U.S. COMMODITY FUTURES TRADING COMMISSION

Three Lafayette Centre 

1155 21st Street, NW, Washington, DC 20581 

Telephone: (202) 418-5110

Page 1 of 2 

TO: Heath P. Tarbert, Chairman 

Brian D. Quintenz, Commissioner 

Rostin Behnam, Commissioner 

Dawn Stump, Commissioner 

Dan Berkovitz, Commissioner 

 

FROM: Miguel A. Castillo, CPA, CRMA

Assistant Inspector General for Auditing 

 

DATE: November 15, 2019

 

SUBJECT: CFTC Financial Statements Audit: Fiscal Year (FY) 2019

Annually the Office of the Inspector General (OIG) engages an independent 

public accountant (IPA) to perform a required audit of the Commodity Futures 

Trading Commission’s (CFTC) financial statements. We contracted Allmond & 

Company, LLC (Allmond & Co.) to audit the financial statements of the CFTC

as of September 30, 2019, and for the year then ended, to report on internal 

control over financial reporting and compliance with laws and regulations. We 

required that the audit be done in accordance with U.S. Generally Accepted 

Government Auditing Standards (GAGAS). 

In its audit, Allmond & Co. found: 

 The financial statements were fairly presented, in all material respects, in 

conformity with U.S. Generally Accepted Accounting Principles; 

 No deficiencies in internal control over financial reporting that are 

considered to be material or significant; 

 One reportable instance of noncompliance (and potential Anti-Deficiency) 

from FY 2018 that remained open, pending completion of an internal 

management review; and

 One item pertaining to information security training (included in a 

management letter).

In connection with the contract, we reviewed Allmond & Company’s report and 

related documentation and inquired of its representatives. Our review, as 

differentiated from an audit of the financial statements in accordance with U.S. 

GAGAS, was not intended to enable us to express, and we do not express, 
Page 2 of 2 

opinions on CFTC’s financial statements or internal control over financial 

reporting, or conclusions on whether CFTC’s financial management systems 

substantially complied with FFMIA requirements, or on compliance with laws 

and other matters. Allmond & Co. is responsible for the attached auditor’s

report dated November 7, 2019, and the conclusions expressed therein. 

However, our review disclosed no instances where Allmond & Co. did not 

comply, in all material respects, with GAGAS. 

Attached is a copy of Allmond & Co.’s unmodified (clean) opinion and 

management letter, and the financial statements of the CFTC. Please call me if 

you have any questions, at (202) 418-5084. 

Cc: 

Jamie Klima, Chief of Staff 

Kevin S. Webb, Chief of Staff 

John Dunfee, Chief of Staff 

Daniel Bucsa, Chief of Staff 

Erik Remmler, Chief of Staff 

Anthony C. Thompson, Executive Director 

Keith A. Ingram, Accounting Officer 

Melissa Jurgens, Chief, Executive Secretariat Branch 

A. Roy Lavik, Inspector General 

Judith A. Ringle, Deputy Inspector General and Chief Counsel 
1 

Independent Auditors’ Report

Chairman and Inspector General of 

U.S. Commodity Futures Trading Commission: 

 

Report on the Financial Statements

We have audited the accompanying financial statements of the U. S. Commodity Futures Trading 

Commission (CFTC), which comprise the balance sheets as of September 30, 2019 and 2018; the related 

statements of net cost, changes in net position, custodial activity, and budgetary resources for the fiscal 

years then ended, and the related notes to the financial statements (hereinafter referred to as the financial 

statements). 

Management’s Responsibility for the Financial Statements

Management is responsible for the preparation and fair presentation of these financial statements in 

accordance with accounting principles generally accepted in the United States of America; this 

responsibility includes the design, implementation, and maintenance of internal control relevant to the 

preparation and fair presentation of financial statements that are free from material misstatement, whether 

due to fraud or error. 

Auditors’ Responsibility 

Our responsibility is to express an opinion on the fiscal years 2019 and 2018 financial statements of 

CFTC based on our audits. We conducted our audits in accordance with auditing standards generally 

accepted in the United States of America; the standards applicable to financial audits contained in 

Government Auditing Standards issued by the Comptroller General of the United States; and Office of 

Management and Budget (OMB) Bulletin No. 19-03, Audit Requirements for Federal Financial 

Statements. Those standards and OMB Bulletin No. 19-03 require that we plan and perform the audit to 

obtain reasonable assurance about whether the financial statements are free from material misstatement. 

An audit involves performing procedures to obtain audit evidence about the amounts and disclosures in 

the financial statements. The procedures selected depend on the auditors' judgment, including the 

assessment of the risks of material misstatement of the financial statements, whether due to fraud or error. 

In making those risk assessments, the auditor considers internal control relevant to the entity' s 

preparation and fair presentation of the financial statements in order to design audit procedures that are 

appropriate in the circumstances, but not for the purpose of expressing an opinion on the effectiveness of 

the entity' s internal control. Accordingly, we express no such opinion. 

An audit also includes evaluating the appropriateness of the accounting policies used and the 

reasonableness of significant accounting estimates made by management, as well as the overall 

presentation of the financial statements.
Independent Auditors’ Report 

2 

We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for 

our audit opinion. 

Opinion

In our opinion, the financial statements referred to above present fairly, in all material respects, the 

financial position of the U.S. Commodity Futures Trading Commission as of September 30, 2019 and 

2018, and its net costs of operations, changes in net position, custodial activity, and budgetary resources 

for the fiscal years then ended in accordance with accounting principles generally accepted in the United 

States of America.

Other Matter

Required Supplementary Information

U.S. generally accepted accounting principles require that the information in the Message from the 

Chairman, Management and Discussion Analysis section, and Other Accompanying Information section 

of this report is presented to supplement the basic financial statements. Such information, although not a 

part of the basic financial statements, is required by the Federal Accounting Standards Advisory Board. 

We have applied certain limited procedures, which consisted principally of inquiries of management 

regarding the methods of preparing the information and comparing the information for consistency with 

management’s responses to our inquiries, the basic financial statements, and other knowledge we 

obtained during our audit of CFTC’s financial statements. However, we did not audit this information 

and, accordingly, we express no opinion on it. 

Other Reporting Required by Government Auditing Standards

Internal Control over Financial Reporting

In planning and performing our audit of CFTC’s financial statements as of and for the year ended 

September 30, 2019, in accordance with generally accepted government auditing standards, we 

considered CFTC’s internal control over financial reporting as a basis for designing audit procedures that 

are appropriate in the circumstances for the purpose of expressing our opinion on the financial statements, 

but not for the purpose of expressing an opinion on the effectiveness of CFTC’s internal control over 

financial reporting. Accordingly, we do not express an opinion on the effectiveness of CFTC’s internal 

control over financial reporting. We limited internal control testing to those necessary to achieve the 

objectives described in OMB Bulletin No. 19-03. We did not test all internal control relevant to operating 

objectives as broadly defined by the Federal Managers’ Financial Integrity Act of 1982.

A deficiency in internal control exists when the design or operation of a control does not allow 

management or employees, in the normal course of performing their assigned functions, to prevent, or 

detect and correct misstatements on a timely basis. A material weakness is a deficiency, or a combination 

of deficiencies, such that there is a reasonable possibility that a material misstatement of the entity's 

financial statements will not be prevented, or detected and corrected, on a timely basis. A significant 

deficiency is a deficiency, or a combination of deficiencies, in internal control that is less severe than a 

material weakness, yet important enough to merit attention by those charged with governance. 

Our consideration of internal control over financial reporting was for the limited purpose as described in 

the first paragraph of this section and was not designed to identify all deficiencies in internal control over 

financial reporting that might be material weaknesses or significant deficiencies and therefore material 
Independent Auditors’ Report 

3 

weaknesses or significant deficiencies may exist that were not identified. Given these limitations, during 

our fiscal year 2019 audit we did not identify any deficiencies in internal control over financial reporting 

that we considered to be material weaknesses, as defined above. However, material weaknesses may exist 

that have not been identified. 

Compliance and Other Matters

As part of obtaining reasonable assurance about whether CFTC’s fiscal year 2019 financial statements are 

free of material misstatements, we performed tests of CFTC’s compliance with certain provisions of 

applicable laws, regulations, contracts, and grant agreements, which noncompliance could have a direct 

and material effect on the determination of material amounts and disclosures in CFTC’s financial 

statements, and certain provisions of other laws specified in OMB Bulletin No. 19-03. However, 

providing an opinion on compliance with those provisions was not an objective of our audit, and 

accordingly, we do not express such an opinion. 

The results of our tests of compliance as described in the preceding paragraph, disclosed an instance of 

noncompliance or other matters that is required to be reported herein under Government Auditing 

Standards or OMB Bulletin No. 19-03 and which is described in Exhibit I. 

Purpose of the Other Reporting Required by Government Auditing Standards

The purpose of the communication described in the Other Reporting Required by Government Auditing 

Standards section is solely to describe the scope of our testing of internal control and compliance with 

selected provision of applicable laws, regulations, contracts, and grant agreements, and the results of that 

testing, and not to provide an opinion on the effectiveness of CFTC's internal control or on compliance. 

This communication is an integral part of an audit performed in accordance with U.S. generally accepted 

government auditing standards in considering internal controls and compliance with laws, regulations, 

contracts, and grant agreements which could have a material effect on CFTC’s financial statements. 

Accordingly, this communication is not suitable for any other purpose.

Allmond & Company, LLC

November 7, 2019 

Lanham, MD
Independent Auditors’ Report 

Exhibit I

Compliance and Other Matters

4 

Potential Anti-deficiency Act (ADA) violation 

One management review is ongoing within the agency, which has or may identify an ADA violation, as 

follows: 

• In FY 2014, CFTC did not freeze the pay of certain senior official pursuant to an FY 2014 

government wide appropriation provision that has remained in each subsequent appropriation 

including FY 2018 appropriation. This issue is under management review. 

Title 31 U.S. Code (U.S.C.) Section 1517 Prohibited Obligations and Expenditures states:

(a) An officer or employee of the United States Government or of the District of Columbia 

government may not make or authorize an expenditure or obligation exceeding – 

(1) An apportionment; or

(2) The amount permitted by regulations prescribed under section 1514(a) of this title. 

(b) If an officer or employee of an executive agency or of the District of Columbia government 

violates subsection (a) of this section, the head of the executive agency or the Mayor of the 

District of Columbia, as the case may be, shall report immediately to the President and Congress 

all relevant facts and a statement of actions taken. A copy of each report shall also be transmitted 

to the Comptroller General on the same date the report is transmitted to the President and 

Congress.

Recommendation: We recommend that CFTC’s management complete the investigation into the potential 

ADA violation noted and report to the appropriate parties, as necessary. 

MANAGEMENT’S RESPONSE

Management concurs with the recommendation.
Independent Auditors’ Report 

Exhibit I

Status of Prior Year Findings and Recommendations

5 

The following table provides the fiscal year (FY) 2019 status of all recommendations included in the 

Independent Auditors' Report on the Commodity Futures Trading Commission’s FY 2018 Financial

Statements (November 8, 2018). 

FY 2018

Finding

FY 2018 Recommendation FY 2019

Status

Potential

AntiDeficiency Act 

Violation

Recommendation: 

Complete the investigation into the potential ADA violation noted and 

report to the appropriate parties, as necessary.

Open
MANAGEMENT LETTER REPORT

Chairman and Inspector General of 

U.S. Commodity Futures Trading Commission: 

We audited the U.S. Commodity Futures Trading Commission (CFTC) financial statement as of 

September 30, 2019 and 2018 and issued our report dated November 7, 2019 to CFTC under separate 

cover. 

In planning and performing our audit, we considered CFTC’s internal controls to determine 

auditing procedures for the purpose of expressing an opinion on the financial statements and not to 

provide assurance on the internal controls. Though not considered to be a material weakness or significant 

deficiency, we noted additional matters involving internal control that is presented in this letter for 

CFTC’s management’s attention and consideration. 

 The purpose of this report is solely for the information and use of CFTC management. We 

appreciate your assistance and cooperation during the audit and look forward to serving you in the near 

future. 

Sincerely, 

Allmond & Company, LLC

Lanham, MD 

November 7, 2019 
Management Letter Report

1 

Allmond & Company audited the balance sheet of the U.S. Commodity Futures Trading 

Commission (CFTC) as of September 30, 2019 and 2018, and the related statements of net cost, changes 

in net position, and budgetary resources for the fiscal years then ended; and the related notes to the 

financial statements (the consolidated financial statements).We noted one matter involving internal 

control in CFTC’s operations that we think warrant management’s attention; however, this issue was not 

considered either a significant deficiency or a material weakness. 

Under standards issued by the American Institute of Certified Public Accountants, a deficiency in 

internal control exists when the design or operation of a control does not allow management or 

employees, in the normal course of performing their assigned functions, to prevent, or detect and correct 

misstatement on a timely basis. A material weakness is a deficiency, or combination of deficiencies, such 

that there is a reasonable possibility that a material misstatement of the entity’s financial statements will 

not be prevented, or detected and corrected, on a timely basis. A significant deficiency is a deficiency or a 

combination of deficiencies, in internal control that is less severe than a material weakness yet important 

enough to merit the attention by those charged with governance. However, we noted the following 

deficiency during our audit: 

1. Improvements needed in enforcing the policy requiring security awareness training. This condition is

discussed in detail in the finding outlined below: 

FINDING 1: Improvements Needed in Enforcing Policy Requiring Security Awareness Training

CONDITION

CFTC did not disable the accounts of four (4) employees who were in past due status as a result of not 

completing the 2019 Mandatory Cyber-security & Privacy Awareness Training by October 18, 2019.

CRITERIA

1. National Institute of Standards and Technology (NIST) Special Publication (SP) 800-53, Revision 4, 

Security and Privacy Controls for Federal Information Systems and Organizations, Section AT-2- 

Security Awareness Training states that:

The organization provides basic security awareness training to information system users (including 

managers, senior executives, and contractors):

a. As part of initial training for new users; 

b. When required by information system changes; and

c. [Assignment: organization-defined frequency] thereafter.

2. National Institute of Standards and Technology (NIST) Special Publication (SP) 800-53, Revision 4, 

Security and Privacy Controls for Federal Information Systems and Organizations, Section AC-2- Access 

Control states that:

 The organization:
Management Letter Report

2 

f. Creates, enables, modifies, disables, and removes information system accounts in accordance with 

[Assignment: organization-defined procedures or conditions]; 

j. Reviews accounts for compliance with account management requirements [Assignment: organizationdefined frequency];

CAUSE

CFTC did not enforce their policy of disabling user accounts when employees have not completed the 

annual Security Awareness Training by the required date.

EFFECT

The confidentiality, integrity, privacy and security of data at the agency are potentially affected. 

RECOMMENDATION

We recommend that CFTC’s management work closely with the ODT on an annual basis to ensure each 

employee has completed the Security Awareness Training by the required date and to obtain a report

depicting user accounts that have been disabled for non-compliance with the annual security awareness 

training.

MANAGEMENT RESPONSE

Management concurs with the recommendation.

AUDITORS’ RESPONSE

We will conduct follow-up procedures in FY 2020 to determine whether corrective actions have been 

developed and implemented. 
Management Letter Report

Appendix A 

Status of Prior Year Findings and Recommendations 

3 

The following table provides the fiscal year (FY) 2019 status of all recommendations included in the FY 

2018 Management Letter Report.

FY 2018 Finding FY 2018 Recommendation FY 2019 Status

Improvements are needed in 

Maintaining Time and 

Attendance Records

Recommendation: We 

recommend that CFTC’s 

management: 

1. Review its current policies 

and procedures related to 

preparation, submission and 

approval of Requests for 

Leave to ensure that they are 

aligned with OPM’s and 

GAO’s requirements. 

2. Provide training to 

employees and supervisors 

on the process of preparing 

and approving Requests for 

Leave and how to verify that 

the leave that appears on the 

Time and Attendance Report 

has an accompanying 

approved leave request prior 

to approving employees’ 

T&A’s in webTA.

3. Coordinate with the service 

provider to enable the Time 

and Attendance system to 

prevent the supervisors from 

being able to approve T&A’s 

when a Validation Warning 

appears on the T&A report.

Closed

Improvements needed in 

maintaining the Property, Plant 

and Equipment 

Recommendation: We 

recommend that CFTC’s 

management update their

physical inventory records at the 

completion of the annual 

physical inventory.

Closed
Commodity Futures Trading Commission

FY 2019

Financial Statements and Notes

as of and for the Years Ended 

September 30, 2019 and 2018

Version - 01

Statement Run Date: 10/24/2019 9:52:49 AM

Prepared by: CFTC Accounting Office
FY 2019 Agency Financial Report

 COMMODITY FUTURES TRADING COMMISSION

Financial Highlights

The following chart is an overview of the Commission’s financial position, preceding a discussion of 

the agency’s financial highlights for fiscal year 2019: 

2019 2018

 CONDENSED BALANCE SHEET DATA

Fund Balance with Treasury $ 86,407,483 $ 66,320,101

Investments 141,300,000 157,518,375

Accounts Receivable, Net 54,582 44,667

Prepayments 5,693,295 4,145,426

Custodial Receivables, Net 51,364,449 11,497,175

General Property, Plant and Equipment, Net 29,738,196 35,176,845

 TOTAL ASSETS $ 314,558,005 $ 274,702,589

Accounts Payable $ 21,419,590 $ 10,575,642

FECA Liabilities 564,109 539,092

Accrued Payroll and Annual Leave 19,885,383 17,618,256

Custodial Liabilities 51,364,449 11,497,175

Deposit Fund Liabilities 445,754 369,175

Deferred Lease Liabilities 21,494,054 23,970,026

Liability for Whistleblower Awards 20,280,146 4,913,875

Contingent Liabilities - 38,696

 Total Liabilities $ 135,453,485 $ 69,521,937

Unexpended Appropriations - All Other Funds $ 58,465,701 $ 47,626,826

Cumulative Results of Operations - Funds from Dedicated Collections 125,439,162 158,337,598

Cumulative Results of Operations - All Other Funds (4,800,343) (783,772)

Total Net Position $ 179,104,520 $ 205,180,652

 TOTAL LIABILITIES AND NET POSITION $ 314,558,005 $ 274,702,589

 CONDENSED STATEMENTS OF NET COST

Gross Costs $ 301,553,671 $ 305,304,023

Earned Revenue (248,915) (42,739)

 TOTAL NET COST OF OPERATIONS $ 301,304,756 $ 305,261,284

 NET COST BY STRATEGIC GOAL

Goal One - Market Integrity and Transparency $ 67,476,123 $ 65,351,841

Goal Two - Financial Integrity and Avoidance of Systemic Risk 90,364,976 89,433,103

Goal Three - Comprehensive Enforcement 129,854,799 136,287,044

Goal Four - Domestic and International Cooperation and Coordination 13,608,858 14,189,296

 TOTAL NET COST OF OPERATIONS $ 301,304,756 $ 305,261,284

Figure 1: Financial Summary
PRINCIPAL FINANCIAL STATEMENTS

Commodity Futures Trading Commission

BALANCE SHEETS

As of September 30, 2019 and 2018 

1 COMMODITY FUTURES TRADING COMMISSION

ASSETS

Intragovernmental:

Fund Balance With Treasury (Note 2) $ 86,407,483 $ 66,320,101

Investments (Note 3) 141,300,000 157,518,375

Accounts Receivable (Note 4) 1,167 3,692

Prepayments (Note 1H) 2,663,914 1,596,970

Total Intragovernmental 230,372,564 225,439,138

Custodial Receivables, Net (Note 4) 51,364,449 11,497,175

Accounts Receivable, Net (Note 4) 53,415 40,975

General Property, Plant and Equipment, Net (Note 5) 29,738,196 35,176,845

Prepayments (Note 1H) 3,029,381 2,548,456

TOTAL ASSETS $ 314,558,005 $ 274,702,589

LIABILITIES

Intragovernmental:

Accounts Payable $ 436,014 $ 454,015

Custodial Liabilities 51,364,449 11,497,175

Employer Contributions and Payroll Taxes Payable 1,432,636 1,171,806

FECA Liabilities (Note 1N) 85,660 84,533

Total Intragovernmental 53,318,759 13,207,529

Accounts Payable 20,983,576 10,121,627

Actuarial FECA Liabilities (Note 1N) 478,449 454,559

Accrued Payroll 5,779,774 4,901,912

Annual Leave 12,672,973 11,544,538

Deferred Lease Liabilities (Note 7) 21,494,054 23,970,026

Liability for Whistleblower Awards (Note 8) 20,280,146 4,913,875

Deposit Fund Liabilities 445,754 369,175

Contingent Liabilities (Note 9) - 38,696

Total Liabilities $ 135,453,485 $ 69,521,937

NET POSITION

Unexpended Appropriations - All Other Funds $ 58,465,701 $ 47,626,826

Cumulative Results of Operations - Funds from Dedicated Collections 125,439,162 158,337,598

Cumulative Results of Operations - All Other Funds (4,800,343) (783,772)

 Total Net Position - Funds from Dedicated Collections (Note 12) $ 125,439,162 $ 158,337,598

 Total Net Position - All Other Funds 53,665,358 46,843,054

Total Net Position $ 179,104,520 $ 205,180,652

TOTAL LIABILITIES AND NET POSITION $ 314,558,005 $ 274,702,589

The accompanying notes are an integral part of these financial statements.

2019 2018
FY 2019 Agency Financial Report

 2 COMMODITY FUTURES TRADING COMMISSION

Commodity Futures Trading Commission

STATEMENTS OF NET COST

For the Years Ended September 30, 2019 and 2018

2019 2018

NET COST BY GOAL

GOAL ONE: MARKET INTEGRITY AND TRANSPARENCY

Gross Costs $ 67,538,202 $ 65,362,175

Less: Earned Revenue (62,079) (10,334)

NET COST OF OPERATIONS -- GOAL ONE $ 67,476,123 $ 65,351,841

GOAL TWO: FINANCIAL INTEGRITY AND AVOIDANCE OF SYSTEMIC RISK

Gross Costs $ 90,448,114 $ 89,447,245

Less: Earned Revenue (83,138) (14,142)

NET COST OF OPERATIONS -- GOAL TWO $ 90,364,976 $ 89,433,103

GOAL THREE: COMPREHENSIVE ENFORCEMENT

Gross Costs $ 129,945,977 $ 136,303,063

Less: Earned Revenue (91,178) (16,019)

NET COST OF OPERATIONS -- GOAL THREE $ 129,854,799 $ 136,287,044

GOAL FOUR: DOMESTIC AND INTERNATIONAL COOPERATION AND COORDINATION

Gross Costs $ 13,621,378 $ 14,191,540

Less: Earned Revenue (12,520) (2,244)

NET COST OF OPERATIONS -- GOAL FOUR $ 13,608,858 $ 14,189,296

GRAND TOTAL

Gross Costs $ 301,553,671 $ 305,304,023

Less: Earned Revenue (248,915) (42,739)

TOTAL NET COST OF OPERATIONS $ 301,304,756 $ 305,261,284

The accompanying notes are an integral part of these financial statements.
FY 2019 Agency Financial Report

 COMMODITY FUTURES TRADING COMMISSION 3

Commodity Futures Trading Commission

STATEMENTS OF CHANGES IN NET POSITION

For the Years Ended September 30, 2019 and 2018 

Dedicated Collections All Other Funds Consolidated Total

UNEXPENDED APPROPRIATIONS:

BEGINNING BALANCES, OCTOBER 1 $ 

 

 - $ 47,626,826 $ 47,626,826

BUDGETARY FINANCING SOURCES:

Appropriations Received - 268,000,000 268,000,000

Other Adjustments (+/-) - (4,032,357) (4,032,357)

Appropriations Used - (253,128,768) (253,128,768)

 Total Budgetary Financing Sources - 10,838,875 10,838,875

TOTAL UNEXPENDED APPROPRIATIONS, SEPTEMBER 30 $ - $ 58,465,701 $ 58,465,701

CUMULATIVE RESULTS OF OPERATIONS:

BEGINNING BALANCES, OCTOBER 1 $ 158,337,598 $ (783,772) $ 157,553,826

BUDGETARY FINANCING SOURCES:

Appropriations Used - 253,128,768 253,128,768

Nonexchange Interest Revenue (Note 3) 3,206,457 - 3,206,457

OTHER FINANCING SOURCES:

Imputed Financing Sources (Note 1M) - 8,054,524 8,054,524

 Total Financing Sources 3,206,457 261,183,292 264,389,749

Net Cost of Operations (36,104,893) (265,199,863) (301,304,756)

Net Change (32,898,436) (4,016,571) (36,915,007)

TOTAL CUMULATIVE RESULTS OF OPERATIONS, SEPTEMBER 30 $ 125,439,162 $ (4,800,343) $ 120,638,819

NET POSITION $ 125,439,162 $ 53,665,358 $ 179,104,520

Dedicated Collections All Other Funds Consolidated Total

UNEXPENDED APPROPRIATIONS:

BEGINNING BALANCES, OCTOBER 1 $ - $ 50,591,522 $ 50,591,522

BUDGETARY FINANCING SOURCES:

Appropriations Received - 249,000,000 249,000,000

Other Adjustments (+/-) - (454,135) (454,135)

Appropriations Used - (251,510,561) (251,510,561)

 Total Budgetary Financing Sources - (2,964,696) (2,964,696)

TOTAL UNEXPENDED APPROPRIATIONS, SEPTEMBER 30 $ - $ 47,626,826 $ 47,626,826

CUMULATIVE RESULTS OF OPERATIONS:

BEGINNING BALANCES, OCTOBER 1 $ 196,336,209 $ 4,225,293 $ 200,561,502

BUDGETARY FINANCING SOURCES:

Appropriations Used - 251,510,561 251,510,561

Nonexchange Interest Revenue (Note 3) 3,447,675 - 3,447,675

OTHER FINANCING SOURCES:

Imputed Financing Sources (Note 1M) - 7,295,372 7,295,372

 Total Financing Sources 3,447,675 258,805,933 262,253,608

Net Cost of Operations (41,446,286) (263,814,998) (305,261,284)

Net Change (37,998,611) (5,009,065) (43,007,676)

TOTAL CUMULATIVE RESULTS OF OPERATIONS, SEPTEMBER 30 $ 158,337,598 $ (783,772) $ 157,553,826

NET POSITION $ 158,337,598 $ 46,843,054 $ 205,180,652

The accompanying notes are an integral part of these financial statements.

2018

2019
FY 2019 Agency Financial Report

 4 COMMODITY FUTURES TRADING COMMISSION

Commodity Futures Trading Commission

STATEMENTS OF BUDGETARY RESOURCES

For the Years Ended September 30, 2019 and 2018 

BUDGETARY RESOURCES

 Unobligated Balance from Prior Year Budget Authority, Net (Note 10A) $ 23,928,531 $ 80,863,263

 Appropriations 268,000,000 249,000,000

 Spending Authority from Offsetting Collections 3,216,362 3,251,946

TOTAL BUDGETARY RESOURCES $ 295,144,893 $ 333,115,209

STATUS OF BUDGETARY RESOURCES

 New Obligations and Upward Adjustments $ 268,029,495 $ 310,043,029

 Unobligated Balance, End of Year

Apportioned, Unexpired Accounts 142,982,838 160,197,074

Unapportioned, Unexpired Accounts (126,714,806) (149,078,415)

Unexpired Unobligated Balance, End of Year 16,268,032 11,118,659

Expired Unobligated Balance, End of Year 10,847,366 11,953,521

 Unobligated Balance, End of Year (Total) 27,115,398 23,072,180

TOTAL BUDGETARY RESOURCES $ 295,144,893 $ 333,115,209

OUTLAYS, NET

Outlays, Net 260,156,840 327,283,911

Distributed Offsetting Receipts (14,569) (1,939)

AGENCY OUTLAYS, NET $ 260,142,271 $ 327,281,972

The accompanying notes are an integral part of these financial statements.

2019 2018
FY 2019 Agency Financial Report

 COMMODITY FUTURES TRADING COMMISSION 5

Commodity Futures Trading Commission

STATEMENTS OF CUSTODIAL ACTIVITY

For the Years Ended September 30, 2019 and 2018 

2019 2018

TOTAL CUSTODIAL REVENUE

SOURCES OF CASH COLLECTIONS:

 Registration and Filing Fees $ 2,243,849 $ 602,108

 Fines, Penalties, and Forfeitures 47,229,052 856,913,686

 General Proprietary Receipts 14,569 1,939

Total Cash Collections 49,487,470 857,517,733

Change in Custodial Receivables 39,867,274 6,214,855

TOTAL CUSTODIAL REVENUE $ 89,354,744 $ 863,732,588

DISPOSITION OF COLLECTIONS

AMOUNTS TRANSFERRED TO:

 Department of the Treasury $ (49,487,470) $ (857,517,733)

Total Disposition of Collections (49,487,470) (857,517,733)

Change in Custodial Liabilities (39,867,274) (6,214,855)

NET CUSTODIAL ACTIVITY $ - $ -

The accompanying notes are an integral part of these financial statements.
NOTES TO THE FINANCIAL STATEMENTS 

As of and for the Fiscal Years Ended September 30, 2019 and 2018

 6 COMMODITY FUTURES TRADING COMMISSION

Note 1 Summary of Significant Accounting Policies 

A. Reporting Entity

The Commodity Futures Trading Commission (CFTC or Commission) is an independent agency of 

the executive branch of the Federal Government. Congress created the CFTC in 1974 under the 

authorization of the Commodity Exchange Act (CEA) with the mandate to regulate commodity 

futures and option markets in the United States. The agency’s mandate was renewed and 

expanded under the Futures Trading Acts of 1978, 1982, and 1986; under the Futures Trading 

Practices Act of 1992; under the CFTC Reauthorization Act of 1995; under the Commodity Futures 

Modernization Act of 2000; and under the Dodd-Frank Wall Street Reform and Consumer 

Protection Act of 2010 (Dodd-Frank Act, or the Act). Congress passed the Food, Conservation, and 

Energy Act of 2008, which reauthorized the Commission through FY 2013. In the absence of 

formal reauthorization, CFTC has continued to operate through annual appropriations. 

The CFTC is responsible for ensuring the economic utility of futures markets by encouraging their 

competitiveness and efficiency, ensuring their integrity, and protecting market participants against 

manipulation, abusive trade practices, and fraud. 

On July 21, 2010, the Dodd-Frank Act was signed into law, significantly expanding the powers and 

responsibilities of the CFTC. According to Section 748 of the Act, there is established in the U.S. 

Department of the Treasury (Treasury) a revolving fund known as the CFTC Customer Protection 

Fund. The Customer Protection Fund shall be available to the Commission, without further 

appropriation or fiscal year limitation, for a) the payment of awards to whistleblowers; and b) the 

funding of customer education initiatives designed to help customers protect themselves against 

fraud or other violations of this Act or the rules and regulations thereunder. 

B. Basis of Presentation 

The financial statements have been prepared to report the financial position and results of 

operations for the CFTC, as required by the Accountability of Tax Dollars Act of 2002. They are 

presented in accordance with the form and content requirements contained in OMB Circular A136, Financial Reporting Requirements, as amended. 

The principal financial statements have been prepared in all material respects from the agency’s 

books and records in conformity with U.S. generally accepted accounting principles (GAAP), as 

prescribed for the Federal government by the Federal Accounting Standards Advisory Board 

(FASAB). The application and methods for applying these principles are appropriate for 

presenting fairly the entity’s assets, liabilities, financial position, net cost of operations, changes in 

net position, budgetary resources, and custodial activities. Accounting standards allow certain 

presentations and disclosures to be modified, if needed, to prevent the disclosure of classified 

information. 

The books and records of the agency served as the source of information for preparing the financial 

statements in the prescribed formats. All agency financial statements and reports used to monitor 

and control budgetary resources are prepared from the same books and records. The statements 

should be read with the understanding that they are for a component of the U.S. Government, a 

sovereign entity.
FY 2019 Agency Financial Report

 COMMODITY FUTURES TRADING COMMISSION 7

The Balance Sheets present the financial position of the agency. The Statements of Net Cost 

present the agency’s operating results; the Statements of Changes in Net Position display the 

changes in the agency’s equity accounts. The Statements of Budgetary Resources present the 

sources, status, and uses of the agency’s resources and follow the rules for the Budget of the U.S.

Government. The Statements of Custodial Activity present the sources and disposition of 

collections for which the CFTC is the fiscal agent, or custodian, for the Treasury General Fund 

Miscellaneous Receipt accounts.

Throughout these financial statements, assets, liabilities, revenues and costs have been classified 

according to the type of entity with whom the transactions were made. Intragovernmental assets 

and liabilities are those from or to other federal entities. Intragovernmental earned revenues are 

collections or accruals of revenue from other federal entities, and intragovernmental costs are 

payments or accruals to other federal entities. The CFTC does not transact business among its own 

operating units, and therefore, intra-entity eliminations were not needed. 

C. Budgetary Resources and Status 

The CFTC is funded through congressionally approved appropriations. The CFTC is responsible 

for administering the salaries and expenses of the agency through the execution of these 

appropriations. 

Congress annually enacts appropriations that provide the CFTC with the authority to obligate 

funds within the respective fiscal year for necessary expenses to carry out mandated program 

activities. All appropriations are subject to quarterly apportionment as well as Congressional 

restrictions. 

The CFTC’s budgetary resources for FY 2019 consist of: 

 Unobligated balances of resources brought forward from the prior year, 

 Recoveries of obligations made in prior years, and 

 New resources in the form of appropriations and spending authority from offsetting 

collections. 

Unobligated balances associated with resources expiring at the end of the fiscal year remain 

available for five years after expiration only for upward adjustments of prior year obligations, after 

which they are canceled and may not be used. All unused monies related to canceled 

appropriations are returned to Treasury and the canceled authority is reported on the Statements 

of Budgetary Resources and the Statements of Changes in Net Position.

D. Entity and Non-Entity Assets 

Assets consist of entity and non-entity assets. Entity assets are those assets that the CFTC has 

authority to use for its operations. Non-entity assets are those held by the CFTC that are not 

available for use in its operations. Non-entity assets held by the CFTC include deposit fund 

balances, custodial fines, interest, penalties, and administrative fees receivable. 

E. Fund Balance with Treasury 

Fund Balance with Treasury is the aggregate amount of the CFTC’s funds with Treasury in general, 

receipt, revolving, and deposit fund accounts. Appropriated funds recorded in general fund 

expenditure accounts are available to pay current liabilities and finance authorized purchases. 

Revolving fund custodial collections recorded in the deposit fund and miscellaneous receipts 

accounts of the Treasury are not available for agency use. At fiscal year-end, receipt account 

balances are returned to Treasury or transferred to the Customer Protection Fund. 

The CFTC does not maintain bank accounts of its own, has no disbursing authority, and does not 

maintain cash held outside of Treasury. Treasury disburses funds for the agency on demand. 
FY 2019 Agency Financial Report

 8 COMMODITY FUTURES TRADING COMMISSION

Spending authority from offsetting collections is recorded in the agency’s expenditure account and 

is available for agency use subject to certain limitations. 

F. Investments

The CFTC has the authority to invest amounts deposited in the Customer Protection Fund in shortterm market-based Treasury securities. Market-based Treasury securities are debt securities that 

the Treasury issues to Federal entities without statutorily determined interest rates. Although the 

securities are not marketable, the terms (prices and interest rates) mirror the terms of marketable 

Treasury securities. Investments are carried at their historical cost basis which approximates fair 

value due to their short-term nature.

Interest earned on the investments is a component of the Fund and is available to be used for 

expenses of the Customer Protection Fund. Additional details regarding Customer Protection Fund 

investments are provided in Note 3. 

G. Accounts Receivable, Net 

Accounts receivable consists of amounts owed by other federal agencies and the public to the CFTC 

and is valued net of an allowance for uncollectible amounts. The allowance is based on past 

experience in the collection of receivables and analysis of the outstanding balances. Accounts 

receivable arise from reimbursable operations, earned refunds or the Civil Monetary Sanctions 

program. 

H. Prepayments

Payments to federal and non-federal sources in advance of the receipt of goods and services are 

recorded as prepayments and recognized as expenses when the related goods and services are 

received. Intragovernmental prepayments reported on the Balance Sheet were made primarily to 

the U.S. Department of Interior for contract support. Prepayments to the public were primarily for 

software maintenance and subscription services. 

I. General Property, Plant and Equipment, Net

Furniture, fixtures, equipment, information technology hardware and software, and leasehold 

improvements are capitalized and depreciated or amortized over their useful lives. 

The CFTC capitalizes assets annually if they have useful lives of at least two years and an individual 

value of $25,000 or more. Bulk or aggregate purchases are capitalized when the individual useful 

lives are at least two years and the purchase is a value of $25,000 or more. Property, plant and 

equipment that do not meet the capitalization criteria are expensed when acquired. Depreciation 

for equipment and amortization for software is computed on a straight-line basis using a 5-year 

life. Leasehold improvements are amortized over the remaining life of the lease. The Commission’s 

assets are valued net of accumulated depreciation or amortization.

J. Liabilities

The CFTC’s liabilities consist of actual and estimated amounts that are likely to be paid as a result 

of transactions covered by budgetary resources for which Congress has appropriated funds or 

funding, or are otherwise available from reimbursable transactions to pay amounts due. 

Liabilities include those covered by budgetary resources in existing legislation, those not requiring 

budgetary resources, and those not yet covered by budgetary resources. The CFTC liabilities not 

requiring budgetary resources include deferred lease liabilities, deposit funds, and custodial 
FY 2019 Agency Financial Report

 COMMODITY FUTURES TRADING COMMISSION 9

revenue deemed collectible but not yet collected at fiscal year-end. Liabilities that are not yet 

covered by budgetary resources but will require budgetary resources in the future include: 

 Intragovernmental Federal Employees’ Compensation Act (FECA) liabilities, 

 Annual leave benefits that will be funded by annual appropriations as leave is taken,

 Actuarial FECA liabilities,

 Liability for whistleblower awards,

 Contingent liabilities, and

 Advances received for reimbursable services yet to be provided.

K. Accounts Payable 

Accounts payable consists primarily of contracts for goods or services, such as operating leases, 

leasehold improvements, software development, information technology, telecommunications, and 

consulting and support services. 

L. Accrued Payroll and Benefits and Annual Leave Liability 

 

The accrued payroll liability represents amounts for salaries and benefits owed for the time since 

the payroll was last paid through the end of the reporting period. Total accrued payroll is 

composed of amounts to be paid to CFTC employees as well as the related intragovernmental 

payable for employer contributions and payroll taxes. The annual leave liability is the amount 

owed to employees for unused annual leave as of the end of the reporting period. At the end of 

each quarter, the balance in the accrued annual leave account is adjusted to reflect current 

balances and pay rates. Sick leave and other types of non-vested leave are expensed as taken.

The agency’s employees participate in the Civil Service Retirement System (CSRS) or the Federal 

Employees’ Retirement System (FERS). On January 1, 1987, FERS went into effect pursuant to 

Public Law 99-335. Most employees hired after December 31, 1983, are automatically covered by 

FERS and Social Security. Employees hired prior to January 1, 1984, could elect to either join 

FERS and Social Security or remain in CSRS. 

For employees under FERS, the CFTC contributes an amount equal to one percent of the 

employee’s basic pay to the tax deferred Thrift Savings Plan and matches employee contributions 

up to an additional four percent of pay. FERS and CSRS employees can contribute a portion of 

their gross earnings to the plan up to Internal Revenue Service limits; however, CSRS employees 

receive no matching agency contribution.

M. Retirement Plans and Other Employee Benefits

The CFTC imputes costs and the related financing sources for its share of retirement benefits 

accruing to its past and present employees that are in excess of the amount of contributions from 

the CFTC and its employees, which are mandated by law. The Office of Personnel Management 

(OPM), which administers federal civilian retirement programs, provides the cost information to 

the CFTC. The CFTC recognizes the full cost of providing future pension and Other Retirement 

Benefits (ORB) for current employees as required by Statement of Federal Financial Accounting 

Standards (SFFAS) 5, Accounting for Liabilities of the Federal Government. 

Full costs include pension and ORB contributions paid out of the CFTC’s appropriations and costs 

financed by OPM. The amount financed by OPM is recognized as an imputed financing source. 

Reporting amounts such as plan assets, accumulated plan benefits, or unfunded liabilities, if any, 

is the responsibility of OPM.

Liabilities for future pension payments and other future payments for retired employees who 

participate in the Federal Employees Health Benefits Program and the Federal Employees Group 

Life Insurance Program are reported by OPM rather than CFTC. 
FY 2019 Agency Financial Report

10 COMMODITY FUTURES TRADING COMMISSION

N. FECA Liabilities

FECA provides income and medical cost protections to covered federal civilian employees injured 

on the job, to employees who have incurred work-related occupational diseases and to 

beneficiaries of employees whose deaths are attributable to job-related injuries or occupational 

diseases. The FECA program is administered by the U.S. Department of Labor (DOL), which pays

valid claims against the CFTC and subsequently seeks reimbursement from the CFTC for these 

paid claims. Accrued FECA liabilities represent amounts due to DOL for claims paid on behalf of 

the agency. 

In addition, the Commission’s actuarial FECA liability represents the liability for future workers 

compensation benefits, which includes the expected liability for death, disability, medical, and 

miscellaneous costs for approved cases. The Commission records an estimate for the FECA 

actuarial liability using the DOL’s FECA model. The model considers the average amount of 

benefit payments incurred by the Commission for the past three fiscal years, multiplied by the 

medical and compensation liability to benefits paid ratio for the whole FECA program. 

O. Leases 

The CFTC does not have any capital lease liabilities. The operating leases consist of commercial 

property for the CFTC’s headquarters and regional offices. Lease expenses are recognized on a 

straight-line basis. 

P. Deposit Funds 

Deposit funds are expenditure accounts used to record monies that do not belong to the Federal 

government. They are held awaiting distribution based on a legal determination or investigation. 

The CFTC Deposit Fund is used to collect and later distribute collections of monetary awards to the 

appropriate victims as restitution. The cash collections recorded in this fund are offset by a Deposit 

Fund liability. Activities in this fund are not fiduciary in nature because they are not legally 

enforceable against the government. 

Q. Net Position

 

Net position consists of unexpended appropriations and cumulative results of operations. 

Unexpended appropriations are appropriations that have not yet been used to acquire goods and 

services or provide benefits. Appropriations are considered expended, or used, when goods and 

services have been acquired by the CFTC or benefits have been provided using the appropriation 

authority, regardless of whether monies have been paid or payables for the goods, services, or 

benefits have been established. 

Cumulative results of operations represent the excess of budgetary or other financing sources over 

expenses since inception. Cumulative results of operations are derived from the net effect of 

capitalized assets, expenses, exchange revenue, and unfunded liabilities. 

R. Revenues

 

The CFTC receives reimbursement and earns revenue for the following activities:

 Reimbursement for travel, subsistence, and related expenses from non-federal sources for 

attendance at meetings or similar functions that an employee has been authorized to 

attend in an official capacity on behalf of the Commission; 

 Reimbursement for Intergovernmental Personnel Act Mobility Program assignments from 

state and local governments, institutions of higher education, and other eligible 
FY 2019 Agency Financial Report

 COMMODITY FUTURES TRADING COMMISSION 11

organizations for basic pay, supplemental pay, fringe benefits, and travel and relocation 

expenses; and 

 Reimbursement from non-federal sources for registration fees to cover the cost of 

expenses related to the CFTC's annual International Regulators Conference. 

S. Net Cost of Operations 

 

Net cost of operations is the difference between the CFTC’s expenses and its earned revenue. The 

presentation of program results by strategic goals is based on the CFTC’s current Strategic Plan 

established pursuant to the Government Performance and Results Act of 1993 (GPRA). 

The mission statement of the CFTC is to protect market users and the public from fraud, 

manipulation, and abusive practices related to the sale of commodity and financial futures and

options, and to foster open, competitive, and financially sound futures and option markets. For FY 

2019, the mission was accomplished through the following four strategic goals, each focusing on a 

vital area of regulatory responsibility:

 Goal 1: Market Integrity and Transparency. The focus of Market Integrity and 

Transparency is to recognize that derivatives markets provide a means for market users to 

offset price risks inherent in their businesses and to serve as a public price discovery 

mechanism. 

 Goal 2: Financial Integrity and Avoidance of Systemic Risk. The focus of Financial 

Integrity and Avoidance of Systemic Risk is to strive to ensure that Commission-registered 

derivatives clearing organizations, swap dealers, major swap participants, and futures 

commission merchants have the financial resources, risk management systems and 

procedures, internal controls, customer protection systems, and other controls necessary to 

meet their obligations so as to minimize the risk that the financial difficulty of any of these 

registrants, or any of their customers has systemic implications.

 Goal 3: Comprehensive Enforcement. Through the goal of Comprehensive Enforcement, 

the CFTC enforces the CEA and Commission regulations, and works to promote awareness of 

and compliance with these laws. 

 Goal 4: Domestic and International Cooperation and Coordination. Domestic and 

International Cooperation and Coordination focuses on how the Commission interacts with 

domestic and international regulatory authorities, market participants, and others affected by 

the Commission’s regulatory policies and practices. 

To advance its mission goals and objectives, the CFTC will achieve Commission-wide excellence by 

empowering strong, enterprise-focused leaders, maintaining a high-performing and engaged 

workforce, and ensuring effective stewardship of resources. 

T. Custodial Activity 

The CFTC collects penalties and fines levied against firms for violation of laws as described in the 

CEA as codified at 7 U.S.C. § 1, et seq, and the Commodities Futures Modernization Act of 2000, 

Appendix E of Public Law 106-554, 114 Stat. 2763. Unpaid fines, penalties and accrued interest are 

reported as custodial receivables, with an associated custodial liability. The receivables and the 

liability are reduced by amounts determined to be uncollectible. Revenues earned and the losses 

from bad debts are reported to Treasury. 

Collections made by the CFTC during the year are deposited and reported into designated Treasury 

miscellaneous receipt accounts for: 
FY 2019 Agency Financial Report

12 COMMODITY FUTURES TRADING COMMISSION

 Registration and filing fees, 

 Fines, penalties and forfeitures, and 

 General proprietary receipts. 

At fiscal year-end, custodial collections made by the CFTC are either returned to Treasury or when 

determined eligible, transferred to the Customer Protection Fund. The CFTC does not retain any 

amount for custodial activities including reimbursement of the cost of collection. 

U. Use of Management Estimates 

The preparation of the accompanying financial statements in accordance with accounting 

principles generally accepted in the United States of America requires management to make 

certain estimates and assumptions that directly affect the results of reported assets, liabilities, 

revenues, expenses, and custodial activities. Actual results could differ from these estimates.

V. Reconciliation of Net Outlays and Net Cost of Operations 

In accordance with OMB Circular A-136, the Commission reconciles its budgetary outlays with its 

net cost of operations.

W. Funds from Dedicated Collections

The Customer Protection Fund was established to operate a whistleblower program and support 

customer education initiatives. See Note 1A for a description of the purpose of the Customer 

Protection Fund and its authority to use revenues and other financing sources. Deposits into the

Customer Protection Fund are credited from monetary sanctions collected by the Commission in a 

covered judicial or administrative action where the full judgment is in excess of $1,000,000 and 

the collection is not otherwise distributed to victims of a violation of the Dodd-Frank Act or the 

underlying rules and regulations, unless the balance of the Customer Protection Fund at the time 

the monetary judgment is collected exceeds $100 million. No new legislation was enacted as of 

September 30, 2019, that significantly changed the purpose of the fund or redirected a material 

portion of the accumulated balance. 

Note 2 Fund Balance with Treasury

A. Reconciliation to Treasury 

There are no differences between the fund balances reflected in the CFTC Balance Sheets and the 

balances in the Treasury accounts.

B. Fund Balance with Treasury

Fund Balance with Treasury as of September 30, 2019, and 2018, consisted of the following:

2019 2018

Unobligated Fund Balance

 Available $ 2,299,197 $ 3,426,145

 Unavailable 10,821,543 11,871,422

Obligated Balance Not Yet Disbursed 72,840,989 50,653,359

Non-Budgetary Fund Balance with Treasury 445,754 369,175

TOTAL FUND BALANCE WITH TREASURY $ 86,407,483 $ 66,320,101
FY 2019 Agency Financial Report

 COMMODITY FUTURES TRADING COMMISSION 13

Obligated and unobligated balances reported for the status of Fund Balance with Treasury differ 

from the amounts reported in the Statement of Budgetary Resources due to the fact that budgetary 

balances are supported by amounts other than Fund Balance with Treasury. These amounts 

include Customer Protection Fund investments, uncollected payments from Federal sources, and

unfunded lease obligations. 

Note 3 Investments 

The CFTC invests amounts deposited in the Customer Protection Funds in overnight short-term 

Treasury securities. Treasury overnight certificates of indebtedness are issued with a stated rate of 

interest to be applied to their par amount, mature on the business day immediately following their 

issue date, are redeemed at their par amount at maturity, and have interest payable at maturity. 

The overnight certificates are Treasury securities whose interest rates or prices are determined 

based on the interest rates or prices of Treasury-related financial instruments issued or trading in 

the market, rather than on the interest rates or prices of outstanding marketable Treasury 

securities. The Commission may invest in other short-term or long-term Treasury securities at 

management’s discretion.

The Commission’s investments as of September 30, 2019, and 2018, were $141,300,000 and 

$157,518,375, respectively. Related nonexchange interest revenue for the years ended September 

30, 2019, and 2018, was $3,206,457 and $3,447,675, respectively. 

Intragovernmental Investments in Treasury Securities

The Federal Government does not set aside assets to pay future claims or other expenditures 

associated with funds from dedicated collections deposited into the Customer Protection Fund. 

The dedicated cash receipts collected by the Commission as a result of monetary sanctions are 

deposited in the Treasury, which uses the cash for general Government purposes. As discussed 

above and in Note 1F, the Commission invests the majority of these funds in Treasury securities. 

These Treasury securities are an asset of the Commission and a liability of the Treasury. Because 

the Commission and the Treasury are both components of the Government, these assets and 

liabilities offset each other from the standpoint of the Government as a whole. For this reason, the 

investments presented by the Commission do not represent an asset or a liability in the U.S. 

Government-wide financial statements.

Treasury securities provide the Commission with authority to draw upon the Treasury to pay 

future claims or other expenditures. When the Commission requires redemption of these securities 

to make expenditures, the Government finances those expenditures out of accumulated cash 

balances, by raising taxes or other receipts, by borrowing from the public or repaying less debt, or 

by curtailing other expenditures. This is the same manner in which the Government finances all 

expenditures.

Note 4 Accounts Receivable, Net

Accounts receivable consist of amounts owed the CFTC by other Federal agencies and the public. 

Accounts receivable are valued at their net collectible values. Non-custodial accounts receivable 

are primarily for overpayments of expenses to other agencies, or vendors, and repayment of 

employee benefits. Historical experience has indicated that most of the non-custodial receivables 

are collectible and that there are no material uncollectible amounts.

Custodial receivables (non-entity assets) are those for which fines and penalties have been

assessed and levied against businesses or individuals for violations of the CEA or Commission 
FY 2019 Agency Financial Report

14 COMMODITY FUTURES TRADING COMMISSION

regulations. Violators may be subject to a variety of sanctions including fines, injunctive orders, 

bars or suspensions, rescissions of illegal contracts, and disgorgements.

An allowance for uncollectible accounts has been established and included in accounts receivable 

on the balance sheets. Although historical experience has indicated that a high percentage of 

custodial receivables prove uncollectible, the Commission determines the collectability of each 

individual judgment based on knowledge of the financial profile of the debtor obtained through the 

course of the investigation and litigation of each case, including efforts to identify and freeze assets 

at the beginning of cases, when any remaining assets are most likely to be recoverable. Accounts 

are re-estimated quarterly based on account reviews and the agency’s determination that changes 

to the net realizable value are needed.

Accounts receivable, net consisted of the following as of September 30, 2019, and 2018: 

2019 2018

Civil Monetary Penalties, Fines, and Administrative Fees $ 207,552,850 $ 122,932,196

Civil Monetary Penalty Interest 1,942,550 852,587

Registration and Filing Fees 1,346,286 2,179,957

Less: Allowance for Loss on Penalties, Fines, and Administrative Fees (157,522,132) (113,605,126)

Less: Allowance for Loss on Interest (1,932,727) (840,061)

Less Allowance for Loss on Registration and Filing Fees (22,378) (22,378)

TOTAL CUSTODIAL RECEIVABLES, NET $ 51,364,449 $ 11,497,175

Other Accounts Receivable 54,582 44,667

TOTAL ACCOUNTS RECEIVABLE, NET $ 51,419,031 $ 11,541,842

Custodial Receivables, Net:

Note 5 General Property, Plant and Equipment, Net 

Property, Plant and Equipment as of September 30, 2019, and 2018, consisted of the following:

2019

Major Class Service Life and Method Cost

Accumulated 

Amortization/ 

Depreciation Net Book Value

Equipment 5 Years/Straight Line $ 41,114,736 $ (31,499,908) $ 9,614,828

IT Software 5 Years/Straight Line 29,684,602 (25,290,789) 4,393,813

Software in Development Not Applicable 3,170,786 - 3,170,786

Leasehold Improvements Remaining Life of Lease/Straight Line 31,292,870 (18,734,101) 12,558,769

TOTAL GENERAL PROPERTY, PLANT, AND EQUIPMENT, NET $ 105,262,994 $ (75,524,798) $ 29,738,196

2018

Major Class Service Life and Method Cost

Accumulated 

Amortization/ 

Depreciation Net Book Value

Equipment 5 Years/Straight Line $ 39,362,988 $ (27,848,249) $ 11,514,739

IT Software 5 Years/Straight Line 31,788,200 (25,752,071) 6,036,129

Software in Development Not Applicable 2,732,083 - 2,732,083

Leasehold Improvements Remaining Life of Lease/Straight Line 31,292,870 (16,398,976) 14,893,894

TOTAL GENERAL PROPERTY, PLANT, AND EQUIPMENT, NET $ 105,176,141 $ (69,999,296) $ 35,176,845

Depreciation and amortization expense for the years ended September 30, 2019, and 2018, totaled 

$7,443,442 and $7,741,131, respectively.
FY 2019 Agency Financial Report

 COMMODITY FUTURES TRADING COMMISSION 15

Note 6 Liabilities not Covered by Budgetary Resources

As of September 30, 2019, and 2018, the following liabilities were not covered by budgetary 

resources:

2019 2018

Liabilities Not Requiring Budgetary Resources:

 Intragovernmental - Custodial Liabilities $ 51,364,449 $ 11,497,175

 Deferred Lease Liabilities 21,494,054 23,970,026

 Deposit Fund Liabilities 445,754 369,175

Total Liabilities Not Requiring Budgetary Resources $ 73,304,257 $ 35,836,376

Other Liabilities Not Covered by Budgetary Resources:

 Intragovernmental - FECA Liabilities $ 85,660 $ 84,533

 Annual Leave 12,672,973 11,544,538

 Actuarial FECA Liabilities 478,449 454,559

 Liability for Whistleblower Awards 20,280,146 4,913,875

 Contingent Liabilities - 38,696

TOTAL LIABILITIES NOT COVERED BY BUDGETARY RESOURCES $ 106,821,485 $ 52,872,577

Liabilities not covered by budgetary resources of $106,821,485 and $52,872,577 represent 78.86

and 76.05 percent of the Commission’s total liabilities of $135,453,485 and $69,521,937 as of 

September 30, 2019, and 2018, respectively. 

Note 7 Leases 

The CFTC has operating leases in privately-owned buildings for its locations in Washington D.C., 

Chicago, New York, and Kansas City. The CFTC has no real property. Future estimated minimum 

lease payments are not accrued as liabilities and are expensed on a straight-line basis.

As of September 30, 2019, future estimated minimum lease payments continue through FY 2025 

and are as follows:

Fiscal Year

2020 20,889,349 

2021 21,312,686 

2022 20,088,229 

2023 17,880,606 

2024 18,239,105 

Thereafter 18,603,371 

$ 117,013,346 

Future Lease-Related Operating Costs (Estimated) 9,701,460 

$ 126,714,806 

Total Future Scheduled Rent Payments

Dollars

TOTAL FUTURE MINIMUM LEASE PAYMENTS

CFTC recognizes leases expenses on a straight-line basis because the Commission’s lease payment 

amounts vary at negotiated times and reflect increases in rental costs, and in some cases, 

allowances or credits from landlords. Consistent with the utility of its office space, the Commission 

records deferred lease liabilities representing expense amounts in excess of payments to date. The 

deferred lease liabilities at September 30, 2019, and 2018, were $21,494,054 and $23,970,026, 

respectively. 
FY 2019 Agency Financial Report

16 COMMODITY FUTURES TRADING COMMISSION

The following table describes the Commission’s existing lease arrangements for buildings and 

multifunction devices, including major asset categories by location and associated lease terms.

BUILDINGS (NON-FEDERAL)

Location Lease Terms

Washington, D.C.

Lease of office space from October 5, 1995, through September 30, 2025, 

subject to annual escalation amounts1 and including allowances for leasehold 

improvements and rent offsets.

New York Lease of office space from November 16, 2001, through April 30, 2022, with no 

escalation clauses or option to renew.

Kansas City Lease of office space from April 1, 2011, through April 14, 2021, including 

allowances for leasehold improvements and rent offsets.

Chicago

Lease of office space from March 10, 2002, through June 30, 2022, including 

proportionate share of operating expenses and taxes for premises and 

allowances for leasehold improvements and rent offsets.

1 If market rent were $100 per square foot with a 10 percent annual escalation and a $10 operating expense base, 

then 98 percent of the applicable market rent would be $98 per square foot with a 10 percent escalation and a $10 

operating base.

MULTIFUNCTION DEVICES (FEDERAL)

Location Lease Terms

Washington, D.C., New 

York, and Kansas City 

Two-year rental of multifunction printers through the U.S. Government 

Printing Office with three one-year options to renew.

Note 8 Liability for Whistleblower Awards

As mentioned in Note 1A, the Customer Protection Fund will be used to pay awards to 

whistleblowers if they voluntarily provide original information to the CFTC that leads to the 

successful enforcement by the CFTC of a covered judicial or administrative action in which 

monetary sanctions exceeding $1 million are imposed. Whistleblowers are entitled to appeal any 

decisions by the Commission in regards to claims made against the Fund. 

At the time the whistleblower voluntarily provides information to CFTC, they have no guarantee or 

promise that the Commission will exchange funds in return for that information. In accordance 

with federal accounting standards, the Commission records liabilities for these nonexchange 

transactions when they are due and payable. The Commission therefore records a liability for 

pending whistleblower payment after the whistleblower has been formally notified of an award and 

the related sanction, or some portion thereof, has been collected. The liability will be paid when the 

appeal period has ended and the whistleblower has provided necessary banking information. As of 

September 30, 2019, and September 30, 2018, the Commission recorded liabilities for pending 

payments to whistleblowers of approximately $20,280,146 and $4,913,875, respectively. During 

FY 2019, the Commission disbursed $8,384,664 in whistleblower awards, which included 

$3,783,174 from pending payments at the end of FY 2018 and $4,601,490 in new awards issued 

during the year. Accounts payable includes approximately $7,000,000 for awards that have been 

finalized as of September 30, 2019. 

In addition to the pending payments to whistleblowers, the Commission had 14 additional 

whistleblower claims currently under review as of September 30, 2019. These additional claims, 
FY 2019 Agency Financial Report

 COMMODITY FUTURES TRADING COMMISSION 17

depending on whether the whistleblowers are determined to be eligible for an award and the 

related sanctions have been collected, could result in total future payments ranging from $0 to 

$29,286,750. 

Note 9 Contingent Liabilities

The CFTC records contingent liabilities for legal cases in which payment has been deemed 

probable and for which the amount of potential liability has been estimated, including judgments

that have been issued against the agency and which have been appealed. Additionally, the 

Commission discloses legal matters in which an unfavorable outcome is reasonably possible. 

There were no legal matters deemed reasonably possible as of September 30, 2019. 

Note 10 Statements of Budgetary Resources

The Commission corrected a violation of the recording statute in FY 2016 by recording its 

obligations for all future building lease payments in accordance with OMB Circular A-11. The 

recording of these previously unrecorded obligations resulted in negative unobligated balances in 

its salaries and expenses general expenditure funds because budgetary resources have not been 

made available to the Commission to fund these multi-year leases (see the Combining Statements 

of Budgetary Resources in the Required Supplementary Information section immediately following 

the notes). The effect on the status of the Commission’s budgetary resources and reconciliation to 

the U.S. Budget is detailed in the note disclosures below. 

A. Net Adjustments to Unobligated Balance Brought Forward, October 1

The Unobligated Balance Brought Forward from the prior fiscal year has been adjusted for 

recoveries of prior year paid and unpaid obligations and other changes such as canceled authority. The Adjustments to Unobligated Balance Brought Forward, October 1, as of September 30, 2019, 

and 2018, consisted of the following:

Unobligated Balance Brought Forward, October 1 $ 23,072,180 $ 73,301,723

Recoveries of Prior Year Obligations 4,888,708 8,015,676

Other Changes in Unobligated Balance (4,032,357) (454,136)

UNOBLIGATED BALANCE FROM PRIOR YEAR BUDGET AUTHORITY, NET $ 23,928,531 $ 80,863,263

2019 2018
FY 2019 Agency Financial Report

18 COMMODITY FUTURES TRADING COMMISSION

B. Undelivered Orders

The amount of budgetary resources obligated for undelivered orders as of September 30, 2019, and 

2018, consisted of the following:

2019 2018

Undelivered Orders - Federal

 Paid $ 2,663,914 $ 1,596,970

 Unpaid 5,889,053 4,203,978

 Total Undelivered Orders - Federal $ 8,552,967 $ 5,800,948

Undelivered Orders - Non-Federal

 Paid $ 3,029,381 $ 2,548,456

 Unpaid 165,034,743 179,191,090

 Total Undelivered Orders - Non-Federal $ 168,064,124 $ 181,739,546

TOTAL UNDELIVERED ORDERS $ 176,617,091 $ 187,540,494

The amount of undelivered orders represents the value of unpaid and paid obligations recorded 

during the fiscal year, and upward and downward adjustments of obligations that were originally 

recorded in a prior fiscal year. Non-federal unpaid undelivered orders include the Commission’s 

unfunded future lease payments as of September 30, 2019, and 2018, as follows:

2019 2018

Unfunded Lease Obligations Brought Forward, October 1 $ 149,391,066 $ 172,353,400

Change in Unfunded Lease Obligations (22,676,260) (22,962,334)

TOTAL REMAINING UNFUNDED LEASE OBLIGATIONS $ 126,714,806 $ 149,391,066

C. Explanations of Differences between the Statement of Budgetary Resources and 

Budget of the United States Government

The CFTC had material differences between the amounts reported in the Statement of Budgetary 

Resources and the actual amounts reported in the Budget of the U.S. Government for FY 2018 

related to unfunded lease obligations that are being funded each fiscal year through annual 

appropriations (see table below). These unfunded obligations will cease to be a reconciling 

difference when the last unfunded lease ends in FY 2025. 

 

Budgetary 

Resources

CFTC FY 2018 Statement of Budgetary Resources $ 333,115,209

 Less Amounts in Customer Protection Fund (239,490,096)

 Less Amounts in Expired Accounts (13,734,337)

 Less New Budget Authority Used to Liquidate Deficiencies (22,304,808)

 Less Recovery of Prior Year Lease Obligations Due to Space Reduction (657,526)

 Plus Unfunded Lease Obligations Brought Forward, October 1 172,353,400

 Plus Rounding to Nearest Million (+/-) (281,842)

BUDGET OF THE U.S. GOVERNMENT $ 229,000,000

The Budget of the U.S. Government with actual numbers for FY 2019 has not yet been published. 

The expected publish date is February 2020. A copy of the Budget may be obtained from OMB’s 

website. 
FY 2019 Agency Financial Report

 COMMODITY FUTURES TRADING COMMISSION 19

Note 11 Reconciliation of Total Net Cost of Operations to Net Outlays

The schedule presented in this note reconciles the Total Net Cost of Operations reported in the 

Statements of Net Cost with Net Outlays reported in the Statements of Budgetary Resources. 

Differences between net costs and net outlays are primarily the result of timing differences and 

paying for assets that are used over more than one reporting period. 

TOTAL NET COST OF OPERATIONS $ 301,304,756 $ 305,261,284

$ (7,443,442) $ (7,741,131)

Gain/(Loss) on Disposal (91,859) (136,730)

 Accounts Receivable 9,915 33,442

 Decrease in Prepayments - (2,720,618)

 (10,843,948) (817,623)

 (1,138,692) 813,485

 (15,366,271) 40,586,125

 38,696 (38,696)

 (1,153,452) (789,315)

Other Financing Sources:

 Federal employee retirement benefit costs paid by OPM and imputed to CFTC (8,054,524) (7,295,372)

$ (44,043,577) $ 21,893,567

$ 4,572,624 $ 3,564,600

 1,547,869 - 

Nonexchange Interest Revenue (excluding interest receivable) (3,224,832) (3,435,540)

$ 2,895,661 $ 129,060

$ 260,156,840 $ 327,283,911

Distributed Offsetting Receipts (14,569) (1,939)

AGENCY OUTLAYS, NET $ 260,142,271 $ 327,281,972

Outlays, Net

 Salaries and Benefits

Components of Net Outlays That Are Not Part of Net Cost:

Increase in Prepayments

Acquisition of capital assets

Total Components of Net Outlays That Are Not Part of Net Cost

 Other liabilities (Unfunded leave, Unfunded FECA, Actuarial FECA)

 Liability for Whistleblower Awards

Depreciation and Amortization

Total Components of Net Cost That Are Not Part of Net Outlays

2019 2018

Components of Net Cost That Are Not Part of Net Outlays:

(Increase)/Decrease in Liabilities:

 Accounts Payable

Increase/(Decrease) in Assets:

 Contingent liabilities
FY 2019 Agency Financial Report

20 COMMODITY FUTURES TRADING COMMISSION

Note 12 Funds from Dedicated Collections 

Funds from dedicated collections arise from disgorgement and penalty collections and are 

transferred to the Customer Protection Fund, established by the Dodd-Frank Act. The collections 

are transferred from the custodial receipt account if they are found to be eligible before the end of 

each fiscal year. In cases where the collection has been returned to Treasury, the Commission can 

recover the funds directly from Treasury. The collections will fund the Commission’s 

whistleblower awards program and customer education initiatives. 

The Dodd-Frank Act provides that whistleblower awards shall be paid under regulations 

prescribed by the Commission. An important prerequisite to implementation of the whistleblower 

awards program is the issuance of rules and regulations describing its scope and procedures. The 

Commission issued revised rules effective July 31, 2017. 

No eligible collections have been transferred into the fund since it reached its legislative maximum 

during FY 2014. The following chart presents the Fund’s balance sheets, statements of net costs, 

and statements of changes in net position as of and for the years ended September 30, 2019, and 

2018: 

2019 2018

BALANCE SHEETS

Fund Balance with Treasury $ 13,148,336 $ 7,293,399

Investments 141,300,000 157,518,375

Prepayments 221,818 - 

General Property, Plant and Equipment, Net 50,126 93,090

TOTAL ASSETS $ 154,720,280 $ 164,904,864

Accounts Payable 8,670,172 1,361,602

Accrued Payroll 141,492 111,631

Accrued Annual Leave 189,308 180,158

Liability for Whistleblower Awards 20,280,146 4,913,875

Total Liabilities $ 29,281,118 $ 6,567,266

Cumulative Results of Operations - Funds from Dedicated Collections 125,439,162 158,337,598

Total Net Position $ 125,439,162 $ 158,337,598

TOTAL LIABILITIES AND NET POSITION $ 154,720,280 $ 164,904,864

STATEMENTS OF NET COST

Gross Costs $ 36,104,893 $ 41,446,286

TOTAL NET COST OF OPERATIONS $ 36,104,893 $ 41,446,286

STATEMENTS OF CHANGES IN NET POSITION

Beginning Cumulative Results of Operations, October 1 $ 158,337,598 $ 196,336,209

Nonexchange Interest Revenue 3,206,457 3,447,675

Net Cost of Operations (36,104,893) (41,446,286)

 Net Change (32,898,436) (37,998,611)

TOTAL NET POSITION, SEPTEMBER 30 $ 125,439,162 $ 158,337,598
REQUIRED SUPPLEMENTARY INFORMATION

(UNAUDITED)

21 COMMODITY FUTURES TRADING COMMISSION

Commodity Futures Trading Commission

COMBINING STATEMENTS OF BUDGETARY RESOURCES BY MAJOR ACCOUNT

For the Years Ended September 30, 2019 and 2018 

2019

BUDGETARY RESOURCES

 Unobligated Balance from Prior Year Budget Authority, Net (Note 10A) $ 159,272,922 $ (143,858,784) $ 8,514,393 $ 23,928,531

 Appropriations - 218,000,000 50,000,000 268,000,000

 Spending Authority from Offsetting Collections 3,024,893 191,469 - 3,216,362

TOTAL BUDGETARY RESOURCES $ 162,297,815 $ 74,332,685 $ 58,514,393 $ 295,144,893

STATUS OF BUDGETARY RESOURCES

 New Obligations and Upward Adjustments $ 20,862,226 $ 195,322,004 51,845,265 $ 268,029,495

 Unobligated Balance, End of Year

Apportioned, Unexpired Accounts 141,435,589 1,288,578 258,671 142,982,838

Unapportioned, Unexpired Accounts - (126,714,806) - (126,714,806)

Unexpired Unobligated Balance, End of Year 141,435,589 (125,426,228) 258,671 16,268,032

Expired Unobligated Balance, End of Year - 4,436,909 6,410,457 10,847,366

 Total Unobligated Balance, End of Year 141,435,589 (120,989,319) 6,669,128 27,115,398

TOTAL BUDGETARY RESOURCES $ 162,297,815 $ 74,332,685 $ 58,514,393 $ 295,144,893

OUTLAYS, NET

Outlays, Net $ 10,345,063 $ 204,714,251 $ 45,097,526 $ 260,156,840

Distributed Offsetting Receipts - (14,569) - (14,569)

AGENCY OUTLAYS, NET $ 10,345,063 $ 204,699,682 $ 45,097,526 $ 260,142,271

Combined

Salaries and

Expense

Information

Technology

Customer

Protection Fund

2018

BUDGETARY RESOURCES

 Unobligated Balance from Prior Year Budget Authority, Net (Note 10A) $ 236,280,890 $ (163,971,689) $ 8,554,062 $ 80,863,263

 Appropriations - 201,000,000 48,000,000 249,000,000

 Spending Authority from Offsetting Collections 3,209,206 42,740 - 3,251,946

TOTAL BUDGETARY RESOURCES $ 239,490,096 $ 37,071,051 $ 56,554,062 $ 333,115,209

STATUS OF BUDGETARY RESOURCES

 New Obligations and Upward Adjustments $ 80,540,550 $ 179,500,940 $ 50,001,539 $ 310,043,029

 Unobligated Balance, End of Year

Apportioned, Unexpired Accounts 158,636,895 1,014,937 545,242 160,197,074

Unapportioned, Unexpired Accounts 312,651 (149,391,066) - (149,078,415)

Unexpired Unobligated Balance, End of Year 158,949,546 (148,376,129) 545,242 11,118,659

Expired Unobligated Balance, End of Year - 5,946,240 6,007,281 11,953,521

 Total Unobligated Balance, End of Year 158,949,546 (142,429,889) 6,552,523 23,072,180

TOTAL BUDGETARY RESOURCES $ 239,490,096 $ 37,071,051 $ 56,554,062 $ 333,115,209

OUTLAYS, NET

Outlays, Net $ 76,767,593 $ 201,170,882 $ 49,345,436 $ 327,283,911

Distributed Offsetting Receipts - (1,939) - (1,939)

AGENCY OUTLAYS, NET $ 76,767,593 $ 201,168,943 $ 49,345,436 $ 327,281,972

Salaries and

Expense Combined

Customer

Protection Fund

Information

Technology