Office of the 

Inspector General 

Mark Wetjen 

Acting Chairman 

U.S. COMMODITY FUTURES TRADING COMMISSION 

Three Lafayette Centre 

1155 21st Street, NW, Washington, DC 20581 

Telephone: (202) 418-5110 

Facsimile: (202) 418-5522 

April14, 2014 

Commodity Futures Trading Commission 

Washington, D.C. 20581 

Dear Chairman Wetjen: 

On July 22,2010, President Obama signed into law the Improper Payments Elimination 

and Recovery Act of2010 (IPERA; Public Law 111-204). IPERA directs each agency's 

Inspector General, beginning with Fiscal Year (FY) 2011, to review agency improper payments 

and submit a report to the head of the agency, select congressional committees, and the 

Comptroller General. An improper payment is any payment that should not have been made or 

that was made in an incorrect amount under statutory, contractual, administrative, or other 

legally applicable requirements.1 It is the responsibility of the agency to review during the year 

after IPERA' s enactment2 and thereafter annually all programs and activities and identify those 

that are susceptible to significant improper payments. In accordance with OMB Memorandum 

M-11-16, the agency's Inspector General is expected to review the agency's Annual Financial 

Report (AFR) and assess the agency's compliance with Improper Payments Information Act of 

20023

. 

Accordingly, the Office of the Inspector General conducted a limited review of the Commodity 

Futures Trading Commission's (CFTC) compliance with IPERA for FY 2013. Our limited 

review was carried out in a reasonable and prudent manner and in accordance with Office of 

Management and Budget Circular No. A-123, Management Accountability and Control revised 

parts I and II to Appendix C4

• 

Our scope included a review of the CFTC Accounting Officer's attestation to the absence of any 

improper payments at CFTC during FY 2013 and a review of the agency's Annual Financial 

Report-including the independent auditors report of the agency's fmancial statements and the 

fmancial statements for the CFTC Customer Protection Fund. We also reviewed the CFTC 

database of payments during FY 2013 which contained 7,739 payments to vendors, individuals, 

1 See Improper Payments Elimination and Recovery Act of2010, Section 2 (e) (codified at 31 U.S.C. 3321 note). 2 See Improper Payments Elimination and Recovery Act of2010, Section 2(a) (codified at 31 U.S.C. 3321note). 

3 IPERA amended the Improper Payments Information Act of2002 Public Law 107-300. 

4 See OMB M-11-16 Memorandum for the Heads of Executive Departments and Agencies from Jacob J. Lew, 

Director Subject: Issuance of Revised Parts I and II to Appendix C ofOMB Circular A-123, dated April14, 2011. 
and external entities. In order to identify potential improper payments we established several 

database queries which the Office of Financial Management (OFM) used to generate reports 

indicating no improper payments were made during Fiscal Year 2013. OFM inf01med us and we 

reviewed documentation indicating that payments were checked to the government-wide "Do 

Not Pay"5 list and no exceptions were found. We also reviewed the Agency Financial Report for 

FY20 13 and found that the agency determined "that none of its programs and activities are 

susceptible to significant improper payments at or above the threshold levels set by OMB,"6 and 

we agree. 

Therefore, during the OIG's limited review, nothing came to our attention that would indicate 

that the CFTC did not comply with IPERA requirements. 

Sincerely, 

Inspector General 

cc: 

The Honorable Thomas R. Carper, Chairman, Senate Committee on Homeland Security and 

Governmental Affairs; 

The Honorable Tom Coburn, Ranking Member, Senate Committee on Homeland Security and 

Governmental Affairs; 

The Honorable Darrell E. Issa, Chairman, House Conunittee on Oversight and Government 

Reform; 

The Honorable Elijah Cummings, Ranking Member, House Conunittee on Oversight and 

Govenunent Reform; 

Mr. Gene L. Dodaro, Comptroller General of the United States, United States Government 

Accountability Office; 

Mr. Mark Reger, Interim Conh·oller, Office of Federal Financial Management. 

5 See OMB M-12-11 Memorandum for the Heads of Executive Departments and Agencies from Jeffe1y D. Zients, 

Acting Director Subject: Reducing l mproper Payments through the "Do Not Pay List" dated April 12, 20 12. 

6 See Commodity Futures Trading Commission Agency Financial Report Fiscal Year 20 13 page 73, available at 

http://www .cftc.gov/ucm/ groups/pub! ic/@aboutcftc/documents/fi le/20 13afrreduced. pdf 

2