A MESSAGE FROM 

THE CHAIRMAN

FY 2015 

COMMISSIONERS

THE COMMISSION 

IN BRIEF

FORWARD LOOKING

PERFORMANCE 

HIGHLIGHTS

FINANCIAL 

HIGHLIGHTS

INSIDE

COMMODITY FUTURES TRADING COMMISSION

Summary of Performance

and Financial Informati

F sca  Y ear 
COMMODITY FUTURES TRADING COMMISSION

Timothy G. Massad

Chairman

Anthony C. Thompson

Executive Director

Mary Jean Buhler

Chief Financial Officer

March 2016

This report is in the public domain. Authorization to reproduce it in whole or in part is granted. While permission 

to reprint this publication is not necessary, the citation should be: Commodity Futures Trading Commission, 

FY 2015 Summary of Performance and Financial Information, Washington, D.C., 20581.

All photographs in this document are proprietary and prior permission from the photographer 

is required for any use or reproduction of the photographs.
Summary of Performance

and Financial Informati

F i s c a l Y e a r 2 0 1 5

C O M M O D I T Y F U T U R E S T R A D I N G C O M M I S S I O N

A Message from the Chairman 2

FY 2015 Commissioners 

The Commission in Brief 8

Forward Looking – Future Business Trends and Events 16

Performance Highlights 21

Financial Highlights 24

Table of Conten
A Message fr

the Chairm

Iam pleased to present the Agency Financial Report for Fiscal Year (FY) 2015, which details our performance accomplishments and audited financial statements for 

this period. Over the past year, the U.S. Commodity Futur

Trading Commission (CFTC or Commission) continued to 

make progress on behalf of the American people. We have

brought increased transparency and sensible oversight to the 

derivatives markets, so they continue to operate with integrity 

and stability

The CFTC oversees the U.S. derivatives markets, whic

include commodity futures, options, and swaps. Although

most Americans do not participate in these markets directly, 

they are vital to our economy, affecting the prices we pay 

for food, energy and other goods and services. They are

critical to the economic success of many businesses, farmers 

and ranchers in the United States, who use them for price 

discovery and to manage routine commercial risk

The Commission’s key focus remains to foster transparent, 

open, competitive and financially sound markets. Our

mission is to protect market participants from fraud, manipulation and abusive practices, while safeguarding customer 

funds. And we seek to protect the public from the buildup of

excessive risk, the very type that contributed to making the 

2008 financial crisis the worst since the Great Depression

CFTC 

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, 

abusive practices related to derivatives and other products that

are subject to the Commodity Exchange A

Commodity Futures Trading Commissi
The derivatives markets are continuously evolving, driven 

by new technologies, innovation, competition and a 

global marketplace. As a result, the Commission’s work is

constantly changing, increasingly complex and focused on 

the challenges that lie ahead

This past year marked significant continued progress implementing the Dodd-Frank Wall Street Reform and Consumer 

Protection Act of 2010 (Dodd-Frank Act) and bringing transparency to the over-the-counter swaps market. Clearing is

now mandated for most interest rate and credit default 

swaps. Today, approximately 75 percent of swap transactions are being cleared, as compared to about 16 percent in

2007. We now require registration and regulation of swap

dealers. More than 100 are now registered and required to

comply with strong risk management practices

There are now more than 23 swap execution facilities (SEFs)

The volume of trading taking place on SEFs is growing. We

have four swap data repositories (SDRs) that are collecting 

market data and making it available publically. As a result,

market participants, the public, and we as regulators have 

much more information regarding the swaps marketplace

The CFTC also continues to fulfill its traditional duties in overseeing the futures and options markets. We are working tirelessly to help these markets operate safely and with integrit

Over the past year, the Commission continued to focus on an 

aggressive enforcement program that protects customers and 

prevents fraud and manipulation. The Commission filed 69

new enforcement actions in FY 2015 and imposed a record 

$3.1 billion in civil monetary penalties against wrongdoer

This included an $800 million sanction, the largest in Commission history. In addition to these sums, the CFTC was also

awarded $59 million in restitution and disgorgement orders, 

bringing its total monetary sanctions to over $3.2 billion for

the year. Robust enforcement is vital to maintaining the integrity of our markets, and will remain a priority going forwar

Over the past year, the Commission has placed a particular 

emphasis on making sure that, amidst various regulatory 

changes, commercial end-users can continue to use the 

derivatives markets efficiently and effectively. Many companies rely on these markets to hedge price, production and

other types of risk. For example, we exempted commercial

end-users from our proposed rule on margin for uncleared 

swaps. We amended our rules so that publicly-owned utility

companies can continue to effectively hedge their risks in 

the energy swaps market, which helps them provide reliable, 

cost-effective service to their customers. We approved a

modification to the “residual interest” rule, which can affect 

when customers must post collateral with clearing members

We exempted end-users from certain recordkeeping requirements to avoid undue burdens. And we have made some

important rule adjustments and clarifications addressing 

contracts with embedded volumetric optionality

Over the past year, the Commission also has been very focused 

on the resiliency of clearinghouses. With the increased significance they have taken on in the financial system, it is important we make sure they are strong and stable. In addition t

our domestic efforts on this issue, we are leading substantial work that is taking place internationally—working 

with foreign regulators and other U.S. agencies. We are al

working to strengthen the security of our financial markets 

against cyber-attacks and technological failures

FY 2015 Summary of Performance and Financial Inform

 Commodity Futures Trading Commission 

A MESSAGE FROM THE CHAIRMAN
Commission staff has also taken a number of actions to finetune our rules to improve SEF trading. However, SEF trading

is still new, and we still have significant work ahead of us

Our objectives go beyond improving and further encouraging 

the open, transparent and competitive trading of swaps on 

SEFs. It’s also about making SEF trading attractive, to build

participation and create a strong foundation upon which it 

can thrive

The Commission has also made a number of technological 

improvements this past year. Among many other efforts, the

CFTC opened its “OPERA” (Organizations, Products, Events, 

Rules and Actions) portal, which allows submissions to be 

electronically filed with the Commission. Over the course of

the year, nearly 96 percent of the product and rule amendment filings made by designated contract markets, SEFs, and 

SDRs were filed through OPERA, making data entry, filings 

and review more efficient

How far we have come is a credit to the hardworking and dedicated efforts of the professional staff of the CFTC. Their significant contributions are highlighted in the pages that follo

Although much progress has been made, there is much 

more we need to accomplish. The Dodd-Frank Act greatly

expanded the CFTC’s responsibilities. The $270 trillion swaps

market we are now tasked with overseeing is vast, global in 

nature and dramatically larger than the futures and options 

markets we also must oversee. But simply put, our budget has

not kept pace with this expansion. As a result, our markets

cannot be as well-supervised, participants cannot be as wellprotected, and market transparency and efficiency cannot be 

as fully achieved as we believe the American people deserve

The CFTC places a strong emphasis on being an effective 

steward of its operating funds. The Chief Financial Officer’s

(CFO) message includes the results of the independent audit 

of our FY 2015 Financial Statements. The auditors have identified a material weakness in financial reporting related to the

Commission’s historic practice with respect to the recording 

of lease obligations. When the Commission entered into

multiple year leases, such as in 1994 for its Washington office, 

it recorded only the annual lease payments each year, rather 

than the full multi-year obligation in the year the lease was 

initiated. The Commission is awaiting a U.S. Governme

Accountability Office (GAO) opinion on this matter, and it is 

reasonably possible that the CFTC will need to recognize the 

unfunded obligations covering all future payments. We believe

that this is an isolated issue which does not impact our overall 

internal controls. The Commission remains committed to high

standards of financial operations, reporting, and accountability, and to the continued improvement of our financial 

management and internal controls

The CFTC and its talented staff worked diligently during 

fiscal year 2015, and accomplished a great deal on behalf of 

the American public. As a result, the markets we oversee are

stronger, more transparent, and more competitive

Timothy G. Massa

Chairman

January 15, 2016

FY 2015 Summary of Performance and Financial Inform

4 Commodity Futures Trading Commissio
Timothy G. Massad, Chairman

Timothy Massad was sworn-in as Chairman 

of the CFTC on June 5, 2014, 

after being confirmed by the 

U.S. Senate as Chairma

and as a Commissioner of 

the CFTC

Previously, Mr. Massad was

nominated by President 

Obama and confirmed by 

the U.S. Senate as the Assistant Secretary for Financial Stability at the U.S. Departm

of the Treasury (Treasury). In that capacity, Mr. Massa

oversaw the Troubled Asset Relief Program (TARP), the 

principal U.S. governmental response to the 2008 financia

crisis designed to help stabilize the economy and provide 

help to homeowners. Under TARP, Treasury’s investments

in financial institutions, the credit markets and the auto 

industry prevented the economy from falling into a depression. Mr. Massad was responsible for the day-to-day management and recovery of TARP funds, and during his tenure

Treasury recovered more on all the crisis investments than 

was disbursed. Mr. Massad also served as Chief Counsel fo

the program prior to becoming Assistant Secretary

Prior to joining Treasury, Mr. Massad served as a legal advisor

to the Congressional Oversight Panel for TARP, under the 

leadership of (now Senator) Elizabeth Warren. Mr. Massa

assisted the panel in its first report evaluating the investments made by Treasury under TARP

Prior to his government service, Mr. Massad was a partner in

the law firm of Cravath, Swaine & Moore, LLP. Mr. Massa

had a broad corporate practice with a focus on corporate 

finance and financial markets. He helped to draft the original

standardized agreements for swaps and helped many businesses negotiate and execute transactions to hedge exposures 

in the derivatives markets

Mr. Massad earned his bachelor’s and law degrees at Harvar

Mr. Massad was born in New Orleans, Louisiana, and also

lived in Texas, Oklahoma and Connecticut as a child

He and his wife, Charlotte Hart, live in Washington with 

their two children

From left to right; J. Christopher Giancarlo, Commissioner; Mark P. Wetjen, Commissioner; 

Timothy G. Massad, Chairman; Sharon Y. Bowen, Commissioner

FY 2015 Summary of Performance and Financial Inform

 Commodity Futures Trading Commission 

Fiscal Year 2015 Commissioner
Sharon Y. Bowen, Commissioner 

Sharon Y. Bowen wassworn in as a Commissioner of the CFTC on 

June 9, 2014 for a five-year 

term.

Ms. Bowen was previously confirmed by the

U.S. Senate and appointe

by President Obama on 

February 12, 2010 to serve 

as Vice Chair of the Securities Investor Protection Corporation (SIPC). She assumed the

role of Acting Chair in March 2012. Prior to her appointment

to the CFTC, Ms. Bowen was a partner in the New York office

of Latham & Watkins LLP. Ms. Bowen’s broad and divers

corporate and transactional practice of almost 32 years 

began in 1982 when she started her career as an associate 

at Davis Polk & Wardwell. She joined Latham as a senior

corporate associate in the summer of 1988 and became a 

partner January 1991

Ms. Bowen’s practice has included corporate, finance,

and securities transactions for large global corporations 

and financial institutions, including mergers and acquisitions, private equity, securities offerings, strategic alliances, 

corporate restructurings, leveraged finance, securitizations, distressed debt and asset acquisitions, and venture 

capital financings

Ms. Bowen served in several leadership positions in her firm,

including co-chair of the Diversity Committee, co-chair of 

the Diversity Hiring Subcommittee and co-founder and head 

of Latham’s Women Enriching Business (WEB) Task Force, 

whose mission is to create broader networks and productive 

business development relationships for women

Ms. Bowen has been involved in numerous pro bono, educational, diversity and civic matters throughout her career and

has received many awards in recognition of her contributions. She has served as a member of the Board (formerly

Executive Committee and Chair) and Emeritus Board of New 

York Lawyers for the Public Interest, Inc., the Boards of New

York City Economic Development Corporation (formerly 

Executive Committee), Northwestern University Law 

School (formerly Executive Member and Chair), and Public 

Education Needs Civil Involvement in Learning (PENCIL) 

(formerly Executive Committee)

Ms. Bowen is one of America’s “Top Black Lawyers” according

to Black Enterprise Magazine. She is a recipient of the 2011

Diversity Trailblazer Award of the New York State Bar Association, and was selected as the New York City Bar Association 

2007 Diversity Champion and the Metropolitan Black Bar 

Association 2006 Lawyer of the Year

Ms. Bowen was born in Chesapeake, Virginia. She receive

her B.A. in Economics from the University of Virginia, MB

from the Kellogg School of Management and J.D. fro

Northwestern University School of Law. She lives with her

husband in New York City

J. Christopher Giancarlo, Commissioner 

J

. Christopher “Chris

Giancarlo was nominated by President Obama 

on August 1, 2013 and confirmed by unanimous consent of the U.S. Senate o

June 3, 2014. On June 16,

2014, Mr. Giancarlo was

sworn in as a CFTC Commissioner for a term expiring in April 2019

Before entering public service, Mr. Giancarlo served as the

Executive Vice President of GFI Group Inc., a financial services

firm. Prior to joining GFI, Mr. Giancarlo was Executive Vic

President and U.S. Legal Counsel of Fenics Software an

was a corporate partner in the New York law firm of Brown 

FY 2015 Summary of Performance and Financial Inform

6 Commodity Futures Trading Commissio
Raysman Millstein Felder & Steiner. Mr. Giancarlo joine

Brown Raysman from Giancarlo & Gleiberman, a law practice 

founded by Mr. Giancarlo in 1992 following his return from

several years in London with the international law firm of 

Curtis, Mallet-Prevost, Colt & Mosle

Mr. Giancarlo was also a founding Co-Editor-in-Chief of

eSecurities, Trading and Regulation on the Internet (Leader 

Publications). In addition, Mr. Giancarlo has testified thre

times before Congress regarding the implementation of the 

Dodd-Frank Act, and has written and spoken extensively on 

public policy, legal and other matters involving technology 

and the financial markets

Mr. Giancarlo was born in Jersey City, New Jersey. He attende

Skidmore College in Saratoga Springs, New York where he 

graduated Phi Beta Kappa with Government Department 

Honors. Mr. Giancarlo received his law degree from th

Vanderbilt University School of Law where he was an associate 

research editor at the Vanderbilt Journal of Transnational Law 

and President of the Law School’s International Law Society

Mr. Giancarlo has been a member of the Bar of the State of

New York since 1985

Mark P. Wetjen, Commissioner 

Mark P. Wetjen servedas a Commissioner 

until August 28, 2015. His

seat is presently vacant

Mr. Wetjen was nominated by President Obama

to serve a five-year term 

in March 2011 and was 

confirmed by the U.

Senate in October 2011

Subsequent to his confirmation as commissioner, Mr. Wetjen was elected to serve as the

CFTC’s acting chairman upon the departure of the previous 

chairman, Gary Gensler, in 2013. Mr. Wetjen served in tha

role for approximately five months, managing daily operations and setting overall policy direction of the Commission

During his chairmanship, Mr. Wetjen oversaw implementation

of the first trading mandate for certain interest rate and credit 

default swaps (CDS) and approved or directed the Commission and its staff to undertake approximately 95 enforcement 

and implementing actions related to the Dodd-Frank Act 

and the CFTC’s other responsibilities under the Commodity 

Exchange Act (CEA)

Prior to joining the CFTC, Mr. Wetjen worked for seven years

in the U.S. Senate as a senior leadership staffer advising on al

financial-services-related matters, including the Dodd-Frank 

Act. Mr. Wetjen also advised Senator Harry Reid and member

of the Democratic caucus on a number of banking, housing, 

communications, technology, and gaming policy issues and 

legislative initiatives

Before his service in the U.S. Senate, Mr. Wetjen was a lawy

in private practice and represented clients in a variety of litigation, transactional and regulatory matters. Born and raised in

Dubuque, Iowa, Mr. Wetjen received a bachelor’s degree from

Creighton University and a law degree from the University of 

Iowa College of Law

FY 2015 Summary of Performance and Financial Inform

 Commodity Futures Trading Commission 

FISCAL YEAR 2015 COMMISSIONERS
Organization and Locat

The Commission consists of five Commissioners, with two positions currently vacant. The President

appoints and the Senate confirms the CFTC Commissioners 

to serve staggered five-year terms. No more than three sitting

Commissioners may be from the same political party. With

the advice and consent of the Senate, the President designates one of the Commissioners to serve as Chairman

The Office of the Chairman oversees the Commission’s 

principal divisions and offices that administer and enforce the 

CEA and the regulations, policies, and guidance thereunder

The Commission is organized largely along programmatic 

and functional lines. The four programmatic divisions—the

The Commission in Brief

Division of Clearing and Risk, Division of Enforcement, 

Division of Market Oversight, and the Division of Swap 

Dealer and Intermediary Oversight—are partnered with, 

and supported by, a number of offices, including the Office 

of the Chief Economist, Office of Data and Technology, 

Office of the Executive Director, Office of the General 

Counsel, and the Office of International Affairs. The

Office of the Inspector General is an independent office 

of the Commission

The Dodd-Frank Act established the CFTC Customer Protection Fund for the payment of awards to whistleblowers, 

through the whistleblower program, and the funding of 

customer education initiatives designed to help customers 

protect themselves against fraud or other violations of the 

CEA or the rules or regulations thereunder

CFTC Organization Structure, Locations and F

The Commission is headquartered in Washington D.C. Regional offices are located in Chicago, Kansas City and New York. T

CFTC organization chart is also located on the Commission’s website at http://www.cftc.gov/About/CFTCOrganization/index.htm

8 Commodity Futures Trading Commissio
Our Peo

Collectively, the Commission employs 731 full-time permanent employees that compute to 690 full-time equivalents (FTE)1 in 

FY 2015. CFTC staff are comprised of 75 percent direct mission staff (attorneys, economists, auditors, risk and trade analysts, and

other financial specialists) and 25 percent management and support staff to accomplish four strategic goals and one management 

objective in the regulation of commodity futures, options, and swaps

Attorneys across the CFTC’s divisions and offices represent the Commission in 

administrative and civil proceedings, assist U.S. Attorneys in criminal proceeding

involving violations of the CEA, develop regulations and policies governing clearinghouses, exchanges and intermediaries, and monitor compliance with applicable rules

Auditors, Investigators, Risk Analysts, and Trade Practice Analysts examine 

records and operations of derivatives exchanges, clearinghouses, and intermediaries for compliance with the provisions of the CEA and the Commission’s 

regulations.

Economists and Data Analysts monitor trading activities and price relationships in 

derivatives markets to detect and deter price manipulation and other potential market 

disruptions. Economists also analyze the economic effect of various Commission

and industry actions and events, evaluate policy issues and advise the Commission 

accordingly

Management Professionals support the CFTC mission by performing strategic 

planning, information technology, human resources, staffing, training, accounting, 

budgeting, contracting, procurement, and other management operations

1 In the U.S. Federal government, FTE is defined by the Government Accountability Office, as the number of total hours worked divided by the maximum number 

of compensable hours in a full-time schedule as defined by law.

FY 2015 Summary of Performance and Financial Inform

 Commodity Futures Trading Commission 

T HE COM
CFTC Regulatory L

CFTC M

To foster open, transparent, competitive, and financially sound marke

systemic risk; and to protect market users and their funds, consu

public from fraud, manipulation, and abusive practices related to d

and other products that are subject to the Commodi

DERIVATIVE

is a financial instrument, traded on or off an exchange, 

the price of which is directly dependent upon (i.e., 

derived from) the value of one or more underlying 

securities, equity indices, debt instruments, commodities, other derivative instruments, or any agreed upon 

pricing index or arrangement (e.g., the movement over 

time of the Consumer Price Index or freight rates)

Derivatives include futures, options, and swaps

The Commission construes the definition of a futures contract 

broadly, but it is an agreement to purchase or sell a commodity for delivery in the future: 1) at a price that is determined at 

initiation of the contract; 2) that obligates each party to the contract to fulfill the contract at the specified price; 3) that is used 

to assume or shift price risk; and 4) that may be satisfied by 

delivery or offset. The CEA generally requires futures contracts

to be traded on regulated exchanges, with futures trades cleared 

and settled with clearinghouses, referred to as derivatives clearing organizations (DCOs). To that end, futures contracts are

standardized to facilitate exchange trading and clearing

Although a futures contract agreement is set today, the person 

selling (for example, a farmer marketing bushels of wheat) will 

not receive payment and the buyer (in this case a bakery) will 

not receive goods purchased until the predetermined delivery 

date agreed to in the contract, which is November 1 in the 

following example. The farmer benefits from this agreement

because he is certain as to the amount of money he will earn 

from the farming operation, even if the price of wheat changes 

between today and November 1. Similarly, the bakery buying

the wheat also benefits by knowing how much the wheat will 

The Commission administers the CEA, 7 U.S.C. section 

et seq. The 1974 Act brought under Federal regulation futures

trading in all goods, articles, services, rights and interests; 

commodity options trading; leverage trading in gold and silver 

bullion and coins; and otherwise strengthened the regulation 

of the commodity futures trading industry. The Commission’s

mandate has been renewed and expanded several time since 

then, most recently by the 2010 Dodd-Frank Act

In carrying out this mission and to promote market integrity, 

the Commission polices the derivatives markets for various 

abuses and works to ensure the protection of customer funds

Further, the agency seeks to lower the risk of the futures and 

swaps markets to the economy and the public

Derivatives first began trading in the United States before the 

Civil War, when grain merchants came together and created 

this new marketplace. When the Commission was founded in

1974, the majority of derivatives trading consisted of futures 

trading in agricultural sector products. These contracts gave

farmers, ranchers, distributors, and end-users of products 

ranging from corn to cattle an efficient and effective set of 

tools to hedge against price risk

FY 2015 Summary of Performance and Financial Inform

10 Commodity Futures Trading Commissio
cost on November 1 and it will be better positioned to estimate 

its baking costs and set prices for its products. Finally, even

though the actual price of wheat on November 1 (when the 

contract is fulfilled) may be greater or less than the pricing 

in the November 1 contract, the price is fixed and both the 

farmer and the bakery are bound by the price agreed to when 

they entered into the agreement. Most futures contracts are

not settled with the actual physical delivery of the commodity, 

but by the purchase of opposite (offsetting) futures contracts, 

which serve to close out the original positions, with profits or 

losses dependent on the direction in which the price of the 

contracts have moved relative to those positions

Speculators may also buy or sell such futures contracts. The

speculator buying a futures contract for November wheat 

believes the value of the wheat in November will be higher 

than the price he is paying for the contract today. As time

passes, and November draws closer, people may try to 

estimate whether the cost of November wheat will rise or 

fall, and may cause the value of that futures contract to fluctuate. For example, if people expect there to be an especially

bad harvest in November, then the price of November wheat 

will rise, and the speculator may sell that futures contract for 

November wheat for even more (or less) than he or she paid

Over the years, the futures industry has become increasingly diversified. Futures based on other physical, such as

metals and energy products were developed. Highly complex

financial contracts based on interest rates, foreign currencies, 

Treasury bonds, security indexes, and other products have far 

outgrown the agricultural contracts in trading volume

Electronic integration of cross-border markets and firms, as 

well as cross-border alliances, mergers and other business 

activities have transformed the futures markets and firms into 

a global industry. With the passage of the Dodd-Frank Act,

the Commission was tasked with bringing regulatory reform 

to the swaps marketplace. Swaps, which had not previously

been regulated in the United States, formed a collective global 

trading market valued in the hundreds of trillions of dollars 

when measured by notional amount

Generally speaking, a swap is an exchange of one asset or 

liability for a similar asset or liability for the purpose of, 

inter alia, shifting risks, where the value of those payments 

is determined in the future based on some previously agreed 

measure. With a swap, counterparties agree to exchange

future cash flows at regular intervals, with each cash flow 

calculated on a different (previously agreed-upon) basis

Before the Dodd-Frank Act, swaps were, for the most part, 

FY 2015 Summary of Performance and Financial Inform

 Commodity Futures Trading Commission 1

T HE COM
traded over-the-counter (also called bilaterally), which means 

that swaps were not traded on regulated derivatives exchanges 

and many were not cleared through DCOs. Swaps are tools

for hedging risks associated with, among other things, interest 

rates, currency fluctuations, and the cost of energy products, 

such as oil and natural gas. The value of a swap is derived

from the value of the underlying asset or rate that serves as 

the basis for each (or both) legs of the exchange

For example, two people may agree to swap the cost of a fixed 

interest rate on a $100,000 mortgage for a variable interest 

rate on a $100,000 mortgage. Person A agrees to pay a fixed

interest rate of five percent to Person B, every month for a 

year. In exchange, Person B agrees to pay Person A variable

interest rate based on the prime rate (currently 3.25 percent)

plus 1.75 percent. Because these two interest rates equal eac

other at the time the swap is agreed, neither person owes 

anything to the other. If, however, the prime rate rises, then

Person B will owe more money to Person A. Thus, at the

time the swap is agreed, Person A is assuming interest rates 

will rise, whereas Person B is hoping interest rates will fall

In normal times, these markets create substantial, but largely 

unseen, benefits for American families. During the recent financial crisis, however, their effect was just the opposite. It wa

during the financial crisis that many Americans first heard the 

word derivatives. That was because over-the-counter swaps

accelerated and intensified the crisis. The government was then

required to take actions that today still stagger the imagination: for example, largely because of excessive swap risk, the 

government committed $182 billion to prevent the collapse 

of a single company—AIG—because its failure at that time, in 

those circumstances, could have caused our economy to fall 

into another Great Depression

It is hard for most Americans to fathom how this could have 

happened. While derivatives were just one of many things that

caused or contributed to the crisis, the structure of some of these 

products created significant risk in an economic downturn

In addition, the extensive, bilateral transactions between the 

largest banks and other institutions meant that trouble at one 

institution could cascade quickly through the financial system 

like a waterfall. The opaque nature of this market meant that

regulators did not know the level of exposure that any one 

institution or the financial system faced

FY 2015 Summary of Performance and Financial Inform

12 Commodity Futures Trading Commissio
Dodd-Frank Act: Enha

Regulatory Envir

On July 21, 2010, the Dodd-Frank Act was enacted and the 

CEA was significantly amended to establish a comprehensive new regulatory framework to include swaps, as well as 

enhanced authorities over historically regulated entities

The purpose of the derivatives provisions of the DoddFrank Act was to implement the commitments made by the 

United States at the G20 summit in Pittsburgh in 2009. The

members of the G20 made four commitments: 1) require 

regulatory oversight of the major market players; 2) require 

clearing of standardized transactions through regulated 

DCOs; 3) require more transparent trading of standardized 

transactions; and 4) require regular reporting so that regulators and market participants would have an accurate picture 

of what is going on in the market

Regulatory Oversight 

Five years ago, swap dealers (SDs) had no specific requirement to their swap dealing activity. The first of the major

directives Congress gave to the CFTC was to create a framework for the registration and regulation of SDs and major 

swap participants (MSPs). The Commission has done thi

As of September 30, 2015, there are 104 SDs and one MSP 

provisionally registered with the CFTC

REGISTERED PROFESSIONALS 

AS OF SEPTEMBER 30, 2015

Type of Registered Professional Number 

Associated Persons (AP) (Sales People) 56,003

Commodity Pool Operators (CPOs) 1,719

Commodity Trading Advisors (CTAs) 2,377

Floor Brokers (FBs) 4,191

Floor Traders (FTs) 764

Futures Commission Merchants (FCMs)2 71

Introducing Brokers (IBs) 1,306

Major Swap Participant (MSP) 1

Retail Foreign Exchange Dealer (RFEDs) 5

Swap Dealer (SDs) 104

TOTAL 66,541

Companies and individuals who handle customer funds, solicit or 

accept orders, or give trained advice must apply for CFTC registration through the National Futures Association (NFA), a selfregulatory organization (SRO) with delegated oversight authority 

from the Commission. The Commission regulates the activities of 

over 66,000 registrants. 

The Commission has adopted rules requiring strong risk 

management by SDs and MSPs. It will be carrying out periodic

examinations to assess risk and compliance at these registered entities. The new framework requires registered SDs

and MSPs to comply with various business conduct requirements. These include strong standards for documentation and

confirmation of transactions, as well as dispute resolution 

processes. The regulations include requirements to reduce risk

of multiple transactions through what is known as portfolio 

reconciliation and portfolio compression. In addition, SDs

are required to make sure their counterparties are eligible to 

enter into swaps, and to make appropriate disclosures to those 

counterparties of risks and conflicts of interest

As directed by Congress, the Commission has worked with the 

U.S. Securities and Exchange Commission (SEC), other 

regulators, and our international counterparts to establish this 

framework. The Commission will continue to work with them

to achieve as much consistency as possible. It will also look

to make sure these rules work to achieve their objectives, and 

fine-tune them as needed where they do not

Clearing 

A second directive 

of the Dodd-Frank 

Act was to require 

clearing of standardized transactions at DCOs. DCOs reduce the risk that one

market participant’s failure could adversely impact other 

market participants or the public, by standing in between 

the two original counterparties to a transaction—as the buyer 

to every seller and the seller to every buyer—and maintaining 

financial resources to cover potential defaults. DCO’s value

positions daily and require parties to post adequate margin 

on a regular basis. “Margin” is the collateral that holders of

financial instruments have to deposit with DCOs to cover 

some or all of the risk of the positions. Collateral must be

in the form of cash or highly liquid securities

The use of DCOs in financial markets is commonplace and 

has been around for over one hundred years. The idea is

simple: if many participants trade standardized products on 

a regular basis, the tangled, hidden web created by thousands 

of private two-way trades can be replaced with a more transparent and orderly structure, like the spokes of a wheel, with 

2 Includes FCMs registered as RFEDs.

FY 2015 Summary of Performance and Financial Inform

 Commodity Futures Trading Commission 1

T HE COM
the DCO at the center interacting with market participants

The DCO is required to monitor the overall risk and positions 

of each participant

The CFTC was the first of the G-20 nations’ regulators to 

implement a regime for mandatory clearing of swaps. The

Commission has required clearing for certain types of interest 

rate swaps denominated in U.S. dollars, Euros, Pounds an

Yen, as well as CDS on certain North American and European 

indices. Based on CFTC analysis of data reported to SDRs, as

of September 2015, measured by notional value, 75 percent 

of all outstanding transactions were cleared. This is compared

to estimates by the International Swaps and Derivatives 

Association (ISDA) of only 16 percent in December 2007

With regard to index CDS, most new transactions are being 

cleared—85 percent of notional value, as of September 2015

The CFTC rules for clearing swaps were patterned after the 

successful regulatory framework used for many years in the 

futures market. The Commission requires that clearing occurs

through CFTC-registered or exempt DCOs that meet certain 

standards—a comprehensive set of core principles and regulations that ensures each DCO is appropriately managing 

the risk of its members, and monitoring its members for 

compliance with important rules

Of course, central clearing by itself is not a panacea. DCOs

do not eliminate the risks inherent in the swaps market. The

Commission must therefore be vigilant. It must do all it can

to ensure that DCOs have financial resources, robust risk 

management tools, systems that minimize operational risk, 

and all the necessary standards and safeguards consistent 

with the core principles to operate in a fair, transparent and 

efficient manner. DCOs must also have tools in place to

address a wide range of situations that may arise if a clearing 

member defaults. They must develop plans to deal with losses

to the DCO in non-default situations. The Commission must

also make sure that DCO contingency planning to deal with 

operational events, such as cyber-attacks, is sufficient

Trading 

The third area for reform under the Dodd-Frank Act was to 

require more transparent trading of standardized derivatives products. In the Dodd-Frank Act, Congress provided

that certain swaps must be traded on a SEF or a designated 

contract market (DCM) exchange. The Dodd-Frank Act

defined a SEF as “a trading system or platform in which 

multiple participants have the ability to execute or trade 

swaps by accepting bids and offers made by multiple participants.” The trading requirement was designed to facilitate

a more open, transparent and competitive marketplace, 

benefiting, among others, commercial end-users seeking to 

lock in a price or hedge risk

The CFTC finalized its rules for SEFs in June 2013. Twentythree SEFs have been temporarily registered with the CFTC,

and one application is pending. These SEFs are diverse, but

each will be required to operate in accordance with the same 

core principles. These core principles provide a framework

that includes obligations to establish and enforce rules, 

as well as policies and procedures that enable transparent 

FY 2015 Summary of Performance and Financial Inform

14 Commodity Futures Trading Commissio
and efficient trading. SEFs must make trading information

publicly available, put into place system safeguards, and 

maintain financial, operational and managerial resources 

to discharge their responsibilities

Trading on SEFs began in October 2013. As of February

2014, specified interest rate swaps and CDSs were required 

to be traded on a SEF or other regulated exchange. As of

July 2015, 60 percent of client trading by notional volume 

is now electronic, up from nine percent in 2010. Notional

value executed on SEFs has generally been in excess of 

$1 trillion monthly. It is important to remember that trading

of swaps on SEFs is still new. SEFs are still developing best

practices under the new regulatory regime. The new technologies that SEF trading requires are likewise being refine

Additionally, other jurisdictions have not yet implemented 

trading mandates, which has slowed the development of 

cross-border platforms. There will be issues as SEF trading

continues to mature. The Commission will need to work

through these to fully achieve the goals of efficiency and 

transparency SEFs are meant to provide

Data Reporting 

The fourth G20 reform commitment implemented by the 

Dodd-Frank Act was to require ongoing reporting of swap 

activity. Having rules that require oversight, clearing, and

transparent trading is not enough. The Commission must

have an accurate, ongoing picture of what is going on in 

the marketplace to achieve greater transparency and to 

address potential systemic risk. Title VII of the Dodd-Frank

Act assigns the responsibility for collecting and maintaining 

swap data to SDRs, a new type of entity necessitated by these 

reforms. All swaps, whether cleared or uncleared, must be

reported to SDRs. There are currently four SDRs that are

provisionally registered with the CFTC

The collection and public dissemination of swap data by 

SDRs helps regulators and the public. It provides regulators with information that can facilitate informed oversight

and surveillance of the market and implementation of our 

statutory responsibilities. Dissemination, especially in realtime, also provides the public with information that can

contribute to price discovery and market efficiency. While the

Commission has accomplished a lot, much work remains

The task of collecting and analyzing data concerning this 

marketplace requires intensely collaborative and technical 

work by industry and the agency’s staff. Going forward, it

must continue to be one of the CFTC’s chief priorities

There are three general areas of activity. The CFTC must

have data reporting rules and standards that are specific and 

clear, and that are harmonized as much as possible across 

jurisdictions. The Commission is leading the international

effort in this area. It is an enormous task that will take tim

The Commission must also make sure the SDRs collect, 

maintain, and publicly disseminate data in the manner 

that supports effective market oversight and transparency

Finally, market participants must live up to their reporting 

obligations. Ultimately, the market participants bear the

responsibility to make sure that the data is accurate and 

reported promptly

Guiding Principles

A few core principles must motivate the Commission’s 

work in implementing the Dodd-Frank Act. The first is that

the CFTC must never forget the cost of the financial crisis 

to American families, and it must do all it can to address 

the causes of that crisis in a responsible way. The second is

that the United States has the best financial markets in the 

world. They are the strongest, most dynamic, most innovative, most competitive and transparent. They have been 

significant engine of U.S. economic growth and prosperi

The Commission’s work should strengthen U.S. markets an

enhance those qualities in a way that does not place unnecessary burdens on the dynamic and innovative capacity of 

the industry

FY 2015 Summary of Performance and Financial Inform

 Commodity Futures Trading Commission 1

T HE COM
Forward Looking – 

Future Business Trends and Even

Evolving Industry Tre

Their Implicati

The market participants (the industry) under CFTC jurisdiction continue to change how they conduct 

business in order to comply with regulatory responsibilities 

and to maximize opportunities. Industry continues to shift its

operating model due to other environmental influences, such 

as global prudential and other regulatory framework, macroeconomic, and technology trends. As industry continues to

evolve, the CFTC must have the ability to make accompanying 

changes across all components of its operations

This understanding is critical to the Commission’s ability 

to appropriately regulate industry of today and tomorrow

Swap Markets are Increasingly Operating under the 

Dodd-Frank Regulatory Framework

By the end of FY 2016, participants in the swaps market 

under CFTC jurisdiction will be registered and operating 

under the framework established by the Dodd-Frank Act. The

low-tech, high-touch bilateral voice transactions era for swaps 

trading will be increasingly replaced by trading on regulated 

platforms, central clearing and real-time trade reporting as 

provided for in the Dodd-Frank Act. Much of the regulatory

uncertainty for these market participants will have been lifted, 

and while phasing and fine-tuning of rules will be ongoing, 

the marketplace will be increasingly trading, settling, and 

reporting swaps, and reaping the benefits of risk-mitigated 

hedging strategies. CFTC resources will shift largely from a

rule-writing focus, through a period of intense interpretative guidance development, moving towards an operational 

stance that will emphasize compliance, risk management, 

monitoring and further refinement and improvement to the 

Commission’s regulatory framework.

Growth in Clearing through DCOs, New Requirements 

for Uncleared Swaps, and Monitoring DCOs Reduces 

Swaps-Related Risks

Fundamental to the Dodd-Frank Act 

were heightened risk management 

requirements for DCOs and swap 

counterparties. Market participants

(mainly dealers) began moving to 

central clearing of standardized 

swaps prior to the issuance of the 

CFTC’s mandatory clearing determination for interest rate swaps and 

CDS, reducing credit risk between 

counterparties

Under the Dodd-Frank Act, clearing members and swap 

customers are required to pay variation margin through their 

FCMs to avoid the accumulation of large gain and/or loss obligations. In addition, clearing members and swap customers

are required to post initial margin to cover the potential future 

exposure of their positions in the event of default. Complementary margin requirements have been proposed for uncleared

16 Commodity Futures Trading Commissio
swaps for SDs and MSPs subject to the CFTC’s jurisdiction 

(i.e., non-bank SDs and MSPs). In addition to posting margin

non-bank SDs and MSPs are required to hold minimum levels 

of capital under Section 731 of the Dodd-Frank Act. These

capital and margin requirements are intended to reduce swapsrelated systemic risk in the global financial system and to 

encourage clearing. As DCOs offer new swaps for clearing, the

CFTC will evaluate whether such swaps should be required to 

be cleared, as well as assess the ability of the DCO to properly 

manage the risk of clearing those swaps

The CFTC faces a number of challenges with its new jurisdiction related to swaps. Foremost, the notional value of cleared

swaps is estimated to be on the order of a factor of almost 

eight times that of futures and options. This fact alone

demonstrates the need for the CFTC to apply significant 

staffing resources to monitor the risk surveillance activities 

of DCOs, FCMs, and swaps market participants, in addition 

to maintaining (if not increasing) surveillance of futures and 

options market participants. FCMs and end-users are keenly

aware of the importance of DCOs, and of their exposure to 

loss if DCOs fail to properly manage risk, and thus the CFTC 

will focus on supervision of DCOs to ensure their reliable 

and safe operation

The movement of swaps to a cleared environment has 

created greater transparency in the market but has also 

shifted significant new levels of counterparty risk to DCOs

As more swap activity migrates to clearing the DCOs are 

holding substantially more collateral that has been deposited 

by market participants. There is a need to perform examinations of DCOs to evaluate the resources and capabilities of

the DCO to monitor and control their financial and operational risks

Clearing Firms and Customers Trade the Same Asset 

Class at Multiple DCOs

Firms and customers often clear the same asset classes at 

multiple DCOs. Each DCO’s view is limited to the position

it clears, while the Commission has the unique perspective of 

being able to analyze positions and the risks that they pose 

across DCOs. The Commission has to ensure it has the data

and tools necessary to evaluate the risk of these positions. The

Commission should be able to ascertain if the positions at the 

multiple DCOs increase or offset risk. The Commission must

further be able to determine if the firm or customer has the 

resources to cover the potential losses at each DCO and not 

require the gains at one DCO to pay the losses at the others

Aggregating Cleared Swaps and Futures Risk

Many large swap accounts (firms and customers) also clear 

large futures positions. In many cases, the swaps and futures

are cleared at the same firm. The Commission has to ensure

it has the procedures in place to first identify these accounts

Then secondly, the Commission has to ensure it has the 

software and information necessary to determine if the 

different asset classes increase or decrease risk. DCOs now and

increasing in the future are offering cross-margin programs 

between asset classes. The Commission has to ensure it

receives all position and account information for accounts 

in these programs. The Commission then has to have the

software and expertise necessary to review and understand 

the risk and margin offsets present in the program

New Regulatory Environment Driving Innovations 

in Derivatives Markets

The Commission will also continue to oversee the activities of 

existing SEFs and DCMs to ensure compliance with Commission regulations and the CEA. In addition, the Commission

expects to receive new applications for SEF registration and 

DCM designation. The industry is responding quickly to

the competitive opportunities engendered by the shifting 

regulatory landscape—the introduction of futures contracts 

by DCMs that are economically equivalent to standardized 

swaps is one such example. Innovation in the industry, which

is likely to increase in pace with the addition of SEFs, will 

continue to add complexity in ways currently unanticipated

For example, the Commission is seeing new methods for 

executing transactions that were not proposed in previous 

years. While these changes will impact all of the CFTC

mission activities, the near-term impacts will fall most heavily 

on the registration, product review, examinations, enforcement, and economic analysis mission activities

FY 2015 Summary of Performance and Financial Inform

 Commodity Futures Trading Commission 1

FORWARD LOOKING – FUTURE BUSINESS TRENDS AND EVENTS
Exponential Growth in Data Must be Acquired, 

Validated, Warehoused, and Analyzed to Fulfill the 

Commission’s Regulatory Responsibilities 

The Commission continues to enhance its software and 

automated tools to accommodate its enhanced surveillance 

responsibilities and access to data, including that generated by the swap data reporting rules, enhanced customer 

protection rules, chief compliance officer annual reports, risk 

exposure reports, Volcker Rule3, other regulatory changes, 

increasing number of participants, and increasing number 

and complexity of data sources relevant to surveillance. The

technology (data and processes) required for surveillance 

of swaps markets differs from that required for futures and 

options markets, and differs across asset classes. In addition,

the ability to view risk across asset classes and in combination 

with futures is an overarching requirement that must also 

be automated and the Commission must continue to work 

closely with the SDRs, SROs and other Federal and international regulators (as appropriate) to harmonize how this 

data is recorded, organized, and stored. 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

The CFTC is required to perform a comprehensive function 

that cannot be done by any single SRO and needs to see 

data from all industry participants in the swaps and futures 

markets. In response to the influx of new types of data from

new and existing registrants, the CFTC must continue to 

enhance and adjust its information infrastructure and analytical capabilities to support its responsibilities as a first line 

regulator. Only by providing advanced tools and enriched

data for staff to connect, analyze, and aggregate data can the 

Commission apply its unique view of the derivatives market 

toward effective market and risk surveillance. With each additional set of data collected there are data, technology, and

usage requirements:

■ Defining data standards (e.g., FIXML, FpML) to collect 

data;

■ Architecting data repositories to facilitate data loading 

and integration;

■ Developing software to load new data;

■ Developing data validation mechanisms to report 

errors and metrics to submitters;

3 The Volcker Rule refers to refers to § 619 (12 U.S.C. § 1851) of the Dodd-Frank Act, originally proposed by American economist and former United States Federal 

Reserve Chairman Paul Volcker to restrict U.S. banks from making certain kinds of speculative investments that do not benefit their customers. Volcker argued that such 

speculative activity played a key role in the financial crisis of 2007–2010. The rule is often referred to as a ban on proprietary trading by commercial banks, whereby 

deposits are used to trade on the bank’s own accounts, although a number of exceptions to this ban were included in the Dodd-Frank law.

4 Swaps data include Part 20 and Part 39 interim records reporting files, additional by-rule development, Part 45 swaps data reporting, OCR-ownership and control 

reporting, and Volcker data.

5 CFTC Form 40, Statement of Reporting Trader, is a reporting requirement for every person that holds a reportable position in accordance to Section 1804 of the CEA. The 

information requested is used generally in the Commission’s market surveillance activities to provide information concerning the size and composition of the commodity 

futures or option markets, and to permit the Commission to monitor and enforce the speculative position limits that have been established. The complete listing of routine 

uses, in accordance with the Privacy Act, 5 U.S.C. §522a, and the Commission’s rules thereunder, 17 CFR Part 146, of the information contained in these records is 

found in the Commission’s annual notice of its system of records.

FY 2015 Summary of Performance and Financial Inform

18 Commodity Futures Trading Commissio
■ Providing operations support to facilitate timely 

submission of data;

■ Developing data profiles on data submissions, 

submitters, markets, etc. (not currently done); an

■ Analyzing data in a wide variety of ways to support 

mission functions

The Commission will continue to adapt its data architecture 

and data management practices to manage the exponential growth in the size and complexity of mission data and 

facilitate continuous improvements in data quality and the 

ability to isolate anomalous market activity and complex 

financial and systemic risk

There is heightened attention, both domestically and internationally, to cyber-security and the risk of cyber-attacks 

against DCOs, DCMs, SEFs, and the Commission itself. The

CFTC will utilize and collaborate with FS-ISAC, ChicagoFIRST, CYWATCHTM, and NIST and other regulatory bodies to 

ensure that current information and trends can be used when 

monitoring compliance with the systems safeguards core 

principle applicable to registered entities. The Commission

also continues to increase its own cyber-security protections 

over the data collected from market participants for surveillance and enforcement

COMPARISON OF REPORTED PUBLIC SECTOR AND 

FINANCIAL SERVICES SECTOR6 CYBER-SECURITY BREACHES7

Year

Confirmed 

Breaches

Records 

Compromised Public Sector 

Financial 

Services Sector

2010 75 4 million 4% 22%

2011 855 174 million 7% 28%

2012 621 44 million 5% 8.1%

2013 1,367 200 million 13% 34%

2014 2,122 700 million 14% 13%

As a Federal government agency, the CFTC is a public sector entity that provides regulatory oversight for parts of the financial services 

sector, or marketplace. Both sectors are a magnet for those looking for economic advantage or wishing harm to the Federal government, therefore the Commission’s due diligence in ensuring systems safeguards for CFTC-registered entities and its own cyber-security 

protections is critical. 

6 Public sector is defined as Federal government entities and the financial services sector encompasses a broad range of businesses that manage money, including credit 

unions, banks, credit-card companies, insurance companies, accountancy companies, consumer-finance companies, stock brokerages, investment funds and some 

government sponsored enterprises.

7 Data Source: Verizon Data Breach Investigation Reports 2010–2014, http://www.verizonenterprise.com/dbir. The 2015 Cyber Security Breach report has not been 

published, to date.

Growth and Complexity of the Market 

the Commission Enforces

The CFTC will continue to use the resources it has to engage 

in robust enforcement, including using its anti-manipulation 

authority for the futures and swaps markets and the statutory 

prohibition on disruptive trading, including the provision 

outlawing “spoofing”. The Commission continues to investigate

cases of high-frequency trading and spoofing tactics, however 

the analytics required to interpret the “layering algorithms” are 

an issue, particularly given the resource-intensive nature of the 

matters. Without adequate resources, the Commission may be

limited in its ability to prevent fraud from use of algorithms, 

high-frequency trading, and other automated trading

Growth and Complexity of the Markets and Schemes 

The CFTC continues to devote significant resources to investigate and prosecute trading schemes that threaten the integrity 

of the markets and place market participants at risk. With the

increase of markets and products that the Commission oversees and growing complexity and interrelated nature of the 

markets, the CFTC will see a commensurate increase in the 

complexity of its investigations of manipulative, fraudulent and 

disruptive trading practices. For example, while the Commission continues to investigate cases of spoofing tactics by highfrequency traders and other market participants, the CommisFY 2015 Summary of Performance and Financial Infor

 Commodity Futures Trading Commission 1

FORWARD LOOKING – FUTURE BUSINESS TRENDS AND EVENTS
sion needs to ensure it has the requisite expert capabilities and 

analytical resources to efficiently and effectively investigate

Maintaining Integrity of Benchmarks

The integrity of benchmarks remains a priority for the 

Commission. Over the last two years, the Commission has

imposed civil monetary penalties of $4.7 billion for manipulation and attempted manipulation of global benchmark

rates, including: $1.9 billion for misconduct relating to

foreign exchange benchmarks; and over $2.8 billion for

misconduct relating to International Swaps and Derivatives 

Association Fix (ISDAFIX), London Interbank Offered Rate 

(LIBOR), Euro Interbank Offered Rate (Euribor), and other 

interest rate benchmarks. These benchmarks are an essential

valuation tool for thousands upon thousands of derivatives 

across financial markets, including: options on interest rate 

swaps, or swaptions; cross-currency swaps; foreign exchange 

swaps; spot transactions; forwards; options; and futures

These investigations are global in nature and continue to 

require a significant allocation of enforcement resources

Protecting Customers from Fraud

Anti-fraud enforcement remains a core commitment of the 

CFTC’s enforcement program. During FY 2015, the Commission prosecuted wrongdoers for a wide range of fraudulent

schemes, including Ponzi schemes that preyed upon the 

retail public’s hopes to participate in foreign exchange (forex) 

trading, precious metals speculation, and commodity pools

The Commission’s experience with fraudsters is that they gravitate towards, and flourish in, financial markets that are not 

“policed.” Therefore, the Commission must continue to devote

significant resources to “walk the beat” of the financial markets 

within its jurisdiction and protect the retail public that wants 

to participate in them

Ensuring that Markets, Firms and Participants 

Meet their Obligations

In protecting the markets and market participants, the 

Commission engages in investigations and takes enforcement 

action, when necessary, to make sure that firms maintain 

their financial integrity and that markets, firms and significant market participants fulfill their regulatory obligations, 

including reporting obligations. Commission registrants

are required to meet standards for their capitalization and 

handling of funds, which standards are intended to safeguard 

against market disruption and abuse from imprudent practices or intentional misconduct and to protect customers

The reporting requirements for markets, firms and significant 

market participants are essential to the CFTC’s ability to 

conduct effective surveillance of the futures and derivatives 

markets that it regulates. With the Dodd-Frank Act’s expansion of the Commission’s responsibility, the Commission

is doing all it can with its available resources to ensure that 

the markets, firms and significant market participants in 

the trillion dollar swaps marketplace uphold these essential 

obligations

8 The sanctions ordered represent civil monetary penalties, disgorgement, and restitution.

FY 2015 Summary of Performance and Financial Inform

20 Commodity Futures Trading Commissio
The bar graph above presents the ratings distribution for 

performance results reported from FYs 2011 through 2015

Results prior to FY 2015 are based on targets contained in 

the FY 2011–2015 Strategic Plan. FY 2015 results are based

on targets contained in the CFTC’s new Strategic Plan, which 

covers FY 2014–2018. Although results achieved under the two

Strategic Plans are not directly comparable, results from years 

prior to FY 2015 are presented to provide a historical context 

to the current performance data

The following, in chronological order, are the results for the 

past five years:

■ In FY 2011, CFTC published the FY 2011–2015 Strategic 

Plan introducing 54 performance metrics; however, most 

of FY 2011 was spent under a continuing resolution, making 

it challenging to fund mission critical activities, which 

resulted in 27 of the 54 targets being met. In addition, seven

performance measures were considered “Not Applicable” 

during FY 2011 either because they were dependent on completion of rules related to the Dodd-Frank Act or remained 

in development from the onset of the Strategic Plan. These

seven “Not Applicable” measures were not included in the 

Summary of Performance Results which brings the total 

number of performance metrics to 47 for FY 2011

■ In FY 2012, results declined to 22 targets being met

Progress was hampered in many areas by significant 

resource deficiencies and reallocations as the Commission 

focused on writing new rules required under the DoddFrank Act

■ In FY 2013, the Commission was not provided with the 

commensurate increase in budget authority to oversee the 

markets and market participants. These constraints, which

were exacerbated by the FY 2013 budget sequestration, 

limited the effectiveness of the Commission in carrying 

out its mission, leading to 21 targets met by year end

■ In FY 2014, the Commission demonstrated some progress 

toward achievement of the Commission’s mission 

and strategic goals. However, in many key areas, such as

9 Expired performance measures were under the FY 2011–2015 Strategic Plan.

Summar of Performan

 Commodity Futures Trading Commission 2

Performance Highligh
risk-based examinations of entities, including clearinghouses, exchanges, and swap dealers that the Commission 

oversees, progress was limited by resource constraints, 

ending the year with 18 targets met

■ In early FY 2015, the CFTC published a new Strategic 

Plan that spans 2014–2018, with a new set of 44 metrics

At the end of FY 2015, eight performance metrics are 

“baseline” and thus do not have annual targets. These

baseline metrics are being evaluated in FY 2016 with the 

intent of creating a basis for future measurement. Four

of the six “other” metrics are related to external factors 

with activities that are worth tracking but have no targets; 

while two of the six “other” metrics were discontinued 

during FY 2015. Of the remaining 30 measurable metrics,

20 met the FY 2015 targets

Strategic Goals and Ke

The selected accomplishments described below demonstrate progress made in FY 2015 toward the achievement of 

the Commission’s mission and strategic goals. In order to

provide better and more frequent assessments to leadership, 

the CFTC is monitoring the progress of these performance 

goals on a quarterly basis

The Commission’s FY 2015 Annual Performance Report and 

FY 2017 Agency Performance Plan, issued in February 2016 

as part of its Congressional Budget Justification in conjunction with the President’s Budget, presents more detailed 

analysis of the following performance results

FY 2015 Summary of Performance and Financial Inform

22 Commodity Futures Trading Commissio
Strategic Goal One – Market Integrity and Transparency

2015 Accomplishments

■ Opened the OPERA portal through which exchanges electronically file submissions directly with the 

Commission. DCMs, SEFs, and SDRs made 2,140 product and rule amending filings. Nearly 96 percen

of those submissions were filed through OPERA, which automatically routes submissions to relevant staff 

and reduces staff time spent on data entry tasks.

■ Completed reviews of 634 new product certifications, 944 rule filings, 10 foreign security index certifications, 

and one foreign board of trade no-action request

■ Continued its work to implement OCR. The Commission expects that identification and data-series linking

will begin in 2016 when the OCR data will begin to be collected. Over time, the CFTC anticipates identifying

85 percent of trading volume in approximately 90 percent of futures products, thereby enabling 100 percent 

of matching of parties present in both datasets

Strategic Goal Two – Financial Integrity and Avoidance of Systemic Risk

2015 Accomplishments

■ Monitored retail forex dealers during the foreign currency volatility event that occurred in January 2015. Staff

worked closely with designated SROs and industry participants to ensure that retail forex dealers remained 

in compliance with Commission capital and other financial requirements, and that retail forex customer 

deposits held as security deposits by the retail forex dealers were protected

■ Completed annual examinations of two systemically important DCOs. The Commission focused on financial

integrity, system safeguards, including cyber-security, and risk management for the examinations

■ Conducted various direct and horizontal limited scope reviews while reviewing over 1,200 financial filings 

and 1, 700 notices. The new horizontal reviews focused on the liquidity of FCMs, the sufficiency of excess

segregation and secured requirements, risk management, and internal controls of FCMs

Strategic Goal Three – Comprehensive Enforcement 

2015 Accomplishments

■ Filed 69 new enforcement actions and opened more than 220 new investigations in FY 2015. In addition,

the Commission obtained more than $3.2 billion in sanctions, including orders imposing more than

$3.1 billion in civil monetary penalties and more than $59 million in restitution and disgorgement

■ Took significant enforcement action in its: spoofing and disruptive trading enforcement, headlined by its 

“Flash Crash” enforcement action; benchmark rate manipulation cases; actions against bitcoin trading 

platforms to ensure their compliance with the CEA; and enforcement actions against swaps markets 

intermediaries to ensure their compliance with reporting obligations, which are critical to the smooth 

running of the markets and the CFTC’s ability to respond to potential misconduct

■ Developed a communications strategy for the Whistleblower Program, which included 12 public forums 

and trade shows, such as the Futures Industry Association Expo, and other key activities to inform the 

public about the assistance and protections available under the Whistleblower Program. In addition, the

Whistleblower Office developed and completed training sessions for all Division of Enforcement staff on 

the responsibility and protocol for handling whistleblower information

Strategic Goal Four – Domestic and International Cooperation and Coordination

2015 Accomplishments

■ Collaborated with U.S. Treasury, U.S. Securities and Exchange Commission, Federal Deposit Insurance Corporation, the Federal Reserve, and the Office of Comptroller of the Currency on setting up the Global Le

Entity Identifier System (GLEIS) including the implementation of the Legal Entity Identifier (LEI) Regulatory 

Oversight Committee that assist the Commission in the implementation of Part 45 swap data reporting

■ Issued approximately 200 requests for assistance to foreign regulators and received approximately 30 

assistance requests from foreign regulators. The information obtained from and exchanged with foreign

regulators and domestic government agencies assisted the CFTC in bringing many of its actions in FY 2015, 

including the “Flash Crash” case brought under the Commission’s new disruptive trading and “spoofing” 

authority, and the foreign exchange, LIBOR, and ISDAFIX Benchmark Rates cases, and facilitated the filing 

of many parallel criminal proceedings

■ Handled nearly 300 matters involving joint cooperation with Federal and state criminal and civil authorities, 

and approximately 90 percent of its major fraud and manipulation cases in FY 2015 involved parallel 

criminal proceedings

FY 2015 Summary of Performance and Financial Inform

 Commodity Futures Trading Commission 2

PERFORMANCE HIGHLIGHTS
Financial Highligh

Iam honored to 

join Chairman 

Massad in presenting the FY 2015 Agency 

Financial Report for the 

CFTC. This report provides

financial and high-level 

performance information 

to the American taxpayer 

and the Commission’s 

stakeholders to enable them to understand and evaluate how 

the Commission accomplishes its mission. This Financial

Section includes the Commission’s principal financial statements—Balance Sheets, Statements of Net Cost, Statements of 

Changes in Net Position, Statements of Budgetary Resources, 

and Statements of Custodial Activity—as well as accompanying 

notes that are integral to fully understanding the Commission’s 

position and operations for FY 2015

Despite noteworthy progress, for FY 2015 our independent 

auditor, KPMG LLP, on behalf of the Commission’s Office 

of the Inspector General, has issued a qualified opinion on 

our financial statements for FY 2015. In FY 2015, the auditors

identified a material weakness in internal controls over 

financial reporting related to the recording of lease obligations that dates back to the inception of CFTC’s leases

During FY 2015, the GAO requested information on the 

Commission’s views regarding various legal issues involving 

the CFTC’s leases, including CFTC’s practice for recording obligations arising under the agency’s current leases for office 

space in Washington, D.C., Chicago, New York, and Kansa

City. The CFTC was granted independent leasing authority in

1974, and received authority to expend appropriated funds 

on multiple year leases in FY 1981. The CFTC’s historical

practice has been to obligate only the annual portion of lease 

payments due each fiscal year. As a result of the CFTC’s review

of information gathered during the course of responding to 

the GAO inquiry, the Commission concluded that its historical 

practice for recording lease obligations may be inconsistent 

with OMB Circular A-11, Preparation, Submission and Execution 

of the Budget; the recording statute in 31 U.S.C. § 1501 (a)(1

and previous GAO decisions. The GAO is currently reviewing

the matter and the agency expects an opinion to be issued 

during FY 2016. As a result of the potential findings of the

anticipated GAO opinion, it is reasonably possible that an 

unfunded obligation, covering all potential future payments 

agreed to under current leases, will need to be recognized and 

the Commission has disclosed this potential obligation in the 

notes to its financial statements. Once the GAO opinion is

received, the agency will address the appropriate accounting 

treatment of this matter

Since FY 2007, the CFTC has leveraged a financial management 

systems platform operated by the U.S. Department o

Transportation’s (DOT) Enterprise Services Center (ESC), an 

Office of Management and Budget (OMB) designated 

financial management service provider. As a result, the CFTC

is able to accumulate, analyze, and present reliable financial 

information, and provide reliable, timely information for 

managing current operations and timely reporting of financial 

information to central agencies. The Commission’s financial

management systems strategy for FY 2016 includes continued 

monitoring and oversight of the financial management system 

(DELPHI) operated by its shared service provider; no major 

upgrades are planned for the near future

The Commission is committed to maintaining strong internal 

controls over operations. We will continue to focus efforts to

improve the efficiency and effectiveness of agency operations 

and strive to ensure that the Commission will be well-positioned to respond to additional challenges as they arise

Mary Jean Buhler

Chief Financial Officer

January 15, 2016

A Message from the Chief Financ

24 Commodity Futures Trading Commissio
Summary of FY 2015 Financial Statement Audit

Audit Opinion: Qualified

Restatement: No

MATERIAL WEAKNESS BEGINNING BALANCE NEW RESOLVED CONSOLIDATED ENDING BALANCE

0 1 1

Summary of Management Assurances

EFFECTIVENESS OF INTERNAL CONTROL OVER FINANCIAL REPORTING (FMFIA § 2)

Statement of Assurance: Qualified

MATERIAL WEAKNESS BEGINNING BALANCE NEW RESOLVED CONSOLIDATED REASSESSED ENDING BALANCE

0 1 1

EFFECTIVENESS OF INTERNAL CONTROL OVER OPERATIONS (FMFIA § 2)

Statement of Assurance: Unqualified

MATERIAL WEAKNESS BEGINNING BALANCE NEW RESOLVED CONSOLIDATED REASSESSED ENDING BALANCE

0 0 0

CONFORMANCE WITH FINANCIAL MANAGEMENT SYSTEM REQUIREMENTS (FMFIA § 4)

Statement of Assurance: Systems conform to financial management system requirements

NON-CONFORMANCE BEGINNING BALANCE NEW RESOLVED CONSOLIDATED REASSESSED ENDING BALANCE

0 0 0

DEFINITION OF TERMS

Beginning Balance: The beginning balance will agree with 

the ending balance if material weaknesses from the prior year

New: The total number of material weaknesses that have been 

identified during the current year

Resolved: The total number of material weaknesses that have 

dropped below the level of materiality in the current year

Consolidation: The combining of two or more findings

Reassessed: The removal of any finding not attributable 

to corrective action

Ending Balance: The agency’s year-end balance

Summar of Audit and Management 

FY 2015 Summary of Performance and Financial Inform

 Commodity Futures Trading Commission 2

FINANCIAL HIGHLIGHTS
10 In FY 2015, the CFTC issued its FY 2014–2018 Strategic Plan. With this plan, the Commission changed Strategic Goal Five, Organizational and Management Excellence, into 

Management Objectives.

5-Year Financial Sum

The table below presents trend information for each major component of the Commission’s balance 

sheets and statements of net cost for FY 2011 through FY 2015

The table is immediately followed by a discussion and analysis of 

the Commission’s major financial highlights for FY 2015

Highlights 2015 2014 2013 2012 2

Condensed Balance Sheet 

Fund Balance with Treasury $ 67,246,060 $ 47,070,343 $ 36,467,970 $ 82,557,690 $ 81,785,717

Investments 263,000,000 270,000,000 95,000,000 77,135,901 –

Accounts Receivable 18,614 11,112 13,252 20,976 59,226

Prepayments 2,473,459 1,712,871 1,541,681 1,803,497 1,109,626

Custodial Receivables, Net 4,696,176 4,218,788 69,744,626 4,140,347 2,574,173

General Property, Plant, and Equipment, Net 50,358,266 54,464,549 58,251,172 53,410,435 42,346,895

Deferred Costs 28,487 64,201 220,953 1,234,223 6,254,873

TOTAL ASSETS $387,821,062 $377,541,864 $261,239,654 $220,303,069 $134,130,510

Accounts Payable $ 8,607,890 $ 5,483,221 $ 5,092,410 $ 7,217,772 $ 7,092,349

FECA Liabilities 498,101 549,734 596,353 764,243 528,512

Accrued Payroll and Annual Leave 15,004,112 13,007,491 11,651,586 16,477,676 15,464,338

Custodial Liabilities 4,696,176 4,218,788 69,744,626 4,140,347 2,574,173

Deposit Fund Liabilities 179,806 134,683 83,997 77,098 57,127

Deferred Lease Liabilities 25,673,457 25,961,973 25,241,114 24,808,042 21,974,782

Contingent Liabilities 300,000 85,000 – – –

Other 22,397 11,699 19,600 19,050 19,649

TOTAL LIABILITIES $ 54,981,939 $ 49,452,589 $112,429,686 $ 53,504,228 $ 47,710,930

Unexpended Appropriations – All Other Funds 50,997,602 35,420,980 25,006,039 46,349,473 44,666,156

Cumulative Results of Operations – Funds from 

Dedicated Collections 267,612,410 274,315,312 99,904,291 99,996,749 23,755,000

Cumulative Results of Operations – All Other Funds 14,229,111 18,352,983 23,899,638 20,452,619 17,998,424

Total Net Position 332,839,123 328,089,275 148,809,968 166,798,841 86,419,580

TOTAL LIABILITIES AND NET POSITION $387,821,062 $377,541,864 $261,239,654 $220,303,069 $134,130,510

Condensed Statements of Ne

Gross Costs $ 249,861,126 $ 217,450,008 $ 218,155,538 $ 207,618,265 $ 187,648,360

Earned Revenue (53,074) (31,375) (49,483) (227,504) (88,720)

TOTAL NET COST OF OPERATIONS $249,808,052 $217,418,633 $218,106,055 $207,390,761 $187,559,640

Net Cost of Operations by Strategi

Goal One – Market Integrity and Transparency $ 68,322,502 N/A N/A N/A N/A

Goal Two – Financial Integrity and Avoidance of 

Systemic Risk 73,918,203 N/A N/A N/A N/A

Goal Three – Comprehensive Enforcement 95,501,618 N/A N/A N/A N/A

Goal Four – Domestic and International Cooperation 

and Coordination 12,065,729 N/A N/A N/A N/A

Goal One – Market Integrity N/A $ 56,746,263 $ 62,225,658 $ 59,168,584 $ 48,390,387

Goal Two – Clearing Integrity N/A 51,963,054 57,470,946 54,647,465 43,701,396

Goal Three – Robust Enforcement N/A 71,530,730 64,123,179 60,972,883 61,144,442

Goal Four – Cross-Border Cooperation N/A 11,740,606 7,306,553 6,947,591 8,440,184

Goal Five – Organizational and Management Excellence N/A 25,437,980 26,979,719 25,654,238 25,883,231

$ 249,808,052 $217,418,633 $218,106,055 $207,390,761 $187,559,640

FY 2015 Summary of Performance and Financial Inform

26 Commodity Futures Trading Commissio
Balance Sheet

The Balance Sheet presents, as of a specific point in time, the 

assets and liabilities retained or managed by the Commission

The difference between assets and liabilities represents the net 

position of the Commission

Financial Discussion an

The CFTC prepares annual financial statements in accordance 

with U.S. generally accepted accounting principles (GAAP

for Federal government entities and subjects the statements 

to an independent audit

Management recognizes the need for performance and 

accountability reporting, and regularly assesses risk factors 

that could have an impact on the Commission’s ability to 

effectively report. Improved reporting enables managers to

be accountable and supports the concepts of the Government 

Performance and Results Act (GPRA), which requires the 

Commission to: 1) establish a strategic plan with programmatic goals and objectives; 2) develop appropriate measurement indicators; and 3) measure performance in achieving 

those goals

The financial summary as shown on the preceding page highlights changes in financial position between September 30, 

2015, and September 30, 2014. This overview is supplemented

with brief descriptions of the nature of each required financial 

statement and its relevance. Certain significant balances or

conditions featured in the graphic presentation are explained 

in these sections to help clarify their relationship to Commission operations. Readers are encouraged to gain a deeper

understanding by reviewing the Commission’s financial statements and notes to the accompanying audit report presented 

in the Financial Section of this report

Understanding the Financial State

The CFTC presents financial statements and notes in 

accordance with accounting principles generally accepted in 

the United States of America and in the form and content 

requirements of OMB Circular A-136, Financial Reporting 

Requirements, which is revised annually by OMB in 

coordination with the U.S. Chief Financial Officers Counc

The CFTC’s current year and prior year financial statements 

and notes are presented in a comparative format

The chart below presents changes in key financial statement 

line items, as of and for, the fiscal year ended September 30, 

2015, compared to September 30, 2014

Key Financial Statement Line Items 2015 2014 $ Change % Ch

Total Assets $ 387,821,062 $ 377,541,864 $ 10,279,198 2.72%

Total Liabilities $ 54,981,939 $ 49,452,589 $ 5,529,350 11.18%

Total Net Position $ 332,839,123 $ 328,089,275 $ 4,749,848 1.45%

Transfers-In/Out Without Reimbursement $ – $ 176,110,604 $ (176,110,604) (100.00)%

Spending Authority from Offsetting Collections $ 230,746 $ 176,261,959 $ (176,031,213) (99.87)%

Total Budgetary Resources $ 528,502,937 $ 496,899,396 $ 31,603,541 6.36%

Apportioned $ 270,359,908 $ 13,437,561 $ 256,922,347 1,911.97%

Unapportioned $ (558,974) $ 262,111,560 $(262,670,534) (100.21)%

Gross Outlays $ (234,914,187) $ (204,693,512) $ (30,220,675) 14.76%

Actual Offsetting Collections $ (212,554) $ (176,466,655) $ 176,254,101 (99.88)%

Custodial Receivables/Liabilities $ 4,696,176 $ 4,218,788 $ 477,388 11.32%

FY 2015 Summary of Performance and Financial Inform

 Commodity Futures Trading Commission 2

FINANCIAL HIGHLIGHTS
Total Assets. For the year ended September 30, 2015, the Balance 

Sheet reflects total assets of $387.8 million. This is an increas

of $10.3 million, or 2.7 percent, over FY 2014. The increa

is primarily due to a $20.2 million increase in Fund Balance

with Treasury offset by a $7 million decrease in Investments 

and a $4.1 million decrease in Property, Plant, and Equipmen

The $20.2 million, or 42.9 percent, increase in Fund Balanc

with Treasury was primarily due to the excess of appropriations 

of $250 million over appropriations used of $232.3 million

due to the timing of cash payments

The $7.0 million, or 2.6 percent, decrease in Investment

is due to the redemption of investments to pay for eligible 

expenses of the CFTC Customer Protection Fund as no 

further collections of civil monetary sanctions can be deposited into the fund until the balance of the fund falls below 

$100 million

The $4.1 million, or 7.5 percent, decrease in Property, Plant

and Equipment is due to a loss on the disposal of fixed assets 

of $664 thousand and accumulated depreciation and amortization of fixed assets of $12.7 million in excess of fixed asset

purchases of $9.3 millio

Total Liabilities: For the year ended September 30, 2015, the 

Balance Sheet reflects total liabilities of $55.0 million. This i

an increase of $5.5 million, or 11.2 percent, over FY 2014. T

increase is primarily due to increases in Accounts Payable, 

Accrued Payroll, and Contingent Liabilities of $3.1 million,

$1.8 million, and $215 thousand, respectively

The combined $4.9 million increase in Accounts Payable and

Accrued Payroll is reasonable given the $35 million increase 

in appropriations received in FY 2015, which resulted in an 

increase in contract obligations and the hiring of approximately 113 employees. In addition, one additional workday

was accrued in the year-end payroll accrual in FY 2015

The $215 thousand, or 252.9 percent, increase in Contingent

Liabilities is due to a pending whistleblower payment that 

is expected to be paid in FY 2016 after the appeal period 

has ended

FY 2015 Summary of Performance and Financial Inform

28 Commodity Futures Trading Commissio
Total Net Position: For the year ended September 30, 2015, the 

Balance Sheet reflects a total net position of $332.8 million. Thi

is an increase of $4.7 million, or 1.5 percent, over FY 2014. T

increase is the result of a $15.6 million increase in Unexpended

Appropriations—All Other Funds, offset by decreases of 

$6.7 million in Cumulative Results of Operations—Funds

from Dedicated Collections and $4.1 million in Cumulative

Results of Operations—All Other Funds

The $15.6 million, or 44.0 percent, increase in Unexpende

Appropriations—All Other Funds is primarily due to FY 2015 

appropriations received of $250 million in excess of appropriations used of $232.3 million due to the timing of actual

cash payments, less $2.2 million in canceled funds returned

to Treasury

The $6.7 million, or 2.4 percent, decrease in Cumulative Result

of Operations—Funds from Dedicated Collections is due to 

CPF expenses of $6.8 million offset by interest revenue of

$58 thousand

The $4.1 million, or 22.5 percent, decrease in Cumulativ

Results of Operations – All Other Funds is primarily due to an 

increase in unfunded liabilities of $62 thousand (e.g., accruals 

for annual leave and Federal Employees’ Compensation Act 

expenses and contingent liabilities), net disposal of fixed assets 

of $664 thousand, and accumulated depreciation and amortization of fixed assets of $12.7 million in excess of fixed asset

purchases of $9.3 millio

Statement of Net Cost

This statement is designed to present the components of the 

Commission’s net cost of operations. Net cost is the gross cost

incurred less any revenues earned from Commission activities

The Commission experienced a $32.4 million, or 14.9 percent

increase in the total net cost of operations during FY 2015

This overall increase is made up of increases of $15.5 million

in payroll, $15.4 million in technology and non-Federal

service contracts, $618 thousand in intragovernmental expense, 

$1.0 million in leases, $1.2 million in travel, and $215 thousan

in contingent liabilities. These increases were offset by a decrease

of $1.5 million in depreciation. The $15.5 million increase 

total payroll costs is primarily the result of an increase in the 

number of employees by approximately 113, or 17.3 percen

The $18.2 million increase in non-payroll expenses is reasonable

given the $35 million, or 16.3 percent, increase in appropriations

received in FY 2015

The Commission implemented a new strategic plan in FY 2015 

with slightly different goals; as a result, the FY 2015 and FY 2014 

net costs by strategic goal are presented separately rather than 

comparatively. For FY 2015, the Statement of Net Cost is

categorized by the following four strategic goals:

■ The focus of Strategic Goal One, Market Integrity and Transparency, is to recognize that derivatives markets provide 

a means for market users to offset price risks inherent in 

their businesses and to serve as a public price discovery 

mechanism. In FY 2015, the net cost of operations for this

goal was $68.3 million or 27.4 percent of total net cost o

operations

FY 2015 Summary of Performance and Financial Inform

 Commodity Futures Trading Commission 2

FINANCIAL HIGHLIGHTS
Sheet section above, this increase is the result of a $15.6 million

increase in Unexpended Appropriations—All Other Funds, offset 

by decreases of $6.7 million in Cumulative Results of Operations—Funds from Dedicated Collections and $4.1 million i

Cumulative Results of Operations—All Other Funds

The $15.6 million, or 44.0 percent, increase in Unexpende

Appropriations—All Other Funds is primarily due to FY 2015 

appropriations received of $250 million in excess of appropriations used of $232.3 million due to the timing of actual

cash payments, less $2.2 million in canceled funds returned

to Treasury

The $6.7 million, or 2.4 percent, decrease in Cumulativ

Results of Operations—Funds from Dedicated Collections is 

due to CPF expenses of $6.8 million offset by interest revenue

of $58 thousand

The $4.1 million, or 22.5 percent, decrease in Cumulativ

Results of Operations – All Other Funds is primarily due to an 

increase in unfunded liabilities of $62 thousand (e.g., accruals 

for annual leave and Federal Employees’ Compensation Act 

expenses and contingent liabilities), net disposal of fixed 

assets of $664 thousand, and accumulated depreciation and 

amortization of fixed assets of $12.7 million in excess of fixed

asset purchases of $9.3 millio

Statement of Budgetary Resources

This statement provides 

information about the 

provision of budgetary 

resources and its status 

as of the end of the 

year. Information in this

statement is consistent 

with budget execution 

information and the 

information reported 

in the Budget of the 

U. S. Government, FY 2015

■ The focus of Strategic Goal Two, Financial Integrity and 

Avoidance of Systemic Risk, is to strive to ensure that 

Commission-registered DCOs, SDs, MSPs, and FCMs have 

the financial resources, risk management systems and 

procedures, internal controls, customer protection systems, 

and other controls necessary to meet their obligations so 

as to minimize the risk that the financial difficulty of any 

of these registrants, or any of their customers has systemic 

implications. In FY 2015, the net cost of operations for

this goal was $73.9 million or 29.6 percent of total ne

cost of operations

■ Through Strategic Goal Three, Comprehensive Enforcement, the CFTC enforces the CEA and Commission regulations, and works to promote awareness of and compliance 

with these laws. In FY 2015, the net cost of operations for

this goal was $95.5 million or 38.2 percent of total ne

cost of operations

■ The focus of Strategic Goal Four, Domestic and International 

Cooperation and Coordination, is on how the Commission interacts with domestic and international regulatory 

authorities, market participants, and others affected by the 

Commission’s regulatory policies and practices. In FY 2015,

the net cost of operations for this goal was $12.1 million

or 4.8 percent of total net cost of operation

Statement of Changes in Net Position

The Statement of Changes in Net Position presents the Commission’s cumulative net results of operations and unexpended 

appropriations for the fiscal year. The CFTC’s Net Position

increased by $4.7 million, or 1.5 percent in FY 2015. 

explained in the Total Net Position discussion in the Balance 

$

250.0 

MILLION 

FY 2015 Appropriation

$

234.9 

MILLION 

FY 2015 Gross Outlays

The Commission’s Total Budgetary Resources increased by 

$31.6 million to $250 million, or 6.4 percent, primarily du

to an increase in appropriations of $35 million, which was 

16.3 percent higher than the FY 2014 appropriated amount

of $215 million

FY 2015 Summary of Performance and Financial Inform

30 Commodity Futures Trading Commissio
Gross Outlays increased by $30.2 million, or 14.8 percent, du

to more funds spent in FY 2015 then in FY 2014, primarily due 

to the $35 million, 0r 16.3 percent, increase in appropriations

received

Actual Offsetting Collections decreased by $176.3 million, or

99.9 percent, primarily due to a $176.1 million civil monetar

sanctions collection recovered from the Treasury in FY 2014

Statement of Custodial Activity

Total Cash Collections

($ in millions)

Registration and Filing Fees $ 1.6

Fines, Penalties, and Forfeitures $ 2,841.2

General Proprietary Receipts $ –*

$

2,842.8 * Total cash collections include $6.7 thousand, or <$1, in general proprietary receipts.

This statement provides information about the sources and 

disposition of collections. CFTC transfers eligible funds from

dedicated collections to the CPF when the balance falls below 

$100 million and other non-exchange revenue to the Treasury 

general fund. Collections primarily consist of fines, penalties, and forfeitures assessed and levied against businesses

and individuals for violations of the CEA or Commission 

regulations. They also include non-exchange revenues such

as registration, filing, appeal fees, and general receipts. The

Statement of Custodial Activity reflects total cash collections 

for FY 2015 in the amount of $2.8 billion, an increase of

$1.9 billion, or 200.8 percent, over FY 2014. This increa

in collections was expected due to nine large collections in 

FY 2015 ranging in amounts from $35 million to $800 million 

that resulted from the Commission’s enforcement cases related 

to attempted manipulation of global foreign exchange and 

LIBOR benchmark rates. Of the $2.8 billion in FY 2015 cas

collections, all $2.8 billion was transferred to the Treasury

because the CPF fund balance exceeded $100 million so no 

collections were eligible to be transferred to it

Historical experience has indicated that a high percentage of 

custodial receivables prove uncollectible. An allowance for

uncollectible accounts has been established and included in 

the accounts receivable on the Balance Sheet. The allowance

is based on past experience in the collection of accounts 

receivables and an analysis of outstanding balances. Accounts

are re-estimated quarterly based on account reviews and 

a determination that changes to the net realizable value 

are needed

Limitatios of Financial St

Management has prepared the accompanying financial 

statements to report the financial position and operational 

results for the CFTC for FY 2015 and FY 2014 pursuant to the 

requirements of Title 31 of the U.S. Code, section 3515 (

While these statements have been prepared from the books 

and records of the Commission in accordance with GAAP for 

Federal entities and the formats prescribed by OMB Circular 

A-136, Financial Reporting Requirements, these statements are 

in addition to the financial reports used to monitor and 

control budgetary resources, which are prepared from the 

same books and records

The statements should be read with the understanding 

that they represent a component of the U.S. government, 

sovereign entity. One implication of this is that the liabilities

presented herein cannot be liquidated without the enactment 

of appropriations, and ongoing operations are subject to the 

enactment of future appropriations

FY 2015 Summary of Performance and Financial Inform

 Commodity Futures Trading Commission 3

FINANCIAL HIGHLIGHTS
C O M M O D I T Y F U T U R E S T R A D I N G C O M M I S S I O N

Certificate of Excelle

Accountability Re

Best-in-Class Aw

“In recognition for providing the Most Informative Analysis of Financial 

Position and Results in your FY 2014 Agency Financial Report”

Association of Government Accountants (AGA)

Awards the
Additional copies of the 

Commodity Futures Trading Commission 

FY 2015 Summary of Performance and Financial Information 

are available by contacting the following:

Commodity Futures Trading Commission

Financial Management Branch

Three Lafayette Centre

1155 21st Street, N.W.

Washington, DC 20581

Telephone: Mary Jean Buhler, 202.418.5089 or

Lisa Malone, 202.418.5184

E-mail: mbuhler@cftc.gov or lmalone@cftc.gov

Web: http://www.cftc.gov/About/CFTCReports/index.htm

Acknowledgements

This Summary of Performance and Financial Information was produced with the energies and talents of Commission 

staff. To these individuals, the Financial Management Branch would like to offer our sincerest thanks and 

acknowledgement.

We would also like to acknowledge the Office of the Inspector General and KPMG LLP for the professional manner 

in which they conducted the audit of the Fiscal Year 2015 Financial Statements.

We offer our special thanks to The DesignPond, in particular Sheri Beauregard and Michael James, for their 

outstanding contribution to the design of this report.

Page Photo Credits

Clark Day Photography; Page 14

Ken Jones Photography; Pages 2, 3, 4, 5, 6, 7, 8, 10, 12, 16, and 24

Robert Hart Photography; Page 21

Steve Puppe Photography; Page 15

Other Stock Images; Page 9
C O M M O D I T Y F U T U R E S T R A D I N G C O M M I S S I O N

Three Lafayette Cenre •  1155 21st Street,N.W.  • Washngton

202.418.5000 • www.cftc.