Commodity Futures T1·ading 

Commission 

Affirmative Action Plan 

for the Recruitment, Hiring, Advancement, and 

Retention of Persons with Disabilities 

FY2020 

To capture agencies' afftnnative action plan for persons with disabilities (PWD) and persons with targeted disabilities (PWTD), 

EEOC regulations (29 C.F.R. § 1614.203(e)) and MD-715 require agencies to describe how their affinnative action plan will 

improve the recruitment, hiring, advancement, and retention of applicants and employees with disabilities. • 

Section I: Efforts to Reach Regulatory Goals 

EEOC regulations (29 CFR §J 614.203(d)(7)) require agencies to establish specific numerical goals for increasing the participation 

of persons wit/, disabilities and persons wit/, targeted disabilities in the federal government 

1. Using the goal of 12% as the benchmark, does your agency have a trigger involving PWD by grade level cluster in the 

pennanent workforce? If"yes", describe the trigger(s) in the text box. 

a. Cluster GS-I to GS-IO (PWD) 

b. Cluster GS-11 to SES (PWD) 

Answer Yes 

Answer Yes 

ithin the cluster I of 19 pennanent employees in grades CT -1 to CT -10, employees) are people with disabilities, a decrease 

om- % employee) in FY19. Of the 677 employees in the cluster of CT 11 and higher, 5.47% are people with disabilities (37 

em lo ees , an increase from 4.76% 31 em lo ees in FY19. Both clusters are below the 12% benchmark oal. 

1% I

*For GS employees, please use two clusters: GS-I to GS-10 and GS-11 to SES, as set f011b in 29 C.F.R. § 1614.203(d)(7). For all 

other pay plans, please use the approximate grade clusters that are above or below GS-11 Step 1 in the Washington, DC 

metropolitan region. 

2. Using the goal of 2% as the benchmark, does your agency have a trigger involving PWTD by grade level cluster in the 

permanent workforce? If "yes", describe the trigger(s) in the text box. 

a. Cluster GS-1 to GS-10 (PWTD)

b. Cluster GS-11 to SES (PWTD) 

Answer Yes 

Answer Yes 

Within the cluster of 19 pem1anent employees in grades CT -1 to CT -10, 1% I employees) are people with targeted disabilities, a 

decrease from- % I employee) in FY19. Of the 677 pe1111anent employees in the cluster of CT 11 and higher,. % I 

enwlovees) are PWTD. Both clusters are beneath the 2% tari;teted i;toal. 

Grade Level Clustct{GS or Alternate Pay 

Planb) 

Numarical Goal 

Total 

# 

R ortablc Disabili Tar2cted Disabili 

# % # % 

12% 2% 

3. Describe how the agency has conmnmicated the mm1erical goals to the hiri.ng managers and/or recmiters. 

The agency continues to take steps to ensure that key stakeholders know that the CFTC has adopted the mandatory 2% and 12% 

employment goals. For example HR Specialists provided and discussed the various options available to hiring officials for hiring 

PWDs and PWTDs. OMWI also reviews the goals with the Chief Human Capital Officer, and briefs the CFTC Chainnan. Chief of 

*Note that to protect privacy, derived values of 9 or Jess have been redacted from the pubJic posting of this report. 

Additionally, due to accuracy errors from the Equal Employment Opportunity Commission's (EEOC) data 

generation system, all data generated by the EEOC has been redacted. 

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Commodity Futures Trading 

Commission 

lstaff and labor mi.ion to ensure that they are aware of the goals and what the agency can do to reach them. 

Section II: Model Disability Program 

FY 2020 

Pursuant to 29 C.F.R. § 1614.203(d)(l), agencies must ensure sufficient staff, training and resources to recmit and hire persons with 

disabilities and persons with targeted disabilities, administer the reasonable accommodation program and special emphasis program, 

and oversee any other disability hiring and advancement program the agency has in place. 

A. PLAN TO PROVIDE SUFFICIENT & COMPETENT STAFFING FOR THE DISABILITY 

PROG~I 

1. Has the agency designated sufficient qualified personnel to implement its disability program during the reporting period? 

If"no", describe the agency's plan to improve the staffing for the upconiing year. 

Answer Yes 

2. Identify all staff responsible for implementing the agency's disability employment program by the office, staff 

employment status, and responsible official. 

# of FTE Staff By Employment Status Responsible Official 

(Name, Title, Office 

Email) 

Disability Program Task 

Full Time Part Time Collateral Duty

Section 508 Compliance 0 1 0 Kennet Ake 

IT Specialist 

Section508@cflc.gov 

Processing applications from PWD and PWTD 0 1 0 Sarata Head 

Employinent Manager 

SHead@cftc.gov 

Answering questions from the public about 

hiring authorities that take disability into 

account 

0 1 0 Sarata Head 

Employinent Manager 

SHead@cftc.gov 

Processing reasonable accommodation requests 

from applicants and employees 

0 1 0 Lauren Colon 

Chief, Workforce 

Relations 

LColon@cftc.gov 

Architectural Barriers Act Compliance 0 0 1 Wesley French 

Manager - Programs and 

Planning 

dclohelpdesk@cftc.gov 

Special Emphasis Program for PWD and 

PWTD 

0 1 0 Derrick Wilson 

Diversity and Inclusion 

Specialist 

dwilson@cftc.gov 

3. Has the agency provided disability program staff with sufficient training to cany out their responsibilities during the 

reporting period? If "yes", describe the training that disability program staff have received. If "no", describe the training 

planned for the upcoming year. 

Answer Yes 

CFTC staff has sufficient training to carry out their responsibilities, including training and extensive experience in the application of 

federal human resource requirements and best practices regarding reasonable accommodations, non-competitive hiring authorities, 

accessibility, and disability inclusion. Staff also continues to engage in no-cost activities designed to increase their knowledge and 

skill including online ti-aining and reviewing material posted to the EEOC website. Disability Program Staff has full access to 

cutting-edge. legal research tools such as Lexis Nexis to c-ontinue to build on their extensive experience and educate themselves on 

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Commodity Futures Trading 

Commission 

FY 2020 

how to address complex disability issues. For example, staff members recently conducted negotiations for the agency's collective 

bargaining agreement. Through that process, staff conducted in-depth research on reasonable accommodation requirements under 

Section 50 I of the Rehabilitation Act in order to effectively negotiate with the union. 

B. PLAN TO ENSURE SUFFICIENT FUNDING FOR THE DISABILITY PROGRAM 

Has the agency provided sufficient funding and other resources to successfully implement the disability program during 

the reporting period? If"no", describe the agency's plan to ensure all aspects of the disability program have sufficient 

funding and other resources. 

Answer Yes 

IA 

Section III: Program Deficiencies In The Disability Program 

B1ief Description of Prngrnm 

Deficienc.y 

I C.2.b. Has the agency established disability reasonable accommodation procedures that comply with EEOC's 

regulations and guidance? [see 29 CFR §1614.203(d)(3)] 

Objective Establish disability reasonable accommodation procedures that comply with the EEOC's regulations 

and guidance. 

Target Date Sep 30, 22 

Completion Date 

Target Date Coml!,letion Date Planned Activity 

Sep 30, 2022 The CFTC sent its draft procedures to the EEOC for review on 7/29/2019 

and received the EEOC's feedback regarding the procedures on 2/8/2021. 

The agency will update its procedures in accordance with the EEOC's 

feedback and then adopt them. 

Planned Activities 

Accomplishments Fiscal Year Accom1!,lisl1ment 

Btief Description of Prngrnm 

Deficiency 

C.2.c. Has the agency established procedures for processing requests for personal assistance services that comply with 

EEOC's regulations, enforcement guidance, and other applicable executive orders, guidance, and standards? [see 29 

CFR §1614.203(d)(6)] 

Objective 

Target Date 

Completion Date 

Planned Activities 

Accomplishments 

Establish procedures for processing personal assistance services that comply with EEOC's 

regulations and guidance. 

Sep 30, 22 

Target Date 

Sep 30, 22 

Fiscal Year 

Completion Date Planned Activity 

Accomplishment 

The CFTC sent its draft procedures to the EEOC for review on 7/29/2019 

and received the EEOC's feedback regarding the procedures on 2/8/2021. 

The agency is updating its procedures in accordance with the EEOC's 

feedback and will then adopt them. 

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Commodity Futures Trading 

Commission 

FY 2020 

Btief Description of Progrnm 

Deficiency 

I C.2.c.1. Does the agency post its procedures for processing requests for Personal Assistance Services on its public 

website? [see 29 CFR §1614.203(d)(5)(v)] If"yes", please provide the internet address in the comments column. 

Objective 

Target Date 

Completion Date 

Planned Activities 

Accomplishments 

Btief Description of Progrnm

Deficiency 

Objective 

Target Date 

Completion Date 

Planned Activities 

Accomplishments 

The agency will post its procedures for processing requests for Personal Assistance Se1vices on its 

public website. 

Sep 30, 22 

Target Date 

Sep 30, 2022 

Fiscal Year 

Completion Dote Planned Activity 

Accomplishment 

The CFTC sent its draft procedures to the EEOC for review on 7/29/2019 

and received the EEOC's feedback regarding the procedures on 2/8/2021. 

The agency is updating its procedures in accordance with the EEOC's 

feedback. Procedures will be posted once that update is complete. 

I C.3.b.6. Provide disability accommodations when such accommodations do not cause an undue hardship? [ see 29 CFR 

§1614.102(a)(8)] 

Require rating officials to evaluate the perfonna.nce of managers and supe1visors based on the 

activities listed in C.3.bl-C.3.b.9 

Nov 30, 2021 

Target Dote Comu.letion Date Planned Activit'J!. 

Nov 30, 2021 I I Reminders throughout year of the performance rating process. Updates to 

the performance form are underway. 

Fiscal Year Accomu.lishment 

Section IV: Plan to Recruit and Hire Individuals with Disabilities 

Pursuant to 29 C.F .R. § 1614.203( d)(l )(i) and (ii), agencies must establish a plan to increase the recmitment and hiring of 

individuals with disabilities. The questions below are designed to identify outcomes of the agency's recmitment program plan for 

PWD andPWTD 

A. PLAN TO IDENTIFY JOB APPLICATIONS WITH DISABILITIES 

1. Describe the programs and resources the agency uses to identify job applicants with disabilities, including individuals with 

targeted disabilities. 

The agency utilizes a variety of recmitment strategies to increase the number of qualified applicants with disabilities and applicants 

with targeted disabilities within the major occupations. These include sourcing Schedule A, subpart (u) qualified applicants via 

State Vocational Rehabilitation Services and Veteran organizations, utilizing Veteran hiring programs, and attending local career 

fairs that focus on disability hiring, and identifying and reaching out to professional associations that include people with disabilities 

such as the National Association of Attomevs with Disabilities and the Deaf and Ha.rd of He.arin2 Bar Association. 

2 . Pw-suant to 29 C.F.R. § 1614.203(a.)(3), describe the agency's use of hiring authorities that take disability into account 

( e.g., Schedule A) to recmit PWD and PWTD for positions in the pennanent workforce 

IThe Human Resources Branch provides qualified Schedule A and disabled Veteran applicants to hiring officials when appropriate. 

3. When individuals apply for a position under a hiring authority that takes disability into account (e.g., Schedule A), explain 

how the agency (1) detennines if the individual is eligible for appointment wider such authority; and, (2) fo1wa.rds the 

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Commodity Futures Trading 

Commission 

FY 2020 

individual's application to the relevant hiring officials with an explanation of how and when the individual may be 

appointed. 

(1) CFTC dete1mines if the individual is eligible for appointment under such authority by requiring certification for the appropriate 

disability resource. (2) Qualified schedule A, subpart (u) and Veterans applicant information (certs) are fo1warded to hiring officials 

as part of the list of eligible candidates. HR Specialists are available to discuss all pa1ts of the Schedule A and other PWD-type of 

hiring authorities. 

4. Has the agency provided training to all hiring managers on the use of hiring authorities that take disability into account 

( e.g., Schedule A)? If "yes", describe the type(s) of training and frequency. If "no", describe the agency's plan to provide 

this training. 

Answer Yes 

Instruction and use of hiring authorities - including Schedule A, subpart (u) and Veteran Hiring Authorities - are provided to new 

supervisors during their required 40 hours of training. Online courses are also made available and encouraged. Periodic refresher 

courses are also available and orovided to hirirnz officials. 

B. PLAN TO ESTABLISH CONTACTS WITH DISABILITY EMPLOYMENT ORGANIZATIONS 

Describe the agency's effo1ts to establish and maintain contacts with organizations that assist PWD, including PWTD, in 

securing and maintaining employment. 

During FY20 and FY2 l the CFTC will expand its outi·each and find additional resources to increase the recruitinent and hiring of 

PWD and PWTD to mission critical occupations. Two potential resources that have been identified include the National Association 

of Attomevs with Disabilities and the Deaf and Hard of Hearing Bar Association. 

C. PROGRESSION TOW ARDS GOALS (RECRUITMENT AND IDRING) 

1. Using the goals of 12% for PWD and 2% for PWTD as the benchmarks, do triggers exist for PWD and/or PWTD among 

the new hires in the permanent workforce? If"yes", please describe the triggers below. 

a. New Hires for Pe1manent Workforce (PWD) Answer No 

b. New Hires for Permanent Workforce (PWTD) Answer Yes 

Among the 10 hires in FY2020,_ identified as a PWD %), which is above the benchmark of 12% .• hires in FY2020 

identified as a PWTD % which is below the 2% benchmark resultin in a tri er. 

•

New Hires 

% of Total 

Applicants 

% of Qualified 

Applicants 

% of New Hires 

Total 

(#) 

• 

• 

Reportable Disability 

Pe1manent 

Workforce 

(%) 

-

-

Tempora1y 

Workforce 

(%) 

-

-

Targeted Disability 

Permanent 

Workforce 

(%) 

-

-

Temporary 

Workforce 

(%) 

-

- 2. Using the qualified applicant pool as the benchmark, do triggers exist for PWD and/or PWTD among the new hires for any 

of the mission- critical occupations (MCO)? If"yes", please describe the ti·iggers below. Select "n/a" if the applicant data 

is not available for your agency, and describe your plan to provide the data in the text box. 

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Commodity Futures Trading 

Commission 

a. New Hires for MCO (PWD) 

b . New Hires for MCO (PWTD) 

IData w1available for this analysis. See Pait H for plan to collect it. 

New Hires to 

Mission-Critical 

Occupations 

Numerical Goal 

01 l0ECONOMIST 

0301MISC ADMIN 

&PROG 

051 lAUDITOR 

0905ATTORNEY 

l l0lGRAL BUSN 

&IND 

1801GRAL INSP 

INV& 

COMPLIANCE 

2210ITMGMT 

Total 

(#) 

I 

I 

I 

Repo1table Disability 

Qualified 

Applicants 

(o/o) 

New Hires 

(%) 

12% 

- - - - - -

Answer NIA 

Answer NIA 

FY 2020 

Targetable Disability 

Qualified Applicants 

(%) 

2% 

-

-

-

New Hires 

(%) 

-

-

- 3. Using the relevant applicant pool as the benchmark, do triggers exist for PWD and/or PWTD among the qualified internal 

applicants for any of the mission-critical occupations (MCO)? If "yes", please describe the triggers below. Select "n/a" if 

the applicant data is not available for your agency, and desc1·ibe your plan to provide the data in the text box. 

a. Qualified Applicants for MCO (PWD) 

b . Qualified Applicants for MCO (PWTD) 

IData wiavailable for this analysis. See Prut H for plan to collect it. 

Answer NIA 

Answer NIA 

4. Using the qualified applicant pool as the benchmark, do triggers exist for PWD and/or PWTD among employees promoted 

to any of the mission- critical occupations (MCO)? If "yes", please describe the triggers below. Select "n/a" if the 

applicant data is not available for your agency, and describe your plan to provide the data in the text box. 

a. Promotions for MCO (PWD) Answer Yes 

b . Promotions for MCO (PWTD) Answer Yes 

Of the 3 1 MCO employees promoted in FY2020, I identified as a Person with a Disability - %); while higher than the % 

pa1ticipation in the workforce, it is still below the 12% benchmark.I identified as a Person with a Targeted Disability, below the 

2% benchmark. 

•

Section V: Plan to Ensure Advancement Opportunities for Employees with 

Disabilities 

Pursuant to 29 C.F .R. § 1614.203( d)(l )(iii), agencies are required to provide sufficient advancement opportunities for employees 

with disabilities. Such activities might include specialized training and mentoring programs, career development oppo1twiities, 

awards programs, promotions, and similar programs that address advancement. In this section, agencies should identify, and provide 

data on programs designed to ensure advancement oppo1tw1ities for employees with disabilities. 

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Commodity Futures Trading 

Commission 

Describe the agency's plan to ensure PWD, including 

A. ADVANCEMENT PROGRAM PLAN 

PWID, have sufficient opportunities for advancement. 

FY2020 

To ensure that people with disabilities can access all learning oppo1tunities, the CFTC processes all requests for reasonable 

accommodations regarding training appropriately and ensm-es that trainings disseminated through its Leaming Management System 

are compliant with Section 508 of the Rehabilitation Act. Though opportunities for training and development programs do not 

exclude PWD or PWTD and all employees are afforded the same opportunities for advancement as appropriate, the CFTC will 

work to :farther develop a comprehensive plan to ensure advancement opportunities for PWD. The plan will include the use of 

details and job assignments as well as mentoring to advance P\\ID. 

B. CAREER DEVELOPMENT OPPORTUNITES 

1. Please describe the career development opportunities that the agency provides to its employees. 

The Commission offered a munber of regulatory leam.ing engagements that were delivered through eLeam.ing training sessions. TI1e 

Commission continued to offer Continued Legal Educations (CLE) and Continued Professional Education (CPE) training access to 

all employees. These courses afford staff with relevant information in: Accounting, Auditing, Dodd-Frank legislation, Swaps, 

Derivatives, Financial Market essentials, Project Management, Financial Management and ethics. Using blended learning 

techniques, CFTC staff participated in mission-related seminars available via in-person training, fomms, seminars, live webcasts, 

audio CD's and DVDs, MP3s, com-se handbooks and on- demand leaming. Th.is training opportunity is offered to all qualified 

employees, .including persons with disabilities. The CFTC goes to law schools and colleges to recruit unpaid (voluntary) intems. 

CFTC trained these intems on the transition from being an Intem to federal employee and provided training on the OPM hiring 

authorities for .intemship programs: including the Pathways Program, Student Vohmteer Program, Unpaid Intem Program and 

Disability Employment. Additionally, the CFTC utilizes competitive and non-competitive detail assignments both intemally and 

with other agencies as oooortunities for advancement. 

2. In the table below, please provide the data for career development opportmuties that require competition and/or 

supervisory recommendation/ approval to participate. 

Total Participants PWD PWTD 

Career Development Applicants Applicants Opportunities Applicants(#) Selectees (#) (%) Selectees (%) (%) Selectees (%) 

Intemship Programs 0 0 0 0 0 0 

Fellowship Programs 0 0 0 0 0 0 

Mentoring Programs 0 0 0 0 0 0 

Coaclung Programs 0 0 0 0 0 0 

Trai1ung Programs 0 0 0 0 0 0 

Detail Programs 0 0 0 0 0 0 

Other Career Development 0 0 0 0 0 0 

Programs 

3. Do triggers exist for PVlD among the applicants and/or selectees for any of the career development programs? (The 

appropriate benclunarks are the relevant applicant pool for the applicants and the applicant pool for selectees.) If"yes", 

describe the trigger(s) in the text box. Select "n/a" if the applicant data is not available for yom agency, and describe your 

plan to provide the data in the text box. 

a. Applicants (PV/D) 

b. Selections (PWD) 

Answer NIA 

Answer NIA 

!No triggers were identified as the CFTC does not have a fo1mal career development program. 

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Commodity Futures Trading 

Commission 

FY 2020 

b. Selections (PWTD) 

Answer NIA 

Answer NIA 

a. Applicants (PWTD) 

4. Do triggers exist for PWTD among the applicants and/or selectees for any of the career development programs? (The 

appropriate benchmarks are the relevant applicant pool for the applicants and the applicant pool for selectees.) If"yes", 

describe the trigger( s) in the text box. Select "nla" if the applicant data is not available for your agency, and describe your 

plan to provide the data in the text box. 

!No triggers were identified as the CFTC does not have a fotmal career development program. 

C. AWARDS 

1. Using the inclusion rate as the benchmark, does your agency have a trigger involving PWD and/or PWTD for any level of 

the time-off awards, bonuses, or other incentives? If"yes", please describe the trigger(s) in the text box. 

a. Awards, Bonuses, & Incentives (PWD) 

b. Awards, Bonuses, & Incentives (PWTD) 

Answer No 

Answer No 

PWD are 5.3% of the workforce, they received 4.8% of time off awards (1-9 hours), 5.7% of time off awards (9+ hours), and 5.0% 

of cash awards. PWTD are- % of the workforce, they received- % of time off awards (1-9 hours),. % of time off awards 

9+ hours and "-%'--'-of=.....cc ca=s=h'--'a'"' .w"""a=r-"d-'-s.'--------------------------------------1 

Reportable Without Reportable Targeted Disability Without Targeted 

Time-Off Awards Total (#) Disability % Disability % % Disability % 

Time-Off Awards 1 - 10 hours: 

Time-Off 

Awar

Awards 

ds Gi

1 

v

-

en 

10 Hours: 

• - - - -

Time-Off 

T

Awards 

otal Hours 

1 - 10 Hours: - - - - -

Time-Off 

A

Awar

verage 

ds 

H

11 

ours 

- 20 hours: - - - - -

Time-Off 

Awar

Awar

ds 

ds 

Gi

11 

ven 

- 20 Hours: 

• - - - -

Time-Off Awar

Total 

ds 

Hours 

11 - 20 Hours: 

• - - - -

Time-Off 

A

Awar

verage 

ds 

H

2

o

1 -

urs 

30 hours: - - - - - • 

Time-Off 

Awar

Awar

ds 

ds 

Gi

21 -

ven 

30 Hours: 

- - - -

Time-Off Awar

Total 

ds 

Hours 

21 - 30 Hours: - - - - -

Time-Off 

A

Awar

verage 

ds 

Hours 

31 - 40 hours: - - - - -

Awards Given • 

Time-Off Awards 31 - 40 Hours: 

- - - -

Time-Off Awar

Total 

ds 

Hours 

31 - 40 Hours: -

• 

- - - -

Time-Off 

Av

Awar

erage 

ds 

Hours 

41 or more - - - -

Hours: Awards Given I 

Time-Off Awards 41 or more I 

- - - -

Time-Off 

Hours

Awar

: Total 

ds 41 

Hours 

or more I 

- - - -

Hours: Average Hours - - - -

Page 8 
Commodity Futures Trading 

Commission 

Cash Awards 

Cash Awards: $501 - $999: Awards 

Given 

Cash Awards: $501 - $999: Total 

Amount 

Cash Awards: $501 - $999: 

Average Amount 

Cash Awards: $1000 - $1999: 

Awards Given 

Cash Awards: $1000 - $1999: Total 

Amount 

Cash Awards: $1000 - $1999 

Average Amount 

Cash Awards: $2000 - $2999: 

Awards Given 

Cash Awards: $2000 - $2999: Tota

Amount 

l 

Cash Awards: $2000 - $2999 

Average Amount 

Cash Awards: $3000 - $3999 

Awards Given 

Cash Awards: $3000 - $3999: Total 

Amount 

Cash Awards: $3000 - $3999: 

Average Amount 

Cash Awards: $4000 - $4999: 

Awards Given 

Cash Awards: $4000 - $4999: Total 

Amount 

Cash Awards: $4000 - $4999: 

Average Amount 

Cash Awards: $5000 or more: 

Awards Given 

Cash Awards: $5000 or more: Total 

Amount 

Cash Awards: $5000 or more: 

Average Amount 

Total (#) 

I 

I 

I 

• 

-

-

I 

I 

I 

I 

I 

I 

I 

I 

I 

I 

-

-

FY 2020 

Reportable 

Disability % 

Without Reportable 

Disability % 

Targeted Disability 

% 

Without Targeted 

Disability % 

- - - -

- - - -

- - - -

- - - -

- - -

- - - -

- - - -

- - - -

- - - -

- - - -

- - - -

- - - -

- - - -

- - - -

- - - -

- - - -

- - - -

2. Using the inclusion rate as the benchmark, does your agency have a trigger involving PWD and/or PWTD for quality step 

increases or perfonnance- based pay increases? If "yes", please describe the trigger(s) in the text box. 

a. Pay Increases (PWD) Answer No 

b. Pay Increases (PWTD) Answer No 

IThe CFTC is not a title 5 agency and does not have or use QSl's. 

Reportable 

Disability % 

Without Reportable

Disability % 

Targeted Disability 

% 

Without Targeted 

Other Awards Total (#) Disability % 

Total Performance Based Pay 

Increases Awarded 

I - - - -

3. If the agency has other types of employee recognition programs, are PWD and/or PWTD recognized disproportionately 

less than employees without disabilities? (The appropriate benchmark is the inclusion rate.) If"yes", describe the 

employee recognition program and relevant data in the text box. 

a. Other Types of Recognition (PWD) Answer NIA 

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Commodity Futures Trading 

Commission 

b. Other Types of Recognition (PWTD)

D. PROMOTIONS 

FY 2020 

Answer NIA 

1. Does yom agency have a trigger involving PWD among the qua.lilied internal applicants and/or selectees for promotions to 

the senior grade levels? (The appropriate benchmarks are the relevant applicant pool for qualified intemal applicants and 

the qualified applicant pool for selectees.) For non-GS pay plans, please use the approximate senior grade levels. If "yes", 

describe the trigger( s) in the text box. Select "nla" if the applicant data is not available for yom agency, and describe your 

plan to provide the data in the text box. 

a.SES 

i. Qualified Intemal Applicants (PWD) 

ii. Intemal Selections (PWD) 

b. Grade GS-15 

i. Qualified Intemal Applicants (PWD) 

ii. Internal Selections (PWD) 

c. Grade GS-14 

i. Qualified Internal Applicants (PWD) 

ii. Intemal Selections (PWD) 

d. Grade GS-13 

i. Qualified Intemal Applicants (PWD) 

ii. Internal Selections (PWD) 

IData unavailable for this analysis. See Pait H for plan to collect it. 

Answer NIA 

Answer NIA 

Answer NIA 

Answer NIA 

Answer NIA 

Answer NIA 

Answer NIA 

Answer NIA 

2. Does yom agency have a trigger involving PWTD among the qualified intemal applicants and/or selectees for promotions 

to the senior grade levels? (The appropriate benchmarks are the relevant applicant pool for qualified internal applicants 

and the qualified applicant pool for selectees.) For non-GS pay plans, please use the approximate senior grade levels. If 

"yes", describe the trigger(s) in the text box. Select "nla" if the applicant data is not available for your agency, and 

describe your plan to provide the data in the text box. 

a.SES 

i. Qualified Internal Applicants (PWTD) 

ii. Intemal Selections (PWTD) 

b. Grade GS-15 

i. Qualified Intemal Applicants (PWTD) 

ii. Internal Selections (PWTD) 

c. Grade GS-14 

i. Qualified Internal Applicants (PWTD) 

Answer NIA 

Answer NIA 

Answer NIA 

Answer NIA 

Answer NIA 

Page 10 
Commodity Futures Trading 

Commission 

ii. Intemal Selections (PWTD) 

d. Grade GS-13 

i. Qualified Intemal Applicants (PWTD) 

ii. Intemal Selections (PWTD) 

IData unavailable for this analysis. See Patt H for plan to collect it. 

Answer NIA 

Answer NIA 

Answer NIA 

FY 2020 

3. Using the qualified applicant pool as the benchmark, does yom agency have a trigger involving PWD among the new hires 

to the senior grade levels? For non-GS pay plans, please use the approximate senior grade levels. If"yes", describe the 

trigger(s) in the text box. Select "nla" if the applicant data is not available for your agency, and describe your plan to 

provide the data in the text box. 

a. New Hires to SES (PWD) 

b. New Hires to GS-15 (PWD) 

c. New Hires to GS-14 (PWD) 

d. New Hires to GS-13 (PWD) 

IData unavailable for this analysis. See Patt H for plan to collect it. 

Answer NIA 

Answer NIA 

Answer NIA 

Answer NIA 

4. Using the qualified applicant pool as the benchmark, does your agency have a trigger involving PWTD among the new 

hires to the senior grade levels? For non-GS pay plans, please use the approximate senior grade levels. If''yes", describe 

the trigger(s) in the text box. Select "n/a" if the applicant data is not available for your agency, and describe your plan to 

provide the data in the text box. 

a. New Hires to SES (PWTD) 

b. New Hires to GS-15 (PWTD) 

c. New Hires to GS-14 (PWTD) 

d. New Hires to GS-13 (PWTD) 

IData unavailable for this analysis. See Patt H for plan to collect it. 

Answer NIA 

Answer NIA 

Answer NIA 

Answer NIA 

5. Does yom agency have a trigger involving PWD among the qualified internal applicants and/or selectees for promotions to 

supervisory 

positions? (The appropriate benchmarks are the relevant applicant pool for qualified intemal applicants and the qualified 

applicant pool for selectees.) If"yes", describe the trigger(s) in the text box. Select "n/a" if the applicant data is not 

available for your agency, and describe your plan to provide the data in the text box. 

a. Executives 

i. Qualified Intemal Applicants (PWD) 

ii. Intemal Selections (PWD) 

b. Managers 

i. Qualified Intemal Applicants (PWD) 

ii. Internal Selections (PWD) 

Answer NIA 

Answer NIA 

Answer NIA 

Answer NIA 

Page II 
Commodity Futures Trading 

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c. Supervisors 

i. Qualified Intemal Applicants (PWD) 

ii. Internal Selections (PWD) 

IData unavailable for this analysis. See Patt H for plan to collect it. 

Answer NIA 

Answer NIA 

FY 2020 

6. Does yom agency have a trigger involving PWTD among the qualified intemal applicants and/or selectees for promotions 

to supervis01y positions? (The appropriate benchmarks are the relevant applicant pool for qualified intemal applicants and 

the qualified applicant pool for selectees.) If "yes", describe the trigger(s) in the text box. Select "n/a" if the applicant data 

is not available for yow· agency, and describe your plan to provide the data in the text box. 

a. Executives 

i. Qualified Intemal Applicants (PWTD) 

ii. Intemal Selections (PWTD) 

b. Managers 

i. Qualified Intemal Applicants (PWTD) 

ii. Intemal Selections (PWTD) 

c. Supervisors 

i. Qualified Intemal Applicants (PWTD) 

ii. Intemal Selections (PWTD) 

IData unavailable for this analysis. See Pait H for plan to collect it. 

Answer NIA 

Answer NIA 

Answer NIA 

Answer NIA 

Answer NIA 

Answer NIA 

7. Using the qualified applicant pool as the benchmark, does your agency have a trigger involving PWD among the selectees 

for new hires to supervisoty positions? If "yes", describe the trigger(s) in the text box. Select "nla" if the applicant data is 

not available for your agency, and describe your plan to provide the data in the text box. 

a. New Hires for Executives (PWD) 

b. New Hires for Managers (PWD) 

c. New Hires for Supervisors (PWD) 

IData w1available for this analysis. See Patt H for plan to collect it. 

Answer NIA 

Answer NIA 

Answer NIA 

8. Using the qualified applicant pool as the benchmark, does your agency have a trigger involving PWTD among the 

selectees for new hires to supervisoty positions? If "yes", describe the trigger(s) in the text box. Select "nla" if the 

applicai1t data is not available for your agency, and describe your plan to provide the data in the text box. 

a. New Hires for Executives (PWTD) 

b. New Hires for Managers (PWTD) 

c. New Hires for Supervisors (PWTD) 

IData w1available for this analysis. See Patt H for plan to collect it. 

Answer NIA 

Answer NIA 

Answer NIA 

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Section VI: Plan to Improve Retention of Persons with Disabilities 

FY 2020 

To be model employer for persons with disabilities, agencies must have policies and programs in place to retain employees with 

disabilities. In this section, agencies should: (1) analyze workforce separation data to identify ban·iers retaining employees with 

disabilities; (2) describe efforts to ensure accessibility of technology and facilities; and (3) provide infonnation on the reasonable 

accommodation program and workplace assistance services. 

A. VOLUNTARY AND INVOLUNTARY SEPARATIONS 

1. In this repo1t ing period, did the agency conve1t all eligible Schedule A employees with a disability into the competitive 

service after two years of satisfacto1y service (5 C.F.R. § 213.3102(u)(6)(i))? If "no" , please explain why the agency did 

not conve1t all eligible Schedule A employees. 

Answer NIA 

o employees have been eligible for conversion during this reporting period. Any employees that are eligible are conve1ted as 

2. Using the inclusion rate as the benchmark, did the percentage of PWD among voluntary and involuntary separations 

exceed that of persons without disabilities? If"yes", describe the trigger below. 

a.Voluntruy Sepru·ations (PWD) 

b.Involunta1y Sepru·ations (PWD) 

IData unavailable for this ruialysis. See Pait H for plru1 to collect it. 

Seperations Total# 

Permanent Workforce: Reduction in Force 0 

Permanent Workforce: Ren1oval 0 

Pem1anent Workforce: Resignation 0 

Permanent Workforce: Retirement 0 

Permanent Workforce: Other Separations 0 

Pemianent Workforce: Total Separations 0 

Answer No 

Answer No 

Without Reportable 

Reportable Disabilities % Disabilities % 

0.00 0.00 

0.00 0.00 

0.00 0.00 

0.00 0.00 

0.00 0.00 

0.00 0.00 

3. Using the inclusion rate as the benchmark, did the percentage of PWTD among volunta1y and involunta1y separations 

exceed that of persons without targeted disabilities? If "yes", describe the trigger below. 

a.Voluntary Sepru·ations (PWTD) 

b.Involunta1y Separations (PWTD) 

IData m1available for this analysis. See Patt H for plan to collect it. 

Seperations Total# 

Permanent Workforce: Reduction in Force 0 

Pem1anent Workforce: Removal 0 

Permanent Workforce: Resignation 0 

Permanent Workforce: Retirement 0 

Pemianent Workforce: Other Separations 0 

Permanent Workforce: Total Separations 0 

Answer No 

Answer No 

Without Targeted Disabilities 

Targeted Disabilities % % 

0.00 0.00 

0.00 0.00 

0.00 0.00 

0.00 0.00 

0.00 0.00 

0.00 0.00 

Page 13 
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FY 2020 

4. If a trigger exists involving the separation rate of PWD and/or PWTD, please explain why they left the agency using exit 

interview results and other data sources. 

B. ACCESSIBILITY OF TECHNOLOGY AND FACILITIES 

Pursuant to 29 CFR §1614.203(d)(4), federal agencies are required to infonn applicants and employees of their rights under Section 

508 of the Rehabilitation Act of 1973 (29 U.S.C. § 794(b ), concerning the accessibility of agency technology, and the Architectural 

Ban·iers Act of 1968 (42 U.S.C. § 4151-4157), concerning the accessibility of agency facilities. In addition, agencies are required to 

infonn individuals where to file complaints if other agencies are responsible for a violation. 

1. Please provide the internet address on the agency's public website for its notice explaining employees' and applicants' 

rights under Section 508 of the Rehabilitation Act, including a description of how to file a complaint. 

lhttps://www.cftc.gov/WebPolicy/EEONoFearAct/index.htm 

2. Please provide the internet address on the agency's public website for its notice explaining employees' and applicants' 

rights under the 

Architectural Ba1riers Act, including a description of how to file a complaint. 

lhttps://www.cftc .gov/WebPolicy/EEONoFearAct/index.htm 

3. Describe any programs, policies, or practices that the agency has w1de1taken, or plans on undettaking over the next fiscal 

year, designed to improve accessibility of agency facilities and/or technology. 

!Facilities comply with accessibility requirements in all Offices: Washington, DC; New York, NY; Chicago, IL; Kansas City, MO. 

C. REASONABLE ACCOMMODATION PROGRAM 

Pursuant to 29 C.F.R. § 1614.203(d)(3), agencies must adopt, post on their public website, and make available to all job applicants 

and employees, reasonable accommodation procedures. 

1. Please provide the average time frame for processing initial requests for reasonable accommodations during the reporting 

period. (Please do not include previously approved requests with repetitive accommodations, such as interpreting services.) 

The average time frame for processing initial requests for reasonable accommodation during the repo1ting period is seven (7) 

business da s. 

2. Describe the effectiveness of the policies, procedures, or practices to implement the agency's reasonable accommodation 

program. Some examples of an effective program include timely processing requests, timely providing approved 

accommodations, conducting training for managers and supervisors, and monitoring accommodation requests for trends. 

CFTC has consistently provided responses to reasonable accommodation requests, both approved and not approved. Managers and 

su ervisors have been trained on reasonable accommodation res onsibilities. includi.n the rocess. 

D. PERSONAL ASSISTANCE SERVICES ALLOWING EMPLOYEES TO PARTICIPATE IN THE 

WORKPLACE 

Pursuant to 29 CFR §1614.203(d)(5), f ederal agencies, as an aspect of affinnative action, are required to p rovide p ersonal 

assistance sen 1ices (PAS) to emp loyees who need them because of a targeted disability, unless doing so would impose an undue 

hardship on the agency. 

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Commodity Futures Trading 

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FY2020 

Describe the effectiveness of the policies, procedures, or practices to implement the PAS requirement. Some examples of 

an effective program include timely processing requests for PAS, timely providing approved services, conducting training 

for managers and supervisors, and monitoring PAS requests for trends. 

One of the strengths of the CFTC's personal assistance services procedures is that they are integrated into the CFTC's reasonable 

accommodation procedures to ensure consistency and efficiency. The CFTC did not receive any requests for Personal Assistance 

Services in FY 2019, but will continue to evaluate the effectiveness of its procedures in FY 2020 and FY 2021. 

Section VII: EEO Complaint and Findings Data

A. EEO COMPLAINT DATA INVOLVING HARASSMENT 

1. During the last fiscal year, did a higher percentage of PWD file a fo1maI EEO complaint alleging harassment, as compared 

to the govemmentwide average? 

Answer No 

2. During the last fiscal year, did any complaints alleging harassment based on disability status result in a finding of 

discrimination or a settlement agreement? 

Answer No 

3. If the agency had one or more findings of discrimination alleging harassment based on disability status during the last 

fiscal year, please describe the corrective measures taken by the agency. 

ICFTC did not have any findings of discrimination in FY 2020. 

B. EEO COMPLAINT DATA INVOLVING REASONABLE ACCOMMODATION 

IA 

1. During the last fiscal year, did a higher percentage of PWD file a fo1maI EEO complaint alleging failure to provide a 

reasonable 

accommodation, as compared to the govemment-wide average? 

Answer No 

2. During the last fiscal year, did any complaints alleging failure to provide reasonable accommodation result in a finding of 

discrimination or a settlement agreement? 

Answer No 

3. If the agency had one or more findings of discrimination involving the failure to provide a reasonable accommodation 

during the last fiscal year, please describe the corrective measures taken by the agency. 

Section VIII: Identification and Removal of Barriers 

Element D of MD-715 requires agencies to conduct a banier ana~ysis when a trigger suggests that a policy, procedure, or practice 

may be impeding the employment opportunities of a protected EEO group. 

1. Has the agency identified any barriers (policies, procedures, and/or practices) that affect employment oppo1tunities for 

PWD and/or PWTD? 

Answer Yes 

2. Has the agency established a plan to correct the ba1rier(s) involving PWD and/or PWTD? 

Page 15 
Commodity Futures Trading FY 2020 

Commission 

Answer Yes 

3. Identify each trigger and plan to remove the ban-ier(s), including the identified barrier(s), objective(s), responsible 

official(s), planned activities, and, where applicable, accomplishments 

Page 16 
Commodity Futures Trading 

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Source of the Trigger: 

Specific Workforc.e Data 

Table: 

STATEMENT OF 

CONDITION THAT WAS 

A TRIGGER FOR A 

POTENTIAL BARRIER: 

Provide a brief nairntive 

describing the condition at 

issue. 

How was the condition 

recognized as a potential 

ban-ier? 

STATEMENT OF 

BARRIER GROUPS: 

Ba1Tier Analysis Process 

Completed?: 

Ba1Tier(s) Identified?: 

STATEMENT OF 

IDENTIFIED BARRIER: 

Provide a succinct statement 

of the agency policy, 

procedure 

or practice that has been 

detennined to be the ban-ier 

ofthe 

undesired condition. 

Date 

Initiated 

Target Date 

08/07/2019 09/20/2021 

Title 

Chief Human Capital Officer 

OMWI Director 

FY 2020 

Workforce Data (if so identify the table) 

Workforce Data Table - B4 

Trigger 1: PWD/PWTD by Grade level cluster in the permanent workforce - Within the cluster of 

19 pennanent employees in grades CT-1 to CT-10,1 % I employees) are people with disabilities, a 

decrease from- % I employee) in FY19. Of the 677 employees in the cluster of CT 11 and 

higher, 5.47% are people with disabilities (37 employees), an increase from 4.76% (3 1 employees) 

in FY19. Both clusters 

I 

are below the 12% benchmark goal. Within the cluster of 19 pennanent 

employees in grades CT-1 to CT-I0,1 % I employees) are people with tai·geted disabilities, a 

decrease from. % employee) in FY19. Of the 677 pennanent employees in the cluster of CT 

11 and higher, % employees) are PWTD. Trigger 2: PWDIPWTD by new hires in the 

pennai1ent workforce - Among the IO hires in FY2020, _ identified as a PWD • % ), which is 

above the benchmark of 12% resulting in a trigger. hires in FY2020 identified as a PWTD 1 %), 

which is below the 2% benchmark resulting in a trigg

• 

er. Trigger 3: PWD/PWTD by employees 

promoted to any MCO - Ofthe 31 MCO employees promoted in FY2020,I identified as a Person 

with a Disability ft%); while higher than the 5.3% participation in the workforce, it is still below 

the 12% benchmark. identified as a Person with a Targeted Disability, below the 2% benchmark. 

Trigger 4: Participation Below Goal for People with Disabilities (PWD) and People with Targeted 

Disabilities (PWTD) - In FY20, the 12% participation rate goal for PWD was not met for grades 

CTI0 and below nor for grades CTI I at1d 

•

above; instead, the participation rates werel % and 5.7% 

respectively. The 2% participation rate goal for PWTD was not met for grades CTI0 and below or 

CTI I and above and was insteadl % and % respectively. Positively, CTI I -13 was closest to the 

2% participation rate goal for PWTD atl %. 

Barrier Group 

People with Disabilities 

People with Targeted Disabilities 

y 

y 

Barrier Name Descl'iption of Policy, Procedure, 01· Practice 

PWD and PWTD are 

rn1den-epresented in 

applicant pipeline; 

attitudinal bairiers. 

I) PWD and PWTD are undetl'epresented in the CFTC's applicant 

pipeline; and 2) societal attitudinal ban-iers may create a reluctance 

to self-disclose disability status. 

Objective(s) and Dates for EEO Plan 

Sufficient 

Funding / 

Staffing? 

Date 

Modified 

Date 

Completed

Objective Desc.ription 

Yes Increase the number of PWD and PWTD employed by 

the CFTC. 

Responsible Official(s) 

Name Standards Address The Plan? 

KerriLaine Pmnella Yes 

Sarah Summerville Yes 

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Commodity Futures Trading 

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FY 2020 

Planned Activities Toward Completion of Objective 

Target Date Planned Activities Sufficient 

Staffing & 

Funding? 

Modified 

Date 

Completion 

Date 

09/30/2019 Research disability organizations to target for recmitment. Yes 09/30/2019 

09/30/2020 Resurvey the workforce's disability status. Yes 10/01/0019 

09/30/2020 Create and conduct disability inclusion training. Yes 10/01/0019 

03/01/2021 Hire a consultant to conduct a 360 degree diversity, 

equity, and inclusion review along with an agency-wide 

hairier analysis. 

Yes 

09/30/2021 Make diversity and inclusion training mandato1y for 

supervisors and employees; with additional targeted 

training required for supervisors. 

Yes 

12/31/2021 The agency will create a humai1 capital strategic plan 

with diversity, equity, and inclusion principles woven 

into it. 

Yes 

09/30/2021 Fonnalize the Diversity Workgroup Yes 

Report of Accomplishments 

Fiscal Year Accomplishment 

2020 As described in the executive summary and as planned, during FY2020, the agency law1ched the agency's 

first inter-office workgroup to conduct a bai1-ier analysis focused on two agency divisions, ai1d also provided 

an agency-wide training "Diversity in the Legal Profession: Busting Cognitive and Structural Biases." After the 

George Floyd tragedy, leaders of the African Americai1 Affinity Group and labor union made 

recommendations to the agency Chaitman to take further action on diversity, equity, and it1clusion. 

The CFTC Chaitman then annow1ced 4 steps dw-ing FY2020 that will help to address this hairier: 

1) the agency hired a consultant to conduct a 360 degree diversity, equity, and inclusion review along with an 

agency-wide ban-ier ai1alysis; 

2) the agency will plan to formalize the Diversity Workgroup; 

3) the agency will make diversity and inclusion training mandato1y for supervisors and employees; and 

4) the agency will create a human capital strategic plan with diversity, equity, and it1clusion principles woven 

into it. 

2018 The CFTC's OMWI speai·headed a trainit1g on anxiety and depression in the workplace it1 order to address 

stigmas regarding those conditions and to create a more inclusive environment. 

2019 The CFTC's OMWI: 1) c-onducted a campaign to resurvey the workforce's disability status by sending an email 

blast to all agency employees and handing out fliers and candy in the lobby to promote awareness; 2) 

developed and led a training "Disability Inclusion 101" for agency employees; and 3) researched disability 

organizations to target for potential recmitment. 

4. Please explain the factor(s) that prevented the agency from titnely completing any of the planned activities. 

IA 

5. For the planned activities that were completed, please describe the actual impact of those activities towai·d elirninating the 

hairier( s). 

!Further steps are needed to address the ban-iers, as the triggers still remain. 

6. If the planned activities did not con-ect the trigger(s) and/or ban-ier(s), please describe how the agency intends to in1prove 

the plai1 for the next fiscal year. 

Page 18 
Commodity Futures Trading 

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FY 2020 

During FY2021, 1) the agency will hire a consultant to conduct a 360 degree diversity, equity, and inclusion review along with an 

agency-wide ban-ier analysis; 2) the agency will plan to fonnalize the Diversity Workgroup; 3) the agency will make diversity and 

inclusion training mandatory for supervisors and employees; and 4) the agency will create a human capital strategic plan with 

diversity, equity, and inclusion principles woven into it. The agency will ensure that people with disabilities and people with 

targeted disabilities are included throughout all of these initiatives. 

Page 19