U.S. COMMODITY FUTURES TRADING COMMISSION

Three Lafayette Centre

1155 21st Street, NW, Washington, DC 20581

Telephone: (202) 418-5110

Office of the Inspector General

Semiannual Report to Congress

April 1, 2021 – September 30, 2021

U.S. Commodity Futures Trading Commission
U.S. COMMODITY FUTURES TRADING COMMISSION

Three Lafayette Centre

1155 21st Street, NW, Washington, DC 20581

Telephone: (202) 418-5110

October 29, 2021 

TO: Rostin Behnam, Acting Chairman 

Dawn D. Stump, Commissioner 

FROM: A. Roy Lavik 

Inspector General

SUBJECT: Semiannual Report of the Office of the Inspector General 

 Attached is the Office of the Inspector General’s Semiannual Report for the period from 

April 1, 2021, through September 30, 2021. This report is submitted to you in accordance with 

the requirements of Section 5 of the Inspector General Act of 1978, as amended, and summarizes 

completed reports and ongoing projects during the reporting period. 

 I appreciate your continuing support of this office. 
i 

SEMIANNUAL REPORT 

OF THE U.S. COMMODITY FUTURES TRADING COMMISSION (CFTC)

OFFICE OF THE INSPECTOR GENERAL (OIG)

TABLE OF CONTENTS

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

CFTC PROGRAMS and OPERATIONS .................................................................................. 5

CFTC OIG RESPONSIBILITIES, RESOURCES, ORGANIZATION, and 

INDEPENDENCE......................................................................................................................... 6

REQUIRED STATEMENT REGARDING INFORMATION ACCESS AND ASSISTANCE ........................... 8

MANAGEMENT and PERFORMANCE CHALLENGES for FY 2021 ................................ 8

AUDIT OPERATIONS ................................................................................................................ 9

COMPLETED AUDITS, INSPECTIONS, EVALUATIONS, AUDIT REVIEWS, AND OTHER AUDIT 

PROJECTS..................................................................................................................................... 9

FY 2021 CFTC’s Compliance Audit with the Digital Accountability and Transparency 

(DATA) Act of 2014 ................................................................................................................ 9

ONGOING AUDITS, AUDIT REVIEWS, AND OTHER AUDIT PROJECTS .......................................... 10

Audit of the CFTC’s FY 2021 Annual Financial Report ...................................................... 10

Audit of the CFTC’s FY 2021 Customer Protection Fund ................................................... 10

Federal Information Security Management Act (FISMA) Review: FY 2021 ....................... 10

Council of Inspectors General on Financial Oversight (CIGFO) Collaboration ................ 10

AUDIT REPORTS AND REVIEWS OVER SIX MONTHS OLD; REQUIRED STATEMENTS .................. 11

Table 1: Unimplemented Recommendations ................................................................... 11

Table 2: Detail of Unimplemented Recommendations .................................................... 11

INSPECTIONS & EVALUATIONS ......................................................................................... 12

ONGOING INSPECTIONS & EVALUATIONS .................................................................................. 12

CFTC Whistleblower Office’s Confidentiality Protections .................................................. 12

CFTC Policies and Procedures Concerning Capturing, Retaining and Accessing Cell 

Phone Data, Including Text Messages, Location, and Other Information / Data ................ 12

INVESTIGATIVE OPERATIONS ........................................................................................... 13

SUMMARY .................................................................................................................................. 13

DETAILS OF OIG INVESTIGATIVE ACTIVITY .............................................................................. 13

ONGOING INVESTIGATIVE MATTERS AND REQUIRED DISCLOSURES .......................................... 14

Table 3: Investigative Statistics for Referrals and Whistleblower Retaliation ................ 15
LEGAL & ECONOMIC RESEARCH ..................................................................................... 16

ONGOING LEGAL & ECONOMIC RESEARCH PROJECTS ............................................................... 16

White Paper Evaluating CFTC experience with Digital Assets ........................................... 16

White Paper Evaluating CFTC Experience with the Administrative Procedure Act ........... 16

LEGISLATIVE & REGULATORY PROJECTS ................................................................... 16

PEER REVIEWS........................................................................................................................ 17

Most Recent Peer Review of the CFTC OIG Audit Function ............................................... 17

Most Recent Peer Review of CFTC OIG Investigative Function ......................................... 18

SUMMARY of FINAL REPORTS NOT MADE PUBLIC..................................................... 18

STRATEGIC PLAN for the OFFICE of INSPECTOR GENERAL..................................... 18

MISSION, VISION, AND VALUES ................................................................................................. 18

STRATEGIC GOAL 1: EVALUATE THE ECONOMIC IMPACT OF CFTC REGULATORY ACTIONS 

THROUGH LEGAL ANALYSIS, WHITE PAPERS, INSPECTIONS AND EVALUATIONS, MANAGEMENT 

REVIEWS, AND OTHER PRODUCTS .............................................................................................. 19

Office of Legal and Economic Research (OLER): Legislative, Economic, and Regulatory 

Review Agenda ...................................................................................................................... 19

STRATEGIC GOAL 2: ADDRESS HIGH IMPACT ISSUES IN CFTC ADMINISTRATIVE AND MISSION 

PERFORMANCE ........................................................................................................................... 20

Office of Audits: Audit and Review Agenda.......................................................................... 20

STRATEGIC GOAL 3: ADDRESS EMPLOYEE AND CONTRACTOR MISCONDUCT PROMPTLY,

THOROUGHLY, AND RELIABLY .................................................................................................. 21

Office of Investigations: Investigative Agenda ..................................................................... 22

CONTACTING the OFFICE of the INSPECTOR GENERAL............................................. 22

APPENDICES............................................................................................................................. 23

Appendix 1 – Reports Issued with Questioned Costs .............................................................. 23

Appendix 2 – Reports Issued with Recommendations That Funds Be Put to Better Use .... 24

Appendix 3 - Index of IG Act Reporting Requirements ......................................................... 25

ii
1

EXECUTIVE SUMMARY

This semiannual report is issued by the Commodity Futures Trading Commission 

(CFTC) Office of the Inspector General (OIG) pursuant to the Inspector General Act of 1978, as 

amended.1 It summarizes OIG’s activities and accomplishments for the period April 1, 2021, 

through September 30, 2021. During this period, the Inspector General issued the yearly 

mandated assessment of management and performance challenges facing the CFTC. The Office 

of Audits completed an audit of CFTC’s compliance with procurement data requirements, with 

no significant issues noted; and began or continued work on three audits and a collaborative 

survey. Regarding inspections and evaluations, we began work on two new evaluations; both 

were pending at the close of the reporting period. On the investigations side, we began the 

reporting period with two investigations and two allegations pending. We finished the reporting 

period with four investigations and four allegations pending. Finally, the Office of Legal and 

Economic Research initiated a whitepaper project and continued a whitepaper project begun in 

the prior reporting period. 

Highlights of all completed and ongoing audits, inspections and evaluations, 

investigations, and other projects follow as listed below: 

Inspector General’s Assessment of the Most Serious Management and Performance 

Challenges Facing the Commodity Futures Trading Commission FY 2021 

For Fiscal Year (FY) 2021, we identified three management challenges: 

o Climate Change and its impact on the CFTC and the CFTC’s mission; 

o Management of IT (this is repeated from FY 2020 and FY 2019 management 

challenges); 

o Enterprise risk management (ERM). 

These challenges, and CFTC’s current actions addressing them, align with the President’s 

risk-related priorities communicated in several Executive Orders. We also summarized the 

CFTC’s progress on prior year management challenges in our report. 

AUDIT OPERATIONS

Completed

Financial 

• FY 2021 CFTC’s Compliance Audit with the Digital Accountability and Transparency 

(DATA) Act of 20142 - The DATA Act, in part, requires Federal agencies to report 

financial and award data in accordance with established Government-wide financial data 

standards. The audit objectives were to: (1) review a statistically valid sampling of the 

 

1 P.L. 95-452, 92 Stat. 1101 (1978). 2 P.L. 113-101, 128 Stat. 1146 (2014).
2

fiscal year 2021 spending data submitted, and (2) submit to Congress and make publicly 

available a report assessing the completeness, timeliness, quality, and accuracy of the 

data sampled and the implementation and use of data standards. We determined that 

CFTC’s data submission to the Treasury Data Broker was of “excellent” quality, as

measured under the Council of the Inspectors General on Integrity and Efficiency 

(CIGIE) evaluation guide. We recommended and management agreed to enhance 

disclosures in its submissions.

Ongoing

Financial 

• Audit of the CFTC’s FY 2021 Annual Financial Report – The objective of this 

Congressionally mandated audit3 is to render an opinion on the agency financial report 

(financial statements) in accordance with Generally Accepted Government Auditing 

Standards (GAGAS). 

• Audit of the CFTC’s FY 2021 Customer Protection Fund (CPF) – The objective of this 

Congressionally mandated audit4 is to render an opinion on customer protection fund 

financial statements in accordance with GAGAS. 

Information Technology Management and Security 

• Federal Information Security Management Act (FISMA) Review: FY 2021 – The 

objective of this review is to evaluate CFTC’s information security program and practices 

as required by FISMA.5 In addition, technical assessments are being completed by 

contracted information security professionals in coordination with OIG. 

Other

• Council of Inspectors General on Financial Oversight (CIGFO) – The Dodd-Frank Act 

created the Financial Stability Oversight Council (FSOC),6 as well as the Council of 

Inspectors General on Financial Oversight (CIGFO).7 CIGFO is charged with evaluating 

the effectiveness and internal operations of FSOC. During the prior reporting period, 

CIGFO convened a working group to compile guidance for preparing for a crisis, along 

with crisis response lessons learned, based on detailed survey responses from the FSOC 

member agencies. This project was ongoing at the close of the reporting period, and we 

commented on a final report prior to the close of this reporting period. 

 

3 The Accountability of Tax Dollars Act, P.L. 107-289, 116 Stat. 2049 (2002). 4 P.L. 111-203, § 748, 124 Stat. 1739 (2010). 5 P.L. 107-347 (Title III), 116 Stat. 2946 (2002). 6 Dodd-Frank Wall Street Reform and Consumer Protection Act, P.L.111-203, 124 Stat. 1376 (2010) (“Dodd-Frank 

Act” or “Dodd-Frank”). 7 P.L. 111-203, § 989E, 124 Stat. 1946 (2010). 
INSPECTIONS & EVALUATIONS

 We began the reporting period with no inspections and evaluations in process. During the 

reporting period, we commenced the following: 

3

• CFTC Whistleblower Office’s Confidentiality Protections– to assess the policies and 

procedures concerning whistleblower confidentiality protections, including policies and 

procedures concerning inadvertent disclosures; and

• CFTC Policies and Procedures Concerning Capturing, Retaining and Accessing Cell 

Phone Data, Including Text Messages, Location, and Other Information / Data – to assess 

cell phone data retention requirements and compliance with federal record requirements. 

INVESTIGATIVE OPERATIONS

We began the reporting period with two investigations and two allegations pending. We 

completed the two pending investigations. We closed one pending allegation due to a lack of 

evidence after further communication from the complainant, and closed the remaining allegation 

with the opening of an investigation following the receipt of an additional allegation that 

contained more detail. 

During this reporting period we received 81 new allegations. We closed 77 of the new 

allegations: 61 were referred to the CFTC Division of Enforcement (DOE) or to another entity, 

10 were closed due to lack of evidence of violative conduct or jurisdiction, one was closed due to 

lack of evidence (after contacting the complainant), and five were closed with the opening of five

new investigations (including the investigation based in part on the pending allegation from the 

last reporting period, mentioned above). We completed one of the five new investigations during 

this reporting period, for a total of three investigations completed during the reporting period. 

None of the investigations resulted in findings of misconduct or violations of law, regulations, or 

policy. 

While we do not normally comment on open investigations, we have increased our 

investigative capabilities and processes during the reporting period. We began a proactive 

investigation in coordination with CIGIE’s Pandemic Response Accountability Committtee 

(PRAC), CIGIE’s Pandemic Analytics Center for Excellence (PACE), and the Small Business 

Administration (SBA), involving multiple phases. Congress provided OIGs an exemption from 

the Computer Matching Act which enables greater data sharing, and many OIGs have created 

their own data analytics units. While we do not have a data analytics unit, we contracted with a 

third-party vendor for analytic support. In the first phase, which we completed, we matched the 

SBA’s loan level data from their Paycheck Protection Program (PPP) with the CFTC’s personnel 

data to determine any indicia of fraud. We found no prima facia indicia of fraud by any CFTC 

employees. 

This was a substantial effort at the vanguard of OIG investigative activity within the 

federal government involving the analysis of millions of records. We will be making 

recommendations to improve agency processes regarding the reporting of outside business 
activities and ethics obligations. Other phases of work will involve the sharing of data with the 

PACE to deliver analytic, audit, and investigation support to the oversight community as they 

root out historic levels of fraud, waste, and abuse in pandemic relief programs to ensure funds 

are used for their intended purpose. In addition, we are coordinating with the PACE to aid in its

development of risk models to help identify high-risk recipients of pandemic funds for additional 

audit or investigative oversight. CFTC maintains public oversight data of registrants and also 

data regarding civil and adminstrative sanctions, which will be shared with the PRAC and PACE 

for the purpose of detecting potential fraud, waste, and abuse. 

In addition, as part of a separate investigation into suspected impersonation of CFTC 

personnel, we contracted with a cyber security expert to assist a forensic search of the dark web 

for sales of CFTC credentials and other information, and to perform an assessment of CFTC’s 

Security & Privacy Awareness Training program. 

We finished the reporting period with four investigations and four allegations pending. 

4

LEGAL & ECONOMIC REVIEW

The OIG Office of Legal and Economic Research (OLER) continued work on a project 

pending at the close of the prior reporting period, a white paper with three principal goals: (1) 

Provide general background information regarding the requirements of the Administrative 

Procedure Act (APA);

8

 (2) Provide the general public and Congress a taxonomy of the CFTC’s 

panoply of regulatory tools; and (3) Critically evaluate whether the CFTC’s regulatory tools and 

implementation comply with the APA. This analysis will include an evaluation of whether CFTC 

provides guidance that appears to be non-legislative in form but in substance attempts to bind the 

public. 

In addition, OLER began a second white paper that will provide a general background of 

the digital asset market, the CFTC’s participation in the digital asset market, an overview of 

CFTC staff views and experience with digital assets, and potential recommendations for future 

CFTC engagement. 

ADMINISTRATIVE ACTIVITIES

During this period, we enhanced a number of internal and external processes. The Office 

of Audit developed an analytic model to satisfy IG obligations under the Payment Integrity Act. 

The model will be the basis to determine the fairness of CFTC’s reporting threshold. With the 

assistance of CFTC expertise, we updated our public webpage and launched our first on-line 

allegation intake form. 

 

8 P.L. 79-404, 60 Stat. 237 (1946), as amended (codified at 5 U.S.C. § 551, et seq.). 
5

CFTC PROGRAMS and OPERATIONS

Established by statute as an independent agency in 1974, the CFTC assumed 

responsibilities previously belonging to the U.S. Department of Agriculture since the 1920s.9

The mission of the Commodity Futures Trading Commission is: “To promote the integrity, 

resilience, and vibrancy of the U.S. derivatives markets through sound regulation.”10 The CFTC 

and its predecessor were established to protect market participants and the public from fraud, 

manipulation, and other abusive practices in the commodity futures and options markets. After 

the 2008 financial crises and the subsequent enactment of the Dodd-Frank Act, the CFTC’s 

mission expanded to include oversight of the swaps marketplace.11 

The Commission consists of five Commissioners appointed by the President, with the 

advice and consent of the Senate, who serve staggered five-year terms. The President appoints 

one of the Commissioners to serve as Chairman. No more than three Commissioners may be 

from the same political party.12 The CFTC maintains offices in Washington, D.C.; New York, 

NY; Chicago, IL; and Kansas City, MO. As of September 30, 2021, the CFTC organization 

consisted of the following Divisions and Offices (not including OIG):13

• Division of Clearing and Risk (DCR)

• Division of Enforcement (DOE)

• Division of Market Oversight (DMO)

• Market Participants Division (MPD)

• Division of Data (DD)

• Legal Division (LD)

• Division of Administration (DA)

• Office of the Chief Economist (OCE)

• Office of International Affairs (OIA)

• Office of Public Affairs (OPA)

• LabCFTC

• Office of Legislative and Intergovernmental Affairs (OLIA)

• Office of Minority and Women Inclusion (OMWI)

 

9 U.S. Commodity Futures Trading Commission, Strategic Plan FY 2020-2024 (May 2020), page 4. All links in this 

paper were last tested on October 27, 2021. 

10 Id., page 3. 11 Id., page 4. 12 7 U.S.C. § 2(a)(2). 13 https://www.cftc.gov/About/CFTCOrganization/index.htm. 
6

CFTC OIG RESPONSIBILITIES, RESOURCES, ORGANIZATION, 

and INDEPENDENCE

CFTC OIG RESPONSIBILITIES

The CFTC OIG was created in 1989 in accordance with the 1988 amendments to the 

Inspector General Act of 1978.14 OIG was established as an independent unit to:

• Promote economy, efficiency, and effectiveness in the administration of CFTC programs 

and operations, and detect and prevent fraud, waste, and abuse in such programs and 

operations; 

• Conduct and supervise audits and, where necessary, investigations relating to the 

administration of CFTC programs and operations; 

• Review existing and proposed legislation, regulations, and exchange rules and make 

recommendations concerning their impact on the economy and efficiency of CFTC 

programs and operations or the prevention and detection of fraud and abuse; 

• Recommend policies for, and conduct, supervise, or coordinate other activities carried out 

or financed by such establishment for the purpose of promoting economy and efficiency 

in the administration of, or preventing and detecting fraud and abuse in, its programs and 

operations; and

• Keep the Commission and Congress fully informed about any problems or deficiencies in 

the administration of CFTC programs and operations and provide recommendations for 

correction of these problems or deficiencies.

The IG is appointed by the full Commission in accordance with the applicable laws and 

regulations governing appointments within the CFTC, and may be removed upon the written 

concurrence of a 2/3 majority of the Commission.15

The IG is a member of the Council of Inspectors General on Financial Oversight 

(CIGFO), created under the Dodd-Frank Act to examine the work of the Financial Stability 

Oversight Council (FSOC). The IG is also member of the Council of the Inspectors General on 

Integrity and Efficiency (CIGIE), an independent entity established within the executive branch 

to address integrity, economy and effectiveness issues that transcend individual Government 

agencies and to aid in the establishment of a professional, well-trained and highly skilled 

workforce in the Offices of Inspectors General. The IG is a member of the CIGIE Legislation 

Committee, which monitors legislation impacting the IG community and creates a yearly 

legislative agenda for the IG community. 

 

14 The Inspector General Act Amendments of 1988, P.L. 100-504, 102 Stat. 2515 (1988). 15 5 U.S.C. App. §§ 8G(c), 8G(e)(1). 
CFTC OIG conducts audits engagement in accordance with the Generally Accepted 

Government Auditing Standards (GAGAS) issued by the Government Accountability Office 

(GAO). OIG conducts inspections, evaluations, and other covered products in accordance with 

the Quality Standards for Inspection and Evaluation issued by the CIGIE. OIG investigations are 

performed in accordance with the Quality Standards for Investigations issued by the CIGIE. 

The Office of Legal and Economic Research may conduct inspections, evaluations, and other 

covered products in accordance with the CIGIE standards cited above, and may produce white 

papers and other studies in accordance with internal standards. Our webpage is located at 

https://www.cftc.gov/About/OfficeoftheInspectorGeneral/index.htm. 

7

CFTC OIG RESOURCES

CFTC OIG maintains an Office of Audits, Office of Investigations, and Office of Legal 

and Economic Research (OLER). At the end of the reporting period, the CFTC OIG consisted of 

eight FTEs, and we were in the process of backfilling one Attorney, in order to restore OIG to 

2017 staffing levels. During this reporting period, we added one additional attorney to our team. 

One auditor detailed to the U.S. Department of the Treasury. Our organizational chart follows: 
8

OIG INDEPENDENCE

OIG operates independently of the Agency and has not experienced any interference from 

the CFTC Chairman or Commissioners in connection with the conduct of any investigation, 

inspection, evaluation, review, or audit. Our investigations have been pursued regardless of the 

rank or party affiliation of the target. OIG also has conducted audits, inspections, evaluations, 

and reviews without interference where it has perceived the opportunity to recommend 

improvement to futures regulation efforts, again without regard to the party affiliation of any 

Chairman or Commissioner.16 

REQUIRED STATEMENT REGARDING INFORMATION ACCESS AND ASSISTANCE

During the reporting period, no reports were made to the Agency head under section 

6(b)(2) concerning information or assistance unreasonably refused or not provided (mandated 

under section 5(a)(5) of the Act), and there were no direct or intentional attempts by CFTC to 

interfere with Inspector General independence through: 

Type Number Explanation

Budget constraints 0 N/A

Resistance to oversight 0 N/A

Delayed information access 0 N/A

Other 0 N/A

MANAGEMENT and PERFORMANCE CHALLENGES for FY 2021

The Reports Consolidation Act of 200017 requires the Inspector General to summarize the most 

serious management and performance challenges facing the CFTC and to assess the Agency’s 

progress in addressing those challenges. We issued our report on September 29, 2021. 

For FY 2021, we identified three management challenges: 

o Climate Change and its impact on the CFTC and the CFTC’s mission -- Climate Change 

impacts the CFTC’s mission, its physical assets and infrastructure, as well as the businesses 

of market participants. Therefore, we consider Climate Change a management and 

performance challenge as contemplated by the Reports Consolidation Act. 

o Management of IT (this is repeated from FY 2020 and FY 2019 management challenges) --

emerging threats cause us to again identify management of IT as a continuing management 

challenge. CFTC must understand and be prepared to address IT risks that impact both the 

agency and the industry it regulates. 

 

16 The Inspector General Act of 1978, as amended, states: “[T]he head of the designated Federal entity shall not 

prevent or prohibit the Inspector General from initiating, carrying out, or completing any audit or investigation....” 5 

U.S.C. App. 3 § 8G(d)(1). 17 P.L. 106-531, 114 Stat. 2537 (2000). 
9

COMPLETED AUDITS, INSPECTIONS, EVALUATIONS, AUDIT REVIEWS, AND OTHER

AUDIT PROJECTS

o Enterprise Risk Management (ERM) -- An ERM program is critical to the Commission’s 

ability to prioritize and respond to a variety of internal and external risks, including ITrelated risks. Resource and organizational constraints may present a challenge to success in 

this area. 

These challenges, and CFTC’s current actions addressing them (described in our report), align 

with the President’s risk-related priorities communicated in several Executive Orders. 

AUDIT OPERATIONS

Financial 

FY 2021 CFTC’s Compliance Audit with the Digital Accountability and Transparency 

(DATA) Act of 2014

The DATA Act,18 in part, requires Federal agencies to report financial and award data in 

accordance with established Government-wide financial data standards. The audit objectives 

were to: (1) review a statistically valid sampling of the FY 2021 spending data submitted, and (2) 

submit to Congress and make publicly available a report assessing the completeness, timeliness, 

quality, and accuracy of the data sampled and the implementation and use of data standards. 

We determined that management submission to the Treasury Data Broker was of “excellent” 

quality and measured by the Council of the Inspectors General on Integrity and Efficiency 

(CIGIE) evaluation guide. We noted that CFTC’s quarterly reporting and surrounding controls 

were effective to ensure the completeness, accuracy, and timeliness of agency submissions. This 

includes the appropriate use of the Government-wide financial data standards established by 

OMB and Treasury, the submission quality of summary-level data (Files A and B7), and the 

quality of record-level data and linkages (Files C8 and D1/D29). 

We recommended and management agreed to enhance disclosures in its submissions

(specifically, to explain early compliance with upcoming information requirements). We posted 

our audit to our webpage. 

 

18 See fn.2. 
10

ONGOING AUDITS, AUDIT REVIEWS, AND OTHER AUDIT PROJECTS

Financial 

Audit of the CFTC’s FY 2021 Annual Financial Report – The objective of this Congressionally 

mandated audit19 is to render an opinion on the agency financial report (financial 

statements) in accordance with GAGAS. 

Audit of the CFTC’s FY 2021 Customer Protection Fund (CPF) – The objective of this 

Congressionally mandated audit20 is to render an opinion on customer protection fund 

financial statements in accordance with GAGAS. 

Information Technology Management and Security 

Federal Information Security Management Act (FISMA) Review: FY 2021 – The objective of 

this review is to evaluate CFTC’s information security program and practices as required 

by FISMA.21 In addition, the following technical assessments are being completed by 

contracted information security professionals in coordination with OIG:

 IT Risk Management Program and Procedures Assessment: the objective is to assess and 

evaluate the effectiveness of risk management procedures in applying NIST guidance. 

 Vulnerability Management Program and Procedures Assessment: the objective is to 

assess and evaluate the effectiveness of the Information Security Continuous Monitoring 

(ISCM) program.

 FY 2020 Notice of Findings and Recommendations (NFRs): The objective is to perform 

follow-up to prior year process controls notice of findings and recommendations. 

Council of Inspectors General on Financial Oversight (CIGFO) Collaboration 

The Dodd-Frank Act created the Financial Stability Oversight Council (FSOC),22 as well as the 

CIGFO.23 The CIGFO is charged with evaluating the effectiveness and internal 

operations of FSOC. During this reporting period CIGFO continued a working group 

effort to compile guidance for preparing for a crisis, along with crisis response lessons 

learned, based on detailed survey responses from the FSOC member agencies. This 

project was ongoing at the close of the reporting period, and we commented on a final 

draft prior to the close of this reporting period.

 

19 See fn. 3. 20 See fn. 4. 21 See fn. 5. 22 See fn. 6. 23 See fn. 7. 
11

AUDIT REPORTS AND REVIEWS OVER SIX MONTHS OLD; REQUIRED STATEMENTS

Required Statements Regarding Commission Response Exceeding 60 Days, and Regarding 

Management Decisions Not Made

There were no audit reports issued during the reporting period lacking Commission 

response within 60 days, and no instances of an audit report issued before the commencement of 

the reporting period for which a management decision had not been made by the end of the 

reporting period. 

Required Statements Regarding Revised Management Decisions, and Regarding Inspector 

General Disagreement

No management decisions were revised during the reporting period, and the Inspector 

General did not disagree with any management decisions on OIG audit recommendations during 

the reporting period. 

Required Statements Regarding Significant Recommendations that have not been 

Completed, and Audit Reports for which there are any Outstanding Unimplemented 

Recommendations, Including Aggregate Potential Cost Savings 

There were no audit reports with a management action date over six months old where 

the recommendation for corrective action had not been completed. Outstanding 

recommendations are relayed in the two tables that follow, with explanatory text.

Table 1: Unimplemented Recommendations 

Fiscal

Year

Number of Reports 

with Unimplemented 

Recommendations 

Number of 

Unimplemented 

Recommendations 

Dollar Value of 

Aggregate 

Potential Cost 

Savings

No Comment 

Returned 

w/in 60 days

2021 2 3 0 0

2020 1 1

Totals 3 4 0 0

Table 2: Detail of Unimplemented Recommendations 

Fiscal 

Year

Audit Report Unimplemented Recommendations

2021 Performance Audit: CFTC’s 

Compliance with the Digital 

Accountability and 

Transparency Act of 2014 (FY 

2021 Quarter II)

To improve disclosures in DATA Act 

submissions we recommended the Accounting 

Officer report items of significance such as 

informational outlays (early compliance with 

upcoming information requirements).
12

Fiscal 

Year

Audit Report Unimplemented Recommendations

2021 Federal Information Security 

Management Act Review: FY 

2020*

One recommendation to enhance CFTC’s privacy 

program. One recommendation to complete 

backup and restore tests consistent with the 

schedule defined in the NS Backup Recovery 

Reporting Procedures SOP. 

2020 CFTC’s Policies and Procedures 

Regarding Oversight of 

Cybersecurity Safeguards by 

Registered Entities**

Increase the number of dedicated employees to 

the divisions’ System Safeguard Examination 

(SSE) teams, in order to continuously assess 

cybersecurity risks at CFTC registrants.

* The Commission continues to actively work on updating its privacy policies and procedures to 

ensure that they reflect current requirements in law and government-wide policies. With respect 

to backup and restore tests, alternating data plans were not available for each quarter at the close 

of this semiannual period. Estimated completion dates are September 2022 for both 

recommendations. 

 

** DCR has made progress on this recommendation, but would like to leave the finding open. 

DCR hired 3 systems risk analysts with significant experience in the identification of methods to 

increase resilience against current cyber threats. DCR has also designated an additional 

supervisory position to be solely dedicated to cybersecurity oversight initiatives. 

INSPECTIONS & EVALUATIONS

We began the reporting period with no inspections and evaluations in process. As a result 

of our observations in meetings and staff discussions, and based on our experiences with OIG 

investigations, during the reporting period we commenced two evaluations. Both were pending 

at the close of the reporting period. 

ONGOING INSPECTIONS & EVALUATIONS

CFTC Whistleblower Office’s Confidentiality Protections – to assess the policies and procedures 

concerning whistleblower confidentiality protections, including policies and procedures 

concerning inadvertent disclosures; and 

CFTC Policies and Procedures Concerning Capturing, Retaining and Accessing Cell Phone Data, 

Including Text Messages, Location, and Other Information / Data – to assess cell phone 

data retention requirements and compliance with federal record requirements. 
13

INVESTIGATIVE OPERATIONS

SUMMARY

We began this reporting period with two pending investigations, and opened five new 

investigations during this reporting period. We completed the two pending investigations and 

one of the five new investigations during the reporting period. The three completed 

investigations resulted in no findings of misconduct by a CFTC employee or contractor. We 

ended the reporting period with four pending investigations.

We began the reporting period with two allegations under development. We closed one 

allegation when we failed to receive evidence from the complainant sufficient to support an 

investigation. We closed the other allegation with the opening of an investigation following the 

receipt of an additional and more detailed allegation. During the reporting period we received 81 

new allegations. We closed 77 of the new allegations: 61 were referred to the CFTC Division of 

Enforcement (DOE) or to another entity, 10 were closed due to lack of evidence of violative 

conduct or jurisdiction, one was closed due to lack of evidence (after contacting the 

complainant), and five were closed with the opening of five new investigations (including the 

investigation based in part on a pending allegation from the last reporting period, mentioned 

above). We ended the reporting period with four pending allegations. 

We completed a cooperative effort with the CFTC to update our allegation intake 

processes. Our new webpage and online allegation intake form should help visitors to find the 

correct entity for a complaint at the outset. 

DETAILS OF OIG INVESTIGATIVE ACTIVITY

Allegations 

 Closed two allegations pending at the close of the prior reporting period as follows: 

o Closed one allegation with the opening of an investigation following receipt of an 

additional and more detailed allegation 

o Closed one allegation due to inadequate information upon which to proceed, 

following additional interaction with the complainant24

 Received 81 new allegations through the OIG email hotline (66), OIG phone hotline (9), 

OIG fax (1), by other OIG phone (2), by regular mail (2), and by hand delivery (1), and 

closed 77 as follows: 

o Referred 56 allegations to DOE 

o Referred one complainant to CFTC DOE, Whistleblower Office

o Referred one complainant to CFTC DMO 

o Referred one complainant to CFTC MPD

o Referred one complainant to the Department of Homeland Security

 

24 Please know that OIG retains all investigation and allegation files for a period of 10 years; if additional 

information or allegations are received in the future, a closed matter may be reopened. 
o

14

ONGOING INVESTIGATIVE MATTERS AND REQUIRED DISCLOSURES

Referred one allegation to the Social Security Administration

o Closed seven allegations, after consultation with the complainants, because an issue 

of fraud, waste, or abuse relating to the programs and operations of the CFTC was not 

alleged

o Closed two allegations because the allegation did not relate to the programs and 

operations of the CFTC and communication with the anonymous complainants was 

not possible 

o Closed two allegations due to inadequate information upon which to proceed (after 

reaching out to the complainant without success)25

o Closed five allegations with new investigations opened

We ended the reporting period with four allegations pending development. 

Investigations 

 Completed two investigations that were pending at the start of the reporting period 

 Opened five investigations during the reporting period 

 Completed one of the five investigations opened during this reporting period 

The three investigations completed during this reporting period did not result in findings of 

misconduct or violations of statutes, regulations, or policy by a CFTC employee or contractor. 

One investigation involved an allegation that a CFTC staff level employee improperly received 

student loan repayment benefits through dishonest conduct. Following an investigation and 

consultation with the Department of Justice, we concluded that the individual did not act 

dishonestly and referred the matter to DA for administrative treatment. The other two 

investigations involved allegations of multiple improper micro-purchases, and the allegations 

were not sustained following investigation involving review of all relevant procurement micropurchase records and interviews with involved staff. We reported all three investigations to 

relevant management within CFTC, and stated our intention to report a summary of our 

investigations to the Commission and Congress in this report. 

At the close of this reporting period we had four ongoing investigations and four allegations 

pending development, all initiated during this reporting period. All open investigations are 

confidential, as are the content of incoming allegations. As a policy, CFTC OIG does not 

disclose non-public details regarding open investigations absent good cause; if an ongoing 

investigation is disclosed to the public it will be listed here. 

While we do not normally comment on open investigations, we have increased our 

investigative capabilities and processes during the reporting period. We began a proactive 

investigation in coordination with CIGIE’s Pandemic Response Accountability Committtee 

(PRAC), CIGIE’s Pandemic Analytics Center for Excellence (PACE), and the Small Business 

Administration (SBA), involving multiple phases. Congress provided OIGs an exemption from 

 

25 See fn. 24. 
the Computer Matching Act which enables greater data sharing, and many OIGs have created 

their own data analytics units. While we do not have a data analytics unit, we contracted with a 

third-party vendor for analytic support. In the first phase, which we completed, we matched the 

SBA’s loan level data from their Paycheck Protection Program (PPP) with the CFTC’s personnel 

data. 

This was a substantial effort at the vanguard of OIG investigative activity within the 

federal government involving the analysis of millions of records. We took special precautions to 

ensure the integrity of systems security and to safeguard personally identifiable information in 

the datasets we analyzed. We will be making recommendations to improve agency processes 

regarding the reporting of outside business activities and ethics obligations. Other phases of work 

will involve the sharing of data with the PACE to deliver analytic, audit, and investigation 

support to the oversight community as they root out historic levels of fraud, waste, and abuse in 

pandemic relief programs to ensure funds are used for their intended purpose. In addition, we are 

coordinating with the PACE to aid in its development of risk models to help identify high-risk 

recipients of pandemic funds for additional audit or investigative oversight. CFTC maintains 

oversight data of registrants and also data regarding civil and adminstrative sanctions, which will 

be shared with the PRAC and PACE for the purpose of detecting potential fraud, waste, and 

abuse.

In addition, as part of a separate investigation into suspected impersonation of CFTC 

personnel, we contracted with a cyber security expert to assist a forensic search of the dark web 

for any potential sales of CFTC credentials and other information, and to perform an assessment 

of CFTC’s Security & Privacy Awareness Training program. 

15

Table 3: Investigative Statistics for Referrals and Whistleblower Retaliation

April 1, 2021 – September 30, 2021 

A. Completed investigations investigations 3

B. Referrals to prosecuting authorities for criminal prosecution 0 

C. Indictments from prior referrals 0

D. Whistleblower retaliation findings 0

We compiled these statistics from a review of our digital files.

It is our practice to discuss potentially criminal investigations early with an Assistant 

United States Attorney (AUSA) in order to ensure matters of interest are coordinated from the 

outset. While we engaged with AUSAs during the reporting period as necessary to complete our 

work, no formal referrals for prosecution were made. 

There were no findings of whistleblower retaliation during this reporting period. There 

were no reports of investigation involving a senior Government employee where allegations of 

misconduct were substantiated. 
16

LEGAL & ECONOMIC RESEARCH

ONGOING LEGAL & ECONOMIC RESEARCH PROJECTS

White Paper Evaluating CFTC experience with Digital Assets

Digital assets—including, among other things, cryptocurrency—have been widely 

adopted and used by both market participants and ordinary consumers. The CFTC has played an 

active role in the digital asset space, offering information to the public in the form of education 

and guidance as well as prosecuting digital asset-related conduct that violates the CEA. This 

white paper will provide a general background of the digital asset market, the CFTC’s 

participation in the digital asset market, an overview of CFTC staff views and experience with 

digital assets, and potential recommendations for future CFTC engagement. 

White Paper Evaluating CFTC Experience with the Administrative Procedure Act 

The CFTC regularly adopts interpretations of law and uses a wide-range of formats to 

present and communicate these interpretations to its supervised entities, its own personnel, and 

the general public. This white paper has three principal goals: (1) Provide general background 

information regarding the APA’s requirements; (2) Provide the general public and Congress a 

taxonomy of the CFTC’s panoply of regulatory tools; and (3) Critically evaluate whether the 

CFTC’s regulatory tools and implementation comply with the APA. This analysis will include an 

evaluation of whether CFTC provides guidance that appears to be non-legislative in form but in 

substance attempts to bind the public. This project was ongoing at the close of the reporting 

period. 

LEGISLATIVE & REGULATORY PROJECTS 

1. Introduction and Summary 

As specified in Section 4(a)(2) of the Inspector General Act of 1978,26 the Office of 

Legal and Economic Research (OLER) within OIG reviews the impact of existing and proposed 

legislation and regulations on CFTC programs and operations and makes recommendations 

regarding more effective or efficient alternatives or protections against fraud and abuse. The OIG

also reviews exchange rule proposals circulated to senior staff at the CFTC. 

OIG notifies the responsible Divisions as to any concerns with draft and final documents 

relating to legislation, rules or investigations. Formal comments were not submitted to the 

Commission during this reporting period. 

 

26 5 USC App. § 4(a)(2) (made applicable to CFTC OIG at 5 USC App. § 8G(g)).
2. Legislative Activities

OIG reviews legislation impacting programs and operations of the CFTC, and initiates 

contact with Congressional staff concerning various Agency and IG issues as appropriate. This 

work is performed by OLER. In addition, the IG serves on the legislation committee for the 

Council of Inspectors General on Integrity and Efficiency, which comments on proposed 

amendments to the IG Act and other legislation affecting the IG community. CFTC OIG 

participated in legislation committee efforts. No formal projects were undertaken during this 

reporting period. 

17

PEER REVIEWS

An important function in each agency OIG is the peer review process. GAGAS require 

that audit organizations conducting audits of Federal agencies undergo peer reviews every three

years. The IG community has implemented a process to meet this requirement and, in accordance 

with GAGAS and CIGIE peer review quality control and assurance standards, an OIG audit team 

assesses other OIGs’ audit functions. The purpose of the peer review is to determine whether the 

reviewed audit organization’s internal quality control systems are adequate and provide 

reasonable assurance that applicable auditing standards, policies and procedures are met. We are 

required to include in each OIG semiannual report:

• The results of any peer review conducted by another Office of Inspector General during the 

reporting period; or if no peer review was conducted within that reporting period, a statement 

identifying the date of the last peer review conducted by another Office of Inspector General; 

• A list of any outstanding recommendations from any peer review conducted by another 

Office of Inspector General that have not been fully implemented, including a statement 

describing the status of the implementation and why implementation is not complete; and 

• A list of any peer reviews conducted by the Inspector General of another Office of the 

Inspector General during the reporting period, including a list of any outstanding 

recommendations made from any previous peer review (including any peer review conducted 

before the reporting period) that remain outstanding or have not been fully implemented. 

The required information follows: 

Most Recent Peer Review of the CFTC OIG Audit Function

The Federal Maritime Commission, Office of the Inspector General, reviewed the system of 

quality control for the CFTC OIG audit organization in effect for the year ending March 31, 

2019. In their opinion, the system of quality control for the audit organization of CFTC has been 

suitably designed and complied with to provide CFTC with reasonable assurance of performing 

and reporting in conformity with applicable professional standards in all material respects. CFTC 

OIG received the highest external peer review rating of “pass.” 
18

Most Recent Peer Review of CFTC OIG Investigative Function 

Investigative peer reviews are conducted under CIGIE peer review standards to evaluate

compliance with the requirements of the CIGIE Quality Standards for Investigations and the 

adequacy of internal safeguards and management procedures. Because it is a Designated Federal 

Entity Inspector General, the CFTC OIG investigative function is not required to undergo peer 

review. CFTC OIG last voluntarily submitted to a peer review of its investigative function in 

2013; the Federal Trade Commission, Office of Inspector General, reviewed the system of 

quality control for the CFTC OIG investigative function and concluded that the system of 

internal safeguards and management procedures for the CFTC OIG investigative function 

complied with the quality standards adopted by CIGIE, and provided a reasonable assurance of 

conforming with professional standards in the conduct of investigations. 

SUMMARY of FINAL REPORTS NOT MADE PUBLIC

 No reports of investigation were published during this reporting period. The audit report

completed during this reporting period was published to the OIG website. 

STRATEGIC PLAN for the OFFICE of INSPECTOR GENERAL

MISSION, VISION, AND VALUES

Mission

Our mission is to promote integrity, efficiency, and effectiveness by promoting for 

continuous improvement in our agencies' management and program operations of the CFTC. To

accomplish our mission, we: 

• Conduct independent and objective audits, reviews, and other types of engagements of the 

CFTC programs and operations; 

• Conduct independent and objective investigations of potential criminal, civil, and 

administrative violations that could undermine the ability of the CFTC perform its mandated 

mission; 

• Conduct independent and objective reviews of regulatory economic laws under the 

jurisdiction of the CFTC programs and operations; 

• Identify maturity challenges in IT programs and make attainable recommendations to further 

mature them;

• Prevent and detect fraud, waste and abuse in CFTC programs and operations; 
19

• Communicate timely and efficiently with CFTC programs and operations stakeholders by 

providing quick responses with value added results; and 

• Keep agency chairperson, commissioners and Congress fully and currently informed of 

significant issues and developments.

Vision Statement 

The OIG is an independent, professional organization that contributes to the success of 

the CFTC through audits, investigations, economic analysis, and other activities, and thereby acts 

as a champion for positive change in the CFTC’s programs and operations. 

Values Statement 

We most value integrity, accuracy, accountability, effective communication, and efficient 

operations. These values are fundamental to the accomplishment of our mission and our daily 

operations. 

STRATEGIC GOAL 1: EVALUATE THE ECONOMIC IMPACT OF CFTC REGULATORY 

ACTIONS THROUGH LEGAL ANALYSIS, WHITE PAPERS, INSPECTIONS AND 

EVALUATIONS, MANAGEMENT REVIEWS, AND OTHER PRODUCTS

Office of Legal and Economic Research (OLER): Legislative, Economic, and Regulatory 

Review Agenda

OLER plans to continue to identify and explore areas where OIG legal and/or economic 

review might aid the CFTC in improving the economy and efficiency of its programs. OLER 

products may include white papers, management reviews, legal opinion, and other products.27

These efforts are particularly important since the CFTC is an economic regulatory agency. We 

will continue to seek staff that possesses exceptional expertise in relevant law and economics.

 

27 As stated in the Inspector General Act, it is our duty and responsibility to continually review existing and 

proposed legislation and regulations relating to CFTC programs and operations, and to make recommendations 

concerning the impact of such legislation or regulations on the economy and efficiency in the administration of such 

programs. 5 U.S.C. App. § 4(a)(2) (made applicable to the designated federal entity IGs at 5 U.S.C. App. §8G(g)). 
20

STRATEGIC GOAL 2: ADDRESS HIGH IMPACT ISSUES IN CFTC ADMINISTRATIVE 

AND MISSION PERFORMANCE

Office of Audits: Audit and Review Agenda

A. Introduction 

 The primary objectives of OIG’s audit and review agenda are to promote long-term 

efficiency and effectiveness in the administration and operation of the Commission and to 

protect against fraud and abuse. The agenda and priorities for OIG are determined based on the 

following factors: 

• Adequacy of internal control systems as indicated by vulnerability assessments and 

internal control reviews recommended by OMB Circular A-123; 

• Changes in the program conditions or particular vulnerability of the organization, 

program, activity, or function to problems or deficiencies; 

• Current and potential dollar magnitude and likely benefits of a review on the efficiency or 

effectiveness of CFTC programs and operations;

• Management priorities and improvements that may be possible; 

• Results of audits of CFTC programs and operations by other federal agencies; and

• Availability of audit resources and the potential opportunity costs to the agency. 

B. Annual Audits. The following required audits are performed on an annual basis. 

Audit of CFTC Financial Statements

 In FY 2002, Congress passed the Accountability of Tax Dollars Act.28 The Act requires 

the CFTC, along with numerous other Federal entities, to have its financial statements audited 

annually. To this end, OIG has engaged a contractor to provide the audit effort required to enable 

the contractor to render an opinion on the Agency’s financial statements for each fiscal year in 

accordance with GAGAS and OMB Bulletin 19-01. 

Audit of the CFTC Customer Protection Fund 

Section 748 of the Dodd-Frank Act29 requires the Agency to submit to Congress a yearly 

report on the Commission’s whistleblower award program that includes a complete set of audited 

financial statements, including a balance sheet, income statement, and cash flow analysis. To this 

end, OIG has engaged a contractor to perform the audit. 

 

28 See fn. 6. 29 See fn. 7. 
C. Annual Reviews. OIG will perform the following reviews and evaluations annually. 

21

Inspector General’s Assessment of the CFTC’s Most Serious Management and Performance 

Challenges 

The Reports Consolidation Act of 200030 requires the Inspector General to summarize the 

most serious management and performance challenges facing the CFTC and to assess the 

Agency’s progress in addressing those challenges.

Review of Compliance with the Federal Managers' Financial Integrity Act, FMFIA31

In support of OMB Circular A-123, the Inspector General will evaluate, provide technical 

assistance and advise the Agency head as to whether the Agency's review and evaluation process 

was conducted in accordance with the circular's requirements. 

Evaluation of Compliance with Federal Information Security Management Act, FISMA 

The Federal Information Security Management Act32 requires the Inspector General or 

his designee to perform annual independent evaluations of the information security program and 

practices of the Agency. This compliance may also be performed through an audit. 

D. Other Audits, Reviews, and Audit Projects; Data Analytics

OIG will focus the balance of its resources on the review of CFTC program and 

management operations (giving priority to activities relating to the most serious management 

challenges facing the CFTC), and compliance with Congressional mandates. Toward that end, 

OIG intends to increase the use of data analytics to enable audit operations. Data Analytics 

within the Office of Inspector General supports data services and analyses, and provides the 

competency to deliver short-turnaround projects that produce quick, valuable successes. Finally, 

OIG will stand ready to respond to issues and requests as they are received from Congress, the 

Agency, members of the public, or any other source. 

STRATEGIC GOAL 3: ADDRESS EMPLOYEE AND CONTRACTOR MISCONDUCT 

PROMPTLY, THOROUGHLY, AND RELIABLY

As a chain is only as strong as its weakest link, CFTC likewise depends on each and 

every employee and contractor to perform with competence, and to refrain from misconduct. 

CFTC OIG considers and investigates every credible allegation to ensure that CFTC employees 

and contractors uphold the public trust and perform their work with integrity and competence. 

 

30 See fn. 17. 31 P.L. 97-255, 96 Stat. 814 (1982). 32 See fn. 5. 
22

Office of Investigations: Investigative Agenda 

 The Inspector General Act of 1978, as amended, provides that the Inspector General may 

receive and investigate complaints or information from the Commission's employees concerning 

the possible existence of an activity constituting a violation of law, rules or regulations; or 

mismanagement, gross waste of funds, or abuse of authority; or a substantial and specific danger 

to the public health and safety. 

CFTC is an independent regulator with a mission that does not involve grants, substantial 

contracts, or other benefits to administer, and is therefore less likely than some agencies to 

generate a substantial investigative workload. Historically, OIG has conducted only a reactive 

investigative program, chiefly relying on unsolicited complaints as the source of investigative 

leads. Allegations and complaints are received primarily from CFTC staff and management, 

CFTC ethics officials, the general public, and Congress. We also receive referrals from other law 

enforcement agencies. Should further experience show areas at CFTC on which to focus 

proactively, we will consider establishing an investigative agenda. To ensure that employee 

complaints easily reach OIG, we maintain a 24-hour hotline. The hotline phone number is (202) 

418-5510. We also maintain an email address for complaints, OIGComplaint@cftc.gov. 

RESOURCES REQUIRED

OIG estimates that approximately four staff years of effort will be devoted over each of 

the next five years to the annual audit, the annual review, and the annual evaluation described 

above. OIG estimates three staff years of effort will be devoted over each of the next five years 

to the investigative, and legal and economic review functions. OIG estimates two staff years for 

management, administrative, and outreach efforts. Because OIG resources can be diverted at any 

time in order to address current issues or allegations, completed timely in order to be of 

assistance to the Agency or Congress, it is not possible to forecast with complete accuracy how 

resources will be utilized from year to year. 

CONTACTING the OFFICE of the INSPECTOR GENERAL

OIG is located at 1155 21st Street, N.W., Washington, D.C. 20581. Regular business 

hours are between 8:30 AM and 5:00 PM, Monday through Friday, except federal holidays. Our

general telephone number is (202)418-5110. Our facsimile number is (202)418-5522. Our email 

address for general questions and discussion is OIG@cftc.gov. 

Our email for complaints is OIGComplaint@cftc.gov. The hotline phone number is 

(202)418-5510. OIG’s web page, with a link to the OIG online complaint form, is located at 

http://www.cftc.gov/About/OfficeoftheInspectorGeneral/index.htm. 
23

APPENDICES

Appendix 1 – Reports Issued with Questioned Costs

April 1, 2021 – September 30, 2021 

Dollar Value

Thousands

Number Questioned Unsupported

A. For which no management decision has 

been made by the commencement of the 

reporting period 0 0 0

B. Which were issued during the reporting 

period 0 0 0

Subtotals (A + B) 0 0 0

C. For which a management decision was 

made during the reporting period 0 0 0

( I ) dollar value of 

disallowed costs 0 0 0

( ii ) dollar value of costs not 

disallowed 0 0 0

D. For which no management decision

has been made by the end of the 

reporting period 0 0 0
24

Appendix 2 – Reports Issued with Recommendations That Funds Be 

Put to Better Use

April 1, 2021 – September 30, 2021

Dollar Value

Number Thousands

A. For which no management decision has 

been made by the commencement of the 

reporting period 0 0

B. Which were issued during the reporting 

period 0 0

Subtotals (A + B) 0 0

C. For which a management decision was 

made during the reporting period 0 0

( i ) dollar value of 

recommendations that

were agreed to by management

0 0

( ii ) dollar value of 

recommendations that

were not agreed to by 

management 0 0

D. For which no management decision

has been made by the end of the 

reporting period 0 0
25

Appendix 3 - Index of IG Act Reporting Requirements

Section 4(a)(2) Review of legislation and regulations...............................................16

Section 5(a)(1) Significant problems, abuses and deficiencies.....................................9

Section 5(a)(2) Recommendations with respect to significant problems............................9

Section 5(a)(3) Significant recommendations that have not been completed..................11

Section 5(a)(4) Matters referred to prosecutorial authorities....................................15

Section 5(a)(5) Summary of instances where information was refused ..........................8

Section 5(a)(6) Completed audit reports...............................................................9

Section 5(a)(7) Significant audit reports..............................................................9

Section 5(a)(8) Statistical Table—Questioned Costs.............................................23

Section 5(a)(9) Statistical Table—Funds Recommended for Better Use .....................24

Section 5(a)(10) Audit reports lacking management decision ...................................11

Section 5(a)(10) Audit reports without Commission response after 60 days..................11

Section 5(a)(10) Audit reports for which there are any outstanding unimplemented 

recommendations, including the aggregate potential cost savings .........11

Section 5(a)(11) Significant revised management decisions .....................................11

Section 5(a)(12) Significant management decisions where the IG disagrees..................11

Section 5(a)(13) Information described under § 804(b) of the Federal Financial 

Management Improvement Act of 1996 .....................................N/A 

Section 5(a)(14)-(16) Peer Review information ........................................................17

Section 5(a)(17) Statistical tables for investigations.............................................15

Section 5(a)(18) Description of metrics used to develop the statistical tables for 

investigations......................................................................15

Section 5(a)(19) Report on each investigation involving a senior Government employee 

where allegations of misconduct were substantiated .........................15

Section 5(a)(20) Whistleblower retaliation findings ..............................................15

Section 5(a)(21) Attempts to interfere with OIG independence .................................8

Section 5(a)(22) Summary of final reports not made public.....................................18

Section 6(b)(2) Summary of reports to Chairman where assistance was refused.............8