Budget Request

F i s c a l Y e a r 2 0 1 8

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

Prepared for the Committee on Appropriations, May 2017
U.S. Commodity Futures Trading Commission

Three Lafayette Centre, 1155 21st Street, NW, Washington, DC 20581

www.cftc.gov

J. Christopher Giancarlo (202)418-5030

Acting Chairman (202)418-5533 (fax)

jcgiancarlo@cftc.gov

Chairman’s Transmittal Letter

May 23, 2017

The Honorable Thad Cochran

Chairman

Committee on Appropriations

U.S. Senate

Washington, D. C. 20510 

The Honorable Rodney P. Frelinghuysen

Chairman

Committee on Appropriations

U.S. House of Representatives

Washington, D. C. 20515

The Honorable Patrick Leahy

Ranking Member

Committee on Appropriations

U.S. Senate

Washington, D. C. 20510

The Honorable Nita M. Lowey

Ranking Member

Committee on Appropriations

U.S. House of Representatives

Washington, D. C. 20515

Dear Chairman Cochran, Senator Leahy, Chairman Frelinghuysen, and Representative Lowey:

I am pleased to transmit the U.S. Commodity Futures Trading Commission (CFTC or Commission) 

justification for the Commission’s fiscal year (FY) 2018 budget request. If fulfilled, this budget 

request would maximize the Commission’s ability to oversee our nation’s swaps, futures and 

options markets. 

The mission of the CFTC is to foster open, transparent, competitive and financially sound markets 

for the trading of risk hedging instruments through derivatives. Derivatives markets serve the need 

of the American economy to price and transfer commercial risk. They are primary price discovery 

vehicles, across all major asset classes, both in the U.S. and globally. 

Derivatives provide a forum in which market participants can manage the risks of variable 

production costs, such as the price of raw materials, energy, foreign currency and interest rates. 

They serve the vital economic function of permitting risk transfer from those who cannot afford it 

to those who can. For more than 100 years, farmers and ranchers have used listed derivatives 

markets to hedge their costs of production and delivery price so that Americans can always find 

plenty of food on supermarket shelves. But derivatives markets are not just beneficial for 

agricultural producers. They impact the price and availability of heating in American homes, the 

energy used in factories, the interest rates borrowers pay on home mortgages and the returns 

workers earn on their retirement savings.
In short, derivatives serve the needs of society to help moderate price, supply and other 

commercial risks. Thus, derivatives free up capital for other purposes and boost economic growth, 

job creation and American prosperity.

As a civil law enforcement agency, the CFTC has the duty to protect and serve derivative market 

participants. We oversee derivatives clearinghouses, futures exchanges, swap dealers, swap data 

repositories (SDRs), swap execution facilities (SEFs), future commission merchants (FCMs) and 

other intermediaries. Our primary duties include oversight of the over-the-counter (OTC) swaps 

market as legislated by the Dodd-Frank Wall Street Reform and Consumer Protection Act (DoddFrank Act), the enforcement of laws against market fraud such as spoofing and phony dealing, and 

the monitoring of market activity to assess systemic risk. 

In order for the CFTC to fulfill its duty to oversee these vital markets in FY 2018, I am requesting 

$281.5 million and 739 full-time equivalents (FTE). This is an increase of $31.5 million and 36 

FTE over the FY 2017 continuing resolution (CR) level.

Of these additional resources, approximately 36 percent are devoted to economic and legal 

analysis and examinations. The investment in economic capabilities is aimed at boosting the 

CFTC’s analytical expertise and monitoring of systemic risk in the derivatives markets, in 

particular with regard to central counterparty clearinghouses. It includes the expansion of 

sophisticated econometric and quantitative analysis devoted to risk modeling, stress tests, and 

other stability-related evaluations necessary for market oversight. Furthermore, such analysis will 

help the CFTC fulfill the Presidential Executive Order on Core Principles for Regulating the U.S.

Financial System, relating to the principle of “[to] foster economic growth and vibrant financial 

markets through more rigorous regulatory impact analysis that addresses systemic risk and 

market failures, such as moral hazard and information asymmetry.” 

We also seek to strengthen the Commission's examinations capability to enable it to keep pace 

with the explosive growth in the amount and value of swaps cleared by designated clearing 

organizations (DCOs) pursuant to global regulatory reform implementation. As the size and scope 

of DCOs increases, so too has the complexity of the counterparty risk management oversight 

programs and liquidity risk management procedures of the DCOS under CFTC regulation here and 

abroad. 

In FY 2018, the Commission also plans to increase staffing and resources to address financial 

technology innovation (FinTech). Through FinTech, the Commission will look to address three 

fundamental issues arising from this transformational change: 1) how the CFTC should leverage 

FinTech innovation to make it a more effective regulator, 2) how FinTech can help the CFTC 

identify rules and regulations that need to be updated for relevance in digital markets, and 3) the 

role of the Commission in supporting U.S. FinTech innovation in CFTC regulated markets. 

Agency direction and management increases reflect a recent reorganization that shifted, 

streamlined and centralized business management functions from the mission delivery divisions 

to administrative services, a change that will produce long-term savings. In FY 2018, I plan on 

taking actions to further examine and streamline operations where appropriate to maximize 

effective use of resources. 

The $31.5 million in additional funds over FY 2017 is not a formulaic or superficial number, but a 

thorough and informed assessment of what the CFTC needs to execute its mission in FY 2018. In 

the five months since becoming Acting Chairman, I have reviewed all core CFTC budget functions 

in concert with our division directors. I have also reviewed the needs of our offices that provide 

various support services to our four divisions in the shared services organizational model I have 

instituted at the CFTC. I have constructed a budget from the bottom up based upon what we need 

to do our job. The $281.5 million FY 2018 budget request reflects the current needs of the CFTC 

rather than continuing to build upon prior year assessments. 

The U.S. derivatives markets should be neither the most regulated nor the least regulated of the 

world—but the best regulated. This quest for superior regulatory oversight and unswerving 

enforcement of our laws motivates the work of the hundreds of talented men and women who 
serve their country at the CFTC. Only with such a commitment can all Americans experience the 

economic benefits that risk-transfer markets afford. This budget request ensures that the CFTC 

can meet such a standard before the American people. Thank you for your consideration and 

respect.

Sincerely, 

J. Christopher Giancarlo
cc:

The Honorable Shelley Moore Capito

Chairwoman

Subcommittee on Financial Services 

 and General Government

Committee on Appropriations

U.S. Senate

Washington, D. C. 20510

The Honorable Robert B. Aderholt

Chairman

Subcommittee on Agriculture, Rural

 Development, Food and Drug

 Administration, and Related Agencies

Committee on Appropriations

U.S. House of Representatives

Washington, D. C. 20515

The Honorable Christopher A. Coons

Ranking Member

Subcommittee on Financial Services

 and General Government

Committee on Appropriations

U.S. Senate

Washington, D. C. 20510

The Honorable Sanford D. Bishop, Jr.

Ranking Member

Subcommittee on Agriculture, Rural

 Development, Food and Drug

 Administration, and Related Agencies

Committee on Appropriations

U.S. House of Representatives

Washington, D. C. 20515
The FY 2018 Budget Request

Table of Contents

EXECUTIVE SUMMARY.......................................................... 1

Highlights of the 2018 Budget by Mission Function..........................1

OVERVIEW OF THE FY 2018 BUDGET ....................................5

FY 2018 Budget Request by Program .............................................5

FY 2018 Budget Request by Mission Function ................................ 6

FY 2018 Budget Request by Division..................................................7

FY 2018 Budget Request by Object Class .......................................... 8

Crosswalk from FY 2017 to FY 2018.................................................. 9

JUSTIFICATION OF THE FY 2018 BUDGET BY 

MISSION FUNCTION ........................................................... 10

Enforcement ......................................................................................10

Surveillance........................................................................................13

Examinations ..................................................................................... 17

Registration and Compliance............................................................21

Product Reviews ............................................................................... 25

Economic and Legal Analysis........................................................... 29

International Policy .......................................................................... 33

Data and Technology Support.......................................................... 36

Agency Direction and Management................................................. 39

APPENDIX 1 ....................................................................42

The Commissioners .......................................................................... 42

Organizational Divisions and Offices............................................... 42

APPENDIX 2....................................................................46

Information Technology................................................................... 46

APPENDIX 3....................................................................50

Inspector General ............................................................................. 50

Inspector General’s Comment on the CFTC FY 2018 

Budget Request..................................................................................51

Inspector General’s FY 2018 Budget Request ................................. 52

APPENDIX 4....................................................................53

Statement of Availability on Basis of Obligations ........................... 54

APPENDIX 5.................................................................... 55

Customer Protection Fund ................................................................55

APPENDIX 6....................................................................58

APPENDIX 7.................................................................... 79

Table of Acronyms .............................................................................79
The FY 2018 Budget Request

Figures and Tables

Table 1: Summary of FY 2016 to 2018 by Program..........................................5

Figure 1: $281.5 Million Budget Request by Program .....................................5

Table 2: Summary of FY 2016 to 2018 by Mission Function.......................... 6

Figure 2: $281.5 Million Budget Request by Mission Function ..................... 6

Table 3: Summary of FY 2016 to 2018 by Division ...........................................7

Figure 3: $281.5 Million Budget Request by Division......................................7

Table 4: Summary of FY 2016 to 2018 by Object Class................................... 8

Figure 4: $281.5 Million Budget Request by Object Class .............................. 8

Table 5: Crosswalk from FY 2017 to FY 2018.................................................. 9

Table 6: Breakout of Enforcement by Division ..............................................12

Figure 5: Enforcement Request by Division....................................................12

Table 7: Breakout of Surveillance by Division................................................16

Figure 6: Surveillance Request by Division.....................................................16

Table 8: Breakout of Examinations by Division............................................ 20

Figure 7: Examinations Request by Division ................................................. 20

Table 9: Breakout of Registration and Compliance by Division................... 24

Figure 8: Registration and Compliance Request by Division........................ 24

Table 10: Breakout of Product Reviews by Division...................................... 28

Figure 9: Product Reviews Request by Division............................................. 28

Table 11: Breakout of Economic and Legal Analysis by Division.................. 32

Figure 10: Economic and Legal Analysis Request by Division ...................... 32

Table 12: Breakout of International Policy by Division ................................ 35

Figure 11: International Policy Request by Division ...................................... 35

Table 13: Breakout of Data and Technology Support by Division ................ 38

Table 14: Breakout of Agency Direction and Management by Division........41

Figure 12: Agency Direction and Management Request by Division .............41

Table 15: Information Technology Budget .................................................... 49

Table 16: Inspector General’s Budget Request.............................................. 50

Table 17: Summary of FY 2016 to 2018 Statement of 

Availability on Basis of Obligations ................................................................ 54

Table 18: Customer Protection Fund ..............................................................57

Table 19: Matrix of U.S. Registered Entities and Registrants by CFTC 

Mission Function............................................................................................. 59

Table 20: Number of Market Participants by Fiscal Year ............................ 60

Figure 13: Growth of Volume of Contracts Traded ....................................... 62

Figure 14: Volume of Swaps Traded on Swap Execution Facilities .............. 63

Figure 15: Swaps Volume, Cleared vs. Uncleared.......................................... 64

Figure 16: Actively Traded Futures and Option Contracts ........................... 65

Figure 17: Notional Value of Exchange-Traded and OTC Contracts ............ 66

Figure 18: Customer Funds in FCM Accounts................................................67

Figure 19: Margin Requirements ................................................................... 68

Table 21: Swap Execution Facilities .............................................................. 70

Table 22: Contract Markets Designated by the CFTC ...................................72

Table 23: Derivatives Clearing Organizations Registered with the CFTC....74

Table 24: Systemically Important DCOs........................................................75

Table 25: Exempt DCOs..................................................................................76

Table 26: Swap Data Repositories Registered with the CFTC ......................77

Figure 20: Number of Types of Swaps Data Loaded onto CFTC Systems.... 78
FY 2018 Budget Request

Executive Summary 1

Executive Summary

The Commission’s mission is 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 Act (CEA). To fulfill these roles, the Commission oversees the Nation’s futures, 

options, and swaps market intermediaries, including designated contract markets (DCMs), SEFs, 

DCOs, FCMs, swap dealers and SDRs. Effective oversight of today’s markets requires a modern 

regulator that can simultaneously foster economic growth and prosperity in the markets, while also 

fulfilling its mission to protect the public from harm. 

The markets overseen by the Commission have a profound effect on the U.S. economy and the prices 

American families pay for food, energy, transportation and most other goods and services. The 

derivative markets provide the vehicle by which the risks of variable production costs, such as the 

price of raw materials, energy, foreign currency and interest rates, can be transferred from those who 

cannot afford them to those that can. The markets play an essential role in pricing risk and 

transferring it in efficient ways. For example, derivatives enable farmers to lock in a price for their 

crops, and utility companies or airlines to hedge the costs of fuel. The derivatives market enables 

banks to increase business lending and economic investment. A wide variety of businesses—such as 

manufacturers, retailers, farmers and ranchers—use these markets to manage routine commercial 

risk. They allow exporters and importers to manage fluctuations in foreign currency exchange rates, 

and businesses of all types to secure their costs of borrowing. They serve the needs of society to help 

moderate price, supply and other commercial risks to free up capital for economic growth, job 

creation and prosperity. 

In order for the Commission to fulfill its responsibilities in FY 2018 to oversee these vital markets, it is 

requesting $281.5 million and 739 FTE. The requested increase of $31.5 million and 36 FTE above the 

FY 2017 CR level represents a deliberate effort to control costs by streamlining operations, and 

making a few targeted investments that will improve the efficiency of the Commission’s regulatory 

functions. Approximately 78 percent, or $24.5 million, of the requested increase supports continued 

advances in market intelligence, econometric and cost-benefit analysis, and allows for dedicated 

resources that will help financial technology innovators navigate regulatory compliance on new 

transformative products that foster efficient and transparent markets. The remaining 22 percent, or 

$7 million, of the requested $31.5 million increase is to sustain current information technology (IT) 

investments that enhance all of the Commission’s functions, such as market intelligence, financial and 

risk surveillance, data collection and analysis, and enforcement. 

The Commission is undergoing efforts to reduce the regulatory burden put in place under the DoddFrank Act framework, by making existing regulations simpler, less burdensome and less costly to 

understand and follow. Through this effort, market integrity, transparency, and better price 

information will come to the marketplace. The Commission plays a vital role in market stability and 

must make sure that the new regulatory framework is working as intended. The requested resources 

allow the Commission to accomplish this, and effectively oversee the markets and protect those that 

participate in them.

Highlights of the 2018 Budget by Mission Function

Enforcement

In FY 2018, the Commission requests $54.7 million and 153 FTE for its enforcement function. 

Preservation of market integrity and protection of customers from harm are the overarching goals of 

the Commission’s enforcement function. A strong enforcement program is vital to maintaining public 

confidence in the financial markets. This is critical to the market participants who depend on the 

futures and swaps marketplace. It is also critical to the retail customers who trust their hard-earned 

dollars to off-exchange firms who promise that great profits will be achieved quickly, only to 
FY 2018 Budget Request

Executive Summary 2

misappropriate the customers’ funds or lose them through trading or exorbitant commissions. The 

illegal, fraudulent off-exchange firms continue to proliferate. 

The Commission’s enforcement efforts are necessary for public confidence and trust in the financial 

markets. The Commission uses its authority to deter fraudulent and manipulative conduct operations 

and ensure that markets, firms and participants subject to the Commission’s oversight meet their 

obligations. The Commission also engages in cooperative enforcement work with domestic, state and 

Federal, and international regulatory and criminal authorities. When required, the Commission 

supports criminal prosecution of provable, willful violations of the CEA. Based on the continued 

growth of innovative products and practices within the industry, the Commission anticipates more 

time-intensive and inherently complex investigations due to algorithmic, high-speed trading. Today, 

analyzing trading patterns requires the ability to handle massive quantities of data, with the resulting 

increased and enhanced need for sophisticated and evolving IT capabilities, and the forensic 

economic capacity. For example, the advent of new, complicated forms of illegal trading requires 

obtaining and reviewing massive quantities of data. This can only be accomplished through 

maintaining the current investment in technology and infrastructure. 

Surveillance

In FY 2018, the Commission requests $52.1 million and 118 FTE for market surveillance, an increase 

of $3.5 million over the FY 2017 CR level. Surveillance over the complex markets and sophisticated 

trading instruments used in the industry today requires a depth of practical industry knowledge in the 

commercial use of the physical, futures and derivative products. The Commission analyzes current 

and emerging derivative market dynamics, developments, and trends to assist in Commission policy 

development, assist other Federal agencies, Congress, the Administration, and the public in making 

informed decisions. The Commission conducts high value-added analysis using proprietary and 

outside data to inform sound policymaking at the Commission and to promote efficient and 

financially sound markets. The Commission monitors trading and positions of market participants on 

an ongoing basis. Staff screen for potential market manipulations and disruptive trading practices, as 

well as trade practice violations. Such market surveillance is critical, and dependent on the ability to 

acquire large volumes of data and to use it through the development of sophisticated analytics to 

identify trends and/or outlying events that warrant further investigation. 

The CFTC monitors over 40 physical commodities, as well as a wide range of financial futures and 

options products based on interest rates, equities, and currencies. There are over 4,000 actively 

traded futures and options contracts. When all tenors and associated options are included, thousands 

more are subject to Commission oversight. Transactions are only part of the surveillance picture, the 

Commission must also be aware of emerging market issues. In today’s high-speed, constantly evolving 

markets, manipulation and fraud are often conducted using complex strategies involving bids and 

offers, which far outnumber consummated transactions.

Examinations

In FY 2018, the Commission requests $27.7 million and 94 FTE for examinations. Regular 

examinations, in concert with the Commission’s surveillance and other functions, are a highly 

effective method to maintain market integrity so that American businesses can rely on these markets. 

This function includes direct examinations performed by the Commission staff and oversight of 

examinations performed by self-regulatory organizations (SROs). The Commission performs an array 

of mission critical examination functions over registered intermediaries that help ensure market 

integrity, protect customer funds, foster transparent business conduct and support firm compliance 

with the CEA and CFTC regulations.

Examinations of DCOs aid the Commission in identifying issues that may affect a DCO’s ability to 

control and monitor its risks. Among the most important examinations that the Commission conducts 

are those of clearinghouses, which, as noted, have become critical single points of risk in the global 

financial system. Furthermore, the number of clearinghouses, the scope and complexity of the 

examination issues and the importance of these examinations to overall financial stability are all 

increasing. The Commission projects the numbers of registered clearinghouses will continue to 
FY 2018 Budget Request

Executive Summary 3

expand in future fiscal years, as it is currently reviewing new applications. Currently, the Commission 

has six registered clearinghouses located overseas, including some that are extremely important to the 

markets given the volume of swaps and futures cleared for U.S. entities. There are also many other 

foreign clearinghouses that are not registered but are permitted to engage in certain types of activity 

in the United States. Although the Commission relies principally on foreign authorities for oversight, 

it does engage in some monitoring and surveillance of such clearinghouses. 

Registration and Compliance

In FY 2018, the Commission requests $15.9 million and 51 FTE for its registration and compliance 

function, an increase of $0.3 million over the FY 2017 CR level. The Commission’s ability to analyze 

registrations in a timely and thorough manner is critical to market efficiency and confidence. 

Intermediary registrants play a vital role in the Nation’s financial system by connecting customers to 

the global market. They include swap dealers, futures commission merchants, commodity pool 

operators, and commodity trading advisors, among others. With over $275 billion in customer funds, 

they serve as a cornerstone of the Commission’s regulatory framework. As such, the Commission 

directs its registration and compliance resources to provide critical policy and regulatory guidance to 

market participants, both directly and in coordination with the National Futures Association (NFA). 

The Commission also uses these resources to ensure that registration rules, standards and reporting 

requirements keep pace with the needs of the evolving marketplace.

The swap regulatory framework resulted in the registration of 23 SEFs and over 100 swap dealers, 

plus four provisionally registered SDRs. In light of the increasing globalization of the markets, the 

Commission also issued Orders of Registration for 15 foreign boards of trade (FBOTs) and 12 pending 

applications. As part of the process, the FBOT and its clearing entity must demonstrate that they are 

subject to comprehensive regulation by the regulatory authorities in their home country that is 

comparable to the manner in which the Commission oversees DCMs and DCOs. The Commission also 

reviews applications for registration or exemption from a number of foreign central counter-parties 

DCOs. The Commission expects additional petitions for exemption from DCO registration 

applications in FY 2018 and beyond. The Commission performs a thorough review of the applications 

of all entities seeking to be registered or designated as a DCM, SEF, FBOT, clearinghouse, or SDR. It 

also oversees the work of the NFA in regard to the registration of swap dealers, major swap 

participants, futures commission merchants, commodity pool operators, and other intermediaries. 

Product Reviews

In FY 2018, The Commission requests $5.4 million and 17 FTE for its product review function an 

increase of $0.8 million over the FY 2017 CR level. The Commission conducts reviews of new contract 

filings to ensure that the contracts are not readily susceptible to manipulation or price distortion, and 

are subject to appropriate position limits or position accountability. For similar reasons, the 

Commission also analyzes amendments to contract terms and conditions. In addition, new and 

existing swaps products that are offering clearing are reviewed to determine whether they should be 

required to be cleared pursuant to a clearing requirement. Proliferation of products by industry, and 

the inherently greater complexity of swaps contracts require the Commission to maintain a steady 

staff to keep pace with industry’s innovations and act in a timely and efficient manner. The

Commission anticipates that in FY 2018 it will adopt speculative position limit rules pertaining to 

certain physical swaps and futures contracts across DCMs and SEFs that are linked to 25 core 

referenced futures contracts. The Commission anticipates leveraging the exchanges as much as 

possible to conserve resources and reduce burdens to market participants.

Economic and Legal

In FY 2018, the Commission requests $34.8 million and 111 FTE for its economic and legal support 

function. The Commission is expanding its core expertise and capacity under this function in order to 

provide appropriate coverage, conduct in-depth studies of economic issues impacting all areas of 

Commission and regulatory interest, and provide support to emerging financial market technologies, 

FinTech, seeking to introduce innovative products in the market. 
FY 2018 Budget Request

Executive Summary 4

The Commission will support FinTech by providing companies with a single point of contact at the 

CFTC to help guide it through regulatory engagement. Commission staff will help entities understand 

the CFTC's regulatory regime as it relates to the company’s proposed activities, and clarify the CFTC's 

regulatory expectations regarding the type of entity or activity that the company will be providing.

The Commission leverages effective inter-agency collaboration on market structure issues, risk 

assessments, regulatory reform impact assessments, and conducts firm, specific analysis of trading 

activity and risk exposures, of proprietary trading firms, banks, hedge funds, asset management 

companies, end-users, as well as engages in economic analysis of swap market structure, including 

execution methods, using SEF audit trail data. With these efforts and improvements in data quality 

and computing capacity, the Commission through its economic capability will be positioned, by FY 

2019, to develop dashboards to measure and monitor risk, conduct robust quantitative analysis of 

impact of regulations on liquidity, volatility, market quality and transaction costs and to collaborate 

with other regulators, domestic and international, on quantitative economic analysis of crossjurisdictional activities. 

The Commission must also have adequate representation in Federal courts and before administrative 

bodies in litigation, including appeals of enforcement actions, challenges to CFTC actions, derivatives 

industry bankruptcies, employment lawsuits and other administrative matters. The Commission’s 

legal resources also provide reviews of proposed rules, as well as staff interpretive and no-action 

letters to ensure consistency and compliance with the requirements of the CEA. 

International Policy

In FY 2018, the Commission requests $5.5 million and 16 FTE for its international support function. 

The futures and swaps market is global in nature. It is, therefore, important that the Commission 

engage foreign regulators and international standards setting bodies in an effective manner to 

promote consistent, high-quality derivatives regulation and develop measures that are intended to 

minimize systemic risk. This request will allow the CFTC to continue current consultation and 

coordination efforts with international authorities, and ensure consistent regulatory requirements for 

U.S. registrants. The budget request reflects the Commission’s continued outreach with authorities 

responsible for the regulation of commodity and derivatives markets in major market jurisdictions, to 

support the adoption, implementation and enforcement of consistent standards in and across 

jurisdictions. 

Data and Technology Support

IT infrastructure is the foundation upon which the Commission’s mission specific systems are built, 

and is the key enabler for delivery of critical systems and services. The markets and participants that 

the Commission regulates generate and report a large quantity of information from multiple industry 

sources across multiple markets. As the Commission’s regulatory regime is changing, it needs to 

ensure that it is able to integrate data into the existing program initiatives, and that existing program 

and processes are able to accept new techniques and technologies. Data management is essential to all 

of Commission’s regulatory initiatives and, in particular, to integrating swaps oversight into existing 

program initiatives. In order to fulfill its mission, the Commission depends heavily on its ability to 

quickly access and analyze large volumes of complex market data. A primary area of focus must be on 

data understanding and ingestion—particularly because CFTC has a unique imperative to aggregate 

various types of data from multiple industry sources across multiple market segments both domestic 

and international.

In FY 2018, the Commission requests $57.0 million for the purchase of IT, which, when fully loaded 

to include personnel costs, totals $86.4 million and 92 FTE. The total IT Portfolio located in 

Appendix 2 provides a full breakout of the $86.4 million.
FY 2018 Budget Request

Overview of the FY 2018 Budget Request 5

Overview of the FY 2018 Budget

FY 2018 Budget Request by Program1 2 3 4 5

Table 1: Summary of FY 2016 to 2018 by Program

FY 2016 FY 2017 FY 2018

Actual

Continuing

Resolution Request Change

$ (000) $ (000) $ (000) $ (000)

Salaries and Expenses $196,656 $197,380 $221,190 $23,810

Office of the Inspector General $2,608 $2,620 $3,310 $690

Information Technology $50,387 $50,000 $57,000 $7,000

Total $249,650 $250,000 $281,500 $31,500

Figure 1: $281.5 Million Budget Request by Program

 

1 FY 2017 Continuing Resolution: Annualized estimates provided by the Continuing Appropriations Act, 2017 (Division C of 

Public Law 114-223), as amended by the Making Further Continuing Appropriations Act, 2017, and For Other Purposes (Public 

Law 115-30). 

2 Salaries and Expenses: The Salaries and Expenses program provides funding for all CEA-related activities. This includes 

funding for Federal staff salaries and benefits, leasing of facilities, travel, training, and general operations of the Commission. 

3 The Office of the Inspector General program provides audits, investigations, reviews, inspections, and other activities to 

evaluate the operations and programs of the Commission.

4 Information Technology: The Information Technology program provides funding for information technology investments. 

This includes hardware, software, contractor support, and other related information technology requirements.

5The Commission considers the Salary and Expenses, Information Technology, and Office of the Inspector General programs to 

be its sole programs, projects, and activities (PPAs). All other budget displays by mission function, division or any other 

depiction are for informational purposes only.

Columns may not add due to rounding
FY 2018 Budget Request

Overview of the FY 2018 Budget Request 6

FY 2018 Budget Request by Mission Function6 7 8

Table 2: Summary of FY 2016 to 2018 by Mission Function

FY 2016 FY 2017 FY 2018

Actual

Continuing

Resolution Request Change

FTE $ (000) FTE $ (000) FTE $ (000) FTE $ (000)

Agency Direction and Management 114 $37,982 111 $34,450 131 $41,664 20 $7,214

Data and Technology Support 49 $41,227 51 $42,298 48 $43,593 (3) $1,295

Economic and Legal Analysis 81 $23,711 82 $24,428 111 $34,851 29 $10,423

Enforcement Activities 160 $50,007 156 $51,299 153 $54,706 (3) $3,407

Examinations 106 $27,865 86 $23,546 94 $27,769 8 $4,223

International Policy 14 $4,366 16 $5,101 16 $5,488 0 $387

Product Reviews 17 $5,089 16 $4,636 17 $5,416 1 $781

Registration and Compliance 48 $13,537 54 $15,635 51 $15,904 (3) $270

Surveillance 126 $45,866 131 $48,606 118 $52,108 (13) $3,501

Total 715 $249,650 703 $250,000 739 $281,500 36 $31,500

Figure 2: $281.5 Million Budget Request by Mission Function

 

6 The Commission considers the Salary and Expenses, Information Technology, and Office of the Inspector General programs 

to be its sole programs, projects, and activities (PPAs). All other budget displays by mission function, division or any other 

depiction are for informational purposes only.

7 Information technology costs, including IT investments (e.g., hardware, software, and contractor services), FTE, and indirect

costs, are directly attributed to the benefiting mission function wherever possible. IT costs that are not directly attributed to 

another mission function are captured in the Data and Technology Support mission function as shown above.

8 All charts containing FTE and funding incorporate realignments as detailed in CFTC notification letter of March 7, 2017.

Columns may not add due to rounding
FY 2018 Budget Request

Overview of the FY 2018 Budget Request 7

FY 2018 Budget Request by Division9 10

Table 3: Summary of FY 2016 to 2018 by Division

FY 2016 FY 2017 FY 2018

Actual

Continuing

Resolution Request Change

FTE $ (000) FTE $ (000) FTE $ (000) FTE $ (000)

Agency Direction 28 $7,443 28 $8,047 33 $9,151 5 $1,104

Agency Management and Support 76 $19,404 74 $18,788 89 $23,977 15 $5,188

Chief Economist 13 $3,833 12 $3,106 27 $7,758 15 $4,652

Clearing and Risk 69 $18,633 70 $19,518 75 $22,630 5 $3,112

Data and Technology 92 $80,177 95 $78,481 92 $86,452 (3) $7,971

Enforcement 163 $47,685 161 $49,515 180 $58,663 19 $9,148

General Counsel 49 $13,964 47 $13,975 53 $16,833 6 $2,857

Inspector General 10 $2,608 9 $2,620 9 $3,310 0 $690

International Affairs 11 $3,491 11 $3,609 11 $3,858 0 $249

Market Oversight 116 $29,455 112 $29,642 88 $25,171 (24) ($4,471)

Swap Dealer and Int. Oversight 88 $22,959 84 $22,699 82 $23,697 (2) $999

Total 715 $249,650 703 $250,000 739 $281,500 36 $31,500

Figure 3: $281.5 Million Budget Request by Division

 

9The Commission considers the Salary and Expenses, Information Technology, and Office of the Inspector General programs to 

be its sole programs, projects, and activities (PPAs). All other budget displays by mission function, division or any other 

depiction are for informational purposes only.

10 All charts containing FTE and funding incorporate realignments as detailed in CFTC notification letter of March 7, 2017.

Columns may not add due to rounding
FY 2018 Budget Request

Overview of the FY 2018 Budget Request 8

FY 2018 Budget Request by Object Class

Table 4: Summary of FY 2016 to 2018 by Object Class

FY 2016 FY 2017 FY 2018

Actual

Continuing

Resolution Request Change

$ (000) $ (000) $ (000) $ (000)

11.0 Personnel Compensation $115,434 $118,755 $132,022 $13,267

12.0 Personnel Benefits $37,661 $35,389 $39,342 $3,954

13.0 Former Personnel Benefits $0 $0 $0 $0

21.0 Travel and Transportation of Persons $1,582 $1,555 $2,197 $642

22.0 Transportation of Things $64 $49 $49 $0

23.2 Rental Payments to Others $16,957 $22,805 $24,106 $1,301

23.3 Communication, Utilities, & Misc. $3,437 $2,645 $2,859 $214

24.0 Printing and Reproduction $686 $620 $619 ($1)

25.0 Other Services $61,336 $56,105 $71,276 $15,170

26.0 Supplies and Materials $2,806 $2,561 $2,578 $17

31.0 Equipment $9,652 $9,501 $6,437 ($3,064)

32.0 Building and Fixed Equipment $34 $15 $15 $0

44.0 Refunds $0 $0 $0 $0

Total $249,650 $250,000 $281,500 $31,500

Figure 4: $281.5 Million Budget Request by Object Class

Columns may not add due to rounding
FY 2018 Budget Request

Overview of the FY 2018 Budget Request 9

Crosswalk from FY 2017 to FY 2018

FY 2017

Estimate

FY 2018

Request Change

Budget Authority ($000) $250,000 $281,500 $31,500

Full-Time Equivalents (FTEs) 703 739 +36

Explanation of Change FTE

Dollars 

($000)

Current Services Increases: (Adjustments to FY 2017 Base)

To provide for changes in personnel compensation & benefits: $8,872

To provide for the following changes in non-personnel costs: $1,515

 --Space Rental/Communications/Utilities ($1,515)

Program Increase: (Adjustments to FY 2018 Current Services) +36 $21,113

 --Addition of 36 FTE ($8,349)

 --Travel/Transportation ($642)

 --Other Services ($12,105)

 --Supplies/Printing ($17)

Total Change +36 $31,500

Table 5: Crosswalk from FY 2017 to FY 2018
FY 2018 Budget Request

Mission Function─Enforcement 10

Justification of the FY 2018 Budget by Mission Function

Enforcement 

Resource Overview 

FY 2016 FY 2017 FY 2018

Actual

Continuing

Resolution Request Change

BUDGET $50,006,789 $51,299,154 $54,705,897 +$3,406,743

FTE 160 156 153 -3

Columns may not add due to rounding

Mission Function Description 

The Commission is responsible for protecting market participants and other members of the public 

from fraud, manipulation and other abusive practices in the futures and swaps markets. The 

Enforcement function conducts investigations and exercises its authority to litigate matters broadly 

categorized into four areas: 1) manipulation, 2) trade practice, 3) fraud, and 4) supervision and 

control. 

Justification of CFTC Request by Function 

Enforcement

The enforcement function is a critical component of the Commission’s mandate to protect both 

customers and the integrity of the markets. The primary pillars of a robust enforcement function are 

the ability to rigorously and thoroughly investigate potential violations of the CEA and Commission

regulations and the effective prosecution of such alleged violations, including the corresponding 

imposition of sanctions for the greatest deterrent effect. 

In FY 2018, the Commission will utilize its enforcement resources to continue preserving market 

integrity and protecting customers from harm through comprehensive and effective investigation and 

prosecution of violations, including:

• Utilizing the Commission’s authority to address fraud and manipulative conduct, false 

reporting of market information, and disruptive trading practices, including spoofing, trade 

practice violations and other misconduct on registered entities;

• Protecting customers who are victims of retail fraud and illegal off-exchange transactions, 

such as fraud by intermediaries (e.g., pool fraud), and fraud and illegal transactions relating 

to foreign currency (forex) and precious metals;

• Enforcing regulatory requirements to ensure that registrants maintain diligent supervision of 

their operations, adhere to their regulatory obligations, and maintain their financial integrity 

by meeting standards for capitalization, segregation and handling of funds;

• Protecting the data integrity of information by enforcing requirements for recordkeeping and 

reporting across derivatives classes;

• Increasing effectiveness and efficiency of enforcement through cooperative enforcement with 

SROs, state, Federal, and international authorities, including achieving efficiencies through 

referrals; and
FY 2018 Budget Request

Mission Function─Enforcement 11

• Continuing to refine and grow effective receipt and processing of tips, complaints, and 

referrals through the litigation, intake and triage unit in coordination with the Whistleblower 

Office (WBO) and effectively and efficiently process those matters that merit investigation.

Data and Technology

CFTC is committed to integrating information management, forensic and data analytics technology 

continues to shape and strengthen its enforcement mission. CFTC will continue to support mission 

critical programs like eLaw and other support services (e.g., case assessment and management, 

document review, eDiscovery, forensics, searching, audio analytics, and data analytics) that have been 

central to the Commission’s ability to meet the challenges of rising case volumes and increasingly 

complex enforcement actions, while simultaneously providing enforcement staff with rapid, efficient, 

time-saving case support that allows greater focus on the actual investigative and litigation work 

required to execute a successful case. 
FY 2018 Budget Request

Mission Function─Enforcement 12

Breakout of Enforcement Request 11 

Table 6: Breakout of Enforcement by Division

Salaries and

Expenses IT Total

FTE ($000) ($000) ($000)

Enforcement 149 $48,892 $0 $48,892

Data and Technology 4 $1,104 $4,710 $5,814

Total 153 $49,996 $4,710 $54,706

Figure 5: Enforcement Request by Division

 

11 The Commission considers the Salary and Expenses, Information Technology, and Office of the Inspector General programs 

to be its sole programs, projects, and activities (PPAs). The budget displays by mission activity are for informational purposes

only, and do not represent a PPA.

Columns may not add due to rounding
FY 2018 Budget Request

Mission Function─Surveillance 13

Surveillance

Resource Overview 

FY 2016 FY 2017 FY 2018

Actual

Continuing

Resolution Request Change

BUDGET $45,866,255 $48,606,257 $52,107,524 +$3,501,267

FTE 126 131 118 -13

Columns may not add due to rounding

Mission Function Description 

The Commission monitors trading and positions of market participants on a daily and ongoing basis. 

Surveillance of complex markets and sophisticated trading instruments requires a depth of practical 

industry knowledge in the commercial use of the physical, futures and derivative products by 

industry. The Commission analyzes, aggregates and monitors diverse market data sources. With that 

information, the Commission evaluates whether markets are operating in an orderly manner and 

whether market participants’ activities within the CFTC jurisdictional markets appropriately inform 

the price discovery process and comply with trading and other legal requirements. The identified 

conduct from surveillance, such as market trading abuses and non-compliance with Commission rules 

and regulations, are subject to further inquiry, and are forwarded to the Division of Enforcement 

(DOE) for review as necessary.

The function also performs market intelligence activities, which will analyze and communicate 

current and emerging derivatives market dynamics, developments, and trends to Commission 

leadership and Commission policy development teams in order to assist them in making informed 

policy decisions. This initiative will also provide information to the public and Congress to assist them 

in making informed decisions. 

Justification of CFTC Request by Function 

Clearing and Risk

Risk surveillance is a technology-intensive function, and in FY 2018, both the quantity and types of 

position data requiring review will increase. To perform these functions the Commission uses 

internally developed applications and commercially available software. The Commission’s ability to 

function effectively and advance this program is dependent upon its ability to process this data. 

The Commission has begun incorporating uncleared positions into its cleared risk surveillance 

program. The Commission is also sharing its evaluation of risk of cleared and uncleared positions 

with many swap dealers and other market participants. This initial phase of inducting additional data 

types, which includes credit default swap and interest rate swap positions, will be expanded to include 

foreign exchange and equity uncleared activity. 

Enhancing CFTC’s financial analysis tools is critical, as the Commission is the only financial regulator,

regardless of jurisdiction, that will be able to aggregate and evaluate risk across all DCOs. Each DCO’s 

view of risk is limited to market participants clearing at that particular organization. Many market 

participants will have positions at multiple clearinghouses in more than one asset class. The 

Commission has adjusted its risk surveillance activities to include the ability to stress test positions in 

swaps for market participants and DCOs. This additional stress testing is currently only for cleared 

positions. 
FY 2018 Budget Request

Mission Function─Surveillance 14

In order to incorporate uncleared positions in the stress testing, the Commission will develop risk 

metrics for these positions. In addition, resources are needed to review new DCO margin models and 

changes to existing margin models. Many DCOs clear the same asset class, but each uses its own 

margin model to calculate margin requirements. In some instances, the requirements for the same 

positions will not be the same at multiple DCOs. The Commission must compare and contrast these 

models in order to analyze differences and to ensure appropriate coverage.

Market Oversight

During FY 2018, as part of refocusing its efforts, the market intelligence initiative is expected to be 

fully established and functioning. As part of this initiative, the Commission will analyze and 

communicate current and emerging derivatives market dynamics, developments, and trends to policy 

development, other Federal agencies, Congress, the Administration to assist the Commission in 

making informed decisions. The Commission will conduct value-added analysis using proprietary 

data and outside data to inform sound policymaking at the Commission and promote efficient and 

financially sound markets. Through this effort, the Commission will develop mutually rewarding 

relationships with its agency partners, market data providers, and the public through education and 

engagement.

Enforcement

The Commission will maintain a robust market surveillance program that develops and utilizes 

sophisticated systems to analyze trade data and respond to outlying events, and to help identify 

trading or positions that warrant further enforcement inquiry.

In general, the Commission will:

• Conduct surveillance in all traded commodity classes on a prioritized basis, and perform 

discrete forensic analysis involving data reported to the Commission to confirm orderly 

operation of the markets and to identify conduct that may give rise to a potential violation of 

the CEA and Commission regulations;

• Evaluate compliance with Federally-imposed position limits, conduct forensic review of 

market activity to identify potential market and trading abuses;

• Coordinate with other Federal regulators such as U.S. Department of Agriculture, U.S. 

Department of Energy, Federal Energy Regulatory Commission, and Environmental 

Protection Agency on market events involving their respective jurisdictions; and

• Communicate with market participants and the exchanges, about market participant trading 

activities based upon aggregate data across markets. 

Data and Technology

Information technology services support data acquisition and analysis that are crucial to conducting 

effective surveillance and oversight of an increasingly diverse electronic marketplace, 

detecting/investigating illegal activities and conducting regulatory oversight of Commission 

registrants. The Commission must keep pace with rapidly changing practices in the financial industry,

such as high-speed trading, evolving swaps trading practices, and the increasingly modernized 

systems. 

In support of the surveillance function, the Commission plans to improve the quality of data ingested 

using a multifaceted approach, including development of detailed data quality, acceptance 

specifications/standards, data validation checks, data quality monitoring and reporting and 

stakeholder outreach efforts.

The Commission plans to maintain and enhance data reporting tools by collecting and presenting 

large trader futures and options end-of-day positions and all related open interest, volume, price, and 

clearing member data from exchanges, intermediaries, and the large traders themselves. In order to 
FY 2018 Budget Request

Mission Function─Surveillance 15

improve the accuracy of data, and the quality of information about market participants, the 

Commission will also continue to receive electronic forms to identify the owners and controllers of 

futures, options, swaps, and options positions in support of the ownership and control reporting rule. 

In the modern marketplace, where automated trading dominates, many manipulation strategies 

cannot be determined by using legacy data already filed with the Commission by market participants 

or available in the market. In light of this need and the continued growth of algorithmic, high-speed 

trading in the marketplace, the Commission will continue to investigate methods of acquiring and 

ingesting message data from regulated commodities exchanges. 

The surveillance function is also dependent on providing reliable, high quality data regarding swaps 

activities to its analysts and investigators. Although work proceeds within the financial industry via 

the SDRs to develop and enhance reporting of the previously unregulated trillion-dollar swaps 

market, the Commission is also working with stakeholders to develop and refine its own ability to 

ingest, process, and analyze swaps data from a variety of sources to improve Commission capabilities.
FY 2018 Budget Request

Mission Function─Surveillance 16

Breakout of Surveillance Request 12 

Table 7: Breakout of Surveillance by Division

Salaries and

Expenses IT Total

FTE ($000) ($000) ($000)

Clearing and Risk 28 $8,484 $0 $8,484

Market Oversight 28 $7,916 $0 $7,916

Enforcement 22 $6,814 $0 $6,814

Data and Technology 40 $11,037 $17,856 $28,893

Total 118 $34,251 $17,856 $52,108

Figure 6: Surveillance Request by Division

 

12 The Commission considers the Salary and Expenses, Information Technology, and Office of the Inspector General programs 

to be its sole programs, projects, and activities (PPAs). The budget displays by mission activity are for informational purposes

only, and do not represent a PPA.

Columns may not add due to rounding
FY 2018 Budget Request

Mission Function─Examinations 17

Examinations

Resource Overview 

FY 2016 FY 2017 FY 2018

Actual

Continuing

Resolution Request Change

BUDGET $27,865,037 $23,546,008 $27,769,060 +$4,223,053

FTE 106 86 94 +8

Columns may not add due to rounding

Mission Function Description 

Examinations are formal, structured reviews of regulated entities’ operations, cybersecurity, or 

enforcement programs to assess ongoing compliance with statutory and regulatory mandates. Regular 

examinations, in concert with the Commission’s surveillance and other activities, are a highly effective 

method for ensuring that entities are complying with the CEA and Commission’s regulations. This 

mission function covers both direct examinations performed by Commission staff and oversight of the 

examinations conducted by designated SROs. The CEA requires annual examinations of DCOs that 

are designated as systemically important by the Financial Stability Oversight Board and these 

examinations are to be performed by the Supervisory Agency. The CFTC is the Supervisory Agency for 

the Chicago Mercantile Exchange (CME) and ICE Clear Credit. It also requires the CFTC to consult 

with the Board of Governors of the Federal Reserve System regarding the scope and methodology of 

each examination. The Commission also believes that LCH Ltd and ICE Clear Europe are DCOs that 

play an important function in the clearing of the U.S. derivatives and swaps markets and the 

Commission attempts to examine at least one of these DCOs on an annual basis. The CEA requires 

examinations of market structures such as DCMs, DCOs, SEFs, and SDRs.

Justification of CFTC Request by Function 

Swap Dealer and Intermediary Oversight

The Commission performs an array of mission-critical examination functions regarding registered 

intermediaries that help ensure market integrity, protect customer funds, foster transparent business 

conduct and support firm compliance with the CEA and Commission regulations.13 

Key missions funded through this function include:

• The Commission’s mission of ensuring open, transparent, and financially sound markets and 

protecting market users and the public forms is the cornerstone for the examinations 

function. Examinations employ CFTC-approved policies, regulations, and procedures to 

assess principal compliance areas including business conduct, capital, margin and 

segregation, and risk management. In order to exercise the Commission’s regulatory 

responsibilities across the thousands of registered intermediaries operating in today’s 

markets, the CFTC has delegated routine direct examination functions to designated SROs. 

The CFTC is responsible for overseeing SRO regulatory activities, and ensures and validates 

regulatory compliance. The CFTC also assists with legal interpretations, guidance and policy 

support to address new regulations or emerging issues. 

 

13 Examples of futures market intermediaries include futures commission merchants, commodity pool operators, introducing 

brokers, commodity trading advisors, swap dealers, etc.
FY 2018 Budget Request

Mission Function─Examinations 18

• The Commission also conducts its own review activities. The CFTC supports the needs of 

policy makers and/or stakeholders through horizontal reviews of key issues. For example, the 

Commission is working with the other financial regulatory authorities to determine which 

entities the CFTC has primary responsibility for that are part of banking organizations and

subject to the Volcker Rule, and thereby subject to direct examination. Certain banking 

affiliates are simultaneously registered as multiple types of intermediaries, such as FCMs, 

swap dealers, and/or broker-dealers. These dual registrations can make the entity subject to 

oversight from multiple financial regulators. In such cases, the CFTC works with other 

agencies to determine which registrants are within CFTC’s scope as primary regulator, and 

therefore subject to direct examination. Furthermore, during times of crisis, examinations 

staff must respond quickly to assess risks to customer assets, validate firm compliance with 

Commission regulations and rapidly develop mitigation solutions.

• The Commission regularly monitors registrants to identify both signs of individual firm noncompliance overall trends within the market or market sectors that warrant further review. 

These monitoring activities are especially important during major market events or periods of 

heightened uncertainty, such as the immediate aftermath of the “Brexit” decision in June 

2016. In such cases, the CFTC may pivot to direct engagement with the SROs or firms as 

appropriate to gather additional information or proactively address issues. 

• The Commission’s day-to-day monitoring operations utilize audit software tools and 

analytical techniques to monitor and oversee the activities of registrants, as well as regulatory 

notices filed with the Commission. In FY 2018, the Commission will continue efforts to 

integrate data software tools and sources to include additional financial and business data 

points from a variety of sources to enhance the effectiveness of its reviews.

Clearing and Risk

The Commission projects the number of DCOs to continue to expand in FY 2018, as it is currently 

reviewing new applications. This illustrates that new market participants continue to enter the 

marketplace and clear new business. The Commission has recognized this requirement and is 

positioning additional resources to support the increase. As the number of DCOs increase, the 

number of quarterly financial resource reports and certified financial statements and the potential 

number of required examinations increase oversight responsibilities. As the number of DCOs 

increases, so too will the complexity of the counterparty risk management oversight program and 

liquidity risk management procedures of the DCOs. The Commission’s examination function also 

examines DCOs’ compliance with emerging risks in information security and complex system 

safeguard requirements. 

Examinations of DCOs’ compliance with the core principles and implementing regulations will 

necessitate use of new automated tools to assist in the evaluation of compliance with the regulations. 

This is especially important in the areas of evaluating compliance in backtesting and stress testing. 

Many of the DCOs are expanding their registration in other jurisdictions around the world. Those 

jurisdictions look to the Commission to provide insight regarding the effectiveness of the programs 

implemented by the DCOs. The Commission supports the expanding market participant registrations 

through information sharing and compliance discussions in the areas of cybersecurity, liquidity risk 

management, default management and high profile risk management issues.

Market Oversight

The Commission conducts critical examinations of market operators and trade repositories to foster 

open, transparent, fair, competitive, and secure markets. To do so, the Commission conducts formal 

structured reviews of DCMs, SEFs, and SDRs’ operations and oversight procedures to review whether 

these registered entities are complying with the core principles established in the CEA and published 

regulations. In the face of extensive change and cyberattacks on the markets, the Commission 

provides robust oversight and system safeguards review over DCMs, SEFs, and SDRs to foster market 

integrity and security. 
FY 2018 Budget Request

Mission Function─Examinations 19

Additionally, swaps and futures data maintained by entities and available to regulators provides for 

systemic risk mitigation, transparency, and market supervision oversight. The Commission must 

ensure the accuracy and reliability of such data in order to carry out its mission. The Commission 

must also invest in automating procedures and data to integrate its various functions, such as market 

and trade practice surveillance, financial and risk surveillance, examinations, and enforcement 

activities that will allow the Commission to create reusable data sources, improve workflow, increase 

information sharing and increase the ability of staff to correlate data and events. 

Data and Technology

Through information technology, the Commission provides critical audit management and analytical 

tools to review and monitor entity financial data and otherwise support its examination mission for 

exchanges, DCOs, market intermediaries and SROs. The Commission will continue to provide these 

time saving tools and associated review capabilities to allow staff to receive and review financial 

statements and annual reports from a wide range of firms the Commission oversees—FCMs, dually

registered FCM/broker dealers, retail foreign exchange dealers, swap dealers and DCOs. These 

statements and reports provide detailed financial information so that staff can assess the overall 

financial health of these firms. The Commission will also continue to provide tools to enable staff to 

import and evaluate registrant collateral information in order to monitor and assess risk within these 

portfolios and further strengthen situational awareness. 
FY 2018 Budget Request

Mission Function─Examinations 20

Breakout of Examinations Request 14 

Table 8: Breakout of Examinations by Division

Salaries and

Expenses IT Total

FTE ($000) ($000) ($000)

Swap Dealer and Intermediary Oversight 46 $13,288 $0 $13,288

Clearing and Risk 24 $7,164 $0 $7,164

Market Oversight 24 $7,079 $0 $7,079

Data and Technology 0 $0 $238 $238

Total 94 $27,531 $238 $27,769

Figure 7: Examinations Request by Division 

 

14 The Commission considers the Salary and Expenses, Information Technology, and Office of the Inspector General programs 

to be its sole programs, projects, and activities (PPAs). The budget displays by mission activity are for informational purposes

only, and do not represent a PPA.

Columns may not add due to rounding
FY 2018 Budget Request

Mission Function─Registration and Compliance 21

Registration and Compliance

Resource Overview 

FY 2016 FY 2017 FY 2018

Actual

Continuing

Resolution Request Change

BUDGET $13,536,785 $15,634,892 $15,904,404 +$269,512

FTE 48 54 51 -3

Columns may not add due to rounding

Mission Function Description 

The Commission reviews the applications of all entities seeking to be designated as DCMs, and 

registered as DCOs, SEFs and SDRs and FBOTs. Review teams comprised of attorneys, industry 

economists, trade practice analysts and risk analysts ensure that the Commission undertakes a 

thorough analysis of such applications to assess compliance with the applicable statutory core 

principles and Commission regulations. Important to the application process is a site visit to the 

applicant, enabling Commission staff to evaluate fully the operational and managerial resources that 

will support regulatory compliance once the applicant is registered. For swap dealers, major swap 

participants, FCMs, and other intermediaries, where registration responsibility has been delegated to 

the NFA, an SRO, the Commission provides registration regulatory guidance to the NFA and to 

provisional registrants. 

Justification of CFTC Request by Function 

Swap Dealer and Intermediary Oversight

The CFTC’s intermediary registrants play a vital role in the Nation’s financial system by connecting 

customers to the global market. They include swap dealers, FCMs, commodity pool operators, and 

commodity trading advisors, among others. With over $275 billion in customer funds, they serve as a 

cornerstone of the Commission’s regulatory framework. As such, the Commission directs its 

registration and compliance resources to provide critical policy and regulatory guidance to market 

participants, both directly and in coordination with the NFA. The Commission also uses these 

resources to ensure that registration rules, standards and reporting requirements keep pace with the 

needs of the evolving marketplace.

Core functions funded through this function include: 

• The Commission drafts new rules and rule amendments to strengthen its registration and 

compliance regime and, following CFTC approval, oversees effective rule implementation. 

Throughout this process, registrants engage CFTC staff to obtain interpretive guidance, seek 

no action relief for registration purposes, and/or discuss compliance matters requiring 

Commission guidance. 

• The Commission provides answers to other Federal and state agencies, CFTC registrants, and 

to the public at large with respect to intermediary issues. These answers involve an array of 

activities, from responding to inquiries from market participants and registrants to briefing 

policymakers on major registration/compliance issues.

• The Commission provides direct support to the international regulatory community to 

establish agreements on substituted compliance matters central to overseeing the global 

activities of the derivatives industry, implementing key aspects of legislative mandates, and 

other high priority initiatives. 
FY 2018 Budget Request

Mission Function─Registration and Compliance 22

• The Commission provides critical guidance to the SROs to support execution of the 

Commission’s regulatory framework and to oversee delegated regulatory activities. 

Market Oversight

In order to operate in Commission-regulated markets, an entity must submit an application to be 

designated or registered as a DCM, SEF, or SDR. The Commission reviews the applications and 

operations of these entities to ensure that they will comply with the CEA and Commission regulations 

upon designation or registration. 

Currently, 24 SEFs are fully registered and the Commission is analyzing one additional SEF 

application for registration. The Commission has five DCM applications before it for analysis and 

review. Currently, the Commission has provisionally registered four SDRs. As the swap data 

reporting rules and market infrastructure evolve, the Commission will review these entities for 

permanent registration.

The Commission also reviews rule filings from DCMs, SEFs, and SDRs to ensure that they are 

consistent with the CEA and Commission regulations. In FY 2016, DCMs, SEFs, and SDRs submitted 

almost 900 rule filings. At present, the Commission has received 473 rule certification filings (414 

DCMs, 54 SEFs, 5 SDRs). Per the CEA, the Commission must review these filings in a timely manner, 

which is usually 10 business days. The Commission will continue this effort and projects that the 

number of certifications will increase in FY 2018.

This function also reviews applications for FBOT registrations. The Commission has adopted a 

registration requirement for FBOTs that desire to make their electronic order and trade matching 

systems available to members and other participants located in the United States through direct 

access for the trading of futures, options, and swaps contracts. The Commission will continue this 

effort and currently has 12 pending applications for FBOT registration under review. To date, the 

Commission has issued Orders of registration to 15 FBOTs. 

Clearing and Risk

The FY 2018 request will continue to support the Commission’s registration and compliance activities 

for DCOs. The Commission will devote effort to completing the review of pending applications for 

DCO registration, as well as commencing review of new applications. The Commission also expects to 

be reviewing petitions for exemption from DCO registration for the clearing of swaps. These activities,

in addition to oversight of registered DCOs, will continue to require regulatory coordination on both a 

domestic and cross-border basis. As additional DCOs are registered or exempted over the course of FY 

2018, these coordinated efforts will necessarily increase concurrently.

The CFTC performs periodic reviews of registered DCOs to ensure compliance with the CEA’s 

statutory requirements and the Commission’s implementing regulations. 

In addition, the CFTC oversees DCOs on a day-to-day basis, which includes review of their rules, 

operations, and procedures. The CFTC also reviews daily, quarterly, annual and event-specific reports 

to ensure compliance with its regulations, including financial and risk management regulations.

Data and Technology

Information technology will continue to support this function through maintenance of the CFTC 

Portal, which is an application, shared between the registration and compliance and the product 

review functions. This application serves an important role in the day-to-day operations of the 

examination function and provides the interface for industry filings with the Commission. Through 

the CFTC Portal, participants file submissions electronically directly with the Commission, which are 

then automatically routed to the proper systems and staff. This significantly reduces the need for 

manual transcription or hard copies.

Information technology will also continue to support the Commission’s Commission and Staff Letters 

(CSL) application, which captures, manages, reports, and publishes No-Action, Exemption, and 
FY 2018 Budget Request

Mission Function─Registration and Compliance 23

Interpretation actions initiated by both the Commission and by external registered and nonregistered entities. CSL allows the Commission to track all “actions” and prepare appropriate 

responses to requests in a timely manner.
FY 2018 Budget Request

Mission Function─Registration and Compliance 24

Breakout of Registration and Compliance Request 

15 

Table 9: Breakout of Registration and Compliance by Division

Salaries and

Expenses IT Total

FTE ($000) ($000) ($000)

Swap Dealer and Intermediary Oversight 23 $6,646 $0 $6,646

Market Oversight 16 $4,521 $0 $4,521

Clearing and Risk 12 $3,537 $0 $3,537

Data and Technology 0 $0 $1,200 $1,200

Total 51 $14,704 $1,200 $15,904

Figure 8: Registration and Compliance Request by Division

 

15 The Commission considers the Salary and Expenses, Information Technology, and Office of the Inspector General programs 

to be its sole programs, projects, and activities (PPAs). The budget displays by mission activity are for informational purposes

only, and do not represent a PPA.

Columns may not add due to rounding
FY 2018 Budget Request

Mission Function─Product Reviews 25

Product Reviews

Resource Overview 

FY 2016 FY 2017 FY 2018

Actual

Continuing

Resolution Request Change

BUDGET $5,089,058 $4,635,580 $5,416,148 +$780,568

FTE 17 16 17 +1

Columns may not add due to rounding

Mission Function Description 

The Commission reviews new product filings made by exchanges to comply with the requirements of 

the CEA and Commission rules. The CFTC’s scope of work includes reviewing new futures, options 

and swap contract filings, reviewing contract amendment submissions, reviewing foreign stock index 

futures, and developing new rules and policies to accommodate innovations in the industry. The 

Commission primarily focuses on verifying that derivatives contracts are not readily susceptible to 

manipulation or other price distortions, and that contracts are subject to appropriate position limits 

or position accountability standards. The Commission also evaluates transaction and pricing data 

collected by SDRs to determine appropriate block trade and large notional swap threshold levels that 

registered SEFs, DCMs, and market participants may use to delay public reporting of swap 

transaction data. The Commission evaluates market data and contract characteristics to determine 

whether a swap contract should be subject to mandatory clearing and whether it is listed on a DCM or 

SEF and has been “made available to trade.” Additionally, the Commission reviews whether these new 

products are suitable for clearing by DCOs and, with respect to swap contracts, whether they should 

be mandated for clearing.

Justification of CFTC Request by Function 

Market Oversight

The Commission reviews new futures, options, and swaps contract filings by DCMs and SEFs 

primarily to verify that the contracts are not readily susceptible to manipulation and other price 

distortions, and that they are subject to appropriate position limits or position accountability 

standards as required by the CEA and Commission regulations. During FY 2016, the Commission 

received 461 new product filings from these registrants. The Commission reviewed 525 DCM product 

filings during this period, many of which were for products filed in previous years. At present, the 

Commission has received 251 product filings—169 from DCMs and 82 from SEFs—and has completed 

39 reviews. The Commission is decreasing its backlog of reviews through a concentrated effort. The 

proliferation of greater numbers of products by industry participants, and the inherently greater 

complexity of swap contracts, requires the Commission to keep pace with industry’s innovations. In 

addition, the Commission completed reviews of 179 rule amendments to contract terms and

conditions submitted by DCMs. 
FY 2018 Budget Request

Mission Function─Product Reviews 26

To illustrate, over the past seven fiscal years, DCMs and SEFs submitted to the Commission the 

following number of contract filings:

Fiscal Year Derivative Clearing 

Organizations

Swap Execution 

Facilities

FY 2010 700 0

FY 2011 1,718 0

FY 2012 894 0

FY 2013 428 359

FY 2014 423 664

FY 2015 607 254

FY 2016 426 35

The Commission conducts an initial review of each submission to ascertain whether the contract 

conditions or features comply with the CEA core principle and Commission rules. When trading 

volume and open interest build to specified levels, the Commission conducts a more comprehensive 

review to ensure that the contracts continue to comply with the requirements of the CEA and 

Commission rules. The Commission adopted this review level criterion because staffing levels could 

not keep pace with the number of new contract filings. This criterion also allows the Commission to 

avoid committing staff resources to reviewing contracts have little or no trading activity. The 

Commission reviews contracts that do not appear to be functioning effectively. 

The Commission also conducts broad studies of cash markets for physical commodities to ascertain 

the current state of cash market practices as they relate to derivatives contracts. The Commission uses 

such studies to expedite the review of newly listed contracts and to support other areas of the 

Commission that rely on information regarding the nature of the underlying cash markets.

As noted above, the Commission reviews the terms and conditions of contracts when a DCM or SEF 

files them. The Commission is working to develop procedures to identify contracts that may require 

updated reviews of their terms and conditions after initial submission to the Commission. This would 

assist the Commission in determining when the terms and conditions of a contract fail to keep up with 

changes in the underlying cash market, potentially increasing the risk of manipulation.

Through FY 2017 and into FY 2018, the Commission will continue to review position limit rules 

pertaining to certain physical swaps and futures contracts across DCMs and SEFs that are linked to 25

core referenced futures contracts. Based on industry and participant feedback, the Commission will 

develop an approach to adopting position limits that will leverage the exchanges as much as possible 

to conserve resources and reduce burdens to market participants.

Clearing and Risk

All registered and exempt DCOs are required to submit all swaps that they offer for clearing to the 

Commission for consideration as swaps that must be cleared. 

The Commission promulgated the first rules associated with the required clearing of swaps, in 

December 2012, and it expanded the interest rate swap clearing requirement, in September 2016. The 

Commission anticipates that it will conduct ongoing product reviews, during FY 2018 and beyond, as 

new swaps and other contracts are created in response to changing market needs.

Relying on new data from DCOs, SDRs, SEFs, and other market infrastructure and participants, the 

Commission will continue to analyze, by asset class, the percentage and volume of cleared and 
FY 2018 Budget Request

Mission Function─Product Reviews 27

uncleared swaps, the level of risk transfer among market participants, the market dynamics with 

respect to new products, and the implied overall credit and market risk, in FY 2018. This ensures that 

the Commission’s regulations reflect an appropriate understanding of the market segments most 

prone to market failure. The Commission also will review data to monitor market participants, 

including swap dealers, for compliance with the clearing requirement and its exceptions and 

exemptions. 
FY 2018 Budget Request

Mission Function─Product Reviews 28

Breakout of Product Reviews Request 16 

Table 10: Breakout of Product Reviews by Division

Salaries and

Expenses IT Total

FTE ($000) ($000) ($000)

Market Oversight 13 $3,675 $0 $3,675

Clearing and Risk 4 $1,341 $0 $1,341

Data and Technology 0 $0 $400 $400

Total 17 $5,016 $400 $5,416

Figure 9: Product Reviews Request by Division

 

16 The Commission considers the Salary and Expenses, Information Technology, and Office of Inspector General programs to be 

its sole programs, projects, and activities (PPAs). The budget displays by mission activity are for informational purposes only, 

and do not represent a PPA.

Columns may not add due to rounding
FY 2018 Budget Request

Mission Function─Economic and Legal Analysis 29

Economic and Legal Analysis

Resource Overview 

FY 2016 FY 2017 FY 2018

Actual

Continuing

Resolution Request Change

BUDGET $23,710,719 $24,428,228 $34,851,381 +$10,423,153

FTE 81 82 111 +29

Columns may not add due to rounding

Mission Function Description 

Economic analysis activities are critical to supporting the regulatory activities in a wide range of areas, 

including: 1) economic and quantitative analysis, including cost-benefit considerations utilized in 

designing and implementing the Commission’s rulemaking; 2) developing analytical tools and 

methods in support of the Commission’s automated surveillance initiatives; 3) providing the technical 

expertise to evaluate and report on risk models, stress tests, and other stability-related evaluations 

necessary for oversight; 4) developing analytical tools and methods in support of the Commission’s 

enforcement activities, including economic and statistical analysis or expert testimony to promote 

compliance with and deter violations of the CEA; and 5) economic analysis and research to inform the 

Commission, staff and the public of activities in the derivatives and related markets, including 

periodic reports on futures and swaps markets and risk transfer though these markets. Legal activities 

of the Commission include: 1) regulatory issues; 2) engaging in defensive, appellate, and amicus 

curiae litigation; 3) providing general legal advice and support; 4) assisting the Commission in the 

performance of its adjudicatory functions; and 5) providing advice on legislative and other 

intergovernmental affairs issues. 

Justification of CFTC Request by Function 

General Counsel

This function ensures consistency in the interpretation and application of the CEA. Review of 

proposed and final rules, enforcement and regulatory actions, and various forms of staff action are 

conducted within this area for legal sufficiency and administrative regularity. The Commission 

interprets and applies the requirements of a variety of government-wide statutes, such as, but not 

limited to, the Federal Advisory Committee Act, the Federal Information Security Management Act

(FOIA), the Freedom of Information Act and the Administrative Procedure Act. As a Federal entity, 

the Commission must assure the legal sufficiency of Commission actions concerning personnel laws, 

procurement laws and regulations, Federal records requirements, and other applicable laws as 

applied. The Commission also ensures it has proper representation when required to appear in the 

U.S. Courts of Appeals, U.S. District Courts and other administrative proceedings in appeals 

stemming from enforcement actions and other matters including regulatory challenges, bankruptcy, 

personnel litigation, labor disputes, and FOIA. 

In FY 2018, the Commission also plans to increase staffing and resources to address FinTech. FinTech 

comprises a range of financial technology in the financial services sector and includes technological 

innovations in retail banking, investment and crypto-currencies like bitcoin. Through FinTech, the 

Commission will look to address three fundamental issues arising from this transformational change: 

1) how the CFTC should leverage FinTech innovation to make it a more effective regulator, 2) how 

FinTech can help the CFTC identify rules and regulations that need to be updated for relevance in 

digital markets, and 3) the role of the Commission in supporting U.S. FinTech innovation in CFTC 

regulated markets. 
FY 2018 Budget Request

Mission Function─Economic and Legal Analysis 30

Specifically, the Commission will support innovation within markets by providing companies with a 

single point of contact to help guide it through regulatory engagement. Commission staff will 

primarily help entities understand the CFTC's regulatory regime as it relates to the company’s 

proposed activities, and clarify the CFTC's regulatory expectations regarding the type of entity or 

activity that the company would be providing. In addition, the Commission will leverage FinTech 

innovation to make the CFTC a more effective and efficient regulator. The Commission will also 

strengthen its cooperation with other authorities, domestic and international, to support FinTech 

innovation. CFTC will build upon its relationships with domestic and international authorities to 

develop the legal and operating model, and ensure best practices are implemented. 

Chief Economist

The Commission provides economic analyses and research in support of its rulemaking and policy 

development. The Commission conducts research on various issues of significance to the 

Commission, both to improve publicly available information and to establish a sound empirical basis 

for decision-making. Publicly available research products produced by the Commission includes onetime and recurring reports on activity, liquidity, price discovery, risk, and other market structure 

issues in futures and swaps markets. This request will allow the Commission to develop its economic 

modeling and econometric capabilities to execute high-quality economic studies that span futures 

markets and both the cleared and uncleared swaps space. The Commission will also conduct 

econometric analysis of critical issues pertaining to DCOs, FCMs and swap dealers/major swap 

participants.

This request also focuses on expanding the economic analysis expertise and capacity of the 

Commission in order to provide appropriate coverage across areas of Commission interest—markets, 

participants, products, DCMs, SEFs, intermediaries, DCOs. At the requested level, the Commission

expects to conduct data-driven studies of futures and swaps markets in order to inform the 

Commission and the public on a variety of topics, such as descriptive studies of derivatives markets, 

economic assessments of their functioning, analyses of the potential effects of policy choices, risk 

assessments pertaining to liquidity, financial stability and CCPs, etc. 

The Commission will continue to support work developing the analytical capability to integrate 

activity across multiple markets, between cleared and uncleared swaps, among the different 

categories of market participants, and a holistic view of the life cycle of the derivative contract and its 

risk from trade to settlement. In particular, the request will support the work required to incorporate 

data on uncleared swaps into the analytical framework. By definition, these non-standardized swaps 

tend to include the most unique derivatives instruments that require more attention and resources 

than standardized swaps in order to characterize the data and transactions accurately. During the last 

crises, many of the problems manifested in these swaps; additional funding requested will help the 

Commission develop strong analytical capabilities to continue monitoring activity in these markets 

for systemic risk build-up. Large numbers of end-users also actively rely on these markets to hedge 

their complex risk exposures, and the Commission is focused on monitoring them for their ability to 

continue meeting the critical liquidity and hedging needs.

Swap Dealer and Intermediary Oversight

The function supports required legal activity in the swap dealer and intermediary oversight programs 

to include the following: 

• Providing draft rulemakings, interpretations, and opinions on questions of statutory and 

regulatory authority relevant to market intermediaries and legal advice for substantive 

Commission actions relevant to intermediaries, including registration and futures association 

rule submission reviews, regulations, and exemptions; 

• Drafting and administering the applicable capital, margin, segregation and financial reporting 

requirements for market intermediaries and swap dealers and major swap participants, to 

include drafting related rulemakings, no-action letters, interpretations and exemptions; 

• Responding to informal requests for guidance from market participants and the public; and
FY 2018 Budget Request

Mission Function─Economic and Legal Analysis 31

• Coordinating capital, margin, and financial reporting requirements with the U.S. Securities 

and Exchange Commission (SEC) and Prudential Regulators regarding swap dealers and 

major swap participants.

Market Oversight

The Commission develops, interprets, and applies rulemakings and other legal requirements on a 

variety of government-wide statutes to ensure the efficient and effective functioning of the derivatives 

markets. 

Under management, reform and efficiency efforts, the Commission intends to continue a holistic 

review to repurpose rules to ensure that they: 1) keep pace with the rapidly changing digital 

transformation of markets; 2) allow for innovation; 3) unburden the U.S. economy; and 4) promote 

healthy and vibrant markets. In addition, the Commission anticipates reviewing and streamlining 

existing and proposed rules on SEF regulations, proposed position limits regulations for swap data 

reporting and SDR obligations, proposed automated trading regulations, and existing ownership and 

control reporting regulations. 

The Commission will continue to respond to market operators and market participants regarding 

regulatory interpretations and issues. The Commission staff also drafts no-action relief letters, 

guidance documents, interpretative letters, exemptive letters, and other written communications to 

clarify requirements or provide relief to market operators or industry participants.

Clearing and Risk

The FY 2018 request for resources will allow the Commission to remain focused on ensuring 

regulations and standards governing DCOs appropriately minimize systemic risk, promote rigorous 

risk management, avoid duplicative and conflicting regulation of DCOs and market participants, and 

prevent gaps in regulation. Additionally, this allows simultaneous support of registration and 

continuing compliance oversight concerning the intersection of clearing, settlement, margining and 

bankruptcy.

Enforcement

The Commission utilizes forensic economists to performance complex and extensive data analysis to 

develop evidence for investigations into potential market manipulation, disruptive trading practices 

(including spoofing) and other unlawful trade-based conduct. This analytical evidence is used to 

determine the nature and scope of the trading or activity at issue and informs the Commission’s

determination of whether to recommend an enforcement action and the scope and potential 

resolution of any recommended enforcement action. In FY 2018, the Commission will utilize its 

economic forensic analysis resources to keep pace with the enforcement program’s increasing demand 

for, and complexity of, investigative analysis, which has been affected by:

• The rapid innovation and increasing complexity of financial markets, which necessitates the 

collection and analysis of vast amounts of data including fundamental economic data, 

transaction data, position data and order book data; and

• The proliferation of algorithmic and high-speed trading, the use of price benchmarks in 

financial transactions, and the use of economically equivalent or similar instruments in 

futures, options, swaps, and cash markets.

Data and Technology

The FY 2018 request will resource current IT service components for this function such as, services 

for economic and data analysis, litigation, legal research and discovery, ethics and records 

management. Additionally, maintenance costs for data analytics tools and actual data acquisition 

used to perform economic analysis are provided within this category. 
FY 2018 Budget Request

Mission Function─Economic and Legal Analysis 32

Breakout of Economic and Legal Analysis Request 17 

Table 11: Breakout of Economic and Legal Analysis by Division

Salaries and

Expenses IT Total

FTE ($000) ($000) ($000)

General Counsel 53 $16,833 $0 $16,833

Chief Economist 27 $7,758 $0 $7,758

Swap Dealer and Intermediary Oversight 13 $3,763 $0 $3,763

Market Oversight 7 $1,979 $0 $1,979

Clearing and Risk 5 $1,477 $0 $1,477

Enforcement 6 $1,979 $0 $1,979

Data and Technology 0 $0 $1,062 $1,062

Total 111 $33,790 $1,062 $34,851

Figure 10: Economic and Legal Analysis Request by Division

 

17 The Commission considers the Salary and Expenses, Information Technology, and Office of Inspector General programs to be 

its sole programs, projects, and activities (PPAs). The budget displays by mission activity are for informational purposes only, 

and do not represent a PPA.

Columns may not add due to rounding
FY 2018 Budget Request

 

Mission Function―International Policy 33

International Policy

Resource Overview 

FY 2016 FY 2017 FY 2018

Actual

Continuing

Resolution Request Change

BUDGET $4,366,473 $5,101,290 $5,488,302 +$387,012

FTE 14 16 16 +0

Columns may not add due to rounding

Mission Function Description 

The global nature of the futures and swaps markets makes it imperative that the United States consult 

and coordinate with international authorities. The Commission is actively engaged internationally to 

avoid conflicting requirements and to enhance in international cooperative efforts wherever possible. 

For example, the Commission has engaged in bilateral discussions regarding draft rule proposals or 

amendments to rules with international regulators and authorities, including the European 

Commission, the European Central Bank, the Bank of England, the European Securities and Markets 

Authority, and the Japanese Financial Services Agency. 

The Commission participates in numerous international working groups regarding derivatives, 

including numerous International Organization of Securities Commissions (IOSCO) committees and 

task forces, as well as projects with the Basel Committee on Banking Supervision, the Committee on 

Payments and Market Infrastructures, and the Financial Stability Board (FSB). Over the past four 

years, the CFTC, SEC, European Commission, European Securities Market Authority, and market 

regulators from around the globe have been meeting to discuss and resolve issues related to financial 

reform through various technical working groups. 

Justification of CFTC Request by Function 

International Affairs

The global nature of the futures and swaps markets make it imperative that the Commission engage 

foreign regulators and participate in meetings and discussions to enhance international cooperation 

and to support the adoption, implementation, and enforcement of high-quality derivatives regulation. 

The FY 2018 request will allow the CFTC: 1) to advance the interests of the CFTC in bilateral and 

multilateral discussions with foreign regulatory counterparts and in international fora; 2) to facilitate 

information-sharing, cooperation and cross-border assistance; and 3) to ensure international work

streams are consistent with the rules and policies of the CFTC. 

The CFTC will increase its efforts to work toward consistent trading platforms rules with those of 

Europe. The CFTC will continue to work with European Union (EU) authorities to minimize 

differences, to the extent necessary, between EU trading venues and U.S. SEFs and DCMs in order to 

encourage action on relevant EU equivalence determinations and to address trading platform 

equivalence initiatives prior to the effective date of the EU regime, in FY 2018. The exit of the United 

Kingdom (UK) from the EU will require the Commission to maintain and expand its engagement with 

both the UK and EU if necessary to respond to changing regulatory requirements that might affect

existing agreements and regulatory arrangements with the Commission. 

The Commission will continue its active engagement with foreign regulators to work toward 

consistent regulatory requirements imposed on DCOs. The importance of central clearing to the 

derivatives markets makes it critical that the Commission ensures the strength and resiliency of 

clearinghouses. 
FY 2018 Budget Request

 

Mission Function―International Policy 34

The Commission anticipates continuing engagement with the FSB and its working groups and 

committees that directly affect the Commission regulatory regime. In addition, the Commission will 

continue to participate in an international study group created, to identify, quantify and analyze 

interdependencies between central counterparties, major clearing members, and other significant 

participants in the financial system. 

The CFTC will remain actively engaged as a member of the Board of the IOSCO and take leadership 

roles within important policy committees and task forces that develop standards and policy guidance 

for the derivatives markets. The Commission will continue to participate in financial regulatory 

dialogues with Europe, Singapore, Australia, China, India, Canada and Mexico. 

The Commission will continue its work with the Financial Stability Oversight Council’s Designations 

Committee to monitor both designated financial market infrastructures (for continued systemic 

importance) and non-designated financial market utilities (to consider them for designation). 

This function also includes resources that support the Commission’s interaction with our foreign 

counterparts under the international regulator’s meetings and consultations fund.

Clearing and Risk

Commission staff will continue to support participation in the international bodies setting standards 

for central counterparties. The additional investment will enable greater participation by Commission 

staff in these key international groups. Commission staff actively participate in, and in some cases 

lead, international groups such as Committee on Payments and Market Infrastructures (CPMI)-

IOSCO and the FSB’s Resolution Steering Group, that have a direct correlation to clearing, 

clearinghouse regulations and standards. 

Enforcement

The increasingly cross-border nature of enforcement cases means that the Commission, now more 

than ever, has an indispensable need to obtain evidence and testimony located in foreign 

jurisdictions. The Commission, through its international cooperative enforcement office, obtains this 

critical information through formal arrangements with our international counterparts.

The Commission will continue to dedicate enforcement’s international staff to maintain the benefit of 

cooperative enforcement with international regulatory and criminal authorities. Effective crossborder cooperation results in globally coordinated enforcement, which sends a powerful message that 

fraud and threats to market integrity, will be dealt with on a unified front. The Commission’s staff also 

provides timely, well-reasoned, and effective responses to foreign authorities, whose requests for 

reciprocal assistance are increasing both in number and in complexity, commensurate with the

investigations that they support.
FY 2018 Budget Request

 

Mission Function―International Policy 35

Breakout of International Policy Request 18 

Table 12: Breakout of International Policy by Division

Salaries and

Expenses IT Total

FTE ($000) ($000) ($000)

International Affairs 11 $3,858 $0 $3,858

Clearing and Risk 2 $627 $0 $627

Agency Direction 0 $25 $0 $25

Enforcement 3 $978 $0 $978

Total 16 $5,488 $0 $5,488

Figure 11: International Policy Request by Division

 

18 The Commission considers the Salary and Expenses, Information Technology, and Office of the Inspector General programs 

to be its sole programs, projects, and activities (PPAs). The budget displays by mission activity are for informational purposes

only, and do not represent a PPA.

Columns may not add due to rounding
FY 2018 Budget Request

Mission Function─ Data and Technology Support 36

Data and Technology Support 

Resource Overview 

FY 2016 FY 2017 FY 2018

Actual

Continuing

Resolution Request Change

BUDGET $41,227,022 $42,298,244 $43,592,930 +$1,294,686

FTE 49 51 48 -3

Columns may not add due to rounding

Mission Function Description 

Information technology costs, including IT investments (e.g., hardware, software, and contractor 

services), FTE, and indirect costs, are directly attributable the benefiting mission function wherever 

possible, as discussed in the previous section of this document. Any Commission-wide and 

infrastructure IT costs that are not directly attributed to another mission function are captured in the 

Data and Technology Support mission function as described below. A full breakout of the 

Commission’s IT Portfolio, which includes IT costs relating to other mission activities, is located in 

Appendix 2.

The Commission’s IT program uses a service-oriented approach to provide technology infrastructure 

and services. It allows staff Commission-wide to work effectively and increase the integration of data 

and technology into the Commission operating model. The Office of Data and Technology ensures 

that Commission staff has secure and appropriate access to highly available communication, 

processing, and storage infrastructure capabilities. Commission staff must be provided with platforms 

and tools that enable them to analyze data innovatively while minimizing time, process, and resource 

constraints. 

Justification of CFTC Request by Function 

Data and Technology

The Data and Technology function covers the CFTC’s organizational technology needs while, 

simultaneously, adjusting and adapting to the dynamic technology shifts of today’s financial markets. 

This function funds the enterprise-wide IT, data management, telecommunications, security, and 

related IT infrastructure that collectively serve as the central platform for all CFTC regulatory and 

enforcement functions. This request maintains current operational capacity while the Commission 

reviews investments and explores opportunities to streamline services. 

The Commission’s IT program uses an enterprise-wide service-oriented approach to service provision. 

It allows staff to work effectively and increases the integration of data and technology into CFTC 

operations while ensuring that staff has secure and appropriate access to mission critical 

communication, processing, and storage infrastructure capabilities. 

The Commission endeavors to provide available, flexible, reliable, scalable, and high performance 

infrastructure and base services. The Commission will continue to enhance productivity and mobility 

products and services.

One of the CFTC’s top priorities is to provide CFTC market, financial, legal, and economic analysts 

with the ability to adjust analytic activities and approaches rapidly through data aggregation. CFTC 

data storage requires effective management to handle the continual growth of analytical demand.

Secure, private cloud services will be implemented to ensure future scalability and to cost-effectively 

support large volumes of data collected by the Commission.
FY 2018 Budget Request

Mission Function─ Data and Technology Support 37

The foundation of the CFTC IT security program is the confluence of policy and compliance activities 

to govern the use and security of our data and systems. The Commission enforces a mixture of policies 

and exercises that are practical, improve security posture, and comply with regulatory mandates. 

CFTC continues to work with the Department of Homeland Security to improve its security posture. 

 
FY 2018 Budget Request

Mission Function─ Data and Technology Support 38

Breakout of Data and Technology Request 19 

Table 13: Breakout of Data and Technology Support by Division

Salaries and

Expenses IT Total

FTE ($000) ($000) ($000)

Data and Technology 48 $13,245 $30,347 $43,593

Total 48 $13,245 $30,347 $43,593

 

19 The Commission considers the Salary and Expenses, Information Technology, and Office of Inspector General programs to be 

its sole programs, projects, and activities (PPAs). The budget displays by mission activity are for informational purposes only, 

and do not represent a PPA.

Columns may not add due to rounding
FY 2018 Budget Request

 

Mission Function―Agency Direction and Management 39

Agency Direction and Management 

Resource Overview 

FY 2016 FY 2017 FY 2018

Actual

Continuing

Resolution Request Change

BUDGET $37,981,898 $34,450,349 $41,664,355 +$7,214,007

FTE 114 111 131 +20

Columns may not add due to rounding

Mission Function Description 

The Commission’s ability to achieve its mission is driven by well-informed and reasoned executive 

direction, strong and focused management, and an efficiently-resourced, dedicated, and productive 

workforce. This is a top-to-bottom requirement. To ensure the Commission’s continued success, 

continuity of operations, and adaptation to the ever-changing markets it regulates, it must empower 

strong, enterprise-focused leaders; maintain a high-performing, diverse and engaged workforce;

promote transparent and clear communication; and develop, train and equip leaders at all levels of 

the organization. The Commission is committed to managing its resources effectively through 

effective internal controls, governance and planning processes, and ensuring its workforce has the 

leadership, knowledge, data and technology, and other tools to work effectively. 

Justification of CFTC Request by Function 

Administrative Management and Support

The FY 2018 request focuses on strengthening the Commission’s fiduciary posture by enhancing its 

compliance with laws and other Federal requirements related to human capital and workforce 

development, knowledge management, and risk management functions. These efforts will result in 

better informed decision making regarding the management and investment of the Commission’s 

resources.

To ensure a properly managed workforce, the Commission provides mandatory supervisory training 

in accordance with 5 U.S.C. 4121 and Executive Order 13518. This request will enable the Commission 

to offer training to address the Plain Writing Act (per Public Law 111-274) and records management 

training for all employees (36 CFR 1220.34(f)). This request will also enable the implementation of 

certification programs related to the oversight of the financial marketplace, the development of 

executive and leadership skills, and cybersecurity professionals.

The Commission will invest resources to address the Office of Management and Budget (OMB) 

Managing Government Records Directive (M-12-18) and the National Archives and Records 

Administration requirements for agencies to manage electronically all permanent electronic records 

by December 31, 2019. The Commission needs to complete the transition of its business processes and 

systems for managing those records to a fully electronic model. This transition will mitigate 

operational and continuity risks that cannot be managed with the current legacy business processes. 

Additionally, this investment, will allow the Commission to maintain records for administrative 

rulemakings in accordance with the Administrative Procedures Act. 

The Commission will also invest resources to continue evolving its existing risk management 

framework to be more value-added and provide for a strong risk management structure, which is 

essential to effective operations and mission delivery. 
FY 2018 Budget Request

 

Mission Function―Agency Direction and Management 40

The CFTC has taken an aggressive approach to streamlining operations and will realize efficiencies 

from action taken in FY 2017 to centralize business management functions from the various CFTC 

Divisions into the Office of the Executive Director, implement an automated procurement workflow 

system and updates its asset management system and processes. While the Commission is streaming 

operations, some costs have increased. The Commission will experience a significant increase in 

facility leasing costs in FY 2018 directly attributable to sale of the Washington D.C. facility in 

accordance with applicable leasing terms.

Overall, the Commission’s request is a balanced approach that recognizes the need to keep overhead 

costs as low as possible, while making careful investments to continue efficiency, innovation, and 

effectiveness. 

Agency Direction 

The FY 2018 request will support the Commission’s leadership function, which includes the Offices of 

the Chairman and the full complement of Commissioners and support staff, as well as Public Affairs, 

Legislative Affairs and the Office of Minority and Women Inclusion. Support staff for each 

Commissioner is reduced by one FTE, commensurate with pre-Dodd-Frank levels. Under Agency 

Direction, the Chairman’s Office supports efforts to evaluate mandated reforms and focus on 

transparency and market integrity. It also provides responsive, articulate products for a variety of 

domestic and international venues. In addition, the request also includes funding for official reception 

and representation, as well as for the Commission’s Advisory Committees. 

Data and Technology

The IT program funds administrative and management systems required to operate the Commission, 

to include multiple shared-services that provide accounting, procurement, payroll and vendor pay 

services and other functions. 
FY 2018 Budget Request

 

Mission Function―Agency Direction and Management 41

Breakout of Agency Direction and Management Request 20 

Table 14: Breakout of Agency Direction and Management by Division

Salaries and

Expenses IT Total

FTE ($000) ($000) ($000)

Agency Management and Support 89 $23,977 $0 $23,977

Agency Direction 33 $9,126 $0 $9,126

Data and Technology 0 $4,065 $1,186 $5,252

Inspector General 9 $3,310 $0 $3,310

Total 131 $40,478 $1,186 $41,664

Figure 12: Agency Direction and Management Request by Division

 

20 The Commission considers the Salary and Expenses, Information Technology, and Office of the Inspector General programs 

to be its sole programs, projects, and activities (PPAs). The budget displays by mission activity are for informational purposes

only, and do not represent a PPA.

Columns may not add due to rounding
FY 2018 Budget Request

Appendix 1─The Commissioners and Organizational Divisions 42

APPENDIX 1

The Commissioners

The CFTC consists of five Commissioners, with three 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 

following represent the current CFTC Commissioners:

J. Christopher Giancarlo, Acting Chairman

J. Christopher Giancarlo was appointed as Commissioner of the Commodity Futures Trading 

Commission on June 16, 2014. On January 20, 2017, Mr. Giancarlo was selected by his fellow 

Commissioners to be the Acting Chairman of the Commodity Futures Trading Commission. His term 

expires on April 13, 2019.

Sharon Y. Bowen, Commissioner

Sharon Y. Bowen was appointed as Commissioner of the Commodity Futures Trading Commission on 

June 9, 2014. Her term expires on April 13, 2018.

Organizational Divisions and Offices

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 four programmatic 

divisions—the Division of Clearing and Risk (DCR), Division of Enforcement (DOE), Division of 

Market Oversight (DMO), and the Division of Swap Dealer and Intermediary Oversight (DSIO)—are 

supported by, a number of offices, including the Office of the Chief Economist (OCE), Office of Data 

and Technology (ODT), Office of the Executive Director (OED), Office of the General Counsel (OGC), 

and the Office of International Affairs (OIA). The Office of the Inspector General (OIG) is an 

independent office of the Commission.

 
FY 2018 Budget Request

Appendix 1─The Commissioners and Organizational Divisions 43

Agency Direction 

The Offices of the Chairman and the Commissioners provide executive direction and leadership to the 

Commission—specifically, as it develops and adopts Commission policy that implements and enforces 

the CEA and other statutes, rules and regulations. Commission policy is designed to foster the 

financial integrity and economic utility of derivatives markets for hedging and price discovery, to 

conduct market and financial surveillance, and to protect the public and market participants against 

manipulation, fraud, and other abuses.

Administration Management and Support 

The OED, by delegation of the Chairman, directs the internal management of the Commission, 

ensuring the Commission’s continued success, continuity of operations, and adaptation to the everchanging markets it is charged with regulating; directing the effective and efficient allocation of CFTC 

resources; developing and implementing management and administrative policy; and ensuring 

program performance is measured and tracked Commission-wide. The OED includes the following 

branch offices: Business Management and Planning, Executive Secretariat, Library, Records, and 

Privacy, and Proceedings, Financial Management, Human Resources, and Customer Outreach. The 

Office of Proceedings has a dual function to provide a cost-effective, impartial, and expeditious forum 

for handling customer complaints against persons or firms registered under the CEA, and to 

administer enforcement actions, including statutory disqualifications, and wage garnishment 

cases. The Office of Consumer Outreach (OCO) administers the Commission’s consumer anti-fraud 

and public education initiatives.
FY 2018 Budget Request

Appendix 1─The Commissioners and Organizational Divisions 44

Chief Economist

The OCE provides economic analysis, advice and context to the Commission and to the public. The 

OCE provides perspectives on both current topic and long-term trends in derivatives markets. The 

extensive research and analytical backgrounds of staff ensure that analyses reflect the forefront of 

economic knowledge and econometric techniques. The OCE plays an integral role in the cost-benefit 

considerations of Commission regulations and collaborates with staff in other divisions to ensure that 

Commission rules are economically sound. The OCE and the research it provides also play a key role 

in transparency initiatives of the Commission.

Clearing & Risk

The DCR oversees DCOs and other market participants that may pose risk to the clearing process 

including FCMs, swap dealers, major swap participants, and large traders, and administers the 

clearing of futures, options on futures, and swaps by DCOs. The DCR staff: 1) prepare proposed 

regulations, orders, guidelines, and other regulatory work products on issues pertaining to DCOs; 2) 

review DCO applications and rule submissions and make recommendations to the Commission; 3) 

make recommendations to the Commission of which swaps should be required to be cleared; 4) make 

recommendations to the Commission as to the eligibility of a DCO seeking to clear swaps that it has 

not previously cleared; 5) assess compliance by DCOs with the CEA and Commission regulations, 

including examining systemically important DCOs at least once a year; and 6) conduct risk 

assessment and financial surveillance through the use of risk assessment tools, including automated 

systems to gather and analyze financial information, and to identify, quantify, and monitor the risks 

posed by DCOs, clearing members, and market participants and its financial impact.

Data and Technology

The ODT is led by the Chief Information Officer and delivers services to CFTC through four 

components: Systems and Services, Data Management, Infrastructure and Operations, and Policy and 

Planning. Systems and Services focuses on several areas: 1) market and financial oversight and 

surveillance; 2) enforcement and legal support; 3) document, records, and knowledge management; 

4) CFTC-wide enterprise services; and 5) management and administration. Systems and Services 

provide access to data and information, platforms for data analysis, and enterprise-focused 

automation services. Data Management focuses on data analysis activities that support data 

acquisition, utilization, management, reuse, transparency reporting, and data operations support. 

Data Management provides a standards-based, flexible data architecture; guidance to the industry on 

data reporting and recordkeeping; reference data that is correct; and market data that can be 

efficiently aggregated and correlated by staff. Infrastructure and Operations organizes delivery of 

services around network infrastructure and operations, telecommunications, and desktop and 

customer services. Delivered services are highly available, flexible, reliable, and scalable, supporting 

the systems and platforms that empower staff to fulfill the CFTC mission. Policy and Planning focuses 

on IT security, strategic and operational planning, IT policy and procedure development, 

configuration management, enterprise architecture, and internal business management. The four 

service delivery components are unified by an enterprise-wide approach that is driven by the 

Commission’s strategic goals and objectives.

Enforcement

The DOE investigates and prosecutes alleged violations of the CEA and Commission regulations. The 

Commission’s enforcement efforts are necessary for public confidence and trust in the financial 

markets. DOE utilizes its authority to, among other things: 1) shut down fraudulent schemes and seek 

to immediately preserve customer assets through asset freezes and receivership orders; 2) uncover 

and stop manipulative and disruptive trading; 3) ensure that markets, firms, and participants subject 

to the Commission’s oversight meet their obligations, including their financial integrity and reporting 

obligations, as applicable; 4) ban certain defendants from trading in its markets and being registered; 

and 5) obtain orders requiring defendants to pay restitution, disgorgement, and civil monetary 

penalties. DOE also engages in cooperative enforcement work with domestic, state and Federal, and 
FY 2018 Budget Request

Appendix 1─The Commissioners and Organizational Divisions 45

international regulatory and criminal authorities. The WBO within DOE receives tips, complaints and 

referrals of potential violations, which allows the staff to bring cases more quickly and with fewer 

CFTC resources, and guides the handling of whistleblower matters as needed during investigation, 

litigation, and award claim processes.

General Counsel

The OGC provides legal services and support to the Commission and all of its programs. These 

services include: 1) engaging in defensive, appellate, and amicus curiae litigation; 2) assisting the 

Commission in the performance of its adjudicatory functions; 3) providing legal advice and support 

for Commission programs; 4) assisting other program areas in preparing and drafting Commission 

regulations; 5) interpreting the CEA; 6) overseeing the Commission’s ethics program and compliance 

with laws of general applicability; and 7) providing advice on legislative, regulatory issues and 

financial technology innovation.

International Affairs

The OIA advises the Commission regarding international regulatory initiatives; provides guidance 

regarding international issues raised in Commission matters and in matters pertaining to cooperation 

arrangements with foreign authorities; represents the Commission in international fora, such as 

IOSCO, the OTC Derivatives Regulators Group, and various FSB committees; participates in bilateral 

dialogues, such as the U.S.-EU Joint Financial Regulatory Forum and the U.S.-China Strategic and 

Economic Dialogue; coordinates Commission policy as it relates to policies and initiatives of major 

foreign jurisdictions, the G20, FSB and the U.S. Department of the Treasury (Treasury); and provides 

technical assistance to foreign market authorities.

Market Oversight

DMO fosters open, transparent, fair, competitive and secure markets through oversight of derivatives 

platforms and trade repositories. DMO also reviews new applications for DCMs, SEFs, SDRs, and 

FBOTs and examines existing trading platforms and data repositories to ensure their compliance with 

the applicable core principles and other regulatory requirements. DMO also evaluates new products 

to ensure that they are not susceptible to manipulation, and reviews entity rules to ensure compliance 

with the CEA and Commission regulations. Furthermore, DMO conducts value-added analysis using 

internal and external data and to inform sound policymaking at the Commission and promote 

efficient and financially sound markets.

Swap Dealer and Intermediary Oversight

The DSIO oversees the registration and compliance activities of market intermediaries and the futures 

and swaps industry SROs, which includes the NFA. DSIO develops and implements regulations 

concerning registration, fitness, financial adequacy, sales practices, risk management, business 

conduct, capital and margin requirements, protection of customer funds, cross-border transactions, 

and anti-money laundering programs, as well as policies for coordination with foreign market 

authorities and emergency procedures to address market-related events. DSIO provides guidance to 

the Commission, intermediary registrants, SROs and other market participants regarding these 

regulations and the CEA provisions that these regulations implement. DSIO also monitors the 

compliance of these registrants and provides oversight and guidance for complying with the system of 

registration and compliance established by the CEA and the Commission’s regulations. DSIO further 

assesses registrant compliance with the CEA and Commission regulations by conducting targeted 

reviews and examinations of registrants and performing oversight of the SRO examination functions.
FY 2018 Budget Request

Appendix 2─Information Technology 46

APPENDIX 2

Information Technology

Introduction

The Commission’s IT Portfolio reflects strategic priorities to provide highly available infrastructure 

and services, access to data, platforms for staff data analysis, and enterprise-focused automation 

services. The Commission scales and enhances communication, processing, storage, and platform 

infrastructure to meet mission requirements. The Commission has organized its IT portfolio into the 

five major investments described below: 

• Surveillance. Supports market, trade practice, and financial and risk oversight and 

enforcement actions. Success in this area is highly dependent on the ability to acquire large 

volumes of data and the development of standards and analytics to support data segregation, 

as well as identify trends and/or outlying events that warrant further investigation. 

• Enforcement. Provides a variety of critical automated litigation and investigation support 

services to facilitate the overall management of documents and data. Enforcement technology 

also provides the ability to rapidly query and retrieve information about investigations and 

litigation and perform analytics. 

• Other Mission Support. Provides services that are vital to CFTC’s regulatory mission 

functions including: 1) Registration and Compliance, 2) Product Reviews, 3) Examinations, 4) 

Legal and Economic Analysis and 5) International Policy. 

• Data Infrastructure. Supports all mission areas by providing the underlying infrastructure 

for IT services including: messaging, communications, network security, database 

administration, business continuity and data storage management. The data infrastructure 

effort also provides transparency through the CFTC.gov website, staff collaboration and 

knowledge management, as well as document and records management. 

• Management and Administrative Support. Includes IT service to commission-wide general 

support activities that require specialized or dedicated IT service components, for example,

financial management, payroll and personnel services, training, hiring and logistics support. 

Management of the IT Portfolio in FY 2018

The Commission requests $57.0 million for the IT Program and $29.4 million for the Salaries and

Expenses Program, in support of the following IT priorities:

Surveillance:

• Data Standards, Quality and Governance

o Sustain ongoing efforts with domestic and international regulators, as well as 

industry to harmonize and refine data standards and improve data quality.

o Sustain data standardization, collection, correlation and quality efforts for market 

data.

o Sustain intraday trade capture data quality and Hybrid Order data. 

o Support harmonizing of data standards and data access services for all SDR data.

o Sustainment of Data Governance resource to develop a data governance framework, 

data governance artifacts used to make decisions, maintain and extend data catalog 

as a tool for data governance, perform data governance for projects like transitional 

swaps database (TSD), in FY 2018. 
FY 2018 Budget Request

Appendix 2─Information Technology 47

• Swaps Data Management 

o Provide data loading support for all new data submissions.

o Collaborate on integration of NFA systems and data with CFTC systems and ingest of 

NFA data into CFTC systems. 

o Continue integrating futures, swaps, and master and reference data in an enterprise 

data environment.

• Position and Transaction Surveillance 

o Adapt large trader reporting systems to support new swaps data analysis, internal 

reporting requirements, and transparency reporting. 

o Deploy systems that analyze orders as well as trades for trade practice violations.

• OTC Risk Management 

o Intensify capability to stress test positions in swaps for market participants and 

DCOs.

o Amplify systems to identify and aggregate data for related market participants across 

DCOs.

o Improve tools used in backtesting and evaluation of sufficiency of all material product 

and portfolio margin requirements.

o Upgrade monitoring capabilities of firm level variation and initial margin 

requirements across DCOs.

o Expand existing tools utilized in the evaluation of risk to market participants 

positions held at multiple FCMs or DCOs.

o Enhance tools to combine cleared and bilateral positions to obtain a more complete 

picture of a clearing firm’s risk.

o Modify existing financial analysis tools, which support reviews of FCMs and swaps 

dealers risk management controls.

• Market and Data Analytics 

o Continue enhancing data availability and analytics tools that allow staff to prototype 

new surveillance and risk and compliance monitoring methods.

o Adjust production analytics to use high-performance computing platforms.

o Support additional public transparency reporting.

Other Mission Support:

• Registration and Compliance, Product Review and Assessment.

o Automate regulatory mission and key processes.

• Examinations 

o Automate regulatory mission and key processes.

• Legal and Economic Analysis

o Automate regulatory mission and key processes.
FY 2018 Budget Request

Appendix 2─Information Technology 48

Enforcement:

• Enhance eLaw and forensics program technology, and increase litigation technical support 

services.

Data Infrastructure:

• Increase storage, processing, and communications infrastructure to meet demand.

• Finalize implementation of desktop computing technology refresh.

• Implement information security continuous diagnostics and mitigation (CDM).

• Provide support for the Commission-wide collaboration site and division collaboration sites.

• Initiate technology refresh for end-of-life conference room equipment. 

• Continue Full Implementation of “Windows to Go”. 

• Sustain a cost effective and secure remote access to facilitate telework/working remotely.

• Sustain customer support, desktop support, and network operation services. 

• Retain scaled storage and server capacity.

Management and Administrative Support:

• Enhance video production capabilities to support electronic learning and improved 

communications.

Summary of Information Technology Budget by Cost Type

FY 2016 FY 2017 FY 2018

Actual

Continuing

Resolution Request

($000) ($000) ($000)

 Development, Modernization, and Enhancement (DME) 13,951 14,014 14,346

 Operations and Maintenance (O&M) 54,840 55,643 62,823

 S&E (Non-DME/O&M) 7,274 3,773 4,065

 Indirect Overhead 4,111 5,050 5,217

Total IT Portfolio $80,177 $78,481 $86,452

 Information Technology Services 50,387 50,000 57,000

 Information Technology Personnel (S&E) 18,384 19,630 20,143

 S&E Operating 7,295 3,800 4,092

 Indirect Overhead 4,111 5,050 5,217

Total IT Portfolio $80,177 $78,481 $86,452

Columns may not add due to rounding
FY 2018 Budget Request

Appendix 2─Information Technology 49

Detail of Information Technology Budget by Cost Type

FY 2016 FY 2017 FY 2018

Actual

Continuing

Resolution Request

($000) ($000) ($000)

Surveillance 21,662 22,039 26,625

DME 7,734 7,759 10,635

Services 7,402 7,346 10,197

Personnel 331 413 438

O&M 13,929 14,280 15,990

Services 6,479 6,428 7,671

Personnel 7,450 7,852 8,320

Enforcement Activities 4,379 4,351 5,587

DME 111 110 25

Services 111 110 25

Personnel 0 0 0

O&M 4,269 4,241 5,561

Services 3,441 3,415 4,685

Personnel 828 827 876

Other Mission Support 2,452 2,433 2,900

DME 1,032 1,024 1,013

Services 1,032 1,024 1,013

Personnel 0 0 0

O&M 1,420 1,409 1,888

Services 1,420 1,409 1,888

Personnel 0 0 0

Agency Direction and Management 8,530 5,020 5,252

S&E 7,274 3,773 4,065

Services 7,267 3,773 4,065

Personnel 7 0 0

DME 0 0 0

Services 0 0 0

Personnel 0 0 0

O&M 1,256 1,247 1,186

Services 1,256 1,247 1,186

Personnel 0 0 0

Data and Technology Support 39,042 39,587 40,871

DME 5,076 5,121 2,674

Services 4,744 4,708 2,236

Personnel 331 413 438

O&M 33,966 34,466 38,197

Services 24,530 24,341 28,126

Personnel 9,437 10,125 10,071

Indirect Overhead 4,111 5,050 5,217

Total IT Portfolio $80,177 $78,481 $86,452

Table 15: Information Technology Budget

DEFINITION OF TERMS

DME: Costs related to the development, modernization, and enhancement of technology.

O&M: Costs related to the operations and maintenance of technology.

S&E: Costs related to the Salaries and Expenses Program.

Personnel: Costs of government personnel for salary and benefits only. 

Services: Hardware, software, and contracted data and technology services and contracted labor.

Indirect: Overhead related to leases and other centrally funded costs.

Columns may not add due to rounding
FY 2018 Budget Request

Appendix 3 Inspector General 50

APPENDIX 3

Inspector General

The OIG is an independent organizational unit of the CFTC. The mission of the OIG is to detect 

waste, fraud, and abuse and to promote integrity, economy, efficiency, and effectiveness in the CFTC’s 

programs and operations. As such, it has the ability to review all of the Commission’s programs, 

activities, and records. In accordance with the Inspector General Act of 1978, as amended, the OIG 

issues semiannual reports detailing its activities, findings, and recommendations.

Total FY 2018 Budget as described below includes the OIG request of $2,800,000 for estimated direct 

salary and benefit costs of nine FTE, including an estimated contribution of $8,400 to support the 

Council of the Inspectors General on Integrity and Efficiency (CIGIE). The Budget also includes 

overhead of approximately $510,401. Overhead is estimated by the Commission and is additive to the 

OIG direct budget request. Overhead represents a proportional share of estimated operating costs, 

such as, lease of space, utilities, printing, supplies, equipment and other services used by or available 

to all divisions and offices, including the OIG. CFTC allocates overhead to all divisions and offices in 

this budget presentation based on a per FTE distribution. 

Table 16: Inspector General’s Budget Request

Budget Year Total Budget OIG Requested

Budget

Estimated

Overhead

Training Budget

Estimate

CIGIE

Estimate FTE

FY 2018 $3,310,401 $2,800,000 $510,401 20,000 8,400 9
FY 2018 Budget Request

Appendix 3 Inspector General 51

Inspector General’s Comment on the CFTC FY 2018 Budget Request

U.S. COMMODITY FUTURES TRADING COMMISSION

Office of Inspector General 

 Three Lafayette Centre

 1155 21st Street, NW, Washington, DC 20581

 Telephone: (202) 418-5110

 Facsimile: (202) 418-5522

May 18, 2017

TO: Acting Chairman Christopher J. Giancarlo

Commissioner Sharon Y. Bowen 

FROM: A. Roy Lavik,

Inspector General 

SUBJECT: Comments on the CFTC FY 2018 Budget Submission for the Office of Inspector General

We are submitting this brief comment for inclusion with the CFTC FY 2018 Budget Submission 

for the Office of Inspector General.

1

For FY 2018, I have requested $2.8 million to fund operating expenses, including salaries and 

benefits for nine (9) OIG FTEs (which is the entire OIG).

2 This amount – the OIG FY 2018 operating 

budget – is approximately 1% of CFTC’s FY 2018 proposed budget. CFTC has added $510,401 to the

OIG FY 2018 budget request for “overhead.” Overhead increases the total OIG budget request by more 

than 18% (to $3,310,401). 

The OIG overhead amount is not determined by OIG. CFTC sets OIG overhead without 

consulting OIG. The spending of overhead is not controlled by OIG. CFTC in like manner adds 

overhead to each CFTC Division and Office operating budget on a per FTE basis. The per FTE amount 

for FY 2018 appears to be $56,711 ($510,410 divided by 9 FTEs). 

Please keep in mind that CFTC adjusts overhead, agency wide, on an ongoing basis. If overhead 

increases during FY 2018, CFTC will decrease the operating budgets for its Divisions and Offices to 

make up the difference. We believe CFTC should not decrease the OIG operating budget set by 

Congress. By the same token, if per FTE overhead costs drop during FY 2018, we would believe it 

inappropriate for CFTC to supplement the OIG operating budget set by Congress. Both scenarios create 

the appearance that OIG funding – and CFTC oversight – depends on CFTC management, rather than the 

will of Congress. 

We therefore prefer that Congress set OIG’s operating budget, and specify overhead as an 

additional amount. In the absence of such specificity, I ask the Commission’s support in avoiding 

alteration of the OIG operating budget set by Congress. 

As always, I appreciate your continuing support of my Office. 

1 Pursuant to section 6(f)(2)(D) of the Inspector General Act of 1978 (IG Act), as amended, “in transmitting a 

proposed budget to the President for approval, the head of each establishment or designated Federal entity shall 

include ... any comments of the affected Inspector General with respect to the proposal.”

2 This amount includes $20,000 designated for training, which is appropriate for my requested OIG staff of nine (9) 

FTEs. It also includes payment of $8,400 to support the Counsel of Inspectors General on Integrity and Efficiency. 

The OIG request is approximately 1% of the Agency’s FY 2018 total proposed budget.
FY 2018 Budget Request

Appendix 3 Inspector General 52

Inspector General’s FY 2018 Budget Request

Office of the 

Inspector General

U.S. COMMODITY FUTURES TRADING COMMISSION

Three Lafayette Centre

1155 21st Street, NW, Washington, DC 20581

Telephone: (202) 418-5110

Facsimile: (202) 418-5522

May 8, 2017

TO: Chairman J. Christopher Giancarlo

Commissioner Sharon Y. Bowen

FROM: A. Roy Lavik

Inspector General

SUBJECT: FY 2018 President’s Budget

I am requesting $2.8 million for the salaries and benefits of 9 FTEs, contracted audits and 

services, training, travel and our annual contribution to CIGIE.

1

 Of this figure, $20,000 will 

satisfy all training requirements for my Office. 

Our operating budget represents slightly less than 1% of the CFTC’s request. It does not 

include funds for Agency-wide overhead. “Overhead” consists of spending on CFTC leases, 

administrative services such as expenses for contractors, and agency-wide training. Our intent is 

to submit an OIG budget request that is solely for funds under the control of, and to be spent 

directly by, the Office of the Inspector General. 

We request that this be made explicit in the appropriation language – that agency 

overhead, however calculated and in whatever amount – is separate from and in addition to the 

OIG operating budget. This mirrors the Agency’s intent as set forth in Appendix 3, Table 16. 

We believe that express language to this effect will avoid confusion and reserve to the Agency 

maximum flexibility to manage Agency-wide overhead, while ensuring compliance with the 

Inspector General Act. 

Attachment

cc:

Mary Jean Buhler, CFO

Joel Mattingley, Budget Officer

1 On April 24, 2017, we submitted a request of $3.0 million. Shortly thereafter, we received our FY 17 

appropriation and the CFTC’s calculation of overhead. We determined to reduce our FY 18 request.
FY 2018 Budget Request

Appendix 4 Statement of Availability 53

Attachment for Inspector General’s Budget Request:

Direct Costs ($) OIG Request

Salaries and Benefits 2,325,600 

Travel 46,000 

Training 20,000 

Contract Audits 250,000 

Contract Services 150,000

Subtotal Direct Costs $ 2,791,600 

CIGIE Contribution (estimate of .3% of subtotal above) 8,400

Total Direct OIG Costs $ 2,800,000 

Positions 9

FTE 9
FY 2018 Budget Request

Appendix 4 Statement of Availability 54

APPENDIX 4

Statement of Availability on Basis of Obligations

Table 17: Summary of FY 2016 to 2018 Statement of Availability on Basis of Obligations

Actual

FY 2017

Estimate

FY 2018

Request

$ (000) $ (000) $ (000)

New Appropriations $250,000 $250,000 $281,500

Carryover from Prior Year 396 685 200

Recoveries of Prior Year Obligations 675 1,811 826

Total Available 251,071 252,496 282,526

Obligations 249,677 251,896 281,926

Balance Available 1,395 600 600

Lapsing Appropriations (711) (600)

Total Available or Estimate $684 $0
FY 2018 Budget Request

Appendix 5 Customer Protection Fund 55

APPENDIX 5

Customer Protection Fund

Introduction

Section 748 of the Dodd-Frank Act amended the CEA by adding Section 23, entitled “Commodity 

Whistleblower Incentives and Protections.” Among other things, Section 23 establishes a 

whistleblower program that requires the Commission to pay awards, under regulations prescribed by 

the Commission and subject to certain limitations to eligible whistleblowers, who voluntarily provide 

the Commission with original information about violations of the CEA, and that lead to the successful 

enforcement of a covered judicial or administrative action, or a related action. The Commission’s 

whistleblower awards are equal, in the aggregate amount to at least 10 percent but not more than 30 

percent of the monetary sanctions actually collected in the Commission’s action or a related action.

Section 748 of the Dodd-Frank Act also established the CFTC Customer Protection Fund (CPF) 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. The Commission undertakes and 

maintains customer education initiatives through the OCO.

Management of the Whistleblower Office

The WBO has three essential functions:

• Process Whistleblower Submissions. WBO receives, tracks, and handles whistleblower 

submissions and inquiries.

• Coordinate with Commission Divisions and Outside Agencies. WBO answers questions from 

Commission staff and others regarding the whistleblower program, and guides the handling 

of whistleblower matters as needed during examination, investigation and litigation. WBO 

also approves referrals of whistleblower-identifying information to outside agencies.

• Administer Claims Process. WBO receives and tracks whistleblower award claims, gathers 

and prepares the adjudicatory records for the Whistleblower Award Determination Panel 

(Panel), advises the Panel as needed on the whistleblower provisions and rules, and 

memorializes the Panel’s decisions.

In FY 2016, the CFTC issued two orders granting awards to whistleblowers for providing valuable 

information about violations of the CEA—one for more than $10 million and another for 

approximately $50,000. 

All whistleblower award payments are made out of the CPF established by Congress that is financed 

entirely through monetary sanctions paid to the CFTC by violators of the CEA.

In FY 2018, the Commission will continue to increase its communications with market participants 

and voluntary whistleblowers about the protections and incentives under the Whistleblower Program.

Management of the Office of Consumer Outreach

OCO administers the CFTC’s public education initiatives designed to help customers protect 

themselves against fraud and other violations of the CEA. These initiatives include efforts and 

strategies designed to inform and empower commodity producers and end-users who utilize the 

commodity futures and derivatives markets, older Americans often targeted by investment fraud, and 

the public interested in learning more about the markets and how they operate. 
FY 2018 Budget Request

Appendix 5 Customer Protection Fund 56

OCO develops educational content designed to help farmers, ranchers and end-users make decisions 

about utilizing the commodity futures markets as part of their risk management portfolios. The goal 

of the strategy is to educate producers and end-users about a number of key issues, including: 1) 

CFTC’s role in monitoring and policing the markets; 2) products and strategies that could be 

considered to hedge risk; 3) market reports and how they can be used; 4) customer rights, 

responsibilities, and safeguards; and 5) price volatility and price discovery.

The Commission also plans an alliance-based outreach strategy utilizing partnerships with Federal 

and state agencies as well as nonprofit and industry groups. Its first major anti-fraud initiative, “CFTC 

SmartCheckSM,” is now in its third year. The social marketing initiative uses direct-to-customer 

communication and marketing to target investors nearing or in retirement. 

For 2017 and beyond, OCO plans to target advertising to key websites and online media and shift 

resources to content development and marketing that will attract and retain repeat visitors, including 

both potential fraud victims and fraud-prevention educators. Common content marketing tactics 

include improving search engine optimization, increased concentration on social media, and 

identifying and developing communities of interest.

OCO is also creating new and engaging educational content for CFTC.gov. This work is focused on 

raising awareness about the Commission’s role in fostering transparent and competitive markets, and 

protecting market users from fraud, manipulation and abusive practices. Content will be developed in 

plain language, designed to be highly searchable, allowing customers to find it easily on mainstream 

search engines. In FY 2018, the Commission will continue its research and evaluation to ensure 

taxpayer funds are efficiently utilized and current and future messaging and outreach efforts are 

effectively engaging customers. 

Operation of the CFTC Customer Protection Fund 

The CPF is a revolving fund established under section 748 of the Dodd-Frank Act. The Commission 

shall deposit civil monetary penalties, disgorgements, and interest it collects in covered 

administrative or judicial enforcement actions into the CPF whenever the balance in the CPF at the 

time of the deposit is less than or equal to $100 million. The Commission pays whistleblower awards 

and finances customer education initiatives from the CPF but does not deposit restitution awarded to 

victims into the CPF. Program values include allocated CFTC administrative expenses.

In FY 2018, the CFTC estimates that it will use up to $67.7 million:

• Up to $12.8 million will be used to finance customer education initiatives, administrative 

expenses, and 10 FTE, a decrease of $0.1 million under the FY 2017 budgeted level.

• Whistleblower award payouts are estimated at $52 million.

• Up to $2.9 million will be used for the WBO to fund administrative expenses and 10 FTE, which is 

an increase of $0.1 million over the FY 2017 level. 
FY 2018 Budget Request

Appendix 5 Customer Protection Fund 57

Table 18: Customer Protection Fund

FY 2016

Actual

($000)

FY 2017

Estimate

($000)

FY 2018

Estimate

($000)

Budget Authority – Prior Year $264,251 $245,426 $170,501

Budget Authority – New Year 490 845 1,000

Prior Year Recoveries 352 0 0

Sequestration (33) (58)

Total Budget Authority 265,060 246,213 171,500

 Whistleblower Program 2,108 2,795 2,939

 Whistleblower Awards 11,851 60,000 52,000

 Customer Education Program 5,675 12,917 12,796

Total Planned Expenditures 19,634 75,712 67,735

Unobligated Balance $245,426 $170,501 $103,766
FY 2018 Budget Request

Appendix 6The Commission and the Industry We Regulate 58

APPENDIX 6

The Commission and the Industry We Regulate

The mission of the CFTC is to foster open, transparent, competitive, and financially sound markets; to 

avoid systemic risk; and to protect market users and their funds, consumers, and the public from 

fraud, manipulation, and abusive practices related to derivatives and other products that are subject 

to the CEA. As a key mechanism for performing these responsibilities, the Commission delegates 

certain authorities to registered entities such as SROs, clearing entities and data depositories and then 

oversees and supports these organizations by reviewing their operations and procedures and by 

providing guidance, policy and direction in accordance with Commission regulations. 

With respect to its oversight of swap dealers, major swap participants and intermediaries, the CFTC 

oversight occurs in coordination with the SRO system. While the designated SROs are obligated to 

conduct surveillance, compliance oversight and enforcement activities for entities under their 

purview, the Commission conducts surveillance, compliance oversight and enforcement activities 

across all market participants while concurrently providing the rules, legal interpretations and policy 

oversight necessary to guide designated SRO activities. 

Revisions to the Commission’s regulatory requirements have required additional focus on the 

oversight of designated SROs in their implementation of these new requirements for market 

participants. As the CFTC seeks to strengthen the regulatory framework for both FCMs and swap 

dealers, the Commission will continue to work closely with the NFA to emphasize priority areas such 

as risk management, internal controls, legal compliance and FCM and swap dealer examinations. 

CFTC Regulatory Landscape Matrix

The matrix, as detailed in Table 19, reflects how the Commission administers its oversight authorities 

for each regulated entity by CFTC mission function. In summary, regulatory oversight is managed as 

follows:

• CFTC Core. All activities under this category are reflected as “CFTC” in Table 19. Activities under 

this category apply to core functions central to the Commission’s mission. Examples include 

major enforcement actions, rulemaking, policy, legal interpretations, no action determinations, 

etc. 

• CFTC Delegated. All activities under this category are reflected in Table 19 as “NFA/CFTC” or 

“designated self-regulatory organizations (DSRO)/CFTC”, or “self-regulatory organizations” 

(SRO/CFTC), as appropriate. This category captures mission activities that involve the delegation 

of certain regulatory functions to the NFA or other SROs. Examples include cyclical intermediary 

examinations, certain enforcement actions, reporting requirements, etc. However, in all cases of 

delegation, the CFTC is responsible for the review and oversight of the SRO processes, products, 

procedures, etc. to ensure and validate compliance with all applicable regulations. This work 

includes quarterly reviews of SRO examinations activities, review/approval of proposed SRO

rules and policies, guidance and legal interpretations, etc. 

• CFTC Shared. All activities under this category are reflected in Table 19 as “CFTC/DCO Regulator 

or Federal Reserve.” For systemically important DCOs, the CFTC shares regulatory authority with 

the Federal Reserve. For exempt DCOs, the CFTC share regulatory authority with the DCO’s home 

regulatory authority with respect to oversight of swaps clearing by U.S. persons. For registered 

FBOTs, the CFTC shares regulatory authority with the FBOT’s home regulatory authority with 

respect to oversight over direct access trading from the U.S. and review of products to be offered

for trading by direct access. The FBOT’s home regulatory authority has responsibility for the 

remaining mission functions. For intermediaries the CFTC retains certain direct responsibilities 

and those which have been delegated to SROs, CFTC remains responsible for oversight of such 

responsibilities and/or delegates regulatory authority to SROs by CFTC mission function. 
FY 2018 Budget Request

Appendix 6The Commission and the Industry We Regulate 59

Entity Acronym CFTC Mission-Function

Registration 

& 

Compliance

Product 

Reviews Surveillance Examinations Enforcement

Economic 

& Legal 

Analysis

Trading Entities

Designated Contract Market DCM CFTC CFTC CFTC CFTC CFTC CFTC

Swap Execution Facility SEF CFTC CFTC CFTC CFTC CFTC CFTC

Foreign Board of Trade FBOT CFTC/FBOT 

Regulator

CFTC/FBOT 

Regulator

FBOT 

Regulator

FBOT 

Regulator

FBOT 

Regulator

FBOT 

Regulator

Clearing Entities

Derivatives Clearing Organization DCO CFTC CFTC CFTC CFTC CFTC CFTC

Exempt Derivatives Clearing 

Organizations

Exempt 

DCO

CFTC/DCO 

Regulator

CFTC/DCO 

Regulator

CFTC/DCO 

Regulator

CFTC/DCO 

Regulator

CFTC/DCO 

Regulator

CFTC/DCO 

Regulator

Systemically Important Derivatives 

Clearing Organization SIDCO CFTC CFTC CFTC

CFTC/

Federal 

Reserve

CFTC CFTC

Data Repositories

Swap Data Repository SDR CFTC N/A N/A CFTC CFTC CFTC

Registered Futures Association

National Futures Association NFA CFTC N/A N/A CFTC CFTC CFTC

Intermediaries

Futures Commission Merchant FCM NFA/CFTC N/A DSRO/CFTC DSRO/CFTC DSRO/CFTC CFTC

Swap Dealer SD NFA/CFTC CFTC NFA/CFTC NFA/CFTC NFA/CFTC CFTC

Major Swap Participant MSP NFA/CFTC CFTC NFA/CFTC NFA/CFTC NFA/CFTC CFTC

Retail Foreign Exchange Dealer RFED NFA N/A NFA/CFTC NFA/CFTC NFA/CFTC CFTC

Managed Funds

Commodity Trading Advisor CTA NFA/CFTC N/A NFA/CFTC NFA NFA/CFTC CFTC

Commodity Pool Operator CPO NFA/CFTC N/A NFA/CFTC NFA NFA/CFTC CFTC

Other Registrants

Introducing Broker IB NFA N/A NFA/CFTC NFA NFA/CFTC CFTC

Floor Broker FB NFA N/A CFTC N/A SRO/CFTC CFTC

Floor Trader FT NFA N/A CFTC N/A SRO/CFTC CFTC

Associated Person (Sales) AP NFA N/A CFTC N/A SRO/CFTC CFTC

Table 19: Matrix of Regulated Entities and Registrants by Mission Function
FY 2018 Budget Request

Appendix 6The Commission and the Industry We Regulate 60

Number of Regulated Entities and Registrants

The Commission’s regulatory framework continues to evolve in response to market forces, technology 

impacts, legislative mandates, and other factors. The number of registrants operating within this 

framework are similarly impacted by these drivers and as such, their number will fluctuate over time. 

The FY 2016 actuals are provided below. 

Entity Acronym Number of Regulated

Entities and Registrants

FY 2016 Actuals

Trading Entities

Designated Contract Market DCM 15

Swap Execution Facility SEF 23

Foreign Board of Trade21 FBOT 9

Clearing Entities

Derivatives Clearing Organization DCO 15

Exempt Derivatives Clearing Organization Exempt DCO 4

Systemically Important DCO SIDCO 2

Data Repositories

Swap Data Repository SDR 4

22

Intermediaries

Futures Commission Merchant 23 FCM 68

Swap Dealer SD 102

Major Swap Participant MSP 0

Retail Foreign Exchange Dealer RFED 3

Managed Funds

Commodity Trading Advisor CTA 2,298

Commodity Pool Operator CPO 1,710

Other Registrants

Introducing Broker IB 1,275

Floor Broker FB 3,816

Floor Trader FT 694

Associated Person AP 53,431

Table 20: Number of Regulated Entities and Registrants

 

21 Foreign boards of trade are registered with the Commission to allow the FBOT to permit its members and other participants 

in the United States to enter orders directly into the FBOT’s trade matching system.

22 There are currently four swap data repositories that are provisionally registered with the CFTC.

23 Excludes futures commission merchants registered as retail foreign exchange dealers.
FY 2018 Budget Request

Appendix 6─Futures and Option Contract Volume 61

Industry Growth in Volume, Globalization and Complexity

In a marketplace driven by change, it may be helpful to look back at industry and CFTC trends over 

the past few years. The charts that follow reflect many of those changes in the markets affecting the 

CFTC: 

• Volume of futures and option contracts traded; 

• Volume of swaps traded on swap execution facilities;

• Swap data repository swap volume data; 

• Actively traded futures and option contracts; 

• Notional value of exchange traded and OTC contracts;

• Customer funds held at futures commission merchants;

• Margin Requirements;

• Swap execution facilities registered with the CFTC;

• Contract markets designated by the CFTC;

• Derivatives clearing organizations registered with the CFTC;

• Systemically important derivatives clearing organizations;

• Exempt derivatives clearing organizations;

• Swap data repositories registered with the CFTC; and

• Growth in number of types of swaps data loaded onto CFTC systems.
FY 2018 Budget Request

Appendix 6─Futures and Option Contract Volume 62

Volume of Futures & Option Contracts Traded24

Trading volume for CFTC-regulated contracts maintained a general upward trend for the past decade. 

As the volume of futures and option contracts increases, CFTC workload also increases, since the 

CFTC has to conduct trade practice and market surveillance for a larger number of transactions.

Figure 13: Growth of Volume of Contracts Traded

 

24 Data Source: Futures Industry Association (FIA), CFTC estimates.
FY 2018 Budget Request

Appendix 6─Volume of Swaps Traded on Swap Execution Facilities 63

Volume of Swaps Traded on Swap Execution Facilities25

SEFs, a type of CFTC-regulated platform for trading swaps, began operating on October 2, 2013. The 

FIA publishes data on volume and market share trends for interest rate, credit and foreign exchange 

(FX) products traded on SEFs. Visit SEF Tracker at https://www.fia.org for more details on market 

trends. As the volume of swaps traded on SEFs increases, CFTC workload increases, due to the 

increase in data to ingest and process, which results in additional trade practice and market 

surveillance activities over a larger number of transactions.

Figure 14: Volume of Swaps Traded on Swap Execution Facilities

 

25 Data Source: Futures Industry Association (FIA), CFTC estimates.
FY 2018 Budget Request

Appendix 6─Swaps Volume from Swap Data Repositories 64

Swap Volume, Cleared versus Uncleared26

Based on data reported to SDRs, as of January 2017, 83 percent of all new interest rate swap 

transactions were cleared, as measured by notional value. This is compared to estimates by the 

International Swaps and Derivatives Association (ISDA) that only 16 percent, by notional value, of 

outstanding interest rate swaps were cleared in December 2007. With regard to index credit default 

swaps, most new transactions are being cleared—82 percent of notional value, as of January 2017.

An increase in the total volume of swaps effect CFTC workload as the agency must conduct trade 

practice and surveillance on a larger number of transactions. Cleared and uncleared swaps exhibit 

different types of risks, the proper mix of Commission resources depends on the absolute and relative 

sizes of these two types of transactions. (Uncleared swaps are bilateral trades between two entities, 

such as a transaction between a dealer and a customer. Cleared swaps act to reduce counterparty risk 

by replacing a swap between, for example, a dealer and a customer with one swap between the dealer 

and the central counterparty, and an offsetting swap between the customer and the central 

counterparty.)

Swap Volume, Cleared vs. Uncleared

Notional Amount ($ in Trillions)

Figure 15: Swaps Volume, Cleared vs. Uncleared

 

26 Data Source: CFTC Weekly Swaps Report located at http://www.cftc.gov/MarketReports/SwapsReports/index.htm. 
FY 2018 Budget Request

Appendix 6─Actively Traded Futures and Option Contracts 65

Actively Traded Futures & Option Contracts27

The number of actively traded contracts on U.S. exchanges (contracts that trade at least 10 contracts 

on at least one day in the year) has more than doubled in the last 10 years. As the number of actively 

traded contracts increases, CFTC workload also increases since the CFTC has to conduct market 

surveillance for a larger number of products.

Figure 16: Actively Traded Futures and Option Contracts

 

27 Data Source: CFTC Integrated Surveillance System
FY 2018 Budget Request

Appendix 6─Notional Value of Exchange Traded and OTC Contracts 66

Notional Value of Exchange-Traded and Over-the-Counter Contracts28

The notional value of the U.S. swaps markets, as reported in the CFTC weekly swaps report, is a 

significant portion of the global OTC market. U.S. swaps market data currently includes data from 

four SDRs and reflect data relating to interest rates and credit default swaps. The Commission expects 

to include additional SDRs and asset classes in the future. Notional values do not solely reflect risk. 

The aggregate notional value of swaps has declined in recent years due to compression activities that 

reduce the outstanding notional value while keeping economic exposures constant. Because 

exchange-traded and OTC contracts have different risk characteristics, the proper mix of Commission 

resources depends on the absolute and relative sizes of these two types of transactions.

The Commission’s ability to monitor derivatives trading activity has been enhanced in recent years 

with the development of SDRs. CFTC continues to work to render the data in a more useable form so 

that it can be used for economic analyses and to conduct market surveillance. 

Figure 17: Notional Value of Exchange-Traded and OTC Contracts

 

28 Source data: 

Global Exchange-Traded Futures and Options. Reflect interest rate and foreign exchange contracts globally, as reported by the 

Bank of International Settlements. 

U.S. Exchange-Traded Futures and Options. CFTC Integrated Surveillance System.

U.S. Swaps. Currently includes data from four swap data repositories and reflects data relating to interest rates and credit 

default swaps. The Commission expects to include additional swap data repositories and asset classes in the future.

Global OTC Contracts. Reflect OTC derivatives statistics from the Bank of International Settlements, which conducts a semiannual survey of central banks and other authorities from 13 jurisdictions about the size and structure of the largest OTC

derivatives markets.
FY 2018 Budget Request

Appendix 6─Customer Funds in FCM Accounts 67

Customer Funds in Futures Commission Merchants Accounts29

As a key component of the Commission’s regulatory framework, all customer funds held by an FCMs 

for trading on DCMs (exchanges) and SEFs must be segregated from the FCM’s own funds—this 

includes cash deposits and any securities or other property deposited by such customers to margin or 

guarantees their futures and cleared swaps trading. In addition, CFTC Regulation Part 30 requires 

FCMs to hold apart from their own funds a “secured amount” for customers trading futures contracts 

on FBOT through FCMs.

Figure 18: Customer Funds in FCM Accounts

 

29 Data Source: CFTC Monthly FCM Financial Reporting
FY 2018 Budget Request

Appendix 6─ Margin Requirements 68

Margin Requirements30

Initial Margin is the highly liquid collateral that holders of financial instruments must deposit with 

DCOs to cover the vast majority of the risk of their positions. Since the margin requirement is a direct 

estimate of risk for each portfolio, it is useful for monitoring trends at individual customers, clearing 

member firms and DCOs.

CFTC has observed increases in both the number of market participants it oversees, and the sizes of 

their cleared positions, leading to significant increases in margin requirements. Total cleared margin 

(futures and swaps combined) increased $77 billion, or 34 percent from the end of FY 2014 to the end 

of FY 2016.

Clearing of swaps has been growing more rapidly than futures due primarily to the 2013 swaps 

clearing mandates; total margin for cleared swaps alone increased by 45 percent from FY 2014 to FY 

2016.

DCOs only accept trades from their members. If a market participant is not a member of the DCO, it 

must clear through a member as its customer. Customer swap clearing has been growing very rapidly, 

nearly doubling between FY 2014 and FY 2016.

Figure 19: Margin Requirements

 

30 Data Source: Part 39 filings provided daily to CFTC by derivative clearing organizations. 
FY 2018 Budget Request

Appendix 6─Swap Execution Facilities Registered with the CFTC 69

Swap Execution Facilities Registered with the CFTC

The following SEFs currently meet the criteria and core principles for trading swaps by institutional 

participants. For each business day, each SEF electronically submits several data sets to the CFTC. 

These data sets are a major source of input to the Commission’s surveillance function and for input to 

other mission functions throughout the CFTC. In particular, under CFTC Rule 16.01, the SEFs provide 

trading volume, prices, and critical dates. 

The number of new contracts listed by SEFs each year will add to the surveillance workload in several 

ways. New contract terms and conditions have to be studied to fully understand of the product 

characteristics, support data for each contract has to be defined to the internal database systems, new 

analysis if appropriate needs to be developed and software engines may have to be modified. 

Swap Execution Facilities FY 2012 FY 2013 FY 2014 FY 2015 FY 2016 

360 Trading Networks, Inc 

Bats Hotspot SEF, LLC31

 

BGC Derivatives Markets, L.P.

 

Bloomberg SEF LLC 

Chicago Mercantile Exchange, Inc.

 

Clear Markets North America 

DW SEF LLC 

FTSEF LLC32

 

GFI swaps Exchange LLC 

GTX SEF LLC 

ICAP Global Derivatives Limited 

ICAp SEF (US) LLC 

ICE Swap Trade LLC 

LatAm SEF, LLC 

LedgerX SEF33

 

MarketAxess SEF Corporation 

Seed SEF LLC 

SwapExLLC 

TeraExchange, LLC 

 

31 Bats Hotspost SEF, LLC was granted registration under the name Javelin SEF, LLC. The SEF changed its name in 2017.

32 FT SEF was granted temporary registration on January 6, 2016 and was granted and full registration on May 26, 2016.

33 LedgerX withdrew its SEF registration on May 13, 2016 and stopped operating. It reapplied for SEF registration on January 

13, 2017.
FY 2018 Budget Request

Appendix 6─Swap Execution Facilities Registered with the CFTC 70

Swap Execution Facilities (Continued) FY 2012 FY 2013 FY 2014 FY 2015 FY 2016 

Thomson Reuters (SEF) LLC 

tpSEF Inc.

 

Tradition SEF, Inc.

 

trueEX LLC 

TW SEF LLC 

Total 0 16 22 23 23 

Table 21: Swap Execution Facilities
FY 2018 Budget Request

Appendix 6─Designated Contract Markets 71

Contract Markets Designated by the CFTC

The following DCMs are boards of trade or exchanges that meet the criteria and core principles for 

trading futures, options or swaps by both institutional and retail participants. Currently, 15 DCM

participants meet criteria and core principles for trading futures, options and swaps. For each 

business day, each DCM electronically submits several data sets to the CFTC. These data sets are a 

major source of input to the Commission’s surveillance function and for input to other mission 

functions throughout the Commission. Per CFTC Regulation 16.01, basic market level product data 

are submitted that includes open interest, trading volume, exchange of futures for related positions, 

delivery notices, option deltas, and prices. Per CFTC Regulation 16.00, clearing member end of day 

position data by proprietary and customer trading are received. Customer data is the aggregation of 

all customer positions cleared through the clearing member. Data elements include positions, bought 

and sold quantities, exchange of futures for related positions, and delivery notices. Per CFTC Rule 

16.02, each transaction occurring during the business day is submitted, and includes such elements as 

trade quantity, time of trade, price, market participant account numbers, etc. These data sets, along 

with end of day large trader data submitted daily by FCMs, clearing members, and foreign brokers, 

are loaded into internal database systems and analyzed using sophisticated software applications.

The number of new contracts listed by the DCMs each year adds to the surveillance workload in 

several ways. New contract terms and conditions have to be studied for full understanding of the 

product characteristics, support data for each contract has to be defined to the internal database 

systems, new analyses if appropriate need to be developed, and software engines may have to be 

modified. 

Designated Contract Market 2012 2013 2014 2015 2016 

Cantor Futures Exchange, L.P. CX 

Board of Trade of the City of Chicago CBOT 

Chicago Climate Futures Exchange, LLC CCFE 

CBOE Futures Exchange, Inc. CFE 

Chicago Mercantile Exchange, L.P. CME 

Commodity Exchange Inc. COMEX 

ELX Futures, L.P. ELX 

Eris Exchange, LLC ERISDCM 

Green Exchange, LLC34 GREENEX 

ICE Futures US, Inc.35 ICE US 

Kansas City Board of Trade KCBT 

Minneapolis Grain Exchange, Inc. MGE 

North American Derivatives Exchange, Inc. 36 NADEX 

 

34 Designation vacated in July 2012

35 Formerly, New York Board of Trade

36 Formerly, HedgeStreet, Inc.
FY 2018 Budget Request

Appendix 6─Designated Contract Markets 72

Designated Contract Market (Continued) 2012 2013 2014 2015 2016 

NASDAQ OMX Futures Exchange, Inc. 37 NFX 

New York Mercantile Exchange, Inc. NYMEX 

Nodel Exchange, LLC NEX 

NYSE Liffe US, LLC NYSE LIFFE 

OneChicago LLC Futures Exchange OCX 

The Trend Exchange TRENDEX 

trueEx LLC TRUEEX 

TOTAL 19 19 15 15 15 

Table 22: Contract Markets Designated by the CFTC

 

37 Formerly, Philadelphia Board of Trade
FY 2018 Budget Request

 

Appendix 6─Derivatives Clearing Organizations Registered with the CFTC 73

Derivatives Clearing Organizations Registered with the CFTC

A clearinghouse that seeks to provide clearing services with respect to futures contracts, options on 

futures contracts, or swaps must register with the CFTC as a DCO. AS of the end of FY 2016, 15 DCOs 

were registered with the CFTC. The Commission is currently processing two applications for DCO 

registration (both of which are from foreign clearinghouses) and expects to receive one or two more 

applications, in FY 2017. These numbers do not include foreign clearinghouses that have expressed 

an interest in receiving from the Commission an exemption from DCO registration. Any clearinghouse 

that receives such an exemption would still be subject to limited oversight by the Commission. 

The number of DCOs registered with the CFTC is on the rise due to the global nature of the swaps 

markets, and the significant growth in the size and importance of cleared markets in futures and 

swaps. The Commission’s first swaps clearing mandates, in the areas of interest rate swaps and credit 

default swaps, were issued in late 2012, and expanded in September 2016. As a result, the DCOs’ 

activities have become more complex as they have expanded their product offerings and increased 

their memberships. In addition, 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 substantial amounts of collateral 

that have been deposited by clearing members and the customers of those clearing members. Finally,

as cyber-security incidents increase in the financial market sector, the Commission must spend more 

time analyzing the events, updating the information security portion of the examination program, 

ensuring entities comply with Commission regulations, and updating the regulations to it

incorporates best practices established by the industry groups, such as the National Institute of 

Standards and Technology (NIST). 

As the number of DCOs increase, so does the number of quarterly financial resource reports, certified 

financial statements, chief compliance officer reports, and other event-driven notifications that are 

filed with the Commission as required under CFTC Regulation 39.19. The Commission must also risk 

assess an increasing number of DCOs to determine who will be examined. All of these activities 

require staff attention to monitor and analyze.

Finally, the Commission would like to automate and enhance some of the analysis, in particular in the 

area of back testing and stress testing, and is working on developing and creating systems that would 

help in this area. 

Derivatives Clearing Organizations 2012 2013 2014 2015 2016 

Cantor Clearinghouse L.P. Cantor Clearinghouse 

Chicago Board of Trade38 CBOT 

Clearing Corporation39 CCorp 

Chicago Mercantile Exchange , Inc. CME Clearing House 

CME Clearing Europe Limited40 CME Clearing Europe 

Eurex Clearing AG Eurex Clearing 

 

38 Registration vacated as of 8/6/2012

39 Dormant as of 2/5/2016

40 Registration vacated as of 3/13/2012. Reapplied as a DCO and application was approved 11/30/2016.
FY 2018 Budget Request

 

Appendix 6─Derivatives Clearing Organizations Registered with the CFTC 74

Derivatives Clearing Organizations (Continued) 2012 2013 2014 2015 2016 

ICE Clear Credit LLC ICE Clear Credit

 

ICE Clear Europe Ltd ICE Clear Europe 

ICE Clear US, Inc.41 ICE Clear US 

Kansas City Board of Trade Clearing Corp42 KCBT 

LCH, Clearnet LLC.43 LCH LLC 

LCH, Clearnet Ltd LCH Ltd 

LCH, Clearnet SA LCH SA 

Minneapolis Grain Exchange Inc. MGE 

 

Natural Gas Exchange Inc. NGX 

New York Portfolio Clearing, LLC NYPC 

Nodal Clear, LLC Nodal Clear

 

North American Derivatives

Exchange, Inc.44

NADEX 

NYMEX Clearing House45 NYMEX 

Options Clearing Corporation OCC 

Singapore Exchange Derivatives Clearing SGX-DC 

TOTAL 17 13 14 15 15 

Table 23: Derivatives Clearing Organizations Registered with the CFTC

 

41Formerly, New York Clearing Corporation

42 Registration vacated as of 4/16/2013

43Formerly, International Derivatives Clearinghouse LLC

44 Formerly, HedgeStreet, Inc.

45 Registration vacated as of 8/6/2012
FY 2018 Budget Request

 

Appendix 6─Systemically Important Derivatives Clearing Organizations 75

Systemically Important Derivatives Clearing Organizations46

A systemically important DCO is a DCO that is designated as a systemically important financial 

market utility (DFMU). Systemic importance is defined to mean a situation where the failure of or 

disruption to the functioning of the financial market utility could create, or increase, the risk of 

significant liquidity or credit problems spreading among financial institutions or markets and thereby 

threaten the stability of the U.S. financial system47. The Financial Stability Oversight Council was

granted the authority under Title VIII of the Dodd-Frank Act to designate those financial market 

utilities that are systemically important. In 2012, the Financial Stability Oversight Council made the 

determination that the entities listed below meet the designation criteria under Section 804 of the 

Dodd-Frank Act. The Supervisory Agency is the Federal agency that has primary jurisdiction over the 

systemically important financial market utility, and the CFTC is the Supervisory Agency for the two 

systemically important DCO’s listed in the table below. 

Under Section 807(a) of the Dodd-Frank Act, the Supervisory Agency is required to examine each 

DFMU at least once annually in order to determine the nature of the operations of and the risks borne 

by the DFMU; the financial and operational risks presented by the DFMU to financial institutions, 

critical markets, or the broader financial system; the resources and capabilities of the DFMU to 

monitor and control risks; the safety and soundness of the DFMU, and the DFMU’s compliance with 

Title VIII and the rules and orders prescribed thereunder.

In addition, the Supervisory Agency must consult with the Board of Governors of the Federal Reserve 

regarding the scope and methodology of each examination and the Board of Governors may 

participate in the examination led by the Supervisory Agency48.

In December of 2016, the Commission approved rules related to the resolution and recovery of the 

systemically important DCOs listed below. The Commission must develop an examination program to 

measure compliance with CFTC Regulation 39.39 and then must risk assess when it will measure 

compliance with the regulation during an examination. 

Systemically Important DCOs 2012 2013 2014 2015 2016 

Chicago Mercantile Exchange, Inc.

 

ICE Clear Credit, LLC 

TOTAL 2 2 2 2 2

Table 24: Systemically Important DCOs

 

46 The CFTC also considers two U.K.-based registered DCOs to be systemically important to the United States even though they 

have not been designated as such by FSOC. They are LCH.Clearnet Ltd. (LCH Ltd.) and ICE Clear Europe (ICEU).

47 See Section 803(9) of the Dodd-Frank Act.

48 See Section 807(d) of the Dodd-Frank Act.
FY 2018 Budget Request

 

Appendix 6─Exempt Derivatives Clearing Organizations 76

Exempt Derivatives Clearing Organizations

Section 5b(h) of the CEA permits the Commission to exempt, conditionally or unconditionally, a 

clearing organization from DCO registration for the clearing of swaps to the extent that the 

Commission determines that such clearing organization is subject to comparable, comprehensive 

supervision by appropriate government authorities in the clearing organization’s home country. As of

mid-FY 2017, the Commission has two pending petitions for exemption.

Exempt DCOs 2012 2013 2014 2015 2016 

ASX Clear (Futures) Pty Limited 

Japan Securities Clearing Corporation 

Korea Exchange, Inc. 

OTC Clearing Hong Kong Limited 

TOTAL 0 0 0 4 0

Table 25: Exempt DCOs
FY 2018 Budget Request

 

Appendix 6─Swap Data Repositories Registered with the CFTC 77

Swap Data Repositories Registered with the CFTC

SDRs are new entities created by the Dodd-Frank Act in order to provide a central facility for swap 

data reporting and recordkeeping. Under the Dodd-Frank Act, all swaps, whether cleared or 

uncleared, are required to be reported to registered SDRs. The Dodd-Frank Act added new Section 21 

to the CEA, governing registration and regulation of SDRs and establishing registration requirements 

and core duties and responsibilities for SDRs. The Commission, in turn, has promulgated the Part 49 

regulations implementing Section 21. SDRs are required to register with the CFTC and comply with 

rules promulgated by the CFTC, including public reporting of swap transaction and pricing data.

Swap Data Repositories 

(Pending – Provisional Registration) 2012 2013 2014 2015 2016 

BSDR LLC 

Chicago Mercantile Exchange Inc.

 

DTCC Data Repository, LLC 

ICE Trade Vault, LLC 

TOTAL 3 3 4 4 4

Table 26: Swap Data Repositories Registered with the CFTC
FY 2018 Budget Request

Appendix 6Number of Types of Swaps Data Loaded into CFTC Systems 78

Growth in Number of Types of Swaps Data49 Loaded onto CFTC Systems

The CFTC receives data from many entities, such as clearing members, swap dealers, DCO’s, large 

banks and traders in futures and options markets, SDRs and SEFs, many of which did not provide 

data prior to the Dodd-Frank Act. The amount of data received and loaded onto CFTC systems over 

six years has more than quadrupled. The CFTC plans to receive new data feeds and modernize 

existing data feeds during the current year. This will help it provide safe markets for all participants as 

the pace and complexity of products traded continues to increase. 

Figure 20: Number of Types of Swaps Data Loaded onto CFTC Systems

 

49 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.
FY 2018 Budget Request

Appendix 7Table of Acronyms 79

APPENDIX 7

Table of Acronyms

U.S. Federal Law

CEA Commodity Exchange Act 

Dodd-Frank Act Dodd-Frank Wall Street Reform and Consumer Protection Act 

FOIA Freedom of Information Act

CFTC Divisions and Offices

DCR Division of Clearing and Risk

DMO Division of Market Oversight 

DOE Division of Enforcement

DSIO Division of Swap Dealer and Intermediary Oversight

OCE Office of the Chief Economist

OCO Office of Consumer Outreach

ODT Office of Data and Technology

OED Office of the Executive Director 

OGC Office of the General Counsel 

OIA Office of International Affairs 

OIG Office of the Inspector General 

WBO Whistleblower Office 

U.S. Federal Departments and Agencies

CFTC U.S. Commodity Futures Trading Commission

OMB Office of Management and Budget

SEC U.S. Securities and Exchange Commission

Treasury U.S. Department of the Treasury

Other Abbreviations

CDM Continuous Diagnostics and Mitigation

CIGIE Council of the Inspectors General on Integrity and Efficiency

CME Chicago Mercantile Exchange

CPF CFTC Customer Protection Fund

CPO Commodity Pool Operator

CR Continuing Resolution

CSL Commission and Staff Letters Application

CTA Commodity Trading Advisor

DCM Designated Contract Market

DCO Derivatives Clearing Organization

DFMU Designated Financial Market Utility

DSRO Designated Self-Regulatory Organization

EU European Union

FBOT Foreign Board of Trade

FCM Futures Commission Merchant

FIA Futures Industry Association
FY 2018 Budget Request

Appendix 7Table of Acronyms 80

FinTech Financial Technology

FOREX Foreign Currency

FSB Financial Stability Board

FTE Full-time Equivalent

FX Foreign Exchange

FY Fiscal Year

IB Introducing Broker

IOSCO International Organization of Securities Commission

ISDA International Swaps and Derivatives Association

IT Information Technology

MSP Major Swap Participant

NIST National Institute of Standards and Technology

NFA National Futures Association

OTC Over-the-Counter

PPA Program, Project, and Activity

RFED Retail Foreign Exchange Dealer

SD Swap Dealer

SDR Swap Data Repository

SEF Swap Execution Facility

SIDCO Systemically Important Designated Contract Market

SRO Self-Regulatory Organization

TSD Transitional Swaps Database

UK United Kingdom