U.S. COMMODITY FUTURES TRADING COMMISSION

OFFICE OF INSPECTOR GENERAL

Three Lafayette Centre

1155 21st Street, NW, Washington, DC 20581

1 

TO:

FROM:

DATE:

Rostin Behnam, Acting Chairman 

Dawn Stump, Commissioner

Miguel A. Castillo, CPA, CRMA

Assistant Inspector General for 

Auditing 

October 26, 2021 

SUBJECT: Audit of the CFTC Customer Protection Fund Financial Statements 

(Fiscal Year 2021) 

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 (CFTC) Customer Protection Fund (Fund) financial statements. We 

contracted Williams Adley & Company, LLP (Williams Adley) to audit the financial 

statements of the Fund as of September 30, 2021, and for the year then ended, to 

provide negative assurance on internal control and compliance with laws and 

regulations for financial reporting. We required that the audit be done in accordance 

with U.S. Generally Accepted Government Auditing Standards (GAGAS).

In its audit of the Fund, Williams Adley found:

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

conformity with U.S. Generally Accepted Accounting Principles.

In connection with the contract, we reviewed Williams Adley’s report and related 

documentation and inquired of its representatives. Our review, as differentiated from 

an audit of the financial statements in accordance with GAGAS, was not intended to 

enable us to express, and we do not express, opinions on CFTC’s financial statements 

or internal control over financial reporting, or on compliance with laws and other 

matters. Williams Adley is responsible for the attached auditor’s report dated October 

29, 2021 and the conclusions expressed therein. However, our review disclosed no

instances where Williams Adley did not comply, in all material respects, with GAGAS. 
2 

Attached is a copy of Williams Adley’s unmodified (clean) opinion. The Williams 

Adley’s audit report that follows makes reference to other information that is included 

in the CFTC Fiscal Year 2021 Agency Financial Report that is not included herein. 

Please call me if any questions at (202) 418-5084.

Cc:

David Gillers, Chief of Staff

Summer Mersinger, Chief of Staff

Christopher Ehrman, Director, Whistleblower Office

Anthony C. Thompson, Chief Administrative Officer and Executive Director

Joel Mattingley, Chief Financial Officer

Keith A. Ingram, Accounting Officer

John Rogers, Senior Advisor

A. Roy Lavik, Inspector General

Judith A. Ringle, Deputy Inspector General and Chief Counsel
WILLIAMS, ADLEY & COMPANY-DC, LLP 

Certified Public Accountants/ Management Consultants 

1030 15th Street, NW, Suite 350 West • Washington, DC 20005 • (202) 371-1397 • Fax: (202) 371-9161 

www.williamsadley.com 

Independent Auditor’s Report 

Chairman 

U.S. Commodity Futures Trading Commission 

Inspector General 

U.S. Commodity Futures Trading Commission 

In our audit of the fiscal year 2021 financial statements of the U.S. Commodity Futures Trading 

Commission Customer Protection Fund (CPF), we found 

 CPF’s financial statements as of and for the fiscal year ended September 30, 2021 (fiscal year

2021), are presented fairly, in all material respects, in accordance with U.S. generally accepted

accounting principles;

 no material weaknesses in internal control over financial reporting based on the limited

procedures we performed; 1 and

 no reportable noncompliance for fiscal year 2021 with provisions of applicable laws,

regulations, contracts, and grant agreements we tested.

The following sections discuss in more detail (1) our report on the financial statements, which 

includes other information included with the financial statements;2 (2) our report on internal 

control over financial reporting; and (3) our report on compliance with laws, regulations, contracts, 

and grant agreements.

Report on the Financial Statements 

In accordance with 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. 21-04, Audit Requirements for Federal Financial Statements, we have 

audited the CPF’s fiscal year 2021 financial statements. CPF’s fiscal year 2021 financial 

statements comprise the balance sheet as of September 30, 2021, the related statement of net cost, 

1A material weakness is a deficiency, or combination of deficiencies, in internal control over financial reporting, 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 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. 

2Other information consists of the Cash Flow Analysis. 
changes in net position, and budgetary resources for the fiscal year then ended; and the related 

notes to the financial statements. 

We conducted our audit of the fiscal year 2021 financial statements in accordance with auditing 

standards generally accepted in the U.S.; the standards applicable to financial audits contained in 

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

OMB Bulletin No. 21-04. We believe that the audit evidence we obtained is sufficient and 

appropriate to provide a basis for our audit opinions. 

Management’s Responsibility 

CPF management is responsible for (1) the preparation and fair presentation of these financial 

statements in accordance with U.S. generally accepted accounting principles; (2) preparing and 

presenting other information included in documents containing the audited financial statements 

and auditor’s report, and ensuring the consistency of that information with the audited financial 

statements; and (3) maintaining effective internal control over financial reporting, including 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. 

Auditor’s Responsibility 

Our responsibility is to express an opinion on these financial statements based on our audits. U.S. 

generally accepted auditing standards, U.S. generally accepted government auditing standards, and 

OMB 21-04 require that we plan and perform the audit to obtain reasonable assurance about 

whether the financial statements are free from material misstatement. We are also responsible for 

applying certain limited procedures to other information included with the financial statements. 

An audit of financial statements involves performing procedures to obtain audit evidence about 

the amounts and disclosures in the financial statements. The procedures selected depend on the 

auditor’s judgment, including the auditor’s 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 of financial statements also involves evaluating 

the appropriateness of the accounting policies used and the reasonableness of significant 

accounting estimates made by management, as well as evaluating the overall presentation of the 

financial statements. Our audits also included performing such other procedures as we considered 

necessary in the circumstances. 

Opinion on Financial Statements 

In our opinion, CPF’s financial statements present fairly, in all material respects, CPF’s financial 

position as of September 30, 2021, and its net cost of operations, changes in net position, and 

budgetary resources for the fiscal year then ended in accordance with U.S. generally accepted 

accounting principles. 
Other Matters 

Prior Year Financial Statements 

CPF’s financial statements as of and for the year ended September 30, 2020 were audited 

by other auditors, whose Independent Auditor’s Report dated October 14, 2020, expressed 

an unmodified opinion on those financial statements. 

Other Information 

The Other Information (e.g., Cash Flow Analysis for the period October 1, 2020 to 

September 30, 2021) is not a required part of the basic financial statements, but are 

supplementary information required by the Dodd-Frank Wall Street Reform and Consumer 

Protection Act. We read the other information included with the financial statements in 

order to identify material inconsistencies, if any, with the audited financial statements. Our 

audit was conducted for the purpose of forming an opinion on CPF’s financial statements.

We did not audit and do not express an opinion or provide any assurance on the other 

information. 

Report on Internal Control over Financial Reporting 

In connection with our audit of CPF’s fiscal year 2021 financial statements, we considered CPF’s 

internal control over financial reporting, consistent with our auditor’s responsibility discussed 

below. We performed our procedures related to the CPF’s internal control over financial reporting 

in accordance with U.S. generally accepted government auditing standards. 

Management’s Responsibility 

CPF management is responsible for maintaining effective internal control over financial reporting, 

including 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. 

Auditor’s Responsibility 

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

September 30, 2021, in accordance with U.S. generally accepted government auditing standards, 

we considered CPF’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 

CPF’s internal control over financial reporting. Accordingly, we do not express an opinion on 

CPF’s internal control over financial reporting. We are required to report all deficiencies that are 

considered to be significant deficiencies3 or material weaknesses. We did not consider all internal 

controls relevant to operating objectives, such as those controls relevant to preparing performance 

information and ensuring efficient operations. 

3A significant deficiency is a deficiency, or a combination of deficiencies, in internal control over financial reporting 

that is less severe than a material weakness, yet important enough to merit attention by those charged with 

governance. 
Definition and Inherent Limitations of Internal Control over Financial Reporting 

An entity’s internal control over financial reporting is a process effected by those charged with 

governance, management, and other personnel, the objectives of which are to provide reasonable 

assurance that (1) transactions are properly recorded, processed, and summarized to permit the 

preparation of financial statements in accordance with U.S. generally accepted accounting 

principles, and assets are safeguarded against loss from unauthorized acquisition, use, or 

disposition, and (2) transactions are executed in accordance with provisions of applicable laws, 

including those governing the use of budget authority, regulations, contracts, and grant 

agreements, noncompliance with which could have a material effect on the financial statements. 

Because of its inherent limitations, internal control over financial reporting may not prevent, or 

detect and correct, misstatements due to fraud or error. 

Results of Our Consideration of Internal Control over Financial Reporting

Our consideration of internal control was for the limited purpose described above, and was not 

designed to identify all deficiencies in internal control that might be material weaknesses and 

significant deficiencies or to express an opinion on the effectiveness of CPF’s internal control over 

financial reporting. Given these limitations, during our audit, we did not identify any deficiencies 

in internal control over financial reporting that we consider to be material weaknesses. However, 

material weaknesses may exist that have not been identified. 

Intended Purpose of Report on Internal Control over Financial Reporting 

The purpose of this report is solely to describe the scope of our consideration of CPF’s internal 

control over financial reporting and the results of our procedures, and not to provide an opinion on 

the effectiveness of CPF’s internal control over financial reporting. This report is an integral part 

of an audit performed in accordance with U.S. generally accepted government auditing standards 

in considering internal control over financial reporting. Accordingly, this report on internal control 

over financial reporting is not suitable for any other purpose. 

Report on Compliance with Laws, Regulations, Contracts, and Grant Agreements 

In connection with our audit of CPF’s fiscal year 2021 financial statements, we tested compliance 

with selected provisions of applicable laws, regulations, contracts, and grant agreements consistent 

with our auditor’s responsibility discussed below. We caution that noncompliance may occur and 

not be detected by these tests. We performed our tests of compliance in accordance with U.S. 

generally accepted government auditing standards. 

Management’s Responsibility 

CPF management is responsible for complying with laws, regulations, contracts, and grant 

agreements applicable to CPF. 

Auditor’s Responsibility 

Our responsibility is to test compliance with selected provisions of applicable laws, regulations, 

contracts, and grant agreements applicable to the CPF that have a direct effect on the determination 

of material amounts and disclosures in CPF’s financial statements, and perform certain other 
limited procedures. Accordingly, we did not test compliance with all laws, regulations, contracts, 

and grant agreements applicable to CPF. 

Results of Our Tests for Compliance with Laws, Regulations, Contracts, and Grant Agreements 

Our tests for compliance with selected provisions of applicable laws, regulations, contracts, and 

grant agreements disclosed no instances of noncompliance for fiscal year 2021 that would be 

reportable under U.S. generally accepted government auditing standards. However, the objective 

of our tests was not to provide an opinion on compliance with laws, regulations, contracts, and 

grant agreements applicable to the CPF. Accordingly, we do not express such an opinion. 

Intended Purpose of Report on Compliance with Laws, Regulations, Contracts, and Grant 

Agreements 

The purpose of this report is solely to describe the scope of our testing of compliance with selected 

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

testing, and not to provide an opinion on compliance. This report is an integral part of an audit 

performed in accordance with U.S. generally accepted government auditing standards in 

considering compliance. Accordingly, this report on compliance with laws, regulations, contracts, 

and grant agreements is not suitable for any other purpose. 

Washington, D.C. 

October 19, 2021