, 

processes and 

procedures over 

technology risks. 

N/A N/A Discontinued This indicator had no reporting 

during FY 2015 because the 

Commission determined that 

indicators 2.3.a.1 and 2.3.a.2 

better encapsulate DSIO’s 

activities. The Commission

discontinued the indicator at the 

end of FY 2015.

DoE 3.1.a.2 – Strengthen 

and ensure 

coordinated 

approach to 

receiving, assessing, 

and referring tips, 

complaints and 

referrals; establish a 

N/A N/A Discontinued The Enforcement Division 

established a new triage unit in 

FY 2015 to intake and triage tips 

and leads from all sources. This 

indicator was discontinued at the 

end of FY 2015. Success of the 

campaign is measured through 

indicator 3.1.a.1.
Commodity Futures Trading Commission

May 23, 2017 Page 25 of 25 

Division Indicator FY 2016 

Target

FY 2016 

Result

Met/Not 

Met

Why not Included?

unit or office 

dedicated to this 

function.

Division Indicator FY 2016 

Target

FY 2016 

Result

Met/Not 

Met

Why not Included?

OED 5.1.f – Number of 

diversity-related 

partnerships and 

alliances.

Three new 

partnerships

Three new 

partnerships

Met The Commission met its 

strategic plan target of 10 new 

partnerships by the end of FY 

2016. As a result, the CFTC is 

moving the indicator to the 

completed/ discontinued 

Appendix for FY 2017. 

OED 5.3.a – Launch longterm anti-fraud 

campaign.

N/A N/A Discontinued The anti-fraud campaign was 

launched in FY 2015, and the 

CFTC discontinued the indicator 

at the end of FY 2015. Success 

of the campaign is measured 

through indicator 5.b.3.

OED 5.3.c – Complete 

Congressional 

report.

N/A N/A Discontinued The annual report to Congress 

on customer initiatives is a 

routine report and is not a direct 

measure of CFTC priorities. 

Therefore, the indicator does 

not merit inclusion in the APR.