1 

U.S. COMMODITY FUTURES TRADING COMMISSION

Office of the Inspector General

Office of Audits

November 8, 2019

Report Number: 19-AU-03

Performance Audit: CFTC’s Compliance with 

the Digital Accountability and Transparency 

Act (DATA Act) of 2014

(FY 2019 Quarter 1)
U.S. COMMODITY FUTURES TRADING COMMISSION

 Three Lafayette Centre

 1155 21st Street, NW, Washington, DC 20581

 Telephone: (202) 418-5110

 

1 

EXECUTIVE SUMMARY

Why We Did This Audit

 

The Digital Accountability and Transparency Act of 2014 (DATA Act)

1 enables 

taxpayers and policy-makers to track federal spending data (e.g., 

procurements/contracts, grants, and loans) more effectively through the 

establishment of government-wide data standards for financial data; through 

consistent, reliable, and searchable government-wide spending data available on 

USASpending.gov; through simplified reporting for entities receiving federal 

funds; and by holding federal agencies accountable for the completeness, 

timeliness, accuracy and accuracy of the data submitted to USASpending.gov. 

To that end, the DATA Act requires the Inspectors General (IGs) of each Federal 

agency to evaluate the quality of data submitted by testing a sample of agency 

spending data to assess the completeness, timeliness, and accuracy of the data

submitted (among other procedures). 

To meet the requirements of the DATA Act, we conducted a performance audit of 

the U.S. Commodity Futures Trading Commission’s (CFTC) Fiscal Year (FY)

2019 first quarter (Q1) data to evaluate data quality. Our audit was performed in 

accordance with Generally Accepted Government Auditing Standards (GAGAS).

 

1 P.L. 113-101 (May 9, 2014).

TO: Heath P. Tarbert, Chairman

Brian D. Quintenz, Commissioner

Rostin Behnam, Commissioner 

Dawn DeBerry Stump, Commissioner

Dan M. Berkovitz, Commissioner 

 Miguel A. Castillo, CPA, CRMA FROM: Assistant Inspector General for Audits

DATE: November 8, 2019 

Performance Audit: CFTC’s Compliance with the Digital Accountability and SUBJECT: Transparency Act (DATA Act) of 2014 (FY 2019 Quarter 1) 

I om« OfTho!n, 10, G<nml 

_A2IG C<.mmodity hllll.l'ft Tn.d1. ~ U)II\JJliMion 
2 

What We Found

 

We determined that the CFTC’s Financial Management Branch (FMB) prepared 

and submitted FY2019 Q1 data to Treasury DATA Act Broker as required. This is 

true for CFTC generated files known as files A, B, C, and D1, which contained

summary and detailed spending data. These files were also submitted and 

certified timely by CFTC’s Senior Accountable Official (SAO). 

In addition, with regard to internal control analysis, our evaluation of files A and 

B, and detail sample testing of files C and D1, identified no concerns with the 

data’s overall quality. As such, we determined the CFTC’s submission of FY 

2019 Q1 data was of “HIGHER” quality as measured by the Council of the 

Inspector Generals on Integrity and Efficiency (CIGIE) Federal Audit Executive 

Committee (FAEC) Inspectors General Guide to Compliance under the DATA 

Act2 evaluation guide (IG Guide). More specifically, sample results showed that 

error rates for completeness, timeliness, and accuracy are less than 3 percent 

with 95 percent confidence level. 

We acknowledge FMB’s use of a third party service provider, Department of 

Transportation (DoT) Enterprise Services Center (ESC) and its rigorous internal 

controls and reconciliations contributed to the high quality of CFTC’s data 

submission. Thus, we make no recommendations at this time. Management 

concurred with the report contents and their comments in its entirety are

presented in Appendix C. 

We will publish this report on the Office of the Inspector General’s (OIG) web 

page and the report will be summarized in our March 2020 Semiannual Report to 

Congress. If you have any questions, please contact me at (202) 418-5084 or 

Branco Garcia, lead auditor, at (202) 418-5013. 

Cc:

Ron Johnson

Chairman, Committee on Homeland Security and Governmental Affairs 

United States Senate

Gary C. Peters

Ranking Member, Committee on Homeland Security and Governmental Affairs 

United States Senate

Carolyn Maloney

Acting Chairman, Committee on Oversight and Reform 

United States House of Representatives

 

2 CIGIE FAEC Inspectors General Guide to Compliance under the DATA Act (IG Guide).
3 

Jim Jordon 

Ranking Member, Committee on Oversight and Reform 

United States House of Representatives

Mike Enzi 

Chairman, Committee on the Budget

United States Senate 

Bernie Sanders 

Ranking Member, Committee on the Budget

United States Senate

John Yarmuth

Chairman, Committee on the Budget United States House 

United States House of Representatives

Steve Womack

Ranking Member, Committee on the Budget United States House 

United States House of Representatives

U.S. Government Accountability Office 

DATAActImplementation@gao.gov 

U.S. Department of the Treasury, OIG 

DATAAct@oig.treas.gov

Cc:

Jaime Klima, Chief of Staff

Kevin S. Webb, Chief of Staff

John Dunfee, Chief of Staff 

Daniel J. Bucsa, Chief of Staff

Erik F. Remmler, Chief of Staff

Anthony C. Thompson, Executive Director 

Keith Ingram, Chief Accountant

A. Roy Lavik, Inspector General 

Judith A. Ringle, Deputy Inspector General and Chief Counsel
4 

APPENDIX A

FIELDWORK RESULTS

Procurement – Internal Controls

A control deficiency in internal control exists when the design or operation of a 

control does not allow management or employees to prevent or detect and 

correct errors on a timely basis. A significant deficiency is a control deficiency or 

a combination of control deficiencies that adversely affects CFTC’s ability to 

initiate, authorize, record, process, or report financial data reliably. A material 

weakness is a significant deficiency, or combination of significant deficiencies, 

that results in more than a remote likelihood that a material error will not be 

prevented or detected. 

We assessed CFTC’s payment (spending) reporting risk “low” because FY 2017 

and FY 2018 internal control tests performed by independent public accountants3 

(IPA) contracted by OIG did not identify material control deficiencies for 

payments. A review of FY 2018 internal control work papers and test results also 

did not reveal control deficiencies for this matter. 

Completeness, Timeliness, and Accuracy of Files A, B, C, and D1. 

Our evaluation of files A, B, C, D1, and Others (D2, E, and F) noted the following: 

• File A - Contained all required DATA Act elements, which were presented 

in accordance with data standards. We compared the data in File A to 

information reported to OMB and found that all data matched with no 

exceptions. 

• File B - Contained all required DATA Act elements, which were presented 

in accordance with data standards. 

o As illustrated below, files A and B show that appropriation, program 

activity, and object class information were submitted without errors.

 

3 CFTC OIG, 2017 Financial Statement Audit Opinion (Nov. 14, 2017); CFTC OIG, 2018 Financial 

Statement Audit Opinion (Nov. 15, 2018).
5 

Illustration 1. CFTC’s Submission of File A and B to DATA Broker 

• File C and D14 - Contained all required elements, which were presented in 

accordance with the data standards. Our evaluation showed all 

transactions we reported in the correct period. Two transactions were 

reported in the corrected period but were not processed late due to the 

federal government shutdown between December 22, 2018, and January 

25, 2019. We reconciled these transactions to USAspending.gov and 

agree that extenuating circumstances affected the completeness of the 

file. The value of these transactions was within tolerance. The due date for 

FY 2019 Q1 agency submissions was extended to March 20, 2019.

Illustration 2 shows that CFTC submitted Q1 without errors by the due 

date. 

 

4 This file is generated by Treasury’s system for DATA Act Broker reporting.

File A: Appropriation F 1le Size· 2 44 

KB 

Warnings: o Critical Errors: o 

File B: Program Activity & Object Class File Size. 31 6 1 

Data KB 

Warnings: o Critical Errors: o 

Lines in Filff 18 

Lines in File 

17 1 

Original Submitted Fite: 

CFTC 0£:C-18_ FY-19 Formatted File A 

030119 - Removed 2014 2016 TAS txt 

Fite successfully validated 

Original Submitted Fite: 

CFTC OEC-18_FY-1 9 Formatted File B 

030119 - Removed 2014 2016 TAS lxt 

File successfully validated 

- Next 
6 

Illustration 2. CFTC’s FY 2019 Q1 Submission to DATA Broker

Projected Error Rates for Completeness, Accuracy, and Timeliness of the

Statistical Sample from Files C and D1

We tested a statistically valid sample of 186 transactions from files C and D1. For 

completeness, timeliness, and accuracy, we tested at a 95 percent confidence 

level, and our results showed error rates below 3 percent based on a population

universe of 760 transactions. Illustration 3 shows that projected error rates at the 

confidence level of 95 percent would have a confidence interval between .01 

percent and 2.958 percent. 

Illustration 3. STATA Confidence Interval range at the 95 Percent 

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7 

 

Final Determination of the Quality of the Data

Given transactions for FY 2019 Q1 were considered low risk from an internal 

control perspective, the general completeness and timeliness of submitted files, 

and the high probability of low error rates, we conclude that CFTC,s FY 2019 Q1 

submission is of “HIGHER” quality. In addition, we conclude, based on validating 

sampled transactions to source records that required files were appropriately 

linked to provide USAspending.gov the search-ability and transparency it 

currently calls for as a mandate.
8 

APPENDIX B

Background, Objective, Scope, Methodology

Background

The DATA Act, in part, requires Federal agencies to report financial and 

award datain accordance with the established Government-wide financial 

data standards.5 In May 2015, the Office of Management and Budget 

(OMB) and Treasury published 57 data definition standards (commonly 

referred to as data elements) and in January 2017, required Federal 

agencies to report financial and award data in accordance with these 

standards for DATA Act reporting.

6 Subsequently, and in accordance with 

the DATA Act, Treasury began displaying Federal agencies’ data on 

USAspending.gov for taxpayers and policy makers in May 2017.

The DATA Act also requires the IG of each Federal agency to audit a 

statistically valid sample of the spending data submitted by its Federal 

agency and to submit to Congress a publicly available report assessing the 

completeness, timeliness, quality, and accuracy of the data sampled; and

assessing the implementation and use of the Government-wide financial 

data standards by the Federal agency.7 

Federal agencies were not required to display spending data in compliance 

with the DATA Act until May 2017.8 The IGs provided Congress with the first 

required reports in November 2017, one year later than the due date in the 

statute, with subsequent reports due on a 2-year cycle, in November 2019 

and November 2021.9 

During the 2017 testing and reporting period, IGs employed varying 

methods for meeting the requirements set forth in the DATA Act. For 

example, the data the IGs used to select and review sample transactions 

varied based on data availability and the type of engagement performed by 

the respective IGs. Comparing and compiling the information from all IG 

reports was difficult for stakeholders. Of the IG reports reviewed by GAO; 

approximately 72 percent of IGs did not find agency data to be complete, 

 

5 P.L. 113-101, § 3 (codified at 31 U.S.C. § 6101 (note)). 

6 See, Bureau of the Fiscal Service - Data Transparency Resources. 

7 See fn. 5. 

8 Office of Management and Budget, M-17-04, Additional Guidance for DATA Act Implementation 

(Nov. 4, 2016); IG Guide, page 1. 

9 IG Guide, page 2.
9 

timely, accurate, or of quality. In addition, during 2017, IGs identified 

government-wide issues with Treasury’s DATA Act Broker (Broker), which 

impacted the testing results of the IGs.10

IGs, GAO, OMB, Treasury, agencies and Congress found many lessons to 

be learned following the 2017 engagements. The Working Group compiled a 

listing of these lessons learned and came together to make revisions to its 

testing guide to address those concerns and to ensure future IG audits are 

comparable, useful, and meet the requirements of the DATA Act. In 

consultation with GAO, as required by the DATA Act, the Working Group 

developed the IG Guide to set a baseline framework for the required reviews 

performed by the IG community and to foster a common methodology for 

performing these mandates. This guide is followed by the IGs for this report, 

due November 15, 2019, and may again be updated for the subsequent 

report due November 2021.11 

Objective

The audit objective is to assess the completeness, timeliness, accuracy and 

quality of the data sampled and CFTC’s implementation and use of the 

Government-wide financial data standards established by OMB and Treasury12

(also known as assessing data quality). 

Scope and Methodology

The scope of this audit is FY 2019 Q1 financial and award data submitted by 

CFTC for publication on USASpending.gov, and any applicable procedures, 

certifications, documentation, and controls to complete the process.

To accomplish the objectives, we followed the prescribed IG Guide and 

performed the following steps, among others:13

• obtained an understanding of any regulatory criteria related to CFTC’s 

responsibilities to report financial and award data under the DATA Act 

• interviewed officials from FMB and ESC to gain an understanding of (1) 

the policies, procedures, and guidelines FMB and ESC staff followed 

when preparing and submitting to Treasury the CFTC’s FY 2019 Q1 DATA 

 

10 Id. 

11 Id.

12 According to OMB Circular A-11, Preparation, Submission, and Execution of the Budget, 

unless otherwise specified by OMB, all executive branch agencies must electronically submit to 

OMB SF 133 (Report on Budget Execution and Budgetary Resources) information each quarter 

for each open Treasury appropriation fund symbol. Additionally, SF 133 reports provide a 

consistent presentation of information across programs within each agency.

13 We conducted our fieldwork at CFTC headquarters in Washington, D.C.. 
10

Act files; and (2) the reconciliations FMB staff performed to validate 

submitted data;

• assessed the internal and information system controls in place as they 

relate to the extraction of data from the source systems and the reporting 

of data to the Broker, in order to assess audit risk and design audit 

procedures; 

• reviewed and reconciled the FY 2019 Q1 summary-level data submitted 

by the agency for publication on USAspending.gov; 

• reviewed a statistically valid sample from FY 2019 Q1 financial and award 

data submitted by the agency for publication on USASpending.gov; and

• assessed the completeness, timeliness, accuracy and the aggregate 

quality of the financial and award data sampled. 

We used Statistical Data Analysis (STATA) application software to develop a 

sampling methodology consistent with the requirements of the IG Guide and to 

select a statistically valid sample of the CFTC’s FY 2019 Q1 financial and award 

data submitted to the Broker. To determine the sample size, we used the 

following parameters documented in the IG Guide: 

• Population: The total number of detail award transactions from the CFTC’s 

certified FY 2019 Quarter 1 File C data submission (population universe of

760 transactions);

• Confidence Level: 95 percent; 

• Expected Error Rate: 20 percent; 

Our methodology resulted in a sample size of 186 transactions as illustration 4 

shows below. 
11

Illustration 4. STATA Sample Methodology Used

 

We assessed only files A, B, C, and D1, as described in this report. CFTC did not 

have any financial assistance transactions to report. Therefore, the broker did not 

generate File D2 for this reporting period, and we did not include Files D2, E, and 

F in our audit. 

Illustration 5 Shows the small volume of CFTC FY 2019 Quarter 1 transactions

reported in file C; 760 in all totaling ($8,515,964). 

Illustration 5. Population Universe Grouped by Quantiles via DATA Broker 

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~ 90.0% 56852.632 Upper 95% Mean -2715.538 

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12

In reference to internal controls, management is responsible for the design, 

implementation, and operating effectiveness of the agency’s internal controls. We 

assessed applicable internal controls to determine the nature, timing, and extent 

of testing in accordance with GAO’s Standards for Internal Control in the Federal 

Government. As part of our assessment, we reviewed FMB’s fiscal year 2019

management assurance statements and risk assessments and determined that 

no significant deficiencies or material weaknesses were identified. Also, we relied 

on internal control and substantive testing performed by the Department of 

Transportation OIG, which included a review of ESC’s quality controls and 

concluded that ESC suitably designed and implemented internal controls over 

hosting and operating Delphi and PRISM; source systems for data submitted to 

Treasury. 

The Inspectors General guide included a detail testing spreadsheet tool to 

facilitate tests of details, which we used to analyze and conclude on the quality of 

data submissions. We conducted this audit in accordance with Generally 

Accepted Government Auditing Standards (GAGAS). 
13

APPENDIX C

MANAGEMENTS COMMENTS

U.S. COMMODITY FUTURES TRADING COMMISSION 

Three Lafayette Centre 

1155 21st Street, NW, Washington, DC 20581 

Telephone: (202) 418-5000 

Facsimile: (202) 418-5521 

www.cftc. gov 

TO: Miguel A. Castillo 

Assistant Inspector General for Audits 

FROM: Anthony C. Thompsoc

Executive Director 

DATE: October 30, 2019 

SUBJECT: Management's Response to OIG Performance Audit ofCFTC's Compliance with The 

Digital Accountability Act (Data Act) of2014 

17n1, .J C-~ 

Thank you for the opportunity to comment on the Office of the Inspector General's (OIG) draft report, 

CFTC's Compliance with the Digital Accountability and Transparency Act (DATA Act) of2014 

(FY 2019 Quarter I) (Report Number: 19-AU-03), regarding compliance with Data Act submission for 

the first quarter (QI) of Fiscal Year 2019. Thank you for meeting with my Accounting Office to discuss 

issues and potential findings prior to your drafting of this report. · 

I am pleased to hear that your independent audit of the agency's FY 2019 QI Data Act submission 

resulted in a Data Quality rating of "Higher" based on measurements provided by the Council of the 

Inspector Generals on Integrity and Efficiency (CIGIE) Federal Audit Executive Committee (FAEC) 

Inspectors General Guide. I was also pleased to hear that our data was found to have a confidence 

level of95%. 

My Accounting, Budget, and Procurement offices have been fully engaged, along with our third party 

servicer (Enterprise Service Center from the Department of Transportation), in the development, review, 

and oversight of the Data Act compilation and submission process. I am encouraged that CFTC has 

provided spending information that policy makers and taxpayers can rely on. 

Management Response: 

Management Concurs with the draft report. 

Thank you again for the opportunity to comment on this Report in advance of its publication. Please do 

not hesitate to contact us if you need additional information or wish to discuss any of our comments in 

further detail. 
14

APPENDIX D 

DEFINITIONS AND DATA ACT BROKER FLOW & FILES

DEFINITIONS

1. Completeness of Agency Submission - Transactions and events that 

should have been recorded are recorded in the proper period. 

2. Timeliness of Agency Submission - Reporting of the agency DATA Act 

submission to the DATA Act Broker is in accordance with the schedule 

established by the Treasury DATA Act Project Management Office (PMO). 

The reporting submission dates can be found at 

https://www.fiscal.treasury.gov/data-transparency/resources.html under 

“Updates”.

3. Completeness of Data Elements - For each of the required data elements 

that should have been reported, the data element was reported in the 

appropriate Files A through D2. 

4. Accuracy of Data Elements - Amounts and other data relating to recorded 

transactions have been recorded in accordance with the DATA Act 

Information Model Schema (DAIMS), Reporting Submission Specification 

(RSS), Interface Definition Document (IDD), and the online data 

dictionary; and agree with the authoritative source records.

5. Timeliness of Data Elements - For each of the required data elements that 

should have been reported, the data elements were reported in 

accordance with the reporting schedules defined by the financial, 

procurement and financial assistance requirements (FFATA,14 FAR,15

Federal Procurement Data System – Next Generation (FPDS-NG), 

Financial Assistance Broker Submission (FABS) and DAIMS)). 

6. Quality of Data Elements - Data that is complete, accurate, and reported 

on a timely basis.

 

14 Federal Funding Accountability and Transparency Act (FFATA), P.L. 109-282 (Sept. 26, 2006),

requires that information on federal awards be made available to the public on USASpending.gov. 15 Federal Acquisition Regulation, Title 48, CFR. 
15

DATA ACT INFORMATION FLOW DIAGRAM16

DATA ACT BROKER FILES SUBMITTED AND GENERATED

 File A – Appropriations Account; Data submitted by agency.

 File B – Object Class and Program Activity; Data submitted by agency.

 File C – Award Financial; Data submitted by agency.

 File D1 – Award and Awardee Attributes (Procurement Awards); Data 

extracted from the Federal Procurement Data System-Next Generation.

 File D2 – Award and Awardee Attributes (Financial Assistance Awards); 

Data extracted from the Award Submission Portal. NOT APPLICABLE TO 

CFTC.

 

16 Source: Department of the Treasury. https://www.fiscal.treasury.gov/data-transparency/resources.html

Qua rte rly Re po rting- DATA Act 

.. "'

·o 

C 

.. 

:f 

Agency Uploaded Data 

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Financial Account and Program 

Activity 

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Defined in t he Reporting Submission 

Specification (RSS) 

Field-level va lidations for A, B, and C 

Award Linka e 

DATA Act Broker 

Broker Extracted Data 

Award and Awardee Attributes 

(DI ) Award and Awardee Attributes 

Procurement 

(D2) Award and Awardee Attributes 

Financial Assistance 

(E) Additional Award et! Attributes 

(F} Sub-award Attributes 

Defined in the Int erlace Definition Document (IDO) 

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Daily 
16

 File E – Additional Awardee Attributes; Data extracted from the DATA Act 

Broker System for Award Management. NOT APPLICABLE TO CFTC.

 File F – Sub-Award Attributes; Data extracted from the FFATA Sub-award 

Reporting System. NOT APPLICABLE TO CFTC.
17

APPENDIX E 

ACRONYMS ABREVIATIONS

Broker DATA Act Broker

CFTC U.S. Commodity Futures Trading Commission 

DATA Act Digital Accountability and Transparency Act of 2014

DoT Department of Transportation 

ESC Enterprise Services Center

FFATA Federal Funding Accountability and Transparency Act of 

2006

FMB Financial Management Branch

FY Fiscal Year

GAGAS U.S. Generally Accepted Government Auditing Standards

GAO U.S. Government Accountability Office

IG Inspector General

IG Guide CIGIE FAEC Inspectors General Guide to Compliance 

Under the DATA Act

OIG Office of the Inspector General

OMB Office of Management and Budget

Q1 Quarter 1

SAO Senior Accountable Official

Schema DATA Act Information Model Schema

Treasury Department of the Treasury
18

To Report Fraud, Waste, or Abuse, Please Contact:

The Office of Inspector General (OIG) conducts and supervises audits and 

investigations of programs and operations of the CFTC and recommends 

policies to promote economy, efficiency and effectiveness in CFTC 

programs and operations in order to prevent and detect fraud, waste or 

abuse. 

Employees, contractors and members of the public may report any 

instance of fraud, waste, or abuse at CFTC by contacting: 

• OIG Hotline at 202.418.5510

• email to oig@cftc.gov (you do not need to identify yourself)

• Sending a letter to:

o Commodity Futures Trading Commission

 Office of the Inspector General

 Three Lafayette Centre

1155 21st Street, NW

 Washington, DC 20581

• Fax to the CFTC OIG at 202.418.5522

Comments and Suggestions

If you wish to comment on the quality or usefulness of this report or 

suggest ideas for future audits, evaluations, or reviews, please send an email to CFTC OIG Audits Planning at bgarcia@cftc.gov. 

Comments and requests can also be mailed to the attention of the 

Assistant Inspector General for Audits at the address listed above.