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Affirmative Action Plan 

for the Recruitment, Hiring, Advancement, and 

Retention of Persons with Disabilities 

To capture agencies' affirmative 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 affumative 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 §1614.203(d)(7)) require agencies to establish specific numerical goals for increasing the participation 

of persons with disabilities and persons with targeted disabilities in the federal government 

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

pe1manent workforce? If"yes", describe the trigger(s) in the text box.

a. Cluster GS-1 to GS-10 (PWD) Answer Yes 

b. Cluster GS-11 to SES (PWD) Answer Yes 

Within the cluster of 15 pennanent employees in grades CT-1 to CT-10, 0% (0 employees) are people with disabilities in FY21, 

holding constant compared to FY20. Of the 664 employees in the cluster of CT 11 and higher, 6.02% ( 40 employees) are people with disabilities in FY21, an increase from 5.47% (37 employees) in FY20 and from 4.76% (31 employees) in FY19. Both clusters 

are below the 12% benchmark goal. 

*For GS employees, please use two clusters: GS-1 to GS-10 and GS-11 to SES, as set fo1ih 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 of2% as the benclunark, does your agency have a trigger involving PWTD by grade level cluster in the

pe1manent workforce? If"yes", describe the trigger(s) in the text box.

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

b. Cluster GS-11 to SES (PWTD) Answer Yes 

Within the cluster of15 permanent employees in grades CT-1 to CT-10, 0% (0 employees) are people with targeted disabilities 

in FY21, holding constant from FY20. Ofthe 664 pennanent employees in the cluster ofCT 11 and higher, <10 employees) are people with targeted disabilities. a decrease from <10 emplovees in FY20. Both clusters are beneath the 2% targeted goal. 

3. Describe how the agency has communicated the numerical goals to the hiring managers and/or recruiters.

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

em lo ent oals. Durin FY21, OMWI leadershi and staff reviewed the <>oals with the Chief Human Ca ital Officer and briefed 

*To protect privacy, derived values between one and nine have been replaced with <10.

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lthe CFTC Chairman, Chief ofStaff and labor union to ensure that they were aware ofthe goals. 

Section II: Model Disability Program 

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 

PROGRAM 

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 upcoming year. 

Answer No 

The agency will request staffing/funding for a fulltime Disability Employment Program Manager within OMWI and a Selective 

Placement Pro ·am Coordinator in the Human Resources Branch. 

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

employment status, and responsible official. 

Disability Program Task 

# ofFTE StaffBy Employment Status Responsible Official 

(Name, Title, Office 

Full Time Part Time Collateral Duty Email) 

Answering questions from the public about 

hiring authorities that take disability into 

account 

0 1 0 Connie Adkins 

HR Specialist 

CAdkins@CFTC.gov 

Processing reasonable accommodation requests 

from applicants and employees 

0 1 0 Lauren Colon 

Chief, Workforce 

Relations 

LColon@cftc.gov 

Section 508 Compliance 0 1 0 Kennet Ake 

IT Specialist 

Section508@cftc.gov 

Architectural Barriers Act Compliance 0 0 1 Edward Busse 

Manager - Facilities 

Operations and Services 

ebusse@cftc.gov 

Processing applications from PWD and PWTD 0 1 0 Connie Adkins 

HR Specialist 

CAdkins@CFTC.gov 

Special Emphasis Program for PWD and 

PWTD 

0 0 0 

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

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

planned for the upcoming year. 

Answer No 

IThe CFTC will evaluate what further training is needed for Disability Program Staff in order to carry out their responsibilities. 

B. PLAN TO ENSURE SUFFICIENT FUNDING FOR THE DISABILITY PROGRAM 

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

the repo1ting period? If"no", describe the agency' s plan to ensure all aspects ofthe disability program have sufficient 

funding and other resources. 

Answer No 

The new ChiefDiversity and EEO Officer will begin briefing and bringing awareness to the gap in expe1tise, funding, and staffing 

at the a enc to best make the case for further ne.eded resources. 

Section III: Program Deficiencies In The Disability Program 

B1ief Description of Progl'3m 

Deficiency 

IA.2.b.3. Reasonable accommodation procedures? [see 29 CFR § 1614 .203( d)(3)(i)] Ifso, please provide the internet 

address in the comments column. 

Objective 

Target Date 

Completion Date 

Planned Activities 

Accomplishments 

Post the agency's reasonable accommodation procedures on its public facing website, once they are 

approved intemally. 

Sep 30, 23 

Target Date Come}etion Date Planned Activity_ 

Sep 30, 23 The agency will continue to vet the reasonable accommodation 

procedures through internal review and will post them when they are 

complete. 

Fiscal Year Accom[!.lishment 

2021 IA draft ofthe agency's new reasonable accommodation procedures was reviewed 

and found compliant by the EEOC. 

B1ief Description of Progl'3m B.4.a.4. to provide all supervisors and employees with training on the EEO program, including but not limited to

Deficiency retaliation, harassment, religious accommodations, disability accommodations, the EEO complaint process, and ADR? 

[see MD-715, II(B) and ill(C)] Ifnot, please identify the type(s) oftraining with insufficient funding in the comments 

column. 

Allocate sufficient resources to provide all supervisors and employees with training on the EEO 

Objective program, including but not limited to retaliation, harassment, religious accommodations, disability 

accommodations, the EEO complaint process, and ADR. 

Target Date Sep 30, 2023 

Completion Date 

Target Date Com[!.letion Date Planned Activity_ 

Sep 30, 2023 The agency has allocated additional staffing to the Office ofMinority and 

Planned Activities Women Inclusion. The new ChiefDiversity and EEO Officer has 

assessed what additional resources are needed and submitted additional 

funding and staffing requests for consideration. 

Accomplishments Fiscal Year Accom[!.lishment

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B1ief Description of Program 

Deficiency 

IB.4.a.6. to publish and distribute EEO materials (e.g. harassment policies, EEO posters, reasonable accommodations 

procedures)? [see MD-715, II(B)] 

Ensure the EEO p rogram has sufficient resources to publish and distribute EEO materials (e.g. Objective harassment policies, EEO posters, reasonable accommodations procedures .) 

Target Date Sep 30, 2023 

Completion Date 

Target Date Completion Date Planned Activity 

Planned Activities 

Sep 30, 2023 The agency has allocated additional staffing to the Office ofMinority and 

Women Inclusion. The new ChiefDiversity and EEO Officer has 

assessed what additional resources are needed and submitted additional 

funding and staffing requests for consideration. 

Accomplishments Fiscal Year Accomplishment 

B1ief Description of Program B.4.a.8. to effectively administer its special emphasis programs (such as, Federal Women's Program, Hispanic 

Employment Program, and People with Disabilities Program Manager)? [5 USC§ 7201; 38 USC§ 4214; 5 CFR § 

720.204; 5 CFR § 213.3102(t) and (u); 5 CFR § 315.709] 

Deficiency 

Ensure the EEO program has sufficient resources to effectively administer its special emphasis 

Objective programs (such as, Federal Women' s Program, Hispanic Employment Program, and People with 

Disabilities Program Manager). 

Target Date Sep 30, 2023 

Completion Date 

Target Date Comu.letion Date Planned Activitv 

Sep 30, 2023 The agency has allocated additional staffing to the Office ofMinority and 

Planned Activities Women Inclusion. The new ChiefDiversity and EEO Officer has 

assessed what additional resources are needed and submitted additional 

funding and staffing requests for consideration. 

Accomplishments Fiscal Year Accomu.lishment

B1ief Description of Program 

Deficiency 

I C.2.a.6. Do the agency's training materials on its anti-harassment policy include examples ofdisability-based

harassment? [see 29 CFR §1614.203(d)(2)] 

Ensure that the agency's training materials on its anti-harassment policy include examples of Objective disability-based harassment. 

Target Date Dec 31 , 2023 

Completion Date 

Target Date Comu.letion Date Planned Activitv 

Dec 31, 2023 Once the agency finalizes its pending draft ofits anti-harassment policy Planned Activities 

and procedures, it will update its existing training materials and ensure 

examples ofdisability-based harassment are included. 

Accomplishments Fiscal Year Accomu.lishment

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B1ief Description of Program 

Deficiency 

IC.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)] 

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

Target Date Sep 30, 2023 

Completion Date 

Target Date Completion Date Planned Activity 

Planned Activities 

Sep 30, 2023 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. 

Accomplishments Fiscal Year Accomplishment 

B1ief Description of Program 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)] 

Deficiency 

Establish procedures for processing personal assistance services that comply with EEOC's Objective regulations and guidance. 

Target Date Sep 30, 23 

Completion Date 

Target Date Completion Date Planned Activity

Sep 30, 2023 The CFTC received notice from the EEOC that its draft reasonable 

Planned Activities accommodation and personal assistance services procedures were in 

compliance on 9/11/2021. The draft procedures are in the final stages of 

internal review and will be posted once they are finalized. 

Accomplishments Fiscal Year Accomplishment

B1ief Description of Program 

Deficiency 

I C.2.c. l . 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. 

The agency will post its procedures for processing requests for Personal Assistance Se1vices on its Objective public website. 

Target Date Sep 30, 23 

Completion Date 

Target Date Comu.letion Date Planned Activitv 

Sep 30, 2023 The CFTC received notice from the EEOC that its draft reasonable 

Planned Activities accommodation and personal assistance services procedures were in 

compliance on 9/11/2021. The draft procedures are in the final stages of 

internal review and will be posted once they are finalized. 

Accomplishments Fiscal Year Accomu.lishment

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B1ief Description of Progl'3m 

Deficiency 

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

Objective 

Target Date 

Completion Date 

Planned Activities 

§1614.102(a)(8)] 

Require rating officials to evaluate the perfonnance of managers and supervisors based on their 

ability to provide disability accommodations when such accommodations do not cause an undue 

hardship. 

Sep 30, 2023 

Target Date 

Sep 30, 2023 

Completion Date Planned Activity 

Updates to the performance form are underway and are anticipated to be 

completed as part ofthe agency's pay and performance management 

reform initiative. 

Fiscal Year Accomplishment 

2021 The agency has continued to work on its pay and perfo1mance management Accomplishments refonn process, including examining the EEO and DEIA language that other 

agencies have integrated into their superviso1y ratings systems. 

B1ief Description of Progl'3m 

Deficiency 

I C.4 .e. l. Implement the Affirmative Action Plan for Individuals with Disabilities? [ see 29 CFR §1614.203( d); MD-715, 

Objective 

Target Date 

Completion Date 

Planned Activities 

Accomplishments 

II(C)] 

Ensure the ChiefDiversity Officer and the HR Office collaborate to implement the Affinnative 

Action Plan for Individuals with Disabilities. 

Sep 30, 2023 

Target Date 

Sep 30, 2023 

Completion Date Planned Activity 

The CFTC's Chief Diversity and EEO Officer and HR Office will 

collaborate to develop a strategy and process for implementation ofthe 

Affirmative Action Plan for Individuals with Disabilities. 

Fiscal Year Accomplishment 

B1ief Description of Progl'3m 

Deficiency 

ID .4 .d. Has the agency taken specific steps that are reasonably designed to increase the number ofpersons with 

Objective 

Target Date 

Completion Date 

Planned Activities 

Accomplishments 

disabilities or targeted disabilities employed at the agency until it meets the goals? [see 29 CFR §1614 .203( d)(7)(ii)] 

Ensure the CFTC has taken specific steps that are reasonably designed to increase the number of 

persons with disabilities or targeted disabilities employed at the agency until it meets the goals. 

Sep 30, 2023 

Target Date 

Sep 30, 2023 

Completion Date Planned Activity 

The CFTC received notice from the EEOC that its draft reasonable 

accommodation and personal assistance services procedures were in 

compliance on 9/11/2021. The draft procedures are in the final stages of 

internal review and will be posted once they are finalized. 

Fiscal Year Accomplishment 

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B1ief Description of Progl'3m 

Deficiency 

IE.4.b. Does the agency have a system in place to re-survey the workforce on a regular basis? [MD-715 Instructions, 

Sec. I] 

Objective Ensure the CFTC has a system in place to re-survey the workforce on a regular basis. 

Target Date Sep 30, 2023 

Completion Date 

Target Date Completion Date Planned Activity 

Planned Activities Sep 30, 2023 The CFTC will assess and start to implement next steps to create a system I I to re-survey the workforce on a regular basis. 

Accomplishments Fiscal Year Accomplishment 

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 recrnitment and hiring of 

individuals with disabilities. The questions below are designed to identify outcomes ofthe agency's recrnitment program plan for 

PWDandPWTD 

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 CFTC's Human Resources Branch repo1ts that it works with Schedule A, subpa1t (u) qualified applicants and utilizes Veteran 

hirin authorities to identi ·ob a licants with disabilities. 

2. Pursuant to 29 C.F.R. §1614.203(a)(3), describe the agency's use ofhiring authorities that take disability into account 

( e.g., Schedule A) to recrnit 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 under such authority; and, (2) fo1wards the 

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

appointed. 

(1) CFTC determines if the individual is eligible for appointment under such authority by requiring ce1tification for the appropriate 

disability resource. (2) Qualified schedule A, subpart (u) and Veterans applicant information (ce1ts) are fo1warded to hiring officials 

as pa1t ofthe list of eligible candidates. HR Specialists are available to discuss all parts of the Schedule A and other PWD-type of 

hiring authorities. 

4. Has the agency provided training to all hiring managers on the use ofhiring 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 No 

The Chief Diversity and EEO Officer will work with stakeholder offices to ensure that hiring managers are trained on the use of 

hirin authorities that take disabili into account. 

B. PLAN TO ESTABLISH CONTACTS WITH DISABILITY EMPLOYMENT ORGANIZATIONS 

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Describe the agency's effo11s to establish and maintain contacts with organizations that assist PWD, including PWTD, in 

securing and maintaining employment. 

The CFTC has launched a new employee affinity group for People with Disabilities and will work with that group to establish and 

maintain contacts with or anizations that assist PWD and PWTD. 

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 Permanent Workforce (PWD) Answer No 

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

Among the 40 new hires in FY21, <10 identified as a PWD, which is above the benchmark of 12%. <10 hires in FY21 

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

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 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. New Hires for MCO (PWD) Answer Yes 

b. New Hires for MCO (PWTD) Answer Yes

For FY21, out of the 272 qualified applicants who self-identified for the pe1manent 0905 positions, 15.4% were PWD (42 

applicants) and 5.1 % (14 applicants) were PWTD, but PWD and PWTD were 0% of the <10 selections made from the 

self­identified applicants. Out of the 123 qualified applicants who self-identified for the permanent 1101 positions, 15% were 

PWD (19 applicants) and 8.9% (11 applicants) were PWTD, but PWD and PWTD were 0% of the <10 selections made from the 

self­identified applicants. Out of the 73 qualified applicants who self-identified for the permanent 2210 positions, <lO were PWD 

and < O were PWTD, but PWD and PWTD were 0% of the <l O selection made from the self-identified applicants. The 0301, 0511 

series did not have triin:,ers. Please note the small number of selections made. however.

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

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

a. Qualified Applicants for MCO (PWD) Answer No 

b. Qualified Applicants for MCO (PWTD) Answer No 

4. Using the qualified applicant pool as the benclunark, 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 

For FY21, of the <10 qualified applicants who self-identified for intemal competitive promotions to the pe1manent 0905 positions, 

<10 was a PWD and 0% were PWTD, but PWD were 0% of the <10 selections made from the self-identified applicants. Of the 

<10 qualified applicants who self-identified for the intemal competitive promotions for the permanent 1801 positions <10 were 

PWD and <10 were PWTD, but PWD and PWTD were 0% of the <10 selections made from the self-identified applicants. Of the 31 

qualified applicants who self-identified for the intemal competitive promotions for the pe1manent 0301 positions, 32.2% (10 

applicants) were PWD and <10 were PWTD, but PWD and PWTD were 0% of the <10 selections made from the self-identified 

annlicants. Please note the small number of selections made however. 

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 opportunities, 

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

data on programs designed to ensure advancement oppo1tunities for employees with disabilities. 

A.ADVANCEMENT PROGRAM PLAN 

Describe the agency's plan to ensure PWD, including PWTD, have sufficient opportunities for advancement. 

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

accommodations regarding training appropriately and ensures that trainings disseminated tlu·ough its Leaming Management System 

are compliant with Section 508 of the Rehabilitation Act. Though oppo1tunities 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 tlu·ough its DEIA strategic plan to further develop an approach to ensure advancement oppo1tunities for PWD. The plan will 

include the use of details and iob assignments as well as mentorim? to advance PWD. 

B.CAREER DEVELOPMENT OPPORTUNITES

1. Please describe the career development oppo1tunities that the agency provides to its employees.

The Commission offered a number of regulatory teaming engagements that were delivered tlu·ough eLeaming training sessions. The 

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

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

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

techniques, CFTC staff pa1ticipated in mission-related seminars available via in-person training, f01ums, seminars, live webcasts, 

audio CD's and DVDs, MP3s course handbooks and on- demand leaminiz. This traininiz onnortunitv is offered to all oualified 

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employees, including persons with disabilities. Additionally, the CFTC utilizes competitive and non-competitive detail assignments 

both internally and with other agencies as opportunities for advancement. 

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

supervisory recommendation/ approval to participate. 

Career Development 

Opportunities 

Total Participants PWD PWTD 

Applicants (#) Selectees (#) 

Applicants 

(%) Selectees (%) 

Applicants 

(%) Selectees (%) 

Internship Programs 0 0 0 0 0 0 

Fellowship Programs 0 0 0 0 0 0 

Mentoring Programs 0 0 0 0 0 0 

Coaching Programs 0 0 0 0 0 0 

Training Programs 0 0 0 0 0 0 

Detail Programs 0 0 0 0 0 0 

Other Career Development 

Programs 

0 0 0 0 0 0 

3. Do triggers exist for PWD 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 “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. Applicants (PWD) Answer N/A 

b. Selections (PWD) Answer N/A 

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

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 “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. Applicants (PWTD) Answer N/A 

b. Selections (PWTD) Answer N/A 

No triggers were identified as the CFTC does not have a formal 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) Answer No 

b. Awards, Bonuses, & Incentives (PWTD) Answer No 

PWD are 5.64% of the workforce; they received 4.7% of time off awards and 5.8% of cash awards. PWTD are <10 of 

the workforce, they received <10 of time off awards and <10 of cash awards. 

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

increases or performance- 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 

The CFTC is not a title 5 agency and does not have or use QSI’s. 

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 N/A 

b. Other Types of Recognition (PWTD) Answer N/A 

D. PROMOTIONS 

1. Does your agency have a trigger involving PWD among the qualified internal 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 “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. SES 

i. Qualified Internal Applicants (PWD) Answer No 

ii. Internal Selections (PWD) Answer No 

b. Grade GS-15 

i. Qualified Internal Applicants (PWD) Answer N/A 

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ii. Internal Selections (PWD) Answer Yes 

c. Grade GS-14 

i. Qualified Internal Applicants (PWD) Answer N/A 

ii. Internal Selections (PWD) Answer Yes 

d. Grade GS-13 

i. Qualified Internal Applicants (PWD) Answer N/A 

ii. Internal Selections (PWD) Answer Yes 

Out of the 11 qualified self-identified applicants to CT-15 internal competitive promotions, <10 were a PWD, but 0% of the <10

self-identified selectees was a PWD. Out of the 46 qualified self-identified applicants to CT-14 internal competitive promotions, 

26.1% (12 individuals) were PWD, but 0% of the <10 self-identified selectees was a PWD. Out of the 11 qualified self-identified 

applicants to CT-13 internal competitive promotions, <10 were PWD, but 0% of the <10 self-identified selectees was a PWD. 

2. Does your agency have a trigger involving PWTD among the qualified internal 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 “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. SES 

i. Qualified Internal Applicants (PWTD) Answer No 

ii. Internal Selections (PWTD) Answer No 

b. Grade GS-15 

i. Qualified Internal Applicants (PWTD) Answer N/A 

ii. Internal Selections (PWTD) Answer No 

c. Grade GS-14 

i. Qualified Internal Applicants (PWTD) Answer N/A 

ii. Internal Selections (PWTD) Answer Yes 

d. Grade GS-13 

i. Qualified Internal Applicants (PWTD) Answer N/A 

ii. Internal Selections (PWTD) Answer Yes 

Out of the 46 qualified self-identified applicants to CT-14 internal competitive promotions, <10 were PWTD, but 0% of the <10

self-identified selectees was a PWTD. Out of the 11 qualified self-identified applicants to CT-13 internal competitive promotions, . 

<10 were PWTD, but 0% of the <10 self-identified selectees was a PWTD. 

3. Using the qualified applicant pool as the benchmark, does your 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 “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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Commission 

a. New Hires to SES (PWD) Answer No 

b. New Hires to GS-15 (PWD) Answer No 

c. New Hires to GS-14 (PWD) Answer Yes 

d. New Hires to GS-13 (PWD) Answer Yes 

Out of the 120 qualified self-identified applicants to CT-14 new hire positions, 16.7% (20 individuals) were PWD, but 0% of the 

<10 self- identified selectees was a PWD. Out of the 121 qualified self-identified applicants to CT-13 new hire positions, 15.7% 

(19 individuals) were PWD, but 0% of the <10 self-identified selectees was a PWD. 

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) Answer No 

b. New Hires to GS-15 (PWTD) Answer No 

c. New Hires to GS-14 (PWTD) Answer Yes 

d. New Hires to GS-13 (PWTD) Answer Yes 

Out of the 120 qualified self-identified applicants to CT-14 new hire positions, <10 were PWTD, but 0% of the <10 selfidentified selectees was a PWTD. Out of the 121 qualified self-identified applicants to CT-13 new hire positions, <10 were 

PWTD, but 0% of the <10 self-identified selectees was a PWTD. 

5. Does your 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 internal 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 Internal Applicants (PWD) Answer No 

ii. Internal Selections (PWD) Answer No 

b. Managers 

i. Qualified Internal Applicants (PWD) Answer N/A 

ii. Internal Selections (PWD) Answer N/A 

c. Supervisors 

i. Qualified Internal Applicants (PWD) Answer N/A 

ii. Internal Selections (PWD) Answer Yes 

Out of the 23 qualified self-identified applicants to supervisory internal competitive promotion positions, <10 were PWD, but 

0% of the <10 of the self-identified selectees was a PWD. 

6. 

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Does your agency have a trigger involving PWTD among the qualified internal applicants and/or selectees for promotions 

to supervisory positions? (The appropriate benchmarks are the relevant applicant pool for qualified internal 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 Internal Applicants (PWTD) Answer No 

ii. Internal Selections (PWTD) Answer No 

b. Managers 

i. Qualified Internal Applicants (PWTD) Answer N/A 

ii. Internal Selections (PWTD) Answer N/A 

c. Supervisors 

i. Qualified Internal Applicants (PWTD) Answer N/A 

ii. Internal Selections (PWTD) Answer Yes 

Out of the 23 qualified self-identified applicants to supervisory internal competitive promotion positions, <10 were PWTD, but 

0% of the <10 self-identified selectees was a PWTD. 

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

for new hires to supervisory positions? 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 for Executives (PWD) Answer No 

b. New Hires for Managers (PWD) Answer No 

c. New Hires for Supervisors (PWD) Answer No 

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

selectees for new hires to supervisory positions? 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 for Executives (PWTD) Answer No 

b. New Hires for Managers (PWTD) Answer No 

c. New Hires for Supervisors (PWTD) Answer No 

Section VI: Plan to Improve Retention of Persons with Disabilities 

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 barriers retaining employees with 

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

accommodation program and workplace assistance services. 

A. VOLUNTARY AND INVOLUNTARY SEPARATIONS 

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1. In this reporting period, did the agency convert all eligible Schedule A employees with a disability into the competitive 

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

not convert all eligible Schedule A employees. 

Answer N/A 

No employees have been eligible for conversion during this reporting period. Any employees that are eligible are converted as 

appropriate. 

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.Voluntary Separations (PWD) Answer No 

b.Involuntary Separations (PWD) Answer No 

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

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

a.Voluntary Separations (PWTD) Answer No 

b.Involuntary Separations (PWTD) Answer No 

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. 

N/A 

B. ACCESSIBILITY OF TECHNOLOGY AND FACILITIES 

Pursuant to 29 CFR §1614.203(d)(4), federal agencies are required to inform 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 

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

inform 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. 

https://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 Barriers Act, including a description of how to file a complaint. 

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

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

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

The CFTC's Section 508 Coordinator reports that "The CFTC information technology organization has several strategic initiatives 

in process and ensures that accessibility requirements are embedded in these new solutions and assessed prior to acquisition. For 

instance, the CFTC is in the process of relocating our offices to newer facilities, and the underlying technology is being improved to 

enhance accessibility for these new offices. As other initiatives are completed, these projects will ensure that accessibility 

requirements are met and/or exceeded, with examples including cloud adoption of new software, upgraded collaboration software, 

and a laptop refresh." The CFTC's Manager of Facilities and Operational Services reports that "all CFTC facilities are in full 

compliance with applicable building codes, laws, etc. governing disabled persons’ access. In addition, as CFTC renovates and 

relocates from old facilities to new, every effort is made to ensure not only full compliance but any supplemental guidance 

regarding disabled access is reviewed and implemented when possible." 

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 reporting period is seven (7) 

business days. 

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. 

D. PERSONAL ASSISTANCE SERVICES ALLOWING EMPLOYEES TO PARTICIPATE IN THE 

WORKPLACE 

Pursuant to 29 CFR §1614.203(d)(5), federal agencies, as an aspect of affirmative action, are required to provide personal 

assistance services (PAS) to employees who need them because of a targeted disability, unless doing so would impose an undue 

hardship on the agency. 

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. 

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

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

Assistance Services in FY 2021, but will continue to evaluate the effectiveness of its procedures in FY 2022. 

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 formal EEO complaint alleging harassment, as compared 

to the governmentwide 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. 

CFTC did not have any findings of discrimination in FY21. 

B. EEO COMPLAINT DATA INVOLVING REASONABLE ACCOMMODATION 

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

reasonable accommodation, as compared to the government-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. 

N/A 

Section VIII: Identification and Removal of Barriers 

Element D of MD-715 requires agencies to conduct a barrier analysis 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 opportunities for 

PWD and/or PWTD? 

Answer Yes 

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

Answer Yes 

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

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

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Source of the Trigger: Workforce Data (if so identify the table) 

Specific Workforce Data 

Table: 

Workforce Data Table - B4 

STATEMENT OF 

CONDITION THAT WAS 

A TRIGGER FOR A 

POTENTIAL BARRIER: 

Provide a brief narrative 

describing the condition at 

issue. 

How was the condition 

recognized as a potential 

barrier? 

Triggers include: PWD and PWTD in Permanent Workforce, New Hires in Permanent Workforce 

(PWD and PWTD), New Hires for MCO (PWD and PWTD), Promotions for MCO (PWD and 

PWTD), Promotions Senior Grade Levels. (PWD and PWTD), New Hires to Senior Grade Levels. 

(PWD and PWTD), Promotions to Supervisory Positions. (PWD and PWTD). Please see Part J for 

full description of triggers, as this space does not allow for full description. 

STATEMENT OF 

BARRIER GROUPS: 

Barrier Group 

People with Disabilities 

People with Targeted Disabilities 

Barrier Analysis Process 

Completed?: 

Y 

Barrier(s) Identified?: Y 

STATEMENT OF 

IDENTIFIED BARRIER: 

Provide a succinct statement 

of the agency policy, 

procedure 

or practice that has been 

determined to be the barrier 

of the 

undesired condition. 

Barrier Name Description of Policy, Procedure, or Practice 

PWD and PWTD are 

underrepresented in 

applicant pipeline; 

attitudinal barriers. 

“No Commission wide D&I strategy: No specific D&I strategy 

exists to guide initiatives and programming;” 

“Talent Processes do not Effectively Mitigate Bias: Standard 

Operating Procedures for talent processes do not actively remove 

barriers and bias” and “Hiring, performance management, and 

promotions are highly subjective with no measures to combat 

biases. This reduces the ability for the CFTC to actively promote 

DEI through talent processes.” 

“No development programs for underrepresented groups: no 

programs exist to actively support the development of employees 

from underrepresent backgrounds;” 

“Approach to hiring and recruitment is rudimentary: there are no 

explicit D&I focused hiring and recruiting programs” and “Hiring is 

limited to a few positions, mainly high grade, and is done by 

individual hiring managers who own the roles. This leaves the hiring 

process open to bias. Additionally, the recruitment processes at the 

Commission do not proactively source...diverse [candidates.]" 

Objective(s) and Dates for EEO Plan 

Date 

Initiated 

Target Date Sufficient 

Funding / 

Staffing? 

Date 

Modified 

Date 

Completed 

Objective Description 

08/07/2019 09/30/2023 Yes Increase the number of PWD and PWTD employed by 

the CFTC. 

Responsible Official(s) 

Title Name Standards Address The Plan? 

Acting Executive Director Tomeka Gilbert Yes 

IT Specialist Kennet Ake Yes 

Chief Information Officer Janaka Perera Yes 

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Responsible Official(s) 

Title Name Standards Address The Plan? 

Manager - Facilities Operations and 

Services 

Edward Busse Yes 

HR Specialist Connie Adkins Yes 

Acting Chief Human Capital Officer Lauren Colón Yes 

Chief Diversity, Equity, Inclusion and 

EEO Officer 

Tanisha Cole Edmonds Yes 

Planned Activities Toward Completion of Objective 

Target Date Planned Activities Sufficient 

Staffing & 

Funding? 

Modified 

Date 

Completion 

Date 

03/01/2021 Hire a consultant to conduct a DEIA study along with an 

agency- wide barrier analysis. 

Yes 06/04/2021 

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

supervisors and employees; with additional targeted 

training required for supervisors. 

Yes 11/12/0021 

09/30/2023 Formalize the Diversity Workgroup Yes 

09/30/2023 The agency will create a DEIA strategic plan. As part of 

the DEIA strategic planning process, we will identify 

further actions/activities that we will implement to 

address potential barriers to people with disabilities. 

Yes 

09/30/2024 Integrate bias mitigation measures and DEI best practices 

into the hiring and selection processes. 

Yes 

09/30/2024 Use strategic talent acquisitions platforms to build an 

intentional and strategic approach to attracting diverse 

applicants. 

Yes 

09/30/2024 Create a diversity recruitment plan. Yes 

09/30/2024 Continue to analyze applicant flow data to better 

understand by grade, position, and division, where 

potential issues may be. 

Yes 

10/30/2021 Charter an Affinity Group for People with Disabilities Yes 10/30/2021 

Report of Accomplishments 

Fiscal Year Accomplishment 

2021 During FY21, the agency completed the DEIA study that was announced in FY20 and released a report of the 

results to the agency’s workforce. Chairman Behnam then held an agency-wide townhall focused on DEIA to 

review and discuss the results with the agency’s workforce. Furthermore, the agency announced plans to hire 

its first Chief Diversity Officer and completed its first mandatory DEIA training for both employees and 

supervisors. The agency also chartered a new employee affinity group centered on people with disabilities. 

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

The agency has undergone leadership changes in its OMWI office. 

5. For the planned activities that were completed, please describe the actual impact of those activities toward eliminating the 

barrier(s). 

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Further steps are needed to address the barriers, as triggers still remain. 

6. If the planned activities did not correct the trigger(s) and/or barrier(s), please describe how the agency intends to improve 

the plan for the next fiscal year. 

During FY22, the agency will: charter an affinity group focused on people with disabilities; start to create a DEIA strategic plan-- as 

part of the DEIA strategic planning process, we will identify further actions/activities that we will implement to address potential 

barriers to people with disabilities; integrate bias mitigation measures and DEI best practices into the hiring and selection processes; 

use strategic talent acquisitions platforms to build an intentional and strategic approach to attracting diverse applicants; create a 

diversity recruitment plan; formalize the diversity workgroup; and continue to analyze applicant flow data to better understand by 

grade, position, and division, where potential issues may be. 

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