Office of the Inspector General

Commodity Futures Trading Commission

Semiannual Report to Congress

October 1, 2018 – March 31, 2019 
1

TABLE of CONTENTS 

EXECUTIVE SUMMARY .......................................................................................................... 3

CFTC PROGRAMS and OPERATIONS .................................................................................. 6

CFTC OIG RESPONSIBILITIES, RESOURCES, ORGANIZATION, and 

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

CFTC OIG RESPONSIBILITIES ..................................................................................................... 6

CFTC OIG RESOURCES ............................................................................................................... 8

OIG INDEPENDENCE .................................................................................................................... 9

REQUIRED STATEMENT REGARDING INFORMATION ACCESS AND ASSISTANCE ........................... 9

DELAYED INFORMATION ACCESS ................................................................................................ 9

AUDIT OPERATIONS .............................................................................................................. 10

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

PROJECTS

Audit of the CFTC’s FY 2018 Annual Financial Report ...................................................... 10

Audit of the CFTC’s FY 2018 Customer Protection Fund ................................................... 10

Federal Information Security Management Act Review: FY 2018 ...................................... 10

ONGOING AUDITS, INSPECTIONS, EVALUATIONS, AUDIT REVIEWS, AND OTHER AUDIT PROJECTS

Audit of the CFTC’s FY 2019 Annual Financial Report ...................................................... 11

Audit of the CFTC’s FY 2019 Customer Protection Fund ................................................... 11

Evaluation of Office of Data and Technology (ODT) Contracts .......................................... 11

FY 2019 Audit: Compliance with the Digital Accountability and Transparency Act ........... 11

Review of CFTC’s Data Governance Program .................................................................... 11

Council of Inspectors General on Financial Oversight (CIGFO) Evaluation FY 2018 ...... 12

Briefing Report: Unaccounted Laptops ................................................................................ 12

REQUIRED STATEMENT REGARDING COMMISSION RESPONSE EXCEEDING 60 DAYS, AND 

MANAGEMENT DECISION NOT MADE ........................................................................................ 12

REQUIRED STATEMENT REGARDING REVISED MANAGEMENT DECISIONS................................. 12

REQUIRED STATEMENT REGARDING INSPECTOR GENERAL DISAGREEMENT ............................. 12

AUDIT REPORTS AND REVIEWS OVER SIX MONTHS OLD........................................................... 13

Corrective Action Not Completed......................................................................................... 13

INVESTIGATIVE OPERATIONS........................................................................................... 14

UPDATED METHODOLOGY FOR TRACKING INVESTIGATIONS ..................................................... 14

INVESTIGATIVE STATISTICS ....................................................................................................... 14

CLOSED INVESTIGATIONS .......................................................................................................... 14
2

ONGOING INVESTIGATIONS........................................................................................................ 15

FOLLOW-UP ON INVESTIGATIVE REPORTS ISSUED IN PRIOR REPORTING PERIODS ..................... 16

LEGAL AND ECONOMIC REVIEW ..................................................................................... 16

COMPLETED PROJECTS............................................................................................................... 16

Inspection & Evaluation: CFTC Stress-Testing Development Efforts................................. 16

INSPECTIONS AND EVALUATIONS ................................................................................... 17

COMPLETED PROJECTS............................................................................................................... 17

Inspection & Evaluation of the February 2018 CFTC-SEC Harmonization Briefing ......... 17

LEGISLATIVE and REGULATORY PROJECTS................................................................ 18

PEER REVIEWS........................................................................................................................ 18

SUMMARY of FINAL REPORTS NOT MADE PUBLIC .................................................... 19

GAO LIAISON............................................................................................................................ 19

STRATEGIC PLAN for the OFFICE of INSPECTOR GENERAL..................................... 20

MISSION, VISION, AND VALUES ................................................................................................. 20

STRATEGIC GOALS..................................................................................................................... 21

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

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

REVIEWS, AND OTHER PRODUCTS .............................................................................................. 21

Office of Legal and Economic Review: Legislative, Economic, and Regulatory Review 

Agenda .................................................................................................................................. 21

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

PERFORMANCE........................................................................................................................... 21

Office of Audits: Audit and Review Agenda .......................................................................... 21

STRATEGIC GOAL 3: ADDRESS EMPLOYEE AND CONTRACTOR MISCONDUCT PROMPTLY,

THOROUGHLY, AND RELIABLY .................................................................................................. 23

Office of Investigations: Investigative Agenda ..................................................................... 23

CONTACTING the OFFICE of the INSPECTOR GENERAL............................................. 24

Appendix 1 – Reports Issued with Questioned Costs.............................................................. 25

Appendix 2 – Reports Issued with Recommendations That Funds Be Put To Better Use .. 26

Appendix 3 - Index of IG Act Reporting Requirements ......................................................... 27
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EXECUTIVE SUMMARY

This semiannual report is issued by the Commodity Futures Trading Commission’s 

(CFTC’s) 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 October 1, 

2018, through March 31, 2019. During this period, OIG completed three audits, one inspection 

and evaluation, and closed three investigations. OIG began or continued work on 4 audits, one 

evaluation, one inter-agency audit, one briefing report, and 20 investigations or preliminary 

investigations. 

Highlights of completed and ongoing audits, investigations, Office of Legal and 

Economic Review projects, and other projects include: 

AUDIT OPERATIONS

Completed

Financial 

• Audit of the CFTC’s FY 2018 Annual Financial Report (AFR) – The objective of this 

Congressionally mandated audit2 is to render an opinion on the agency financial report 

(financial statements) in accordance with Generally Accepted Government Auditing 

Standards (GAGAS). The financial statements were fairly presented, in all material 

respects, in conformity with U.S. Generally Accepted Accounting Principles. 

• Audit of the CFTC’s FY 2018 Customer Protection Fund (CPF) – The objective of this 

Congressionally mandated audit3 is to render an opinion on customer protection fund 

financial statements in accordance with GAGAS. The financial statements were fairly 

presented, in all material respects, in conformity with U.S. Generally Accepted 

Accounting Principles. 

Information Technology Management and Security 

• Federal Information Security Management Act4 Review: FY 2018 – The objective of 

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

required by FISMA. This report was not made public. 

 

1 P.L. 95-452, 92 Stat. 1101 (1978). 2 The Accountability of Tax Dollars Act, P.L. 107-289, 116 Stat. 2049 (2002). 3 Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act), § 748, P.L. 111-203 

(2010)(codified at 7 U.S.C. § 26(g)(5)). 4 P.L. 107-347, 116 Stat. 2946 (2002).
4

Ongoing 

Financial

• Audit of the CFTC’s FY 2019 Annual Financial Report (AFR) – The objective of this 

Congressionally mandated audit5 is to render an opinion on the agency financial report 

(financial statements) in accordance with GAGAS. 

• Audit of the CFTC’s FY 2019 Customer Protection Fund (CPF) – The objective of this 

Congressionally mandated audit6 is to render an opinion on customer protection fund 

financial statements in accordance with GAGAS. 

• Evaluation of Office of Data and Technology (ODT) Contracts – In FY 2017 ODT 

initiated over $54.6 million in contracts for Information Technology (IT) services. 

Failure to effectively manage these contracts could lead to increased costs, as well as 

delays in delivering core mission services to CFTC. We plan to evaluate the management 

of contracts nearing expiration, as well as compliance with tasks enumerated in contracts. 

• FY 2019 Audit: CFTC’s Compliance with the Digital Accountability and Transparency 

Act – The Digital Accountability and Transparency Act 2014 (DATA Act)7 requires 

Federal agencies to report financial and award data in accordance with the established 

Government-wide financial data standards. Agency Inspectors General are required to 

assess the completeness, timeliness, quality, and accuracy of data reported and use of the 

Government-wide financial data standards.

Information Technology Management and Security 

• Review of CFTC’s Data Governance Program – As an extension of information 

technology audit efforts, the OIG initiated an audit of CFTC’s data governance practices. 

Our audit evaluate practices for determining business value and creation, protecting 

stored data, and maximizing reliability of data for business use, focusing on the 

Integrated Surveillance System. 

Operations 

• Council of Inspectors General on Financial Oversight (CIGFO) Evaluation FY 2018 – 

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

8 as well 

as the Council of Inspectors General on Financial Oversight (CIGFO).9 One of the duties 

established for the FSOC is to monitor domestic and international financial regulatory 

proposals and developments. CIGFO is charged with evaluating the effectiveness and 

 

5 See fn. 2. 6 See fn. 3. 7 P.L. 113-101, 128 Stat. 1146 (2014). 8 P.L. 111-203, § 111, 124 Stat. 1392 (2010). 9 P.L. 111-203, § 989E, 124 Stat. 1946 (2010). 
5

internal operations of FSOC. For FY 2018, CIGFO is assessing FSOC’s monitoring of 

international financial regulatory proposals and developments.

• Briefing Report: Unaccounted Laptops – Our objective was to evaluate controls in place 

for IT equipment accountability (safeguarding assets). Our scope was limited to a CFTC 

September 2015 purchase of 425 Dell 7450 laptops and reported losses from that 

purchase. 

INVESTIGATIVE OPERATIONS

Completed 

We closed one investigation and two preliminary investigations. The investigation 

involved an allegation that someone was impersonating an employee at the CFTC in order to 

assist in a fraud. During our fieldwork we learned that CFTC Enforcement was working on a 

related matter. We determined to refer our matter to Enforcement.

The IG converted one preliminary investigation into an alleged violation of the Sunshine 

Act to an inspection/evaluation. We left the matter open as a preliminary investigation pending 

completion of this inspection/evaluation. OIG closed the inspection/evaluation (see below) 

without a referral back to investigations, and we closed the preliminary investigation. 

Finally, during this reporting period we received an administrative allegation against 

CFTC human resources. We opened a preliminary investigation but found no merit to the 

allegation. We closed the preliminary investigation.

Ongoing 

The Office of Investigations currently has 17 open matters – eight investigations and nine 

preliminary investigations. Two are being investigated in cooperation with other Federal or state 

law enforcement entities. 

LEGAL AND ECONOMIC REVIEW

One economic review of CFTC stress-testing programs, Inspection & Evaluation: CFTC 

Stress-Testing Development Efforts, completed in the prior reporting period, was published on 

the CFTC OIG webpage during this period. We received follow up from CFTC management 

during the reporting period that appears positive. 

INSPECTION AND EVALUATION

We completed an inspection of a February 2018 CFTC/SEC harmonization meeting, and 

concluded CFTC complied with the Government in the Sunshine Act10 in the conduct of the 

meeting. We published the report to our webpage. 

 

10 P.L. 94-409, 90 Stat. 1241 (1976). 
6

CFTC PROGRAMS and OPERATIONS

Congress created the CFTC in 1974 as an independent agency with the mandate to 

regulate commodity futures and options markets in the United States. Congress renewed and/or 

expanded the CFTC’s mandate in 1978, 1982, 1986, 1992, and 1995. In December 2000, 

Congress and the President reauthorized the CFTC with its passage of the Commodity Futures 

Modernization Act of 2000 (CFMA). In May of 2008, Congress reauthorized the CFTC through 

FY 2013. On July 21, 2010, the President signed into law the Dodd-Frank Act, which authorized 

the CFTC to regulate swap dealers and increase transparency in the derivatives marketplace. 

 The CFTC is responsible for fostering the economic utility of the markets under its 

jurisdiction by encouraging their competitiveness and efficiency, ensuring their integrity, and 

protecting market participants against manipulation, abusive trade practices, and fraud. Through 

oversight regulation, the CFTC seeks to empower the markets under its jurisdiction to better 

serve their vital function in the nation’s economy—providing a mechanism for price discovery 

and a means of offsetting price risks. 

The CFTC operating divisions are: Office of the Chairman, Division of Clearing and 

Risk, Division of Swap Dealer and Intermediary Oversight, Division of Enforcement (which 

includes the CFTC Whistleblower Office), Division of Market Oversight, Office of the Chief 

Economist, Office of the Executive Director, Office of General Counsel, Office of International 

Affairs, and Office of Data and Technology. Within the Office of the Chairman reside the

Offices of Minority and Women Inclusion, Legislative Affairs and Intergovernmental Affairs, 

and External Affairs. In addition to its headquarters office in Washington, D.C., the CFTC 

maintains offices in Chicago, Illinois; Kansas City, Missouri; and New York, New York. 

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 1978.11 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; 

 

11 Inspector General Act Amendments of 1988, P.L. 100-504, 102 Stat. 2515 (1988). 
7

• 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 full Commission.12

The IG is a member of the Counsels 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 Counsel 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. 

OIG conducts audits and attestation engagements 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. 

 

12 5 U.S.C. §§ 8G(c), 8G(e)(1). 
8

CFTC OIG RESOURCES

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

and Economic Review. At the end of the reporting period, the CFTC OIG consisted of 8.5 full 

time equivalents—the Inspector General, Deputy Inspector General/Chief Counsel, Assistant 

Inspector General for Investigations (AIGI), Assistant Inspector General for Auditing, two

Auditors, one Senior Program Analyst, one full-time Attorney/Economist, and one part-time 

Attorney/Economist serving as a consultant. During the reporting period, our full-time 

Attorney/Economist was detailed to the Consumer Finance Protection Bureau, and an attorney 

from the Department of Homeland Security OIG was detailed to OIG through the CIGIE 

Fellowship Program. Our organizational chart (for the reporting period) follows. 

A. Roy Lavik

Inspector General

Judith Ringle

Deputy Inspector General & Chief 

Counsel

U.S. Commodities Futures Trading 

Commission Office of the Inspector Genera

(September 2017)

l 

Contracted Admin 

Support

hCCICE hC AUDITS

aiguel Castillo

Assistant Inspector General 

Auditing

Timothy teoples

Audit Specialist and 

terformance Audits

.ranco Garcia 

Cinancial and IT 

Audits

Tony .aptiste

Senior trogram 

Analyst

hCCICE hC IbVESTIGATIhbS

Thaddeus Glotfelty

Assistant Inspector General 

Investigations 

 Christopher 

aufarrige

Attorney Economist

(detailed to CCt.)

 Robert Sarvis

Consultant

hCCICE hC LEGAL AbD 

EChbhaIC REVIEW

Contracted taralegal 

tart-time Support

Investigator

(T.D)

Our webpage is located at https://www.cftc.gov/About/OfficeoftheInspectorGeneral/index.htm. 
9

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.13 During the semimanual reporting period, there were no 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

REQUIRED STATEMENT REGARDING INFORMATION ACCESS AND ASSISTANCE 

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). 

DELAYED INFORMATION ACCESS

In our previous semi-annual reports, we noted that CFTC had been slow to produce 

documents in response to written investigative requests. We did not view this as an attempt to 

interfere with OIG investigations, but rather as a consequence of CFTC prioritizing other matters 

in a time of budget constraint. We emphasize that we have no indication that any delay on the 

part of CFTC is intentional or intended to impede OIG operations. 

The document requests have now been fulfilled. We are not currently waiting on 

additional files or data. When we next make a request for documents, we can evaluate any new 

delays. We will follow up again in the next semi-annual report. 

In our last semi-annual report, we noted that the Chairman’s office had prioritized the 

hire of additional forensic and IT security experts. We anticipated that this would reduce CFTC 

response times for OIG requests for documents or information, and will increase our ability to 

respond to requests from outside law enforcement agencies. Unfortunately, we learned that no 

new forensics staff will be hired. OIG will consider hiring an internal OIG forensics and IT 

expert to assist or manage OIG systems and access to CFTC data in the future, based on the 

availability of funds given competing priorities.

 

13 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 sec. 8G(d)(1). 
10

AUDIT OPERATIONS 

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

AUDIT PROJECTS

Financial 

Audit of the CFTC’s FY 2018 Annual Financial Report 

The objective of this Congressionally mandated audit14was to render an opinion on the 

agency financial report (financial statements) in accordance with Generally Accepted 

Government Auditing Standards (GAGAS). The financial statements were fairly presented, in all 

material respects, inconformity with U.S. Generally Accepted Accounting Principles. There were 

no deficiencies in internal control over financial reporting that are considered to be material or 

significant. There is a separate management letter conveying that time and attendance recording 

keeping, whistle blower award procedures, and accountable property controls warranted 

management’s attention, and one reportable instance of noncompliance (and potential AntiDeficiency) from FY 2017 that remained open, pending completion of an internal management 

review. The Audit of the CFTC’s FY2018 Annual Financial Report is published on our webpage. 

Audit of the CFTC’s FY 2018 Customer Protection Fund 

The objective of this Congressionally mandated audit15 was to render an opinion on 

customer protection fund financial statements in accordance with GAGAS. The financial 

statements were fairly presented, in all material respects, inconformity with U.S. Generally 

Accepted Accounting Principles. The Audit of CFTC’s FY 2018 Customer Protection Fund is 

published on our webpage. 

Information Technology Management and Security 

Federal Information Security Management Act16 Review: FY 2018 

The objective of the review was to evaluate CFTC’s information security program and 

practices as required by FISMA. This report was not made public. 

 

14 See fn. 2. 15 See fn. 3. 16 See fn. 4. 
11

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

AUDIT PROJECTS

Financial 

Audit of the CFTC’s FY 2019 Annual Financial Report 

The objective of this Congressionally mandated audit17 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 2019 Customer Protection Fund

The objective of this Congressionally mandated audit18 is to render an opinion on 

customer protection fund financial statements in accordance with GAGAS. 

Evaluation of Office of Data and Technology (ODT) Contracts 

In FY 2017 ODT initiated over $54.6 million in contracts for Information Technology 

(IT) services. We plan to evaluate management of contracts nearing expiration, as well as

compliance with tasks enumerated in contracts. We plan to later examine management of other 

contracts. 

FY 2019 Audit: CFTC’s Compliance with the Digital Accountability and Transparency Act 

The Digital Accountability and Transparency Act 2014 (DATA Act)19 requires Federal 

agencies to report financial and award data in accordance with the established Government-wide 

financial data standards. Agency Inspectors General are to assess the completeness, timeliness, 

quality, and accuracy of data reported and use of the Government-wide financial data standards.

Information Technology Management and Security 

Review of CFTC’s Data Governance Program

As an extension of information technology audit efforts, the OIG is initiating an audit of 

CFTC’s data governance practices. Data governance is an accountability framework to 

encourage desirable behavior in the valuation, creation, storage, use, archiving and deletion of 

data. It includes the processes, roles, standards and metrics that ensure the effective and efficient 

use of data for CFTC to complete its oversight responsibilities. The scope of our audit will be 

limited to data stored in the Integrated Surveillance System20 to evaluate practices for 

 

17 See fn. 2. 18 See fn. 3. 19 See fn. 7. 20 This system, developed in the late 1990s, hosts confidential and sensitive market data collected pursuant to CFTC 

regulations; it supports CFTC market surveillance, market research, public reports (including the CFTC 

Commitment of Traders (COT) Reports), and other CFTC mission critical activities.
12

determining business value and creation, protecting stored data, and maximizing reliability for 

business use. 

Operations 

Council of Inspectors General on Financial Oversight (CIGFO) Evaluation FY 2018 

One of the duties established for the Financial Stability Oversight Council (FSOC) is to 

monitor domestic and international financial regulatory proposals and developments, including 

insurance and accounting issues, and to advise Congress and make recommendations. During the 

reporting period, CFTC OIG actively participated in a CIGFO audit of FSOC’s monitoring of FY 

2018 international financial regulatory proposals and developments. This project was ongoing at 

the close of the reporting period. 

Briefing Report: Unaccounted Laptops

Our objective was to evaluate controls in place for IT equipment accountability 

(safeguarding assets). Our scope was limited to a CFTC September 2015 purchase of 425 Dell 

7450 laptops and reported losses from that purchase. 

REQUIRED STATEMENT REGARDING COMMISSION RESPONSE EXCEEDING 60

DAYS, AND MANAGEMENT DECISION 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 STATEMENT REGARDING REVISED MANAGEMENT DECISIONS

No management decisions were revised during the reporting period. 

REQUIRED STATEMENT REGARDING INSPECTOR GENERAL DISAGREEMENT

The Inspector General did not disagree with any management decisions on OIG audit 

recommendations during the reporting period. 
13

AUDIT REPORTS AND REVIEWS OVER SIX MONTHS OLD

Corrective Action Not Completed

There were two audit reports over six months old where recommendations for corrective 

action had not been completed by the planned action date. 

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

2019 2 3 0 0

2018 2 4 0 0

Totals 4 7 0 0

Table 2: Detail of Unimplemented Recommendations: 

Fiscal 

Year

Audit Report Unimplemented Recommendations

2019 18-AU-08 - CFTC’S 

Compliance with FISMA for 

Fiscal Year 2018

This audit is not public.

2019 CFTC Financial Statements 

Audit: Fiscal Year (FY) 2018

• Complete the investigation into the potential 

ADA violation noted and report to the 

appropriate parties.

2018 17-AU-03 -Audit of CFTC’s 

Enterprise Architecture 

Program

• Formalize leadership for an EA program with 

responsibilities for a future-state roadmap that 

aligns with mission operations;

• Establish a review board made up of the 

Chairman, Commissioners, and Division 

Directors, to prioritize and approve IT 

investments;21 and

• Establish IT investment performance measures 

to monitor investment status, and periodically 

report progress to Congress.

2018 17-AU-05 – FY 2017 FISMA 

Compliance Audit 

 This audit is not public.

 

21 While we recommended participation by the full Commission, we realize that authority and responsibility to 

create and maintain an EA program ultimately lies with the Chairman. 40 USC § 11311; EO 13103, §2 (Sept. 30, 

1998). This appears consistent with the Chairman’s authority under the Commodity Exchange Act. 7 USC § 2(a)(6).
14

INVESTIGATIVE OPERATIONS

UPDATED METHODOLOGY FOR TRACKING INVESTIGATIONS

OIG has added “preliminary investigations” as a new matter type, which we define as 

allegations that are within OIG’s jurisdiction and will require some preliminary development 

before opening a formal investigation or closing it with a note to file. We are relabeling our 

investigative matters below to reflect this new methodology.

INVESTIGATIVE STATISTICS

There were 17 open matters – nine investigations and eight preliminary investigations – 

pending at the start of the reporting period. We received 29 allegations22 from the OIG hotline 

and from CFTC employees. The OIG engaged in the following investigative activity:

• Referred 18 allegations to the CFTC Division of Enforcement 

• Referred four allegations to another entity for possible investigation 

• Referred one allegation to OIG Audit

• Declined three allegations due to lack of jurisdiction, specificity, or follow-up by 

complainant 

• Opened one investigation

• Opened two preliminary investigations

• Closed one investigation and two preliminary investigations. 

At the close of the reporting period there remained 17 open matters: eight investigations and nine 

preliminary investigations. 

CLOSED INVESTIGATIONS

We closed one investigation and two preliminary investigations. We investigated an 

allegation that someone was impersonating a federal employee; they claimed to be an employee 

at the CFTC, and used their claimed status as an employee to assist in a fraud. During our 

development of the facts, we learned that CFTC’ Division of Enforcement was working on a 

related matter. We determined to refer this investigation to Enforcement. 

During the last reporting period, the IG determined to convert a preliminary investigation 

into an alleged violation of the Sunshine Act by CFTC into an inspection/evaluation. We left the 

 

22 The OIG email and voicemail hotline together received approximately 500 messages during the reporting period. 

We limit our spam filters to avoid missing a meritorious allegation, and consequently the vast majority of emails and

voicemails we receive do not allege any wrongdoing related to the CFTC or OIG mission.
15

matter open pending completion of the inspection/evaluation. OIG completed the 

inspection/evaluation (discussed at page 12) without a referral back to investigations, and so we 

accordingly closed the preliminary investigation during this reporting period. 

Finally, during this reporting period, we received an administrative allegation against 

CFTC’s Office of Human Resources. We opened a preliminary investigation but found no merit 

to the allegations. We closed the preliminary investigation during this reporting period. 

Nine investigations and eight 

ONGOING INVESTIGATIONS

preliminary investigations remained open at the close of the 

reporting period. For one investigation and one preliminary investigation, we are collaborating

with the Justice Department, FBI, or other Federal or state law enforcement authorities. Because 

two investigations pending at the close of the prior reporting period were closed during this 

reporting period, and one preliminary investigation was opened and closed during this reporting 

period, we worked on a total of 20 matters during the reporting period. 

At the start of the reporting period we were awaiting assistance from CFTC to access 

documents for multiple investigations. At the end of the reporting period, CFTC had completed 

production of outstanding document requests; no investigations are currently on hold pending 

production of files from CFTC, nor for any other reason. Seven preliminary investigations are 

currently on hold due to resource constraints. One preliminary investigation is on hold pending 

action from another federal agency.

All open investigations and preliminary investigations are confidential. It is the policy of 

CFTC OIG to not disclose details regarding open investigations absent good cause; if an ongoing 

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

Table 3: Investigative Statistics for Referrals and Whistleblower Retaliation: 

October 1, 2018 – March 31, 2019 

A. Issued investigative reports 0

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) to ensure matters of interest are coordinated from the outset. 

While we engaged with AUSAs on a number of occasions on a number of matters, no formal 

referrals for prosecution were made during the reporting period. 

There were no findings of whistleblower retaliation during the reporting period. 
16

FOLLOW-UP ON INVESTIGATIVE REPORTS ISSUED IN PRIOR REPORTING PERIODS

In our Semiannual Report for the period ending September 30, 2018, we reported that CFTC 

management had not acted on a report of investigation (ROI) issued in August of 2018. This 

investigation involved a senior Government employee where allegations of misconduct were 

substantiated. As of the close of this reporting period, CFTC continues to consider action. 

LEGAL AND ECONOMIC REVIEW

COMPLETED PROJECTS

Inspection & Evaluation: CFTC Stress-Testing Development Efforts

During a prior reporting period, OIG’s Office of Legal and Economic Review completed a report 

titled Inspection & Evaluation: CFTC Stress-Testing Development Efforts. This inspection was 

motivated by allegations of mismanagement conveyed to us by multiple CFTC whistleblowers. 

We found that leadership in the Division of Clearing and Risk (DCR)’s Risk Surveillance Branch 

(RSB) retarded the development of CFTC stress-testing capabilities, undermined efforts to 

improve the usability of uncleared swaps data, denied various employees access to certain 

information technology resources, and overstated publicly the independence and coverage of its 

2016 Supervisory Stress Test program.23 We also contracted with National Economic Research 

Associates, Inc. (NERA) to assist our technical evaluation of CFTC’s stress-testing approaches. 

NERA issued detailed analysis, including substantive criticism of the RSB leadership’s 

methodology (employed in the 2016 Supervisory Stress Test program), compared to what was 

available from its technical staff. No recommendations were issued by NERA or OIG.

We first brought the allegations to the attention of the Chairman’s Chief of Staff in July 2017 

and communicated frequently with the Director of DCR beginning in October 2017. We 

circulated a summary memo to the Chairman in October 2017, followed by a substantially 

complete version of the report in December 2017. In January 2018, we met with the Chairman, 

his staff, and the Director of DCR; they stated they had no major disagreements with the report. 

We finalized a discussion draft in February 2018 and circulated it to the Commission. We 

accommodated the Chairman’s request for an extended time to respond to the February 2018 

discussion draft, and over the following six months, we discussed the situation with the Director 

of DCR, who indicated substantial changes were forthcoming. We received no formal written 

response or any stated disagreements, and circulated the report as final on July 30, 2018.24

 

23 CFTC, Supervisory Stress Test of Clearinghouses, A Report by Staff of the U.S. Commodity Futures Trading 

Commission, November 2016 

(https://www.cftc.gov/sites/default/files/idc/groups/public/@newsroom/documents/file/cftcstresstest111516.pdf.) 24 Section 5(a)(10) of the IG Act, 5 U.S.C. § 5(a)(10), requires the IG to report a summary of each audit report, 

inspection reports, and evaluation reports, issued before the commencement of the reporting period for which no 

management decision has been made by the end of the reporting period (including the date and title of each such 

report), an explanation of the reasons such management decision has not been made, and a statement concerning the 

desired timetable for achieving a management decision on each such report. We issued this inspection report in final 
17

The February 2018 version of the report was submitted to the Office of General Counsel in 

March 2018 for redaction in preparation for publication.25 Seven months later, at the close of the 

September 30, 2018, reporting period, it remained in OGC’s redaction process. CFTC completed 

redactions and we published the report, along with the NERA report, to our webpage on 

December 12, 2018. 

A new Deputy Director of RSB was installed in September 2018, and we reported, in our 

previous semiannual report, optimism regarding the potential for positive change. Six months 

later, we are disappointed that mid-level leadership in RSB responsible for mismanagement 

remain still dealing with stress-testing in mid-level leadership, and that substantive changes have 

been slow to materialize. We also remain concerned that market participants may be given a 

misleading impression about the substantive quality and independence of CFTC’s stress-testing 

reports and capabilities. However, we reserve judgment at this time regarding whether further 

changes and new leadership prove sufficient to address the deficiencies our report described. 

There were no ongoing projects addressing legal and economic issues at the close of the 

reporting period. 

INSPECTIONS AND EVALUATIONS

COMPLETED PROJECTS

Inspection & Evaluation of the February 2018 CFTC-SEC Harmonization Briefing

We completed one inspection during the reporting period, Inspection and Evaluation of 

the February 2018 CFTC-SEC Harmonization Briefing, which we published on our webpage. 

This project responded to two outside complaints that the SEC-CFTC harmonization briefing 

held on February 27, 2018, might have violated the Government in the Sunshine Act.26 Lacking 

a specific allegation of misconduct by an individual, we determined to conduct an inspection and 

evaluation of the meeting. We concluded that CFTC complied with the Government in the 

Sunshine Act in the conduct of the meeting. 

There were no inspections or evaluations pending at the close of the reporting period. 

 

154 days after the February 26, 2018, discussion draft. There were no recommendations. Management’s decisions 

and timetable have been conveyed verbally. 

25 Section 8M(b)(1) of the IG Act, 5 U.S.C. § 8M(b)(1), requires posting to the OIG webpage, within three days of 

issuance, the following: “any audit report, inspection report, or evaluation report (or portion of any such report) 

[that] is submitted in final form to the head of the Federal agency or the head of the designated Federal entity.” That 

deadline was not met. 

26 See fn.10. 
18

LEGISLATIVE and REGULATORY PROJECTS

1. Introduction and Summary 

 As specified in Section 4(a)(2) of the Inspector General Act of 1978,27 the Office of 

Legal and Economic Review 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. 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. 

2. Legislative Activities

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

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

work is performed by the Office of Legal and Economic Review within OIG. 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. No formal projects were undertaken during this reporting period. 

PEER REVIEWS

An important function in each Agency OIG is the peer review process. The Council of 

Inspectors General on Integrity and Efficiency describes the processes for audits and investigative 

peer reviews on its website as follows:

• Government Auditing Standards 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. 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.

• Similarly, investigative peer reviews are conducted to ensure compliance with the 

requirements of the Quality Standards for Investigations and to determine whether adequate 

internal safeguards and management procedures exist. Because it is a DFE Inspector 

General, the CFTC OIG is not required to undergo a peer review of its investigative function, 

but does so voluntarily. CFTC OIG passed its last investigative peer review on March 27, 

2013. 

 

27 5 USC App. 3 § 4(a)(2).
19

 

Section 989C of the Dodd-Frank Act28 implemented a requirement to include in each 

OIG semiannual report an appendix containing: 

• 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. 

An audit peer review was completed on August 16, 2016, and our Office of Audit 

received a rating of “pass”— the highest rating. 

SUMMARY of FINAL REPORTS NOT MADE PUBLIC

 During the reporting period, the following reports (as previously discussed) were issued 

in final and were not made public: 

• 18-AU-08 - CFTC’S Compliance with FISMA for Fiscal Year 2018

GAO LIAISON 

OIG is charged with providing policy direction for, and conducting, supervising, and 

coordinating audits, investigations, and other projects relating to CFTC programs and operations. 

In addition, OIG is required to recommend policies for, and conduct, supervise, and coordinate 

with other federal agencies, state and local governmental agencies, and nongovernmental 

entities, audits, investigations, and evaluations regarding the economy, efficiency, and 

effectiveness of CFTC programs and operations. 

 GAO also conducts audits of CFTC activities, and OIG plans its audits, inspections, 

evaluations, reviews, and investigations so as not to duplicate GAO's efforts. Moreover, OIG in 

its audit activities identifies the goals of each audit and the methods of reaching the goals so as to 

minimize the requirements placed on CFTC resources. 

 

28 See fn. 3. 
20

STRATEGIC PLAN for the OFFICE of INSPECTOR GENERAL

MISSION, VISION, AND VALUES

Mission

The mission of the OIG is to promote the integrity, efficiency, and effectiveness of the 

critical programs and operations of the CFTC. We accomplish this mission by the following:

• Communicating timely and useful information that facilitates decision-making and 

measurable gains;

• Conducting independent and objective audits, evaluations, and other reviews of CFTC 

programs and operations; 

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

administrative violations that undermine the ability of the CFTC to accomplish its statutory 

mission;

• Identifying vulnerabilities in and making recommendations to improve CFTC programs and 

operations; 

• Preventing and detecting fraud, waste, and abuse in CFTC programs and operations; and

• Keeping the Commission and Congress currently and fully 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, and other activities, and thereby acts as a catalyst for 

positive change in the CFTC’s programs and operations. 

Values Statement 

The CFTC believes that integrity and excellence apply foremost to our work. We value 

integrity and excellence in the conduct of OIG activities. These values are fundamental to the 

accomplishment of our mission and our daily operations. 
21

STRATEGIC GOALS

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 Review: Legislative, Economic, and Regulatory Review

Agenda

In the coming year, 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 legal research, white papers, inspections and 

evaluations performed in accord with the CIGIE Quality Standards for Inspection and 

Evaluation, management reviews, and other products. 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.29 These efforts are particularly important since the CFTC is an 

economic regulatory agency. We will continue to seek staff who possess exceptional expertise in 

relevant law and economics. 

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;

 

29 5 U.S.C. App. 3 § 4 (made applicable to the CFTC at 7 U.S.C. §8G(g)). 
22

• 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.30 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 generally accepted auditing standards, Government Auditing Standards

and OMB Bulletin 19-01. 

Audit of the CFTC Customer Protection Fund 

Section 748 of the Dodd-Frank Act31 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. 

C. Annual Reviews. OIG will perform the following reviews and evaluations annually. 

Inspector General’s Assessment of the CFTC’s Management Challenges

The Reports Consolidation Act of 200032 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.

 

30 See fn. 2. 31 See fn. 3. 32 P.L. 106-531, 114 Stat. 2537 (2000). 
23

Review of Compliance with the Federal Managers' Financial Integrity Act, FMFIA33

 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 the CFTC Information Security Management Act, FISMA 

The Federal Information Security Management Act34 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

 Looking to the long term, OIG intends to focus the balance of its resources on the review 

of the management and program operations of the agency and compliance with Congressional 

mandates. OIG plans to concentrate its efforts in reviewing activities relating to the most serious 

management challenges facing the CFTC. 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. 

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 

 

33 P.L. 97-255, 96 Stat. 814 (1982). 34 See fn. 4. 
24

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 law 

enforcement officers at other 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, oig@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, legislative and regulatory review functions. OIG estimates one staff year for 

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

time to an investigation, audit, inspection, evaluation, review, or other project that responds to 

current concerns or allegations, and must be completed in a timely fashion 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. The 

telephone number is (202)418-5110. The facsimile number is (202)418-5522. The hotline email 

is OIG@cftc.gov. OIG’s web page is located at 

http://www.cftc.gov/About/OfficeoftheInspectorGeneral/index.htm. 
25

Appendix 1 – Reports Issued with Questioned Costs

October 1, 2018 – March 31, 2019 

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
26

Appendix 2 – Reports Issued with Recommendations That Funds Be 

Put To Better Use

October 1, 2018 – March 31, 2019

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
27

Appendix 3 - Index of IG Act Reporting Requirements

Section 4(a)(2) Review of legislation and regulations..............................................18 

Section 5(a)(1) Significant problems, abuses and deficiencies..................................3-5 

Section 5(a)(2) Recommendations with respect to significant problems..........................10 

Section 5(a)(3) Significant recommendations that have not been completed..................12 

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

Section 5(a)(5) Summary of instances where information was refused ..........................9 

Section 5(a)(6) Completed audit reports..............................................................10 

Section 5(a)(7) Significant audit reports............................................................10 

Section 5(a)(8) Statistical Table—Questioned Costs.............................................25 

Section 5(a)(9) Statistical Table—Funds Recommended for Better Use .....................26 

Section 5(a)(10) Audit reports lacking management decision ...................................12 

Section 5(a)(10) Audit reports without Commission response after 60 days..................12 

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

recommendations, including the aggregate potential cost savings .........13 

Section 5(a)(11) Significant revised management decisions .....................................12 

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

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 ........................................................18 

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 .........................16 

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

Section 5(a)(21) Attempts to interfere with OIG independence .................................9 

Section 5(a)(22) Summary of final reports not made public....................................19 

Section 6(b)(2) Summary of reports to Chairman where assistance was refused.............9 
28