FY 2022 AGENCY FINANCIAL REPORT

COMMODITY FUTURES TRADING COMMISSION
ABOUT THIS REPORT

The 2022 Agency Financial Report is intended to communicate 

to stakeholders and interested parties the Commodity Futures 

Trading Commission’s (CFTC or Commission) financial position 

and operating performance over the previous 12-month time 

period, and state the CFTC’s plans for the future.

The Reports Consolidation Act of 2000 authorizes Federal 

agencies, with the Office of Management and Budget’s 

(OMB) concurrence, to consolidate various reports in order 

to provide performance, financial, and related information in 

a more meaningful and useful format. The Commission has 

chosen an alternative to the consolidated Performance and 

Accountability Report, and instead, produces an Agency 

Financial Report and an Annual Performance Report, pursuant 

to OMB Circular A-136, Financial Reporting Requirements. 

Unless otherwise indicated, information in this report is 

provided as of November 15, 2022, and covers the period 

October 1, 2021 to September 30, 2022.

This report is in the public domain. Authorization to reproduce 

it in whole or in part is granted. While permission to reprint 

this publication is not necessary, the citation should be: 

Commodity Futures Trading Commission, FY 2022 Agency 

Financial Report, Washington, D.C. 20581.

The report may be electronically accessed at: 

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

Photographs in this document are proprietary and prior 

permission from the photographer is required for any use 

or reproduction.
FY 2022 AGENCY FINANCIAL REPORT

COMMODITY FUTURES TRADING COMMISSION

Rostin Behnam

Chairman and Chief Executive

and

Janaka Perera

Acting Executive Director

November 15, 2022
Photo Section

Message from the Chairman 1

Management’s

Discussion and Analysis

THE COMMISSION 6

CFTC FISCAL YEAR 2022 HIGHLIGHTS 12

WHAT IS ON THE HORIZON? 18

PERFORMANCE HIGHLIGHTS 25

FINANCIAL HIGHLIGHTS 31

MANAGEMENT ASSURANCES 40

MANAGEMENT’S DISCUSSION AND ANALYSIS

The Commission 6

CFTC Fiscal Year 2022 Highlights 12

What is on the Horizon? 18

Performance Highlights .

Financial Highlights .

Management Assurances 40

Financial Section

A LETTER FROM THE CHIEF 

FINANCIAL OFFICER 47

REPORT OF THE INDEPENDENT AUDITOR 48

PRINCIPAL FINANCIAL STATEMENTS 54

NOTES TO THE FINANCIAL STATEMENTS 60

REQUIRED SUPPLEMENTARY 

INFORMATION (UNAUDITED) 77

FINANCIAL SECTION

A Letter from the Chief Financial Officer  .

Report of the Independent Auditor . 

Principal Financial Statements 54

Notes to the Financial Statements 60

Required Supplementary Information (Unaudited) 77

Other Information

INSPECTOR GENERAL’S 

FY 2022 ASSESSMENT 80

SUMMARY OF AUDIT AND 

MANAGEMENT ASSURANCES 84

PAYMENT INTEGRITY 

INFORMATION ACT REPORTING 85

CIVIL MONETARY PENALTY 

ADJUSTMENT FOR INFLATION 87

OTHER INFORMATION

Inspector General’s FY 2022 Assessment .

Summary of Audit and Management Assurances 84

Payment Integrity Information Act Reporting 85

Civil Monetary Penalty Adjustment for Inflation 87

Appendix

CFTC CUSTOMER PROTECTION FUND 90

WHY ARE THE MARKETS IMPORTANT TO ME? 94

CFTC OVERSIGHT OF REGULATED ENTITIES 97

CFTC LIST OF ABBREVIATIONS 

AND ACRONYMS 100

APPENDIX

CFTC Customer Protection Fund .

Why Are the Markets Important to Me? 94

CFTC Oversight of Regulated Entities 97

CFTC List of Abbreviations and Acronyms . 

Table of Conten

FY 2022 Agency Financial Re

II Commodity Futures Trading Commiss
CFTC MISSION

To promote the integrity, resilience, 

and vibrancy of the U.S. derivative 

markets through sound regulation.

CFTC VISION 

To be the global standard for 

sound derivatives regulation.

CFTC VALUES 

Commitment, Forward-Thinking, 

Teamwork, Clarity.

Message fro

the Chairm

Iam pleased to present the CFTC’s FY 2022 Agency Financial Report. Reporting the Commission’s

financial and performance results provides transparency, builds 

accountability, encourages the CFTC and those we regulate to 

act responsibly, and promotes thoughtful dialogue within the 

markets we oversee. This report provides a year-long snapshot

of the Commission’s financial and performance reporting.

U.S. Derivatives Markets

The U S derivatives markets are the most open, transparent 

and competitive in the world. The estimated 2022 notional

value of U.S.derivative markets is $25 trillion for U.S.futu

and $360 trillion for U.S. swap.  These figures underscore t

importance of our mission

For over a century, the derivatives markets have played an 

integral role in the U.S. economy, facilitating risk managemen

and price discovery, and contributing to financial stability 

and predictability of prices that impact the daily lives of all 

Americans. Through the Commodity Exchange Act, Congress

both mandates and empowers the CFTC to implement 

rules and regulations aimed at fostering open, transparent, 

competitive, and financially sound markets; to prevent and 

deter misconduct and disruptions to market integrity; and 

to protect all market participants from fraud, manipulation, 

and abusive practices. The CFTC will continue do its part

to promote and protect the integrity of derivatives markets

 Commodity Futures Trading Commission 
Role of the CFTC

The CFTC plays a unique role as the regulator of the U.

derivatives markets. The agency has a rich history of

principles-based regulation that allows us to foster innovation 

and adapt to changes in our markets.

CFTC staff fulfill the agency’s mission with steadfast dedication

From a market integrity and resiliency standpoint, the U.

derivatives markets met historically unprecedented volume and 

volatility with the powerful benefits of central clearing, capital 

and margin requirements, data, and transparency. FY 2022

and recent years demonstrated that the post-2008 financial 

crisis reforms prepared the agency and the marketplace 

for events and externalities, such as COVID-19 pandemic, 

monetary and fiscal policy shifts, agricultural, environmental, 

and geopolitically driven supply chain disruptions, and 

Fintech growth, evolution, and risks. However, we can never

assume our work is done, and the CFTC remains vigilant and 

responsive to emerging risks, utilizing every tool that it has, 

remaining flexible, and coordinating domestically and abroad 

from a market resiliency and financial stability standpoint

Chairman Rostin Behnam

FY 2022 

This past fiscal year provided numerous opportunities to 

demonstrate our strategic thinking about the growth and innovation in the U.S. derivatives markets and the various ways i

which new and emerging risks present themselves. The CFTC

2022 – 2026 Strategic Plan, published in March 2022, addresses 

the new and significant impacts on derivatives markets such 

as the ongoing and long-term direct and indirect impacts of 

the COVID-19 pandemic and climate change. In addition,

the Commission will strategically address the rapidly evolving 

markets for digital assets, and the persistent need to address 

misconduct in derivatives and underlying cash markets, while 

continuing to incorporate risk identification, mitigation, and 

management into everything we do.

While this message cannot provide a full description of 

the FY 2022 accomplishments of the CFTC and its staff, I 

would like to highlight a few areas where the CFTC has acted 

decisively to address challenges and align priorities for the 

years to come

2 Commodity Futures Trading Commissio
Enforcement

The CFTC’s enforcement program continued to detect and deter 

misconduct by enforcing the law and the commission’s rules

In FY 2022, the CFTC filed 82 actions, and obtained orders 

imposing over $2.5 billion in total monetary relief, including

civil monetary penalties, disgorgement, and restitution. Of

these enforcement actions, 18 involved digital asset-related 

allegations. Cooperation and coordination with criminal

authorities and other regulatory partners strengthened the 

program’s effectiveness. Additionally, the Whistleblower Office

continued to process high volumes of tips, complaints, and 

referrals, totaling 1,506 during FY 2022

Data

As the industry continues to migrate to the cloud, we have 

accelerated our cloud migration efforts to keep pace. This

migration is now almost entirely complete, and will allow the 

Commission to store, analyze, and ingest this data more costeffectively and efficiently. This year, I directed our Division

of Data to transform the agency’s analytics toolkit to leverage 

the cloud architecture with advancements in AI, machine 

learning, and data analytics. This will provide our already

robust surveillance, enforcement, and monitoring capabilities 

with automated systems helping them find the bad actors to 

ensure our markets have utmost integrity and transparency

These technological advancements will not only advance the 

Commission’s internal databases and analytic tools for the 

21st century, but also improve the agency’s ability to recruit 

and retain staff

Digital Assets

The record-breaking growth and widespread adoption of 

derivatives involving digital assets continued to present novel 

issues for CFTC oversight and enforcement, highlighting 

emerging risks especially to a new cohort of predominantly 

noninstitutional market participants. Through our limited

enforcement authorities, the Commission continues to police 

these emerging markets, whose rapid scaling may create 

financial stability risks in the future. The Commission is

also vigilantly monitoring the rise of retail participation and 

the exchanges, intermediaries and innovators who are eager 

to meet demand for products and services in these markets

Climate-Related Financial Risk

Climate change presents physical risk and transition risk, 

including possible sub-systemic shocks, that could negatively 

affect the U.S. financial system and the broader econo

This year, the CFTC’s Climate Risk Unit (CRU) held a public 

meeting to explore the current state of the voluntary carbon 

markets and sought input from the public on a wide range 

of topics regarding climate-related financial risk. After a

thorough review of this feedback, our aim is to collaborate 

with our international counterparts to ensure that our markets 

continue to provide sufficient liquidity, price discovery, and 

transparency for farmers, ranchers, producers, insurers, banks, 

and other financial institutions that use our derivatives 

markets to manage their risk including climate-related 

financial risk. I welcome the opportunity to have candid

discussions on potential courses of action; developing best 

practices; relevant data sources; potential public-private 

forum ideas; and any other topics that would benefit our 

derivatives markets’ oversight

Diversity

The CFTC’s workforce needs to reflect the broader 

constituency and the country at large. Knowing the country

and the markets are changing almost every day, the CFTC 

need to recognize this change and develop a 21st century 

workforce that reflects this change. Earlier this year, I hired

the first-ever Chief Diversity Officer to lead the Office of 

Minority and Women Inclusion (OMWI). This person and

office are providing leadership and executive direction on 

the Commission’s efforts to integrate DEIA into every aspect 

of our talent and business operations. Changes like these

 Commodity Futures Trading Commission 
take time, but I am committed towards implementing a more 

creative approach to source more diverse talent into the CFTC 

workforce through innovative media and marketing strategies 

and building recruitment partnerships with law schools 

and universities, professional associations, and educational 

organizations. For example, OMWI and the Division of

Data are partnering to implement data analytics and a DEIA 

data dashboard to better track, assess, and hold ourselves 

accountable for progress. Further, OMWI is also developing

and implementing our first stand-alone, agency-wide DEIA 

strategic plan, which will be data-driven with clear metrics to 

track progress over time. The plan will encourage a whole-ofagency approach to DEIA to ensure all employees know that

they have a role in creating an inclusive work environment

Agency Financials

The Financial Section in this report includes the results of 

the independent audit of our FY 2022 Financial Statements, 

which I am pleased to report is an unmodified opinion. I can

also report that no CFTC material internal control weaknesses 

exist and that the financial and performance data in this 

report are reliable and complete under Office of Management 

and Budget guidance. Key management assurances and

further details about internal controls are provided in the 

Management’s Discussion and Analysis section

Conclusion

This report provides an overview of the CFTC’s work over 

this past fiscal year. We remain firm and diligent in our

enforcement and customer protection efforts. I thank CFTC

staff and my fellow Commissioners for their hard work and 

dedication to our mission and to the American public

Rostin Behnam 

Chairman

November 15, 2022

Chairman Rostin Behnam

4 Commodity Futures Trading Commissio
Management’s

Discussion and Analysis

Section Page

THE COMMISSION 6

CFTC FISCAL YEAR 2022 HIGHLIGHTS 12

WHAT IS ON THE HORIZON? 18

PERFORMANCE HIGHLIGHTS 25

FINANCIAL HIGHLIGHTS 31

MANAGEMENT ASSURANCES 40
The CFTC is an independent agency of the U.S. government that oversees the U.S. derivatives marke

which include futures, options, and swaps (for a list of abbreviations and acronyms, see page 100)

CFTC was 

established in 

1974 to assume 

regulatory authority 

over commodity 

futures markets 

that had previously 

belonged to the 

U.S. Department of 

Agriculture (USDA) 

since the 1920s.

These markets 

have existed 

since the 1860s, 

beginning with 

agricultural 

commodities 

such as wheat, 

corn, and cotton.

The markets 

grew to include 

energy and metal 

commodities, 

such as crude 

oil, heating oil, 

gasoline, copper, 

gold, and silver.

Over time, financial 

instruments based 

on interest rates, 

stock indexes, 

foreign currency, 

and other products 

far exceeded 

agricultural 

contracts in 

trading volume.

In the aftermath 

of the 2008 

financial crisis, 

the Commission’s 

mandate was 

vastly expanded 

to include most 

over-the-counter 

(OTC) derivatives 

markets.

Why Are Derivatives Important to Me?

The futures and swaps markets are essential to our economy 

and the way that businesses and investors manage risk. The 

CFTC works to ensure that market participants can use markets 

with confidence. These markets also shape the prices we 

pay for food, energy, and a host of other goods and services. 

Please see Why Are the Markets Important to Me on page 94 

for additional information on how futures and swaps work.

To learn more about the regulatory history of the U.S. futures industry—both 

before and after the CFTC was established—please visit the CFTC’s website at: 

https://www.cftc.gov/About/AboutTheCommission

6 Commodity Futures Trading Commissio

The Commission
CFTC Organizational Stru

The Commission consists of five Commissioners, who are 

appointed by the President and confirmed by the Senate to 

serve staggered five-year terms. No more than three sitting

Commissioners may be from the same political party, and with 

the advice and consent of the Senate, the President designates 

one of the Commissioners to serve as Chairman

The Office of the Chairman oversees the Commission’s principal divisions and offices that administer and enforce the 

Commodity Exchange Act (CEA) and the regulations, policies, 

and guidance thereunder. During FY 2022, the Commission

was structured as shown in the organizational chart above 

and described in the sections that follow. The Office of the

Chairman included: The Office of Public Affairs (OPA), the 

Office of Legislative and Intergovernmental Affairs (OLIA), the 

Office of Technology Innovation (OTI), and OMWI

During FY 2022, the four programmatic divisions were the 

Division of Clearing and Risk (DCR), Division of Enforcement 

(DOE), Division of Market Oversight (DMO), and the 

Market Participants Division (MPD). The programmatic

divisions are supported by a number of divisions and offices, 

including the Office of the Chief Economist (OCE), Division 

of Administration (DA), Office of General Counsel (OGC), 

and the Office of International Affairs (OIA). The Office of

the Inspector General (OIG) is an independent office of the 

Commission. A brief summary of each CFTC division and

office as they operated in FY 2022 follows

1

1 More information on the CFTC’s responsibilities, divisions, and offices can be found at https://www.cftc.gov/About/CFTCOrganization/index.htm

FY 2022 Agency Financial Re

 Commodity Futures Trading Commission 

M A N A G E M E N T ’ S D I S C U S S I O N A N D A N A LY S I S
Offies of the Chairman

Commissi

The Office of the Chairman consists of the CFTC’s Chairman 

and Chief Executive and their dedicated staff. Led by the

Chairman, these officials direct the day-to-day management 

of the agency, coordinate Commission business, and shape 

the CFTC’s regulatory and enforcement agenda

Executive Leadership

The CFTC’s Executive Leadership Team consists of the heads 

of each operating division and office, the agency’s Chief of 

Staff/Chief Operating Officer, and the CFTC Chairman in their 

capacity as the agency’s Chief Executive. These individuals are

responsible for carrying out the CFTC’s administrative, regulatory, and enforcement agenda as directed by the Chairman

Divisin of Clearing and R

The DCR oversees derivatives clearing organizations (DCOs) 

and other market participants in the clearing process. These

include futures commission merchants, swap dealers, major 

swap participants, and large traders

Divisin of Enfor

The DOE investigates and prosecutes alleged violations of 

the CEA and Commission regulations. Potential violations

include fraud, manipulation, and other abuses concerning 

commodity derivatives and swaps that harm market integrity, 

market participants, and the general public. Within DOE

is the Whistleblower Office, which administers the CFTC’s 

whistleblower program

Divisin of Market Over

The DMO fosters open, transparent, fair, competitive, and 

secure markets through oversight of derivatives platforms and 

swap data repositories. The DMO reviews new applications

for designated contract markets, swap execution facilities, 

swap data repositories, and foreign boards of trade and 

examines existing trading platforms and swap data 

repositories to ensure their compliance with the applicable 

core principles and other regulatory requirements, including 

system safeguards

FY 2022 Agency Financial Re

8 Commodity Futures Trading Commissio
Market Participants D

The MPD primarily oversees derivatives market intermediaries, including commodity pool operators, commodity 

trading advisors, futures commission merchants, introducing 

brokers, retail foreign exchange dealers, swap dealers, and 

major swap participants, as well as designated self-regulatory 

organizations

Divisin of D

The DOD is responsible for the Commission’s enterprise 

data strategy and data governance approaches. DOD creates

data architecture and centers of excellence for analytics, 

visualization, and storage of data. In addition, DOD supports

the Commission’s strategic objectives with respect to data 

and analytics through collaboration with other Divisions 

and Offices, including ingest of data from registered entities 

pursuant to the CEA and Commission regulations, as well as 

integration of that data with other data sources

Divisin of Adminis

The DA directs the internal management of the Commission’s 

business, personnel, financial, technological, security, 

and strategic operational resources. The Division’s role

is to effectively and efficiently ensure the fulfillment of 

the Commission’s mission through continued success in 

continuity of operations, while providing the required 

resources for regulating the derivatives markets

Offie of the Chief E

The OCE provides economic support and advice to the 

Commission, conducts research on policy issues facing the 

Commission, and educates and trains Commission staff

OCE plays an integral role in the implementation of new 

financial market regulations by providing economic expertise 

and cost-benefit considerations underlying those regulations

Offie of the General Cou

The OGC provides legal services and support to the 

Commission and all of its programs. These services include:

representing the Commission in appellate, bankruptcy, 

and other litigation; assisting in the performance of 

adjudicatory functions; providing legal advice and support for 

Commission programs; drafting and assisting in preparation 

of Commission regulations; interpreting the CEA; advising on 

legislative, regulatory, and operational issues; and managing 

the Commission’s policymaking and enforcement dockets

The OGC also houses the Freedom of Information Act 

(FOIA), Ethics, Secretariat, Privacy, Records, Library, and 

E-discovery programs of the Commission

Offie of Internationa

The OIA advises the Commission regarding international 

regulatory issues and initiatives; represents the Commission 

in international fora such as the International Organization 

of Securities Commissions, OTC Derivatives Working 

Group, and OTC Derivatives Regulators Group; coordinates 

Commission policy as it relates to policies and initiatives 

of major foreign jurisdictions, such as the G20, Financial 

Stability Board, and U.S. Treasury Department; negotiate

cooperative arrangements; and provides technical assistance 

to foreign market authorities, including advice, training, and 

an annual meeting and symposium

Offie of Public 

The OPA is the Commission’s primary public-facing office 

that provides honest, timely and useful information across 

all communication platforms in order to serve internal 

and external stakeholders in all sectors to accomplish and 

facilitate the Commission’s mission. OPA proactively

conducts outreach and creates messages designed to raise 

awareness of the CFTC in order to promote public trust

FY 2022 Agency Financial Re

 Commodity Futures Trading Commission 

M A N A G E M E N T ’ S D I S C U S S I O N A N D A N A LY S I S
Offie of Legisla

Intergovernmental Aff

The OLIA provides support on matters before the U.S. Congres

and serves as the Commission’s official liaison with Members 

of Congress, federal agencies, and the Administration. In this

role, OLIA develops and executes legislative strategy on behalf 

of the Chairman and Commission, manages congressional 

testimony, and works with the various divisions to provide 

technical assistance on legislation

Offie of Mino

Women Inclusion

The OMWI leads the CFTC’s civil rights, equal employment 

opportunity, and diversity, equity, inclusion, and accessibility 

(DEIA) programs, including supporting the Commission’s 

six affinity groups

Offie of Technology Inn

The OTI leads the CFTC’s efforts in incorporating innovation 

and technology into our regulatory oversight and mission 

critical functions by supporting the operating divisions and 

the Commission’s participation in domestic and international 

coordination

Offie of the Inspector

The OIG is an independent organizational unit of the CFTC

Its mission is to detect waste, fraud, and abuse and to promote 

integrity, economy, efficiency, and effectiveness in the CFTC’s 

programs and operations. As such it has the ability to review

all of the Commission’s programs, activities, and records. In

accordance with the Inspector General Act of 1978, the OIG 

issues semiannual reports detailing its activities, findings, 

and recommendations

FY 2022 Agency Financial Re

10 Commodity Futures Trading Commissio
CFTC Staffing and Funding R

The CFTC is funded through the Salary and Expenses (S&E) Appropriation and the Customer Protection Fund (CPF). The S&E

Fund is appropriated annually and provides for the general operating expenses for the Commission to carry out its responsibilities 

under the CEA. The CPF consists entirely of the monetary sanctions the CFTC levies and collects in enforcement actions; no

taxpayer money is included in the Fund. The CPF is a permanent appropriation, but must be apportioned annually by OMB

(See the Appendix for more information on the CPF)

CFTC Industry Over

The Commission is committed to carrying out its mission to promote the integrity, resilience, and vibrancy of the U.S. derivative

markets through sound regulation. For more details on the types and numbers of regulated entities, see pages 97-9

2 In addition to the $284 million annual budget, the CFTC received a one-time, no-year appropriation of $31 million in FY 2020 to cover the move, replication, and related

costs associated with the replacement leases for CFTC regional facilities, resulting in a grand total of $315 million. The $31 million has been omitted from the FY 2020 S&E 

amount in the chart above to provide a more consistent comparison with the appropriations of past fiscal years that did not contain such ma major, one-time investments.

3 In addition to the $320 million annual budget, the CFTC received a one-time, no-year appropriation of $62 million in FY 2022 to cover the move, replication, and related 

costs associated with the replacement leases for CFTC headquarter facility, resulting in a grand total of $382 million. The $62 million has been omitted from the FY 2022 

S&E amount in the chart above to provide a more consistent comparison with the appropriations of past fiscal years that did not contain such major one-time investments.

4 Passed in July 2021, Public Law 117-25 provided the CFTC with one-time authority to set aside $10 million from the primary CPF Fund into a separate, multi-year 

account to fund non-whistleblower costs (e.g., payroll, contracts, etc.) whenever the unobligated balance of the Fund is insufficient. The Commission used existing 

budgetary resources to establish the $10 million account in September 2021 and these resources are available until December 16, 2022 at which time all unobligated 

amounts will be returned to the primary Fund.

5 Per the Dodd-Frank Act, whenever the fund balance falls below $100 million, qualified transfers within that fiscal year are allowed. In FY 2022, the Customer Protection 

Fund received a transfer of $398 million from CFTC’s Civil Monetary Penalties, Fines and Administrative Fees receipt account which covered the payment of significantly 

large whistleblower awards. Prior to this, the most recent transfer into the fund was in FY 2014.

6 The FTE for Salaries and Expenses was adjusted from 677 FTE to 673 FTE for FY 2021 to reflect actuals.

FY 2022 Agency Financial Re

 Commodity Futures Trading Commission 1

M A N A G E M E N T ’ S D I S C U S S I O N A N D A N A LY S I S
Issued 3 Final Rulemakings, including:

■ Adopted Part 12 final rule: Changing Position Title of 

Judgment Officer to Administrative Judge

● The Commission adopted technical amendments to 

its Rules Relating to Reparations to change the position title of the Judgment Officer to Administrative 

Judge and to incorporate gender neutral language, 

where applicable

■ Adopted Part 143 final rule: Annual Adjustment of 

Civil Monetary Penalties to Reflect Inflation – 2022

● The Commission amended Rule 143.8, its rule that

governs the maximum amount of civil monetary 

penalties (CMPs) imposed under the CEA. The

CFTC Fiscal Year 2022 Highli

amended rule sets forth the maximum, inflationadjusted dollar amount for CMPs assessable for 

violations of the CEA and Commission rules, 

regulations and orders thereunder. The rule, as

amended, implements the Federal Civil Penalties 

Inflation Adjustment Act of 1990, as amended

■ Adopted Part 50 final rule: Clearing Requirement 

Determination Under Section 2(h) of the CEA for 

Interest Rate Swaps to Account for the Transition from 

LIBOR and Other IBORs to Alternative Reference Rates

● The Commission modified its existing interest 

rate swap clearing requirement regulations under 

applicable provisions of the CEA due to the global 

transition from reliance on certain interbank offered 

From left, DCR Director Clark Hutchison, Chairman Behnam, and Commissioner Johnson 

at the May 2022 Round Table on Disintermediation.

12 Commodity Futures Trading Commissio
rates (IBORs) (e.g., the London Interbank Offered Rat

(LIBOR)) that have been, or will be, discontinued as 

benchmark reference rates to alternative reference rates, 

which are predominantly overnight, nearly risk-free 

reference rates (RFRs). The amendments update the set

of interest rate swaps that are required to be submitted 

for clearing pursuant to the CEA and the Commission’s 

regulations to a DCO that is registered under the CEA 

(registered DCO) or a DCO that has been exempted 

from registration under the CEA (exempt DCO) to 

reflect the market shift away from swaps that reference 

IBORs to swaps that reference RFRs

Effective Enforcement 

■ The CFTC completed FY 2022 with 82 filings, including 

18 related to digital assets. Using settlements and

litigation, the Commission obtained orders imposing 

over $2.5 billion in restitution, disgorgement and civil

monetary penalties. Digital asset actions included

manipulation, a $1.7 billion fraudulent scheme, and a

decentralized autonomous organization (DAO) failing 

to register as a SEF or FCM or to seek DCM designation

Learn about the CFTC’s FY 2022 enforcement results at 

https://www.cftc.gov/PressRoom/PressReleases/8613-22

■ The Commission settled charges against Blockratize, 

Inc. d/b/a Polymarket, which operated an illegal facility

for event-based binary options online trading contracts, 

known as “event markets.” Despite failing to obtain DCM

designation or register as a SEF, Polymarket deployed 

and executed smart contracts hosted on a blockchain 

for the event-based binary option markets offered on its 

website. Such event market contracts constitute swaps

and are under the CFTC’s jurisdiction; they can only be 

offered on a CFTC-registered exchange

■ As part of the CFTC’s broader efforts to protect U.

customers in a rapidly evolving decentralized finance 

environment, the Commission settled charges against 

bZeroX, LLC (bZeroX) and its founders. Using a

decentralized blockchain-based software protocol that 

functioned similarly to a trading platform, bZeroX illegally 

offered retail commodity transactions in digital assets

Only registered FCMs can perform such transactions

The CFTC also filed a federal civil enforcement action, 

charging the Ooki DAO—a decentralized autonomous 

organization and successor to bZeroX that operated the 

same software protocol as bZeroX—with violating the 

same laws as the respondents

■ In the largest settlement in CFTC history, the Commission 

resolved charges against Glencore International A.

and its partners. Glencore is one of the world’s largest

commodity trading firms and a major participant in the 

global oil markets. Individuals at all levels within the

oil trading group, including senior leadership, engaged 

in long-standing, deceptive and corrupt conduct to 

undermine the pricing mechanism on which trillions 

of dollars of financial derivatives contracts are based. The

CFTC ordered the firm to pay a total of $1.186 billion,

which consists of the highest civil monetary penalty 

($865,630,784) and highest disgorgement amount 

($320,715,066) in any CFTC case

■ The CFTC filed and settled charges that the swap dealer 

and futures commission merchant (FCM) affiliates of 

12 financial institutions committed recordkeeping and 

supervision violations and imposed a total of $796 million 

in civil monetary penalties. Specifically, the 12 orders find

that the swap dealer and/or FCM in question, for a period of 

years, failed to stop its employees, including those at senior 

levels, from communicating both internally and externally 

using unapproved communication methods, including 

messages sent via personal text, WhatsApp or Signal

■ The CFTC brought several enforcement actions against 

Registered Entities, including simultaneously filing 

and settling charges against: ICE Clear Europe Limited 

for violating regulations requiring DCOs to obtain 

written acknowledgment letters from a depository; and 

CX Futures Exchange, L.P., a designated contract market

for violating the CEA and regulations relating to system 

safeguards, swap reporting, option reporting, and a giving 

a false statement to the CFTC

FY 2022 Agency Financial Re

 Commodity Futures Trading Commission 1

M A N A G E M E N T ’ S D I S C U S S I O N A N D A N A LY S I S
Improvements to Commission Data 

and Analytic Capacity

■ The Commission’s substantial progress moving data and 

applications to the cloud is vastly improving its data 

analytics capacity. Cloud migration will increase the

agency’s artificial intelligence (AI), machine learning (ML), 

and natural language processing (NLP) capabilities

These capabilities allow the CFTC to convert financial 

data received in unstructured PDF files or via fax into 

structured data suitable for analysis.

■ The CFTC published limited modifications to the 

instructions for swap data reporting and public dissemination requirements under Parts 43 and 45 of the 

CFTC’s regulations. Through these modifications the

Commission: 

● Clarifies market participants’ compliance obligations, 

● Aligns U.S. reporting requirements with internationa

standards, and

● Enables market participants to build compliant 

systems

Addressing Diversity and Inclusion

■ In January, 2022, Chairman Behnam appointed the 

CFTC’s first Chief Diversity Officer, who is leading 

OMWI. The Chief Diversity Officer’s role is to provide

leadership and executive direction to the Commission’s 

efforts integrating DEIA into every aspect of our talent 

and business operations.

■ OMWI is collaborating with the Commission’s Human 

Resources leadership to implement a more creative 

approach to source more diverse talent into the CFTC 

workforce through innovative media and marketing strategies, as well as building recruitment partnerships with 

law schools and universities, professional associations, 

and educational organizations

■ OMWI is also developing and implementing our first 

stand-alone, agency-wide DEIA strategic plan. The

plan will be data-driven and will have clear metrics 

to track progress over time. The plan will encourage a

whole-of-agency approach to DEIA—we are ensuring that 

all CFTC employees know that everyone has a role to play 

in creating an inclusive work environment

Addressing Systemic Risk in the Clearing Process

■ The Commission proposed regulatory amendments to 

enhance DCO governance standards. The proposed

regulations are consistent with recommendations 

from the Market Risk Advisory Committee’s Central 

Counterparty Risk and Governance Subcommittee, and 

require a DCO to establish one or more risk management 

committees (RMCs) and one or more risk advisory 

working groups (RWGs). The proposed regulations also

prescribe standards related to the composition, activities, 

and policies and procedures of RMCs and RWGs

■ In anticipation of a potential Russian invasion of Ukraine 

and the possibility of related sanctions, the Commission 

collaborated with relevant authorities to manage and 

address exposures to affected market participants. The

invasion and subsequent ongoing tragedy in Ukraine 

sparked extreme volatility. By and large, the U.S. futur

markets have remained orderly through periods of high 

prices and extreme volatility. Despite episodic spikes in

trading volume by as much as two times normal levels, 

markets have been able to clear the volumes without 

significant market disruption

FY 2022 Agency Financial Re

14 Commodity Futures Trading Commissio
Registrant and Intermediary Oversight

■ This summer, the Commission issued a proposed Swap 

Dealer Capital Comparability Determination for Japan, 

the first such proposed order since adopting final capital 

and financial reporting requirements for swap dealers 

in 2020. The CFTC’s principles-based approach to the

proposed determination focuses on whether Japan’s capital 

and financial reporting requirements for swap dealers 

achieve comparable outcomes to the corresponding CFTC 

requirements. If adopted, the comparability determination

order would be neither a compromise nor deference to a 

foreign regulatory authority; the Commission would retain 

enforcement and examinations authority and obtain all 

financial and event-specific reporting

Collaboration and Coordination

■ The CFTC and SEC issued a joint proposal to enhance 

private fund reporting requirements that will improve the 

Financial Stability Oversight Council’s (FSOC) ability to 

assess systemic risk as well as to bolster the oversight of 

private fund advisers

From front to back, Commissioner Goldsmith Romero, Commissioner Johnson, and 

Chairman Behnam at the May 2022 Round Table on Disintermediation.

■ The Inter-Agency Working Group on Treasury Market 

Surveillance, comprised of the CFTC and other US financial 

regulatory agencies, issued a staff report evaluating recent 

disruptions and identifying potential reforms in the U.

Treasury market

■ The CFTC launched the cross-divisional Digital 

Commodity Working Group (DCWG), to:

● Address requirements from President Biden’s Executive 

Order on Ensuring Responsible Development of 

Digital Assets,

● Provide expert technical assistance to members of 

Congress and their staff in drafting legislation, and

● Provide participants to FSOC Digital Asset Working 

Group

■ In its international engagement, OIA worked to foster 

collaboration between the IOSCO and the Financial 

Stability Board, including on topics concerning derivatives 

margin, trade repository data, crypto-currencies, and 

nonbank finance

FY 2022 Agency Financial Re

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M A N A G E M E N T ’ S D I S C U S S I O N A N D A N A LY S I S
■ OMWI partnered with DOD to apply data analytics and 

to create a DEIA data dashboard. These vital tools will

allow the CFTC to better track, assess, and hold ourselves 

accountable for progress integrate DEIA into every aspect 

of our talent and business operations

Improving Market Oversight

■ The Commission modernized and enhanced the widely 

popular Commitments of Traders (COT) reports. COT

reports’ data are used by traders, researchers and news 

organizations to report and analyze market trends in 

dozens of commodities. New features leverage technology

to increase data access, transparency and usability

Economic Research

■ The Commission’s OCE conducted, published, and 

presented valuable research to help identify and refine 

who is in the CFTC’s market, especially relating to 

those participating in novel contract types. Some of the

research was co-authored with prominent academics, 

Commissioner Pham at the May 2022 Round Table on Disintermediation.

while one research project was result of a successful 

collaboration between the CFTC and the U.S. Departmen

of Agriculture’s Economic Research Service

■ Conducted research of traders active in digital asset 

futures contracts, specifically Bitcoin futures (BTC) 

contracts, traded on the CME. This research identified two

primary trader types, concentrated traders who held BTC 

almost exclusively, and diversified traders. The analysis

found that diversified BTC traders tend to hold concurrent 

positions in energy, precious metal and equity index 

futures as well as other cryptocurrency futures when 

they are available

■ Participated and presented research at conferences, 

including research on the impact of uncleared margin 

rules on volunteer clearing decisions, the impact of 

liquidity on futures markets’ market makers, the attributes 

of participants in the markets CFTC regulates, including 

farmers and the use of agricultural swaps, and the 

attributes of participants in markets emphasizing novel 

contract types – specifically bitcoin futures

FY 2022 Agency Financial Re

16 Commodity Futures Trading Commissio
Improving Operational and IT Effectiveness

■ While the Commission has vast internal institutional 

knowledge, there are pockets where staff, and their 

knowledge and expertise are one or two individuals deep

This reality, coupled with the rapidly evolving nature 

of the markets we oversee and the accompanying need 

for our skills to rapidly expand and deepen, requires 

extensive succession planning. To be strategic and useful,

our FCTC-wide succession plan will identify where our 

agency will be 3, 5, 10, 20 years from now and create a 

path forward to ensure that institutional knowledge is 

shared, expanded, and retained, that mentoring is part of 

everyone’s work experience, that we build redundancies 

and mitigate key man risk, and that we hire intentionally, 

seeking to not simply backfill positions, but to use the 

opportunity to build the bench.

■ Two of CFTC’s three regional offices – the Chicago and 

New York Regional Offices – relocated in FY 2022. The

third regional office, in Kansas City, relocated in FY 2021

● These regional office relocations resulted in a greater 

than 65,000 square feet savings in office space, with 

the FY 2022 relocations accounting for nearly 94% 

of the regional office space savings.

● These regional office relocations will result in annual 

rent savings of over $4.2 million, with the FY 2022

relocations accounting for 97.5% of the regional

office annual rent cost savings

■ The Commission has nearly completed an 18-month 

journey – a major technical upgrade to “lift and shift” – 

its data, IT infrastructure, and applications to the cloud

The cloud migration is positioning the agency to vastly 

improve operations, processes, data analytics, policy 

implementation, and regulatory oversight

Innovation and Fintech

■ During 2022, the former LabCFTC matured to the Office of 

Technical Innovation (OTI). OTI incorporates innovation

and technology into the Commission’s regulatory 

oversight mission, supporting staff with resources, 

education, opportunities, and a pipeline to collaborate 

internally and externally, domestically and abroad.

■ OTI regularly advocates for the advancement of responsible 

innovation, industry collaborations, public outreach and 

education. OTI serves as the CFTC’s financial technology

innovation hub, driving change and enhancing knowledge 

through innovation, consulting/collaboration, and 

education

● Innovation is central, as the Commission enhances 

practices through crypto data sets and tools, benefits 

of the cloud, big data, analytics, AI, etc

● As consultants and collaborators, we serve as an 

internal resource of technology innovation expertise 

and we make internal external connections with 

valuable partners including the Financial Instruments 

Working Group, FSOC, and the Global Financial 

Innovation Network

● As educators we look for opportunities to share 

knowledge and provide training through the CFTC’s 

Commission Learning Circles, Lunch and Learns, 

Financial Literacy and Education Commission 

(FLEC), the Empower Innovate Conference, primers, 

and speeches

FY 2022 Agency Financial Re

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M A N A G E M E N T ’ S D I S C U S S I O N A N D A N A LY S I S
The CFTC’s mission is to promote the integrity, resilience, 

and vibrancy of the U.S. derivatives markets through 

sound regulation. As derivatives markets continue to evolve, the

CFTC remains committed to embodying the global standard 

for sound derivatives regulation by ensuring that the derivatives 

markets are responsive to emerging risks, technologies, trends, 

and issues through supporting legislation, promulgating rules, 

issuing guidance, and establishing policies that promote 

innovation while protecting market participants and users, 

as well as the economy at large. The Commission holds itself

accountable for working with market participants domestically 

and abroad to ensure the U.S. derivatives markets are efficient

competitive, and free from fraud, manipulation, and other 

disruptive or abusive practices

The Commission’s work furthers strategic goals outlined in 

the CFTC 2022-2026 Strategic Plan. These goals support the

CFTC’s mission by focusing talent and resources towards 

improving the strength, integrity and resiliency of the U.

derivatives markets to the benefit of all Americans while 

encouraging growth and innovation domestically and abroad

The goals also prioritize ensuring compliance with the CEA 

and Commission regulations through clear, equitable, and 

transparent rules and guidance, targeted surveillance, and 

operating an enforcement program that roots out fraud, 

manipulation, and market abuse, sending a strong, clear 

message to bad actors that misconduct will not be tolerated

Focusing on our unique mission and proficiency, the CFTC 

continuously improves upon its collection, use, analysis, and 

protection of data and seeks to maximize performance and 

efficiency through promoting a workforce comprised of the 

best and brightest and regularly cooperating and collaborating 

with fellow regulators, self-regulatory organizations (SROs), 

trade groups, and other stakeholders.

Broadly, in the face of ever-evolving changes to its markets 

resulting from, among other things, technological innovations 

and external events, the CFTC will continue to ensure the U.

derivatives markets remain sound through strong oversight 

of the registrants, products, and market participants within 

the CFTC’s jurisdiction and commitment to remaining 

nimble and vigilant in identifying and addressing risks and 

uncertainties that may undermine its abilities to achieve its 

mission and long term goals

Strategic Goal 1 – Strengthen the Resilience 

and Integrity of our Derivatives Markets While 

Fostering Their Vibrancy

The CFTC registers and oversees different types of entities that 

are the foundation of the U.S. derivatives market.  Amo

others, these entities range from central counterparties (CCPs) 

and exchanges to the intermediaries through which market 

participants access the markets. The CFTC will continue

to strengthen the resilience and integrity of the derivatives 

markets while fostering their vibrancy in both broad and 

more-targeted ways

For instance, the CFTC focuses on promoting the strength 

and resilience of Commission-registered CCPs (known as 

DCOs) through regular examinations, stress testing, capital 

requirements, financial reporting obligations, and ongoing 

risk monitoring. CCPs provide crucial risk management

services and reduce counterparty risk. Increased internal

CFTC capabilities will provide for sounder derivatives 

regulation. A failure or disruption to the functioning of a

CCP could create or increase the risk of liquidity or credit 

problems that could be spread at a systemic level to other 

financial institutions.

What is on the Horizon

18 Commodity Futures Trading Commissio
organizations, other U.S. regulators, and existing intermediarie

to ensure that all capital and financial reporting requirements 

remain balanced and appropriate given natural developments 

in the derivatives marketplace

Safeguarding the stability of the U.S. and global financia

system requires ongoing international coordination and 

collaboration in a way that neither compromises the 

Commission’s capital and financial reporting requirements nor 

defers to foreign regulatory authority. In 2020 the Commission

adopted a regulatory substituted compliance framework for 

non-U.S. domiciled nonbank swap dealers (SDs.  Substitut

compliance allows, after application and approval, these SDs 

to satisfy certain CEA and CFTC regulatory requirements 

through a Capital Comparability Determination to establish 

that the non-U.S. jurisdiction has comparable financia

reporting requirements. Once a determination is made,

the Commission still retains examination and enforcement 

authority, as well as all financial and event specific reporting – 

which has been determined as comparable – so that the 

CFTC can maintain direct oversight of nonbank SDs located 

throughout the world. To date, the Commission has proposed

swap dealer comparability determinations for capital 

requirements established by Japan and Mexico and is in the 

process of reviewing requests for comparability determinations 

for the applicable swap dealer capital requirements in the 

It is essential that DCOs’ governance arrangements and fitness 

standards evolve to match the pace and complexity of the 

evolution of DCOs’ risk landscape, which includes novel clearing 

structures, new product innovation, and emerging risks, such as 

climate change. Robust DCO risk management is particularly

critical because of the systemic nature of clearinghouses and the 

integral role that DCOs have in promoting financial stability

Near-term actions that will aid in strengthening clearing include 

finalizing the DCO governance rule on risk management and 

resilience, revising the regulatory frameworks for clearing 

organizations (part 39) and for registered entities (part 40), 

and codification of guidance and no action letters.

Also essential to the stability of the derivatives markets are 

financial requirements for registered market participants

The Commission has now fully adopted robust capital and 

financial reporting requirements for swap dealers and futures 

commission merchants, critical market intermediaries in the 

derivatives marketplace. These comprehensive financial

requirements give the Commission and self-regulatory 

organizations the ability to monitor swap dealers and futures 

commission merchants to ensure that they not only hold 

required capital amounts, but retain the financial resources 

to support their dealing activities with existing counterparties 

and brokerage activities for their customers respectively. The

Commission also continues to work with self-regulatory 

FY 2022 Agency Financial Re

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M A N A G E M E N T ’ S D I S C U S S I O N A N D A N A LY S I S
United Kingdom and the European Union. As the future

unfolds, the CFTC will continue to partner with international 

counterparts to identify and address the potential impacts of 

developments associated with emerging issues

CFTC rules requiring margin for uncleared swaps, and similar 

rules around the world, are a foundation of derivatives market 

integrity. By ensuring that collateral is available to offset

counterparty losses, margin requirements provide confidence 

in times of market stress and volatility. Requirements to post

margin discourage firms from taking on excessive risk and 

provide collateral to cover counterparty risk. As such, margin

requirements are a necessary back-stop, protecting customers, 

bolstering the safety and soundness of SDs and major swap 

participants (MSPs), and safeguarding the integrity of the 

financial system.

Having these crucial rules in place does not, by itself, 

guarantee financial system integrity. Continued efficient

and stable functioning of derivatives markets requires sound 

implementation of and faithful adherence to margin and 

capital requirements. The Commission will continue to

collaborate with registered SDs and the National Futures 

Association (NFA) to promote compliance with these 

requirements. In addition to establishing and effectively

implementing margin and capital requirements domestically, 

the Commission will team with international counterparts to 

analyze the impact of various margin practices in centrally and 

non-centrally cleared markets and to both participate in and 

sometimes lead standard-setting bodies to advance strong, 

effective, and practicable margin and capital requirements

Strategic Goal 2 – Regulate our Derivatives 

Markets to Promote the Interests of All Americans

CFTC ensures that derivatives markets work in the best 

interest of all Americans, supporting a market-based system 

for price discovery and risk management. The U.S. derivativ

markets continue to serve the needs of everyday Americans 

and touch all corners of the real economy – from farmers 

and ranchers who need to hedge grain and cattle prices, to 

manufacturers and exporters who need to manage other 

market risks. The U.S. derivatives markets are always rapid

evolving, whether driven by technological innovations or 

in response to emerging areas of regulatory awareness like 

environmental, social, and governance issues

The Commission’s origins in the agricultural markets are 

manifest in a strong and longstanding commitment to the 

agricultural community and its stakeholders to ensure the 

integrity of agricultural derivatives markets, and to understand 

and address issues that have the potential to negatively impact 

these markets. Agricultural derivative products’ hedging utility

is especially critical as America’s farmers and ranchers face 

adverse impacts in their daily operations due to the uncertainty 

caused by the global pandemic and geopolitical events.

The Commission works to ensure that regulated persons 

provide retail persons the information they need to make 

educated decisions regarding their use of derivatives. For

example, The CFTC, in conjunction with the NFA and 

other SROs, devotes significant attention to overseeing 

the preparation and dissemination of detailed disclosure 

documents and financial reporting regarding investments 

in commodity pools. Equal effort is given to similar

communications by commodity trading advisors regarding 

offered trading programs and registered foreign exchange 

dealers and futures commission merchants regarding Foreign 

Exchange (FX) and futures accounts, respectively.

Additionally, the Office of Customer Education and Outreach 

(OCEO) will continue to play an important role in helping 

customers fight against fraud and other violations of the 

CEA. Employing sophisticated multimedia strategies, OCEO

approaches customers where they are to educate them about 

derivatives markets and their associated risks. Proactively

engaging customers through a combination of social 

and traditional media enhances our impact by delivering 

information directly into their newsfeeds instead of relying 

on customers seeking this information. The OCEO also uses

interactive programing to educate customers through two-way 

discussions of risk management and fraud prevention.

The Commission is developing policy to address FCM, SD, 

and MSP system safeguards, further fortifying CFTC markets 

against cyber-attacks and strengthening their resilience 

when attacks succeed. Once enacted, these policies would

complement the suite of system safeguards currently in place 

for CFTC registered DCOs, DCMs, SEFs, and SDRs. The

CEA and CFTC’s system safeguards regulations require these 

entities to have appropriate system safeguards, controls, and 

testing to address all types of cybersecurity and operational 

FY 2022 Agency Financial Re

20 Commodity Futures Trading Commissio
risk to the reliability, security, and capacity of their automated 

systems and the confidentiality, integrity, and availability of 

their data. They must also maintain and test appropriate

business continuity and disaster recovery plans and resources

Accompanying these policies will be rulemakings that 

address SD and FCM risk management, the use of thirdparty service providers, enhanced intermediary reporting 

requirements and cross-border matters aimed at mitigating 

duplicative requirements. Additional rulemakings will focus

on protection of customer funds, with a retail focus, especially 

digital engagement practices

The CFTC is uniquely poised as the regulator at the forefront of 

climate-related risk management, as firms and individuals will 

increasingly turn to the derivatives markets to mitigate climate 

change-induced physical and transition risk and seek price 

discovery for new and evolving risk management products

In March 2021, then Acting Chairman Behnam created 

the Climate Risk Unit (CRU) within the CFTC to leverage 

the agency’s resources and expertise to better understand 

the role of derivatives in pricing and mitigating climaterelated risk, and support the orderly transition to a net zero 

economy through market-based initiatives. In June 2022, the

CFTC published a Request for Information on all aspects of 

climate-related financial risk, including scenario testing and 

risk management, as this risk may pertain to the derivatives 

markets, underlying commodities markets, and related market 

participants. The Commission may use this information

to issue new or amend existing guidance, interpretations, 

policy statements, and regulations, or take other potential 

Commission action. The Commission’s focus is to ensure

that market participants are equipped to manage their risks 

from increasingly severe and frequent weather events as well 

as the transition to a net-zero, low-carbon economy.

Strategic Goal 3 – Encourage Innovation and 

Enhance the Regulatory Experience for Market 

Participants at Home and Abroad

Technological innovation is drastically changing financial 

markets, including the derivatives markets the CFTC regulates

The growing adoption of derivatives involving digital assets 

and the use of distributed ledgers and other technologies 

present novel issues for applying and enforcing the CFTC’s 

regulations.

The accelerated engagement with FinTech through LabCFTC 

fulfilled its mission as set forth by former Chairman Giancarlo, 

and the clear intersection between financial innovation 

and our markets required an updated strategy. Therefore,

CFTC created the Office of Technology Innovation (OTI), 

the successor to LabCFTC. OTI provides a crucial channel

to inform the Commission’s understanding of emerging 

technologies. It operates as a focal point for the development

May 2022 Round Table on Disintermediation.

FY 2022 Agency Financial Re

 Commodity Futures Trading Commission 2

M A N A G E M E N T ’ S D I S C U S S I O N A N D A N A LY S I S
and implementation of regulatory policy within the FinTech 

space. As such, OTI incorporates innovation and technology

into the Commission’s regulatory oversight mission, 

supporting staff with resources, education, opportunities, 

and a pipeline to collaborate internally and externally, 

domestically and abroad. As the CFTC’s financial technology

innovation hub, OTI drives change and enhances knowledge 

through innovation, consulting/collaboration, and education

OTI will help drive innovation within CFTC by introducing 

advanced analytic tools and data sets, providing consulting 

services within CFTC, collaborating with other state, federal, 

and international regulatory bodies, and providing education 

on advances in financial innovation, particularly in the 

crypto sphere

One area of continual innovation is the emergence of digital 

assets. Clearing of these types of instruments is an important

business trend where principles need to be formally defined, 

addressed, and made public. Similarly, the rise of decentralized finance, or DeFi, is an emerging issue  Decentralize

finance is characterized by the use of computer protocol in 

peer-to-peer issuance, exchange, and settlement, as compared 

to the historical intermediation by regulated entities.

The CFTC facilitates customer protections through its 

principles-based market oversight and disclosure regime 

aimed at ensuring transparency, integrity, and security of 

transactions. These structures inform customers about

who they are dealing with and provide clarity on the risks 

of participating in our markets. Critically, all regulated

derivatives and futures platforms must maintain adequate 

financial, operational, and managerial resources, segregate 

customer funds, and comply with Commission requirements 

for the treatment of customer assets. These tools have proven

effective in preserving customer funds and market operations 

in times of instability, uncertainty, or market misconduct

However, digital asset commodity cash markets, which have 

significant speculative retail participation, often use high 

levels of leverage, and rely heavily on platform-based custody 

arrangements outside of the traditional regulated banking 

sector and outside the CFTC’s jurisdiction, as well. Although

many participants in these markets perceive themselves to 

be interacting with exchanges and intermediaries structured 

and regulated like those in other financial markets, the reality 

is quite different. The lack of a comprehensive regulatory

regime means that traditional market-based disclosures 

and bankruptcy protections are frequently absent, and such 

arrangements increase the likelihood of disruptions involving 

conflicts of interest, data reporting, and cybersecurity breaches 

resulting in unprotected customer losses

Although less public, the CFTC’s efforts related to digital 

assets have evolved with the market, and we are now engaged 

in a more proactive and comprehensive effort across the 

agency to prosecute fraud in these markets with the tools 

currently available to us. Also, many digital asset-related

companies now operate CFTC-registered exchanges, and 

CFTC’s DMO is regularly reviewing new products tied to 

digital assets both from these new entrants and from more 

traditional registrants

Strategic Goal 4 – Be Tough 

on Those Who Break the Rules 

The CFTC remains vigilant against those who violate the CEA 

or CFTC regulations. The Commission’s strong enforcement

program emphasizes being tough on those who break the 

rules, while being fair and consistent. Pursuing those that

break the law is critical to market participants who depend 

FY 2022 Agency Financial Re

22 Commodity Futures Trading Commissio
on the futures and swaps marketplace, and more broadly, a 

tough enforcement program is vital to maintaining public 

confidence in financial markets. The Commission uses its

authority to deter fraudulent and manipulative conduct 

and to ensure that markets, firms, and participants subject 

to the Commission’s oversight meet their obligations

To achieve this end, the Commission uses its authority to 

pursue enforcement actions to protect the public interest 

against fraud and manipulation. This authority extends to

any commodity in interstate commerce, as well as futures 

and options contracts and other derivatives, including swaps

The Commission’s exercise of its enforcement authorities to 

address misconduct has a direct impact on CFTC jurisdictional 

markets, affects the larger economy, reduces public harm, 

and bolsters market integrity. Our enforcement program’s

effectiveness in holding individuals and institutions 

accountable promotes confidence in U.S. derivatives markets

which continue to be the premier mechanism for global price 

discovery and risk management

Further, while the CFTC does not have direct statutory 

authority to regulate cash markets, the CFTC maintains antifraud, false reporting, and anti-manipulation enforcement 

authority over commodity cash markets in interstate 

commerce. When the CFTC becomes aware of potential fraud

or manipulation in an underlying market, we investigate and 

address misconduct through our enforcement authority. In

particular, since 2014, the CFTC has aggressively exercised 

this enforcement authority in the digital asset space

To the extent that market integrity preservation and protecting 

the public relies on deterrence, there is a strong case for 

ensuring that every matter we file, and public action we 

take, brings about greater compliance and makes the 

next violation less likely to occur. This makes a market

regulator’s success a function of not only authority, but also 

professionalism, dedication, and commitment of its staff in 

honing their investigative and analytical craft, developing 

leads and forming relationships that bring conduct—good 

and bad—to the surface, expanding cooperative efforts, and 

providing more clarity and transparency to markets and 

market participants

The Commission maintains a robust market surveillance 

program that uses sophisticated systems to analyze trade data 

and respond to outlying events. This technology assists in

identifying trading patterns or positions that warrant further 

investigative inquiry. The Commission also maximizes the

effectiveness and reach of its enforcement program through 

cooperative enforcement work with domestic, state, Federal, 

and international regulatory and criminal authorities.

The CFTC’s whistleblower program is vital to the 

Commission’s enforcement efforts. The program pays awards

to eligible whistleblowers and protects their confidentiality, 

as required by the CEA. The Dodd-Frank Act established the

whistleblower program and set up the Customer Protection 

Fund to pay awards to whistleblowers and to fund customer 

education initiatives.

Strategic Goal 5 – Focus on our Unique Mission 

and Improve our Operational Effectiveness

Operational effectiveness is fundamental to carrying out the 

CFTC’s critical mission. The Commission makes effective

operations a priority, and pursues it by leveraging technology, 

enhancing agency stewardship of taxpayer dollars, and actively 

managing the organization to address mission challenges

Our dedicated workforce continues to rise to any challenge 

through thoughtful communication strategies, continual 

workforce engagement, and innovative technology solutions

In its ongoing effort to attract, retain, and promote a diverse 

workforce of the best and brightest individuals, the CFTC has 

expanded its OMWI to include the Commission’s first Chief 

Diversity Officer. A Commission priority is to eliminate the

gap between our DEIA ideals and our DEIA actions. The CFTC

Chief Diversity Officer is providing leadership and executive 

direction on this priority and also on the Commission’s 

efforts to integrate DEIA into every aspect of our talent 

and business operations. This type of change takes time,

and OMWI is working with Commission human resources 

leadership to implement a creative approach to source more 

diverse talent into the CFTC workforce using innovative 

media and marketing strategies and building recruitment 

partnerships with law schools, universities, professional 

associations, and other educational organizations.

FY 2022 Agency Financial Re

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M A N A G E M E N T ’ S D I S C U S S I O N A N D A N A LY S I S
OMWI and DOD are partnering to implement data analytics 

and a DEIA data dashboard, which will encompass a series 

of key DEIA metrics that will foster a strategic approach to 

meeting DEIA goals and to ensure that the Commission 

recruits and retains the best and brightest regardless of 

background. OMWI is also developing and implementing

the first agency-wide DEIA strategic plan to encourage a global 

approach to DEIA – ensuring that all CFTC employees know 

their role to create an inclusive work environment.

The CFTC’s Information Security Program mitigates risks 

and enhances the information security posture in a world of 

rapidly expanding threats and evolving complex regulations

The Commission is actively engaged in protecting confidential 

trading and clearing data held by the CFTC and the entities 

we regulate. In accordance with Executive Order 14028,

Improving the Nation’s Cyber Security, the CFTC continues 

to modernize and address security vulnerabilities in the 

Commission’s IT infrastructure. CFTC is planning on

implementing three programs to support the cybersecurity 

focus areas outlined in the executive order: 

■ Zero Trust Architecture to provide network-level protections against attackers pivoting from a compromised 

system

■ Data Protection Program to establish data loss prevention 

technologies and processes to manage access to sensitive 

data to ensure it is tightly controlled and monitored

■ Endpoint Detection & Response capability to improve 

protections at the endpoints, the most likely entry point 

for a breach attempt

In addition, the Commission will continue to improve the 

Federal Information Security Management Act (FISMA) and 

related OMB security mandates and ensuring the protection 

of sensitive market participant data

The CFTC Enterprise Risk Management (ERM) program is a 

top agency priority that continues to strengthen its practices

We are building a robust risk management structure by 

expanding and embedding into Commission practices an 

ERM framework. Required by OMB Circular A-123, ERM

provides an enterprise-wide, strategically-aligned view of 

organization risks that promotes improved planning and 

decision-making through a structured understanding of 

opportunities and threats. Effective ERM also helps the CFTC

implement strategies to ensure effective use of resources, 

enable an optimized approach to identifying and remediating 

compliance issues, and provide reliable reporting and 

monitoring across business units

The Commission is applying emerging technologies to 

oversee the increasingly diverse and challenging markets 

we regulate. Our success migrating our high performance,

on-premises datasets into a cloud-based data repository and 

redeveloping analytics applications to take advantage of the 

cloud’s elasticity will improve computing efficiency and 

economy. We will leverage the Commission’s cloud-based

data storage and analytics to gain detailed visibility into 

what is really going on in financial markets. These analytic

insights make the Commission a more effective, efficient and 

resilient agent of transparency and integrity.

The Commission is transforming the agency’s analytics toolkit 

to leverage the cloud architecture with advancements in 

artificial intelligence (AI), machine learning (ML), natural 

language processing (NLP) to improve data analytics. At the

core of these efforts is the need for accurate, efficient, and 

consistent data reporting. Using NLP will allow us to

convert regulatory reports that come in different formats 

into structured data for critical analysis. The data pattern

recognition capabilities ML allows us to perform will enhance 

Commission enforcement through identifying spoofing and 

other types of market manipulation in ways that were not 

previously possible. Through cloud data repositories the

Commission can expand or contract our usage based on 

need, allowing us to more efficiently allocate funding and 

other resources

The CFTC must take full advantage of its incredible 

institutional knowledge. The Commission has deep expertise,

skills, and knowledge in a variety of mission-necessary 

disciplines. However, in many of these areas, we do not

have a “deep bench.” Additionally, our skills must move

in lock step with quickly evolving markets. A detailed and

strategic succession planning program will create a path 

forward to ensure that institutional knowledge is shared, 

expanded, and retained

FY 2022 Agency Financial Re

24 Commodity Futures Trading Commissio
Performance Highligh

This goal structure reflects the CFTC 2022 – 2026 Strategic Plan, adopted in March 2022.

STRATEGIC GOAL 1: Strengthen Derivatives Markets & Foster Their Vibrancy

Strengthening derivatives markets and protecting their participants increases confidence 

in market soundness. Open and competitive markets unaltered by fraud, manipulation, 

or other abuses bolsters confidence in their integrity and fosters economic growth. 

STRATEGIC GOAL 2: Regulate Derivatives Markets in Interest of All Americans

The Commission’s vital role in regulating derivatives markets and their financial 

instruments benefits all Americans. Sound regulation and oversight of these markets 

impacts all of us—enabling businesses to provide stable and predictable prices for 

everything from groceries to gasoline and from heating bills to home mortgages.

STRATEGIC GOAL 3: Encourage Innovation & Enhance Regulatory Experience of All

The Commission aims to develop regulations that keep pace with and encourage 

responsible innovation. When crafting and implementing regulations we will be 

guided by the important outcomes of improving derivatives markets’ integrity, 

resiliency, and avoiding systemic risk.

STRATEGIC GOAL 4: Be Tough on Those Who Break the Rules

The CFTC is committed to protecting the public from misconduct in our markets, 

including manipulation, spoofing, disruptive trading, and other fraudulent actions. 

The Commission detects, investigates, and prosecutes misconduct and fraud. 

Doing so leads to improved confidence in the integrity of derivatives markets. 

STRATEGIC GOAL 5: Focus on Unique Mission & Improve Operational Effectiveness

Achieving the CFTC’s crucial mission requires exceptional operational effectiveness, 

information technology management, and advanced data analysis. This strategic goal 

recognizes the vital role business management and related service play in protecting 

derivatives markets and taxpayer dollars.

 Commodity Futures Trading Commission 2
Verification and Valdation of Per

Key Results for St

The following are results with selected representative indicators from each Strategic Goal. The completeness and reliability

of performance indicators are important to the Commission. The CFTC works to ensure performance indicators for public

reporting demonstrate progress toward achieving the strategic objectives they support

Strategic Goa 1:  Strengthen the Resilience nd 

Derivatives Markets While Fostering The

Public Benefit

Derivatives markets are designed to provide a means for market users to offset price risks inherent in their businesses and 

to act as a public price discovery platform from which prices are broadly disseminated for public use. The CFTC adds to the

strength and resilience of derivatives markets through regular examinations, stress testing, capital requirements, financial 

reporting obligations, and ongoing risk monitoring

Resource Investment Dedicated to Strategic Goal 1

In FY 2022, the Commission invested $54.3 million and 113 FT

Key Indicator Performance Results

Objective 1.1: Ensure our central counterparties remain among the soundest and most resilient in the world.

PERFORMANCE INDICATOR: Aggregate cleared swaps, futures, and options positions 

into a comprehensive risk surveillance process and conduct analysis for each material 

market participant.

Why this is relevant: The Commission has a comprehensive program in place to aggregate and conduct risk surveillance 

of market participants’ futures and options positions. The Commission is developing procedures to aggregate swap 

positions across multiple DCOs and the asset classes for which such DCOs offer clearing services. Upon the development 

of such procedures, the Commission will be in a position to aggregate the risk of market participants that trade futures, 

swaps, and options and conduct risk surveillance for that aggregate portfolio.

Data Source: For futures, options on futures, and swaps, the source of trader data is currently large trader data that the 

Commission receives daily from FCMs and Part 39 margin and position data that the Commission receives daily from 

DCOs. DCR worked with DCOs to have them transmit account level data with their Part 39 transmissions. This work 

is now complete as all DCOs submit account level data. DCR receives additional supplementary data such as delta 

ladders for swaps.

Verification and Validation: The Standard Portfolio Analysist of Risk application can stress test futures position positions. 

Target: DCR will aggregate risk of market participants’ interest rate swap (IRS) & interest rate (IR) futures to get full 

IR exposure.

FY 2019 FY 2020 FY 2021 FY 2022

Aggregated the risk of 

100 IRS and IR futures 

accounts

Aggregated the risk of 

100 IRS and IR futures 

accounts

Aggregated the risk of 

thousands of accounts 

across multiple asset 

classes*

Aggregated the risk of 

thousands of accounts 

across multiple asset 

classes*

* The Risk Surveillance Branch conducts stress tests of all material futures, options and swaps accounts on a regular basis. These stress tests are aggregated by market 

participants across DCO. Market participant risk is then monitored across asset classes and DCOs.

FY 2022 Agency Financial Re

26 Commodity Futures Trading Commissio
Strategic Goa 2:  Regulate our Derivaive

the Inteests of A

Public Benefit

CFTC ensures that derivatives markets work in the best interest of all Americans, supporting a market-based system for price 

discovery and risk management. The U.S. derivatives markets continue to serve the needs of everyday Americans and tou

all corners of the real economy – from farmers and ranchers who need to hedge grain and cattle prices, to manufacturers 

and exporters who need to manage exchange-rate fluctuations

Resource Investment Dedicated to Strategic Goal 2

In FY 2022, the Commission invested $53 million and 107 FTE

Key Indicator Performance Results

Objective 2.3: Increase protections for customer assets and information.

PERFORMANCE INDICATOR: Examine compliance by exchanges and SDRs with the 

system safeguards and cybersecurity requirements of the CEA Core Principles and 

Commission regulations, prioritizing systematically important entities. 

Why this is relevant: Utilizing both risk-based and Core Principles-based approaches, the Commission conducts 

comprehensive examinations of system safeguards and cybersecurity programs at exchanges and SDRs, and prepares 

examinations reports when deficiencies are identified. Exchanges and SDRs are notified, and staff monitor their remediation 

efforts. A system safeguards examination (SSEs) has four main stages: 1) Initiating letter; 2) On-site exam, includes 

data review and interviews with both senior staff and technical expert staff; 3) Review of initial observations, follow 

up questions, followed by development of examination report with findings and recommendations and an overall rating 

(Adequate/Needs Improvement/Inadequate); and 4) Presentation of findings/recommendations to Commission for 

Commission “acceptance,” followed by transmittal of report to entity.

Data Source: DMO and DCR maintain a list of SSEs commenced and completed each year.

Verification and Validation: Management record keeping.

FY 2019 FY 2020** FY 2021** FY 2022

8 on-site reviews 

for SSEs conducted

• 2 SSEs initiated

and staff interviews 

conducted; 

• 1 additional SSE

initiated; 

• 4 additional SSEs

issued*

• 3 entity SSEs initiated,

staff interviews conducted; 

• 3 entity SSEs with staff

interviews conducted 

and report issued; 

• 3 additional entity SSEs

initiated;

• 9 entity Targeted Maturity 

Assessments [TMA – a 

new type of DMO review] 

with on-site interviews 

conducted and report 

issued; 

• 3 additional entity TMAs

initiated

• 2 systemically important DCO SSEs;

• 1 SSE at another DCO;

• 1 DCO & 1 DMO application for

entities that wish to clear or hold 

crypto products;

• 5 entity SSEs initiated, staff

interviews conducted;

• 3 entity SSEs with staff interviews

conducted and report issued;

• 8 entity TMAs initiated;

• 8 designation or registration

reviews initiated; with 4 completed 

system safeguards portion of the 

checklist complete

* DCR also conducts comprehensive SSEs for clearing houses (“CCPs”). During FY 2021 DCR completed systems examinations for 2 systemically important CCPs 

and 2 additional CCPs.

** By necessity, due to COVID-19, staff interviews were conducted over telephone or via video.

FY 2022 Agency Financial Re

 Commodity Futures Trading Commission 2

M A N A G E M E N T ’ S D I S C U S S I O N A N D A N A LY S I S
Strategic Goa 3:  Encourage Innovation and Enhance the R

for Market Participants at H

Public Benefit

CFTC will continue to encourage innovation and enhance the regulatory experience for market participants at home 

and abroad. Technological innovation is drastically changing financial markets, including the derivatives markets the

CFTC regulates. The growing adoption of derivatives involving digital assets and the use of distributed ledgers and other

technologies present novel issues for applying and enforcing the CFTC’s regulations

Resource Investment Dedicated to Strategic Goal 3

In FY 2022, the Commission invested $42.6 million and 77 FT

Key Indicator Performance Results

Objective 3.2: Ensure that the CFTC’s actions result from well-defined, transparent, and consistent processes, with 

regulatory development that complies with applicable laws and regulations, and is consistent with standards agreed 

upon by international bodies.

PERFORMANCE INDICATOR: Percentage of high impact contract and rule submissions 

received by the CFTC through the organizations, products, events, rules, and actions 

(OPERA) portal.

Why this is relevant: This indicator captures the efficiency with which staff can receive and process exchange submissions related to contracts and rules. Through the portal, exchanges are able to electronically file submissions directly 

with the Commission. This decreases the time it takes for the Commission to make information about new contracts and 

amendments available to the public. Portal submissions also increase data accuracy, as they reduce the need to manually 

add data elements into the Filings and Actions (FILAC) database. Finally, automatic routing of submissions to relevant 

staff increases operational efficiency and accuracy by reducing staff time spent on manual routing and improves ability to 

identify high impact contract and rule submissions in preparation for reviews of new or amended contracts and rule filings.

Data Source: The FILAC database indicates whether a filing was made via email or the OPERA portal.

Verification and Validation: The OPERA portal automatically assigns a submission number to all filings made through the 

portal. Filings made via email are not assigned a submission number. 

FY 2019 FY 2020 FY 2021 FY 2022

100% 99.88% 99% 99%*

* Provisional

Strategic Goa 4:  Be Tough on Those Who 

Public Benefit

The CFTC remains vigilant against those who violate the CEA or CFTC regulations. The CFTC’s strong enforcement program

emphasizes being tough on those who break the rules, but also being fair and consistent. A tough enforcement program

is vital to maintaining public confidence in financial markets. The Commission uses its authority to deter fraudulent and

manipulative conduct and to ensure that markets, firms, and participants subject to the Commission’s oversight meet their 

obligations

FY 2022 Agency Financial Re

28 Commodity Futures Trading Commissio
Resource Investment Dedicated to Strategic Goal 4

In FY 2022, the Commission invested $81 million and 199 FTE

Key Indicator Performance Results

Objective 4.2: Leverage the CFTC’s expertise and resources by coordinating with other criminal and civil 

enforcement authorities.

PERFORMANCE INDICATOR: Leverage the impact of its enforcement program through 

coordination with SROs and active participation in domestic and international cooperative 

enforcement efforts.

Why this is relevant: This indicator reflects the Commission’s continued participation in regular meetings with the SROs 

and with domestic and international cooperative partners. The Commission’s enforcement program regularly meets with 

the SROs to discuss matters of common interest; including investigations, enforcement actions, and the sanctioning of 

violative conduct. The Commission’s enforcement program also works cooperatively with both domestic and international 

authorities to maximize its ability to detect, deter, and bring sanctions against wrongdoers involving U.S. markets, 

registrants, and customers. These cooperative efforts bolster the effectiveness of the enforcement program by allowing 

it to investigate and litigate more efficiently, and seek penalties that provide the appropriate punitive and deterrent effect. 

Data Source: Meeting records.

Verification and Validation: Management record keeping.

FY 2019 FY 2020 FY 2021 FY 2022

Participated in 58 

domestic and international 

cooperative enforcement 

meetings, task forces, etc.

Participated in 81 

domestic and international 

cooperative enforcement 

meetings, task forces, etc.

Participated in 73 

domestic and international 

cooperative enforcement 

meetings, task forces, etc.

Participated in 92 

domestic and international 

cooperative enforcement 

meetings, task forces, etc.

Objective 4.3: Focus market surveillance on areas where fraud and manipulation are most likely.

PERFORMANCE INDICATOR: Develop comprehensive communication strategy, geared 

for internal and external stakeholders, relating to role of whistleblowers and the function 

of the WBO.

Why this is relevant: The Commission participates in public forums and trade shows annually, including the national 

Futures Industry Association Conference. This measure reflects the need of the WBO to communicate effectively to 

external audiences. Outreach is an essential part of the program. The WBO sends the message that the program is in 

place and emphasize in its message the rewards and protections offered by Section 23 of the CEA and the Commission 

regulations. Whistleblowers provide the Commission with the opportunity to receive timely information relating to potential 

violations of the CEA that may not otherwise be available.

Data Source: https://www.whistleblower.gov/news/events

https://www.whistleblower.gov/whistleblower-alerts

Verification and Validation: Management record keeping.

FY 2019 FY 2020 FY 2021 FY 2022

Participated in 15 public 

forums and trade shows

Posted three 

“trending topic” alerts 

to WBO website

Participated in 5 public 

forums and trade shows

Posted one new 

“trending topic” alert 

to WBO website

Presented virtually at 

5 public events

Posted one new 

“trending topic” alert 

to WBO website

Presented at 

4 public events, 

3 virtual and 1 live

FY 2022 Agency Financial Re

 Commodity Futures Trading Commission 2

M A N A G E M E N T ’ S D I S C U S S I O N A N D A N A LY S I S
Strategic Goa 5:  Focus on our Unique Missi

Operational Effe

Public Benefit

Operational effectiveness is fundamental to carrying out the CFTC’s critical mission. The Commission makes effective

operations a priority, and pursues it by leveraging technology, enhancing agency stewardship of taxpayer dollars, and 

actively managing the organization to address mission challenges. The Commission is striving to become a model Federal

employer in promoting workforce DEIA, which is not only the right thing to do, but it will result in a more effective CFTC, 

better equipped to achieve its mission

Resource Investment Dedicated to Strategic Goal 5

In FY 2022, the Commission invested $84.5 million and 188 FT

Key Indicator Performance Results

Objective 5.1: Embracing and embedding equal opportunity, diversity, equity, inclusion, and accessibility (DEIA) 

principles and best practices into all Commission operations.

PERFORMANCE INDICATOR: Number of Special Emphasis Programs observed within 

the Commission.

Why this is relevant: Special Emphasis Programs focus special attention on groups that are not well represented or have 

less than expected participation rates in specific occupational categories or grade levels within the agency’s workforce. 

These programs demonstrate affirmative steps to provide equal opportunity to everyone in all areas of employment 

and to eliminate discriminatory practices and policies. Observances of Special Emphasis Programs were designed for 

the purpose of providing cultural awareness to everyone through commemorative activities that are educational and 

employment-related. As such, observances improve the workplace environment by promoting and fostering diversity 

through awareness and educating employees and others to appreciate, value, understand, and celebrate social and 

cultural similarities and differences.

Data Source: Meeting records.

Verification and Validation: Management record keeping. 

FY 2019 FY 2020* FY 2021* FY 2022*

7 7 8 8

* By necessity, due to COVID-19, some of the observance activities were held virtually. 

FY 2022 Agency Financial Re

30 Commodity Futures Trading Commissio
Financial Highligh

Financial Overvi

The following table presents an overview of the Commission’s financial position, net costs, and budgetary resources as of 

and for the fiscal years ending September 30, 2022, and September 30, 2021

Highlights 2022 20

Condensed Balance She

Fund Balance with Treasury $ 174,854,209 $ 207,788,240

Investments 286,000,000 –

Accounts Receivable, Net 27,175 26,983

Custodial Fines and Interest Receivable, Net 659,190,181 34,377,723

General Property, Plant, and Equipment, Net 39,477,653 25,618,531

Advances and Prepayments 6,640,433 13,695,572

TOTAL ASSETS $1,166,189,651 $ 281,507,049

Accounts Payable $ 16,602,824 $ 11,208,649

Accrued Payroll and Unfunded Annual Leave 29,167,978 28,498,460

FECA and Unemployment Liabilities 582,869 623,369

Liability to the General Fund of the U.S. Government for Custodial Assets 659,190,181 34,377,723

Liability for Non-Fiduciary Deposit Funds 73,353 595,476

Deferred Lease Liabilities 15,703,225 15,925,725

Liability for Whistleblower Awards 45,000 203,970,000

Total Liabilities $ 721,365,430 $ 295,199,402

Unexpended Appropriations – Funds from Other than Dedicated Collections $ 137,086,524 $ 87,459,663

Cumulative Results of Operations – Funds from Dedicated Collections 301,921,114 (92,073,033)

Cumulative Results of Operations – Funds from Other than Dedicated Collections 5,816,583 (9,078,983)

Total Net Position $ 444,824,221 $ (13,692,353)

TOTAL LIABILITIES AND NET POSITION $1,166,189,651 $ 281,507,049

Condensed Statements of Ne

Gross Costs $ 328,486,481 $ 514,901,590

Earned Revenue (49,179) –

TOTAL NET COST OF OPERATIONS $ 328,437,302 $ 514,901,590

Net Cost by Strategic

Strategic Goal 1: Strengthen Derivatives Markets & Foster their Vibrancy $ 56,519,959 $ 54,950,470

Strategic Goal 2: Regulate Derivatives Markets in Interest of All Americans 55,239,147 46,228,173

Strategic Goal 3: Encourage Innovation & Enhance Regulatory Experience of All 44,368,661 44,016,448

Strategic Goal 4: Be Tough on Those Who Break the Rules 84,360,406 285,505,184

Strategic Goal 5: Focus on Unique Mission & Improve Operational Effectiveness 87,949,129 84,201,315

TOTAL NET COST OF OPERATIONS $ 328,437,302 $ 514,901,590

Condensed Statements of Budgetary Res

Prior Year Budget Authority $ 52,805,900 $ 51,006,213

New Budget Authority 759,106,348 304,063,234

TOTAL BUDGETARY RESOURCES $ 811,912,248 $ 355,069,447

New Obligations and Upward Adjustments $ 511,348,819 $ 303,467,595

Apportioned, Unexpired Accounts 350,040,567 123,018,339

Unapportioned, Unexpired Accounts (57,983,358) (80,060,414)

Expired Unobligated Balances 8,506,220 8,643,927

TOTAL BUDGETARY RESOURCES $ 811,912,248 $ 355,069,447

Agency Outlays, Net $ 126,645,815 $ 314,127,441

 Commodity Futures Trading Commission 3
The overview on the previous page is supplemented with brief 

descriptions of the nature of each required financial statement 

and its relevance. Significant balances or conditions featured

in the graphic presentation are explained in each section to 

help clarify their relationship to Commission operations

Readers are encouraged to gain a deeper understanding by 

reviewing the Commission’s financial statements and notes 

and the accompanying audit report presented in the Financial 

Section of this report

Understanding the Financial S

The CFTC prepares annual financial statements and notes 

in accordance with U.S. generally accepted accountin

principles (GAAP) for Federal government entities and in 

the form and content requirements of OMB Circular A-136, 

Financial Reporting Requirements. The CFTC’s current year and

prior year financial statements and notes are presented in a 

comparative format. The table below presents changes in key

financial statement line items, as of and for, the fiscal year 

ended September 30, 2022, compared to September 30, 2021

To better comprehend the Commission’s financial statements 

and the reasons for changes from year to year, it is important 

to understand that the Commission’s financial statements 

report on the operations of the Commission as well as its 

Customer Protection Fund (“Fund”). As discussed in Note 1A

to the financial statements, the Fund is available to pay 

whistleblower awards and fund customer education initiatives 

to help investors protect themselves against fraud. Amounts

in the Fund are invested until needed to fund whistleblower 

awards, customer education initiatives, or operating expenses 

of the Fund. As shown in the chart above, the balance in

the Fund can change significantly as a result of transfers of 

eligible collections into the Fund and large whistleblower 

awards. These awards are made to individuals in exchange

for the voluntary disclosure of information that leads to the 

successful enforcement by the CFTC of a covered judicial or 

administrative action in which monetary sanctions exceeding 

$1.0 million are impose

The $394.0 million increase in the net position of the Fund

in FY 2022 was primarily due to eligible collections of 

$398.5 million that were transferred into the Fund during the

fiscal year. When the available balance in the Fund is less than

or equal to $100.0 million, the Fund is replenished by eligible

sanctions collected by the Commission in accordance with 

the provisions of the Dodd-Frank Act. The $209.1 millio

decrease in the net position of the Fund in FY 2021 was 

primarily due to $203.4 million in new whistleblower

awards pending or paid as of September 30, 2021 (disclosed 

in Note 8, Liability for Whistleblower Awards), as well as 

administrative expenses and costs for customer education 

initiatives. The pending awards as of September 30, 2021,

Key Financial Statement Line Items 2022 2021 $ Change % Ch

Total Assets $1,166,189,651 $ 281,507,049 $ 884,682,602 314.27%

Total Liabilities $ 721,365,430 $ 295,199,402 $ 426,166,028 144.37%

Total Net Position $ 444,824,221 $ (13,692,353) $ 458,516,574 (3,348.71%)

Total Net Cost of Operations $ 328,437,302 $ 514,901,590 $ (186,464,288) (36.21%)

Total Budgetary Resources $ 811,912,248 $ 355,069,447 $ 456,842,801 128.66%

New Obligations and Upward Adjustments $ 511,348,819 $ 303,467,595 $ 207,881,224 68.50%

Apportioned $ 350,040,567 $ 123,018,339 $ 227,022,228 184.54%

Unapportioned $ (57,983,358) $ (80,060,414) $ 22,077,056 (27.58%)

Agency Outlays, Net $ 126,645,815 $ 314,127,441 $ (187,481,626) (59.68%)

Custodial Receivables/Liabilities $ 659,190,181 $ 34,377,723 $ 624,812,458 1,817.49%

FY 2022 Agency Financial Re

32 Commodity Futures Trading Commissio
increased liabilities and decreased net position as of 

September 30, 2021, but were not obligated until FY 2022 

when the awards were finalized

7

As of September 30, 2022, the available balance of the Fund, 

which consists of amounts apportioned for use but not yet 

obligated for other purposes, was $269,792,957

8 The Fund’s 

individual balance sheets, statements of net cost, and statements of changes in net position are reported separately in 

Note 12, Funds from Dedicated Collections, and its statements 

of budgetary resources are reported in the “Customer Protection Fund” column of the combining statements of budgetary 

resources in the required supplementary information section 

immediately following the notes to the financial statements

Balance Sh

The Balance Sheets present, as of a specific point in time, the 

assets and liabilities retained or managed by the Commission

The difference between assets and liabilities represents the net 

position of the Commission

Total Assets: As of September 30, 2022, the Balance Sheet 

reflects total assets of $1,166.2 million  This is an increas

of $884.7 million, or 314.3 percent, over FY 2021, primaril

due to increases of $624.8 million in Custodial Receivables,

$286.0 million in Investments, and $13.9 million in Property

7 The $203.3 million disbursed from the Fund for whistleblower awards during FY 2022 was previously reported as pending claims as of September 30, 2021. The amount of 

unpaid whistleblower claims as of September 30, 2022, of $671.5 thousand consists of final whistleblower awards due and payable of $626.5 thousand plus $45.0 thousand 

in awards preliminarily determined by the CFTC as of September 30, 2022, but not issued as final awards during FY 2022.

8 The apportioned balance on the Fund’s Statement of Budgetary Resources totals $278,674,934, consisting of $269,792,957 in the Fund and $8,881,977 that has been 

set aside in a separate account to fund non-whistleblower costs when the unobligated balance of the Fund is insufficient. 

9 11 entities were fined in the order totaling $710.0 million but the Commission collected $75 million from one entity prior to September 30, 2022.

Plant, and Equipment, offset by decreases of $32.9 million in

Fund Balance with Treasury and $7.1 million in Advances and

Prepayments

The $624.8 million, or 1,817.5 percent, increase in Custodia

Receivables was due to an increase in the amount of 

receivables for civil monetary sanctions that are estimated 

to be collectible as of September 30, 2022. The collectible

amount of receivables for civil monetary sanctions is 

driven by enforcement actions and the violators’ ability 

to pay in any given fiscal year. Of the $659.2 million i

outstanding Custodial Receivables as of September 30, 

2022, $636.2 million, or 96.5 percent, was expected to b

collected from 10 entities for civil monetary penalties related 

to recordkeeping and supervision failures for widespread use 

of unapproved communication methods that resulted from 

a Commission order dated September 27, 2022

9

Excluding Custodial Receivables, Investments of $286.0

million comprised approximately 56.4 percent of the

Commission’s total assets as of September 30, 2022. This

significant asset represents the balance of the Customer 

Protection Fund that is not needed to pay whistleblower 

awards or fund customer education initiatives and operating 

expenses of the Fund. During FY 2021, the Commission

FY 2022 Agency Financial Re

 Commodity Futures Trading Commission 3

M A N A G E M E N T ’ S D I S C U S S I O N A N D A N A LY S I S
redeemed all investments to make funds readily available for 

the needs of the Fund. In FY 2022, the Commission began

investing again once there were sufficient funds to satisfy all 

outstanding whistleblower obligations. The $286.0 million

or 100.0 percent, increase in Investments resulted from the

investment of surplus funds remaining in the Fund from 

offsetting collections after all outstanding whistleblower 

awards had been obligated

The $13.9 million, or 54.1%, increase in Property, Plant

and Equipment is the net of new asset purchases, primarily 

for leasehold improvement and equipment related to the 

relocation to new office space in the Chicago and New York 

regions, net of disposals of the old leasehold improvement 

and equipment from the prior locations that were primarily 

fully depreciated

The $32.9 million, or 15.9 percent, decrease in Fun

Balance with Treasury is the net of a $95.2 million decrease

in the Customer Protection Fund balance offset by a 

$62.3 million increase in the non-Customer Protection Fund

balance. The Customer Protection Fund balance primarily

decreased due to $286.0 million in investment purchases

discussed previously and disbursements of $4.1 million

for payroll, $1.6 million for contract payments, and $203.

million for whistleblower awards, partially offset by 

$398.5 million in custodial collections transferred into the

fund and $1.4 million in interest received on investment

The non-Customer Protection Fund balance primarily 

increased due to $64.6 million excess of appropriations

and other offsetting collections over outlays due to increase 

in appropriations received of $78.0 million in FY 2022

(consisting of $62.0 million one-time appropriation for

relocation costs for the DC move and $16.0 million increase

in annual appropriation) and the timing of cash payments, 

less $2.4 million in Fund Balance with Treasury returned to

the U.S. Department of the Treasury from the deposit fun

and 2017 canceled appropriations

The $7.1 million, or 51.5 percent, decrease in Advances an

Prepayments was due to a $6.3 million decrease in prepayments to the Department of Interior for contract support and

less subscriptions and maintenance agreements prepaid in 

FY 2022 than FY 2021

10 Whistleblower awards that have been signed by the Secretary of the Commission and issued as final are obligated and reported as Accounts Payable until paid. Whistleblower awards that have not yet been issued as final awards, but are in preliminary determination status (i.e., the recommended award amount has been communicated 

to the whistleblower(s) but not yet approved by the Commission), are reported in the unfunded Liability for Whistleblower Awards.

Total Liabilities: As of September 30, 2022, the Balance 

Sheet reflects total liabilities of $721.4 million  This is a

increase of $426.2 million, or 144.4 percent, over FY 20

The increase was primarily due to increases of $624.8 million

in Custodial Liabilities and $5.4 million in Accounts Payable,

partially offset by a decrease of $203.9 million in Liability

for Whistleblower Awards

The $624.8 million, or 1,817.5 percent, increase in Custodial Liabilities was directly related to the increase in Custodial Receivables discussed previousl.  Custodial liabiliti

are recorded to offset the custodial receivables balance and 

increase or decrease to reflect outstanding receivables for 

civil monetary sanctions at any given point in time. Once

custodial receivables are collected, the Commission transfers eligible collections to the Customer Protection Fund 

whenever the available balance of the Fund is less than or 

equal to $100.0 million at the time the collection is receive

Remaining amounts collected are transferred to the U.

Department of the Treasury on September 30th each year

The $5.4 million, or 48.1 percent, increase in Account

Payable is primarily the result of unbilled amounts owed to 

the General Services Administration (GSA) for construction 

work related to the Commission's facility relocations in New 

York and Chicago, a $625.0 thousand whistleblower award

issued as final in FY 2022, and the timing of cash payments

10

The Commission estimates the unbilled amounts and records 

an accrual for goods and services received but not yet paid 

for as of the end of each reporting period

FY 2022 Agency Financial Re

34 Commodity Futures Trading Commissio
The $203.9 million, or 99.9 percent, decrease in Liability fo

Whistleblower Awards is directly related to a decrease in the 

estimated amount of pending awards for valid whistleblower 

claims that are in preliminary determination status as of 

the end of the reporting period. The amount of whistleblower awards is driven by the amount of sanctions actually

collected on the related judgments and the extent to which 

information provided by the whistleblowers contributed to 

the cases. Additional information on whistleblower awards

is discussed in the Annual Report on the Whistleblower Program 

and Customer Education Initiatives available at https://www.

whistleblower.gov/reports

Total Net Position: As of September 30, 2022, the Balance 

Sheet reflects a total net position of $444.8 million, an

increase of $458.5 million, or 3,348.7 percent, over FY 20

The changes in each of the three components of the Commission’s net position (Unexpended Appropriations—Funds 

from Other than Dedicated Collections, Cumulative Results 

of Operations—Funds from Dedicated Collections, and 

Cumulative Results of Operations—Funds from Other than 

Dedicated Collections) are discussed separately below

Unexpended Appropriations—Funds from Other than 

Dedicated Collections increased by $49.6 million, or

56.7 percent, due primarily to FY 2022 appropriations

received of $382.0 million in excess of appropriations used

of $330.6 million as a result of the $78.0 million increas

in FY 2022 appropriations received and the timing of actual 

cash payments. In addition, approximately $1.8 millio

unexpended appropriations in cancelled funds were returned 

to Treasury on September 30, 2022

Cumulative Results of Operations—Funds from Dedicated 

Collections increased by $394.0 million, or 427.9 percent

due to eligible collections of monetary sanctions of 

$398.5 million transferred to the Customer Protection Fund

expenses plus $1.4 million in investment interest revenue,

offset by Customer Protection Fund expenses of $5.9 million,

which primarily consisted of administrative costs to operate 

the Fund and implement customer education initiatives

Cumulative Results of Operations—Funds from Other 

than Dedicated Collections increased by $14.9 million, or

164.1 percent, due to total financing sources exceeding net

cost of operations. Cumulative Results of Operations—All

Other Funds became negative at the end of FY 2018 when 

unfunded liabilities exceeded Property, Plant and Equipment 

and non-custodial Accounts Receivable. This condition

resolved itself in FY 2022 when the Commission was able 

to invest in additional assets, which primarily consisted 

of leasehold improvements and equipment for its facility 

relocations in New York and Chicago

Statemets 

The Statements of Net Cost present the components of the 

Commission’s gross and net cost of operations. Net cost is the

gross cost incurred less any revenues earned from Commission 

activities. The Commission experienced a $186.5 million

or 36.2 percent, decrease in the total net cost of operations

during FY 2022

The overall decrease was due to decreases of $203.4 million in

whistleblower awards, $3.3 million in payroll-related accruals,

and $2.3 million in depreciation expense, offset by increases of

$11.0 million in contracts for goods and services, $10.3 millio

in payroll, $734.0 thousand in leases, and $410.5 thousan

in travel. The $16.9 million increase in non-whistleblowe

award expenses is reasonable given a $47.0 million increase

in appropriations from FY 2019 to FY 2020 (including $31.0

million no-year funding for facility relocation), a $20.0 million

increase in regular appropriations from FY 2020 to FY 2021, 

a $78.0 million increase in appropriations from FY 2021 to

FY 2022 (including $62.0 million no-year funding for facility

relocation), and the timing of cash payments

FY 2022 Agency Financial Re

 Commodity Futures Trading Commission 3

M A N A G E M E N T ’ S D I S C U S S I O N A N D A N A LY S I S
Despite receiving a significant increase of $78.0 million in

appropriations in FY 2022, as noted previously, $62.0 million

of the $78.0 million increase are no-year funds for facility

relocation that will take place through FY 2025 when the last 

Commission office relocates (only $473.5 thousand of the

$62.0 million received in FY 2022 for facility relocation was

obligated and none of it was expensed as of September 30, 

2022). The impact of the increase in no-year appropriations

for facility relocation will be evident in increased obligations 

on the Statement of Budgetary Resources and increased costs on 

the Statement of Net Cost in FY 2023 and future years as related 

goods and services are received and amounts are disbursed

In line with the Strategic Plan in effect for both FY 2022 and 

FY 2021, the Commission allocates expenses reported in the 

Statement of Net Cost to the following five Strategic Goals:

■ Strategic Goal One – Strengthen Derivatives Markets & 

Foster Their Vibrancy

■ Strategic Goal Two – Regulate Derivatives Markets in 

Interest of All Americans

■ Strategic Goal Three – Encourage Innovation & Enhance 

Regulatory Experience of All

■ Strategic Goal Four – Be Tough on Those Who Break 

the Rules

■ Strategic Goal Five – Focus on Unique Mission & Improve 

Operational Effectiveness

To aid the financial statement reader in more fully understanding the Commission’s strategic focus and how it changed 

from FY 2021 to FY 2022, the table above presents the gross costs 

by Strategic Goal excluding whistleblower awards. In FY 2022,

CFTC allocated slightly more costs to Strategic Goal Two and 

less costs to Strategic Goals One, Three, Four, and Five. After

adding back the whistleblower awards, the total gross costs in 

the table above ties to the total gross costs on the Commission’s 

Statements of Net Cost for FY 2022 and FY 2021

Statemets of Changes i

The Statements of Changes in Net Position present 

the Commission’s cumulative net results of operations 

and unexpended appropriations for the fiscal year. The

components of the changes in the Commission’s Net 

Position shown below are explained in the Total Net Position 

discussion in the Balance Sheets section

Gross Costs by Strate

2022 2021 2022% 2021% % Change $ Change

Strategic Goal 1 – Strengthen Derivatives 

Markets & Foster Their Vibrancy $ 56,528,423 $ 54,950,470 17.21% 17.64% -0.43% $ 1,577,953

Strategic Goal 2 – Regulate Derivatives 

Markets in Interest of All Americans $ 55,247,419 $ 46,228,173 16.82% 14.84% 1.98% $ 9,019,246

Strategic Goal 3 – Encourage Innovation 

& Enhance Regulatory Experience of All $ 44,375,305 $ 44,016,448 13.51% 14.13% -0.62% $ 358,857

Strategic Goal 4 – Be Tough on Those 

Who Break the Rules (excluding 

Whistleblower Awards) $ 84,349,211 $ 82,114,194 25.68% 26.36% -0.68% $ 2,235,017

Strategic Goal 5 – Focus on Unique Mission 

& Improve Operational Effectiveness $ 87,962,299 $ 84,201,315 26.78% 27.03% -0.25% $ 3,760,984

Gross Costs Excluding Whistleblower Awards $ 328,462,657 $ 311,510,600 100.0% 100.0% $ 16,952,057 

Whistleblower Awards $ 23,824 $ 203,390,990 $ (203,367,166)

GROSS COSTS $ 328,486,481 $ 514,901,590 $ (186,415,109)

FY 2022 Agency Financial Re

36 Commodity Futures Trading Commissio
Statemets of Budget

The Statements of Budgetary Resources provide information 

about the provision of budgetary resources and its status as of 

the end of the year. Information in this statement is consistent with budget execution information and the information

reported in the Budget of the U.S. Government, FY 2022

The changes in the Commission’s total budgetary resources 

from September 30, 2021, to September 30, 2022, can mostly 

be explained by the following three events:

■ The Commission transferred $398.5 million in eligible

monetary sanctions from its custodial receipt account to 

the Customer Protection Fund when the available balance 

of the Fund was less than or equal to $100.0 million and

collected $1.4 million in investment interest revenue  Afte

reducing available budgetary authority by $22.8 million

for temporary sequestration (5.7% of all offsetting

collections), the budgetary authority for the Customer 

Protection Fund increased by $377.0 millio

■ The Commission received $78.0 million more in appropriations in FY 2022 than FY 2021  This $78.0 milli

increase is the result of a one-time appropriation of 

$62.0 million for facility relocation expenses and a

$16.0 million increase in annual appropriation

■ The Commission reduced its outstanding unfunded lease 

deficiency by $22.1 million in FY 2022 and $23.6 millio

in FY 2021 (see Note 10 for additional information). As

lease payments are funded through annual appropriations and subsequently paid, the abnormal balance in 

Unapportioned, Unexpired Accounts is reduced and the 

Unobligated Balance from Prior Year Budget Authority, 

Net increases in the subsequent fiscal year

For the year ending September 30, 2022, the Commission’s 

Total Budgetary Resources increased by $456.8 million, or

128.7 percent  This increase is primarily due to a $455.0 milli

increase in new budget authority

For the year ending September 30, 2022, the Commission’s new 

budget authority increased by $455.0 million, or 149.7 percent

primarily due to a $377.0 million, or 741,919.4 percent increase

in Customer Protection Fund Offsetting Collections as a result 

of (1) $398.5 million transferred into the Fund from eligible

monetary sanctions collected, and (2) significantly higher 

average Treasury interest rates paid on investments in overnight 

Treasury securities (2.3 percent in FY 2022 versus .05 percent i

FY 2021), offset by $22.8 million for temporary sequestration

(5.7% of all offsetting collections)  In addition, new budge

authority increased in FY 2022 due to the $78.0 million increase

in annual appropriations received

New Obligations and Upward Adjustments increased by 

$207.9 million, or 68.5 percen.  This increase was primari

the result of increases in amounts obligated for whistleblower 

awards, payroll, leases, and travel of $200.9 million, $10.

million, $2.1 million, and $520.9 thousand, respectively, offse

by a $6.5 million decrease in amounts obligated for contracts

for goods and services. The overall increase in obligations is

expected given the increase in whistleblower awards issued as 

final in FY 2022 and appropriations received of $78.0 million

in FY 2022 ($62.0 million of the $78.0 million increase i

appropriations were no year-funds for facility relocation 

expenses of which only $473.5 thousand had been obligated

FY 2022 Agency Financial Re

 Commodity Futures Trading Commission 3

M A N A G E M E N T ’ S D I S C U S S I O N A N D A N A LY S I S
as of September 30, 2022) and $20.0 million in FY 2021

and the timing of obligations due to no-year and two-year 

appropriations received

Apportioned, Unexpired Accounts increased by $227.0 million,

or 184.5 percent, due to increases of $167.6 million in th

Customer Protection Fund, $2.2 million in the annual and

multi-year funds, and $57.2 million in the no-year facility

relocation fund due to excess of new budget authority over 

amounts obligated and/or expended by the funds

The $22.1 million, or 27.6 percent, increase in Unapportioned

Unexpired Accounts was the result of the $22.1 million

reduction in unfunded lease obligations. As noted previously,

the Commission reduced its outstanding unfunded lease 

deficiency through funding from current year appropriations 

of $22.1 million  As reported in prior years, the tota

Unapportioned, Unexpired Accounts balance is negative 

because no funds have been appropriated or apportioned to 

fund the remaining lease obligations through FY 2025. These

unfunded lease obligations remaining as of September 30, 

2022, and 2021, are $58.0 million and $80.1 million

respectively

Agency Outlays, Net decreased by approximately 

$187.5 million, or 59.7 percen.  Excluding the decrea

in outlays due to a $400.0 million increase in offsetting

collections received by the Customer Protection Fund, net 

outlays actually increased by approximately $212.5 millio

This increase was primarily due to increases in outlays of 

$199.9 million for whistleblower awards, $8.4 millio

for salaries and benefits, $4.5 million for leases and other

contracts, and $438.7 thousand for travel  Offsettin

collections offset gross outlays so an increase in offsetting 

collections generally results in lower net outlays; however, 

outlays in any given fiscal year are also impacted by such 

things as appropriations available for obligations in the 

current and prior fiscal years, timing of cash payments, level 

of FTE, and whistleblower award activity

Statemets of Custo

This statement provides information about the sources and 

disposition of collections. All collections received during

the fiscal year that are not transferred to the Customer 

Protection Fund when the available balance is less than 

or equal to $100.0 million are transferred to the Treasury

general fund on September 30th. Collections primarily

consist of fines, penalties, and forfeitures assessed and 

levied against businesses and individuals for violations of 

the CEA or Commission regulations. They also include

other non-exchange revenues such as registration, filing, 

appeal fees, and general receipts. The Statement of Custodial

Activity reflects total cash collections for FY 2022 in the 

amount of $604.7 million, an increase of $57.8 million

or 10.6 percent, over FY 2021  These custodial collection

are driven by enforcement actions in any given fiscal year as 

well as the violators’ ability to pay. Of the $604.7 million i

FY 2022 cash collections, $398.5 million in eligible monetary

sanctions were transferred to the Customer Protection 

Fund when the available balance was less than or equal 

to $100.0 million and the remaining $206.2 million wa

transferred to the Treasury

As discussed in the Balance Sheet section, the $624.8 million,

or 1,817.5 percent, increase in Custodial Receivables was

due to an increase in the amount of receivables for civil 

monetary sanctions that are estimated to be collectible as of 

September 30, 2022. Of the $659.2 million in outstandin

Custodial Receivables as of September 30, 2022, $636.2 million,

or 96.5 percent, was expected to be collected from 10 entities

for civil monetary penalties related to recordkeeping and 

supervision failures for widespread use of unapproved 

communication methods that resulted from a Commission 

order dated September 27, 2022

An allowance for uncollectible accounts has been established 

and included in the accounts receivable on the Balance Sheet

Although historical experience has indicated that a high 

percentage of custodial receivables prove uncollectible, the 

Commission determines the collectability of each individual 

judgment based on knowledge of the financial profile of the 

FY 2022 Agency Financial Re

38 Commodity Futures Trading Commissio
debtor obtained through the course of the investigation and 

litigation of each case, including efforts to identify and freeze 

assets at the beginning of cases, when any remaining assets are 

most likely to be recoverable. Accounts are re-estimated quarterly

based on account reviews and the agency’s determination that 

changes to the net realizable value are needed

Financial Risks Occ

During the Reporting

With the increase in payments to whistleblowers, the 

Commission may encounter the possible risk of time lag 

in making payments to whistleblowers if the balance of the 

Customer Protection Fund is not sufficient to make timely 

payments to whistleblowers. This risk is minimized in that there

is a level of due process involved in approving whistleblower 

claims that should provide the Commission with sufficient 

time to replenish the Customer Protection Fund, as necessary

However, given the current requirement for the Commission 

to make whistleblower payments on related matters for which 

another agency collected the sanctions, there is a risk that 

the Customer Protection Fund would have to cease normal 

operations until such time that funds are made available 

to continue. On July 6, 2021, Public Law 117-25 helped

temporarily mitigate this risk by providing the Commission 

with one-time authority to set aside $10.0 million from the

Customer Protection Fund in a separate account to fund 

non-whistleblower costs (e.g., payroll, contracts, etc.) when t

available balance of the Fund is insufficient to pay non-awards 

expenses and expenses for customer education initiatives. In

October 2021, the Commission issued a final whistleblower 

award of nearly $200,000,000, resulting in an obligation that 

exceeded the available balance of the Fund. The Commission

has the authority to make obligations for whistleblower awards 

without taking into consideration the available balance of the 

Fund under the provisions of the Dodd-Frank Act. As a result,

the Commission obligated non-whistleblower costs from this 

separate account until the negative balance in the Fund was 

offset by current year collections of eligible sanctions. This

separate account, of which $8.9 million currently remains

unexpended, will be available until the account expires, at which 

time all unobligated amounts will be returned to the Fund

There were no unanticipated financial risks occurring during 

the reporting period. As in FY 2021, the financial impact

resulting from the COVID-19 pandemic was minimal, 

primarily relating to the acquisition of additional cleaning 

and replacement supplies

Limitatons of Financia

Management has prepared the accompanying financial 

statements to report the financial position and operational 

results for the CFTC for FY 2022 and FY 2021 pursuant to the 

requirements of Title 31 of the U.S. Code, section 3515 (

While these statements have been prepared from the books 

and records of the Commission in accordance with GAAP 

for Federal entities and the formats prescribed by OMB 

Circular A-136, Financial Reporting Requirements, these statements are in addition to the financial reports used to monitor 

and control budgetary resources, which are prepared from 

the same books and records

The statements should be read with the understanding that 

they represent a component of the U.S. Federal government, 

sovereign entity. One implication of this is that the liabilities

presented herein cannot be liquidated without the enactment 

of appropriations, and ongoing operations are subject to the 

enactment of future appropriations

11 Total cash collections include $15.9 thousand, or <$0.1, in general proprietary receipts.

FY 2022 Agency Financial Re

 Commodity Futures Trading Commission 3

M A N A G E M E N T ’ S D I S C U S S I O N A N D A N A LY S I S
Management Overv

The CFTC is committed to management excellence 

and recognizes the importance of strong financial 

systems and internal controls to ensure accountability, integrity, 

and reliability. This operating philosophy has permitted the

Commission to make significant progress in documenting and 

testing its internal controls over reporting, as prescribed in 

OMB Circular A-123, Management’s Responsibility for Enterprise 

Risk Management and Internal Control. The graph on right

depicts all five components of the internal control process 

that must be present in an organization to ensure an effective 

internal control process

■ Control Environment is the foundation for an internal 

control system. It represents management’s commitment

to encourage the highest level of integrity and personal/

professional standards, and promotes internal control 

through our leadership philosophy and operational 

style

■ Risk Assessment is the identification and analysis 

of risks associated with business processes, financial 

reporting, financial systems, controls and legal compliance in the pursuit of agency goals and objectives

■ Control Activities are the actions supported by 

management policies and procedures to address risk, 

e.g. performance reviews, status of funds reporting, an

asset management reviews

■ Information and Communication ensure the agency’s 

control environment, risks, control activities, and performance results are communicated throughout the agency

■ Monitoring is the assessment of internal control 

performance to ensure the internal control processes are 

properly executed and operating effectively in compliance 

with agency policies and procedures

Management Assuranc

Analyss of CFTC’s Systems, Controls, and 

40 Commodity Futures Trading Commissio
The Commission relies on its performance management and 

internal control framework to ensure:

■ divisions and mission support offices achieve the intended 

strategic objectives and performance goals efficiently and 

effectively;

■ maintenance and use of reliable, complete, and timely 

data for decision-making at all levels; and

■ compliance with applicable laws and regulations

Statemet of 

The Statement of Assurance is required by the Federal 

Managers’ Financial Integrity Act of 1982 (FMFIA) and OMB 

Circular A-123, Management’s Responsibility for Enterprise Risk 

Management and Internal Control. The assurance is for internal

controls over operational effectiveness (we do the right things 

to accomplish our mission) and operational efficiency 

(we do things right)

Statement of Assurance

“CFTC management is responsible for establishing and maintaining effective internal controls and financial 

management systems that meet the objectives of the Federal Managers’ Financial Integrity Act of 1982 

(FMFIA). In accordance with OMB Circular A-123, Management’s Responsibility for Enterprise Risk 

Management and Internal Control, CFTC assessed the effectiveness of its internal controls and financial 

management systems to support reliable financial reporting, effective and efficient programmatic operations, 

and compliance with applicable laws and regulations and financial management systems requirements. 

Based on the results of this assessment, the CFTC can provide reasonable assurance that its internal controls 

and financial management systems met the objectives of FMFIA and were operating effectively as of 

September 30, 2022. No material weaknesses were found in the design or operation of CFTC’s internal controls 

or financial management systems.

These reviews include an assessment of CFTC’s safeguarding of assets, the use of budget authority, and other 

laws and regulations that could have a material effect on the financial statements, in accordance with the 

requirements of Appendix A to OMB Circular A-123, Management of Reporting and Data Integrity Risk. 

Based on the results of these reviews, the CFTC can provide reasonable assurance that its internal controls 

over reporting were operating effectively as of September 30, 2022. No material weaknesses were found in 

the design or operation of internal controls over reporting.

The CFTC also reviews the United States Department of Transportation Quality Control Review of Controls 

Over the Enterprise Services Center Report conducted in accordance with the American Institute of Certified 

Public Accountants (AICPA) Statements on Standards for Attestation Engagements (SSAE 18) provided by the 

shared service provider maintaining our financial management system. The report addresses requirements 

outlined in Appendix D of OMB Circular A-123, Compliance with the Federal Financial Management 

Improvement Act of 1996 (FFMIA) and OMB Circular A-136. Based on the results of these reviews, the CFTC 

elects to provide reasonable assurance that its financial management systems comply with applicable 

provisions of the FFMIA as of September 30, 2022.” 

Rostin Behnam

Chairman

November 10, 2022

FY 2022 Agency Financial Re

 Commodity Futures Trading Commission 4

M A N A G E M E N T ’ S D I S C U S S I O N A N D A N A LY S I S
Management’s As

Internal Co

The objectives of the Commission’s internal controls are to 

provide reasonable assurance that:

■ Obligations and costs comply with applicable laws;

■ Assets are safeguarded against waste, loss, unauthorized 

use, or misappropriation;

■ Revenues and expenditures applicable to Commission 

operations are properly recorded and accounted for to 

permit the preparation of accounts and reliable to financial and statistical reports and to maintain accountability 

over assets; and

■ All programs are efficiently and effectively carried out in 

accordance with applicable laws and management policy

During FY 2022, the Commission reviewed key components 

of its internal controls and financial management systems, 

in accordance with FMFIA and OMB guidelines. As part of

this review, the Commission evaluates information obtained 

from reviews conducted by the Government Accountability 

Office (GAO) and the Office of the Inspector General (OIG)

These reviews are helpful in assessing whether the Commission’s systems and controls comply with the standards established by FMFIA

In addition, managers throughout the Commission are 

responsible for ensuring that effective controls are implemented in their areas of responsibility. Individual assurance

statements from division and office heads serve as a primary 

basis for the Chairman’s assurance that internal controls are 

adequate and operating effectively. The assurance statements

are based upon each office’s evaluation of progress made in 

correcting any previously reported problems, as well as new 

problems identified by the OIG, GAO, other management 

reports, and the management environment within each 

office. CFTC has worked vigorously to continually improve its

controls program and assess its effectiveness at accomplishing 

the FMFIA requirements. Examples of some of the FY 2022

work performed to support the assessment of compliance 

with FMFIA and Internal Controls over Reporting (ICOR) 

include, but are not limited to, the following:

■ Implementation of the Data Quality Plan (DQP) to 

ensure data quality, assessment, and reconciliation of 

quarterly spending data submitted in compliance with 

the Digital Accountability and Transparency Act of 2014 

(Data Act);

■ Improper payment risk assessments to identify and reduce 

the risk of improper payments based on the Payment 

Integrity Information Act of 2019;

■ Pay and benefits assessment based on the authority of 

Section 10702 of the Public Law 107-171, Farm Security 

and Rural Investment Act of 2002;

■ Management and internal control reviews conducted 

with the express purpose of assessing internal controls;

■ Management control reviews conducted with the express 

purpose of assessing compliance with applicable laws, 

regulations, and government-wide policies; and

■ Information security compliance as required by the 

Federal Information Security Management Act (FISMA)

FY 2022 Agency Financial Re

42 Commodity Futures Trading Commissio
FMFIA Section 2, Managem

The Commission has no declared material weaknesses under 

FMFIA for FY 2022 and FY 2021 in the administrative controls 

and internal controls over reporting that prevented reliable 

financial reporting, effective and efficient operations, and 

compliance with applicable laws and regulations

FMFIA Section 4, Fi

Management Sy

The Commission declared no nonconformance within 

our financial systems under FMFIA during FY 2022 and 

FY 2021. The independent auditors’ reports for FY 2022

and 2021 disclosed no instances of noncompliance or other 

matters within our financial systems that were required 

to be reported under Generally Accepted Government 

Auditing Standards (GAGAS) and OMB Bulletin 22-01, Audit 

Requirements for Federal Financial Statements

FFMIA, Financial Managemen

As an agency reporting under the Accountability of Tax Dollars 

Act of 2002, the Commission is not subject to the requirements 

of FFMIA. However, based on the robust assessments that

the Commission has conducted to ensure compliance with 

FMFIA, CFTC is able to elect to provide reasonable assurance 

that its financial management systems comply with:

■ Federal financial management system requirements;

■ Applicable Federal accounting standards; and

■ The U.S. Standard General Ledger (USSGL) at th

transaction level

Summary f Current Financial 

and Future Strate

Since FY 2007, the CFTC has leveraged a financial 

management systems platform operated by the U.

Department of Transportation’s Enterprise Services Center 

(ESC), an OMB-designated financial management service 

provider. The Commission implemented an integrated

end-to-end procurement management system through ESC, 

which provides a timely, efficient and consistent contract 

management process and facilitates required DATA Act 

reporting. As a result, the CFTC is able to accumulate,

analyze, and present reliable financial information, provide 

timely information for managing current operations and 

reporting financial information to central agencies, and comply 

with government-wide requirements. The Commission’s

financial management systems strategy for FY 2023 includes 

the continued monitoring, evaluation and oversight of the 

financial management system operated by its shared services 

provider. This will include ensuring that the Commission

has complied with the Treasury mandate to use the new 

G-Invoicing solution for buy/sell activity with other federal 

entities beginning in FY 2023

FY 2022 Agency Financial Re

 Commodity Futures Trading Commission 4

M A N A G E M E N T ’ S D I S C U S S I O N A N D A N A LY S I S
FY 2022 Agency Financial Re

44 Commodity Futures Trading Commissio

THIS PAGE LEFT INTENTIONALLY BLANK
Financial Section

Section Page

A LETTER FROM THE CHIEF 

FINANCIAL OFFICER 47

REPORT OF THE INDEPENDENT AUDITOR 48

PRINCIPAL FINANCIAL STATEMENTS 54

NOTES TO THE FINANCIAL STATEMENTS 60

REQUIRED SUPPLEMENTARY 

INFORMATION (UNAUDITED) 77
FY 2022 Agency Financial Re
On behalf of the CFTC, it is an honor to present 

the Commission’s FY 2022 Agency Financial 

Report (AFR). The AFR provides essential

financial, organizational, and performance information to 

the Congress and the American public about the CFTC’s 

stewardship responsibilities to use, track, and manage 

public funds.

As in years past, the performance of these fiduciary 

responsibilities did not come without challenges. The ability

to authorize spending, oversee the execution of the budget, 

and ensure timely and accurate recording of financial events 

required strict adherence to policy and application of 

procedures. FY 2022 continued to present unique challenges

that tested the execution of the Commission’s public service 

responsibilities. Their efforts, despite the difficult

environment, led the agency to a place of improved financial 

management and greater accountability

I am pleased to report that the Office of the Inspector 

General’s independent auditor has issued an unmodified 

opinion on our FY 2022 financial statements. The audit result

represents the Commission’s sixteenth unmodified opinion

I am also pleased to announce that the auditor’s review of 

our internal controls revealed no material weaknesses or 

significant deficiencies in our controls’ design or operations

In FY 2022, the Commission was recognized by the 

Association of Government Accountants with the 

distinguished Certificate of Excellence in Accountability 

Reporting (CEAR) for its FY 2021 AFR

12

In closing, I would like to thank the Commission’s Leadership, 

the Financial Management team, and key staff across the 

agency for their diligence and dedication to public service

Joel Mattingley

Chief Financial Officer

November 15, 2022

Certificate of Excellence in

Accountability Reporting®

in recognition of outstanding effort in preparing the 

Agency Financial Report for fiscal year 2021

presented to the

Ann M. Ebberts, MS, PMP

Chief Executive Officer, AGA

Diane L. Dudley, CGFM, CPA

Chair, CEAR Board

U.S. Commodity Futures 

Trading Commission

12 Additional information regarding the CEAR program may be found on the AGA’s 

website at https://www.agacgfm.org/Standards/CEAR.aspx

A Letter from the Chief Financi

 Commodity Futures Trading Commission 4
Independent Auditor’s Report

Chairman

U.S. Commodity Futures Trading Commission 

Inspector General 

U.S. Commodity Futures Trading Commission 

In our audits of the fiscal years 2022 and 2021 financial statements of the U.S. Commodity Futures 

Trading Commission (CFTC), we found: 

• CFTC’s financial statements as of and for the fiscal years ended September 30, 2022, and 2021,

are presented fairly, in all material respects, in accordance with U.S. generally accepted

accounting principles;

• no material weaknesses in internal control over financial reporting based on the limited

procedures we performed1

; and

• no reportable noncompliance for fiscal year 2022 with provisions of applicable laws,

regulations, contracts, and grant agreements we tested.

The following sections discuss in more detail (1) our report on the financial statements, which 

includes an emphasis-of-matter paragraph related to unfunded liability, required supplementary 

information (RSI)2 and other information included with the financial statements3

; (2) our report on 

internal control over financial reporting; (3) our report on compliance with laws, regulations, 

contracts, and grant agreements; and (4) agency comments.

Report on the Financial Statements 

Opinion

In accordance with Government Auditing Standards issued by the Comptroller General of the 

United States; and OMB Bulletin No. 22-01, Audit Requirements for Federal Financial 

Statements, we have audited CFTC’s financial statements. CFTC’s financial statements comprise 

1 A material weakness is a deficiency, or combination of deficiencies, in internal control over financial reporting, such that there

is a reasonable possibility that a material misstatement of the entity’s financial statements will not be prevented, or detected and 

corrected, on a timely basis. A deficiency in internal control exists when the design or operation of a control does not allow

management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, 

misstatements on a timely basis.

2 The RSI consists of the “Management’s Discussion and Analysis” and the “Combined Statement of Budgetary Resources”,

which are included with the financial statements.

3 Other information consists of information included with the financial statements, other than the RSI and the auditor’s report.

WILLIAMS, ADLEY & COMPANY-DC, LLP

Certified Public Accountants/ Management Consultants 

1030 15th Street, NW, Suite 350 West • Washington, DC 20005 • (202) 371-1397 • Fax: (202) 371-9161 

www.williamsadley.com

FY 2022 Agency Financial Re

48 Commodity Futures Trading Commissio

Report of the Independent 
the balance sheets as of September 30, 2022, and 2021; the related statements of net cost, changes 

in net position, budgetary resources, and custodial activity for the fiscal years then ended; and the 

related notes to the financial statements. In our opinion, CFTC’s financial statements present fairly, 

in all material respects, CFTC’s financial position as of September 30, 2022, and 2021, and its net 

cost of operations, changes in net position, budgetary resources, custodial activity for the fiscal 

years then ended in accordance with U.S. generally accepted accounting principles. 

Basis for Opinion 

We conducted our audits in accordance with auditing standards generally accepted in the U.S. and

the U.S. generally accepted government auditing standards. Our responsibilities under those 

standards are further described in the Auditor’s Responsibilities for the Audit of the Financial 

Statements section of our report. We are required to be independent of CFTC and to meet our other 

ethical responsibilities, in accordance with the relevant ethical requirements relating to our audit. 

We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis 

for our audit opinion. 

Emphasis of Matter 

As shown in the Balance Sheet at September 30, 2021, and discussed in Notes 6 and 8 to the 

financial statements, CFTC recorded an unfunded liability of $203,970,000. Such unfunded award 

resulted in a total negative Cumulative Results of Operations of $101,152,016 at September 30, 

2021. Upon approval by the Commission in October 2021, this whistleblower award became a 

funded liability, instead of an unfunded one. Our opinion is not modified for this matter. 

Responsibilities of Management for the Financial Statements 

CFTC management is responsible for (1) the preparation and fair presentation of these financial 

statements in accordance with U.S. generally accepted accounting principles; (2) preparing, 

measuring, and presenting the RSI in accordance with U.S. generally accepted accounting 

principles; (3) preparing and presenting other information included in CFTC’s Agency Financial 

Report, and ensuring the consistency of that information with the audited financial statements and 

the RSI; and (4) designing, implementing, and maintaining effective internal control relevant to 

the preparation and fair presentation of financial statements that are free from material 

misstatement, whether due to fraud or error. 

Auditor’s Responsibilities for the Audit of the Financial Statements 

Our objectives are to obtain reasonable assurance about whether the financial statements as a whole 

are free from material misstatement, whether due to fraud or error, and to issue an auditor’s report 

that includes our opinion. Reasonable assurance is a high level of assurance but is not absolute 

assurance and therefore is not a guarantee that an audit of the financial statements conducted in 

accordance with U.S. generally accepted government auditing standards will always detect a 

material misstatement or a material weakness when it exists. The risk of not detecting a material 

misstatement resulting from fraud is higher than for one resulting from error, as fraud may involve 

collusion, forgery, intentional omissions, misrepresentations, or the override of internal control. 

Misstatements, including omissions, are considered to be material if there is a substantial 

likelihood that, individually or in the aggregate, they would influence the judgment made by a 

reasonable user based on the financial statements. 

FY 2022 Agency Financial Re

 Commodity Futures Trading Commission 4

F I N A N C I A L S E C T I O N
In performing an audit in accordance with U.S. generally accepted government auditing standards, 

we: 

• Exercise professional judgment and maintain professional skepticism throughout the audit. 

• Identify and assess the risks of material misstatement of the financial statements, whether due 

to fraud or error, and design and perform audit procedures responsive to those risks. Such 

procedures include examining, on a test basis, evidence regarding the amounts and disclosures 

in the financial statements in order to obtain audit evidence that is sufficient and appropriate 

to provide a basis for our opinion. 

• Obtain an understanding of internal control relevant to our audit of the financial statements in 

order to design audit procedures that are appropriate in the circumstances, but not for the 

purpose of expressing an opinion on the effectiveness of CFTC’s internal control over financial 

reporting. Accordingly, no such opinion is expressed. 

• Evaluate the appropriateness of accounting policies used and the reasonableness of significant 

accounting estimates made by management, as well as evaluate the overall presentation of the 

financial statements. 

• Perform other procedures we consider necessary in the circumstances. 

We are required to communicate with those charged with governance regarding, among other 

matters, the planned scope and timing of the audit, significant audit findings, and certain internal 

control–related matters that we identified during the financial statement audit. 

Required Supplementary Information 

U.S. generally accepted accounting principles issued by the Federal Accounting Standards 

Advisory Board (FASAB) require that the RSI be presented to supplement the financial statements. 

Such information is the responsibility of management and, although not a part of the financial 

statements, is required by FASAB, which considers it to be an essential part of financial reporting 

for placing the financial statements in appropriate operational, economic, or historical context. We 

have applied certain limited procedures to the RSI in accordance with U.S. generally accepted 

government auditing standards, which consisted of inquiries of management about the methods of 

preparing the RSI and comparing the information for consistency with management’s responses 

to the auditor’s inquiries, the financial statements, and other knowledge we obtained during the 

audit of the financial statements, in order to report omissions or material departures from FASAB 

guidelines, if any, identified by these limited procedures. We did not audit and we do not express 

an opinion or provide any assurance on the RSI because the limited procedures we applied do not 

provide sufficient evidence to express an opinion or provide any assurance. 

Other Information 

CFTC’s other information contains a wide range of information, some of which is not directly 

related to the financial statements. This information is presented for purposes of additional analysis 

and is not a required part of the financial statements or the RSI. Management is responsible for the 

other information included in CFTC’s Agency Financial Report. The other information comprises 

the Inspector General’s Assessment, Summary of Audit and Management Assurances, and Civil 

FY 2022 Agency Financial Re

50 Commodity Futures Trading Commissio
Monetary Penalty Adjustment for Inflation but does not include the financial statements and our 

auditor’s report thereon. Our opinion on the financial statements does not cover the other 

information, and we do not express an opinion or any form of assurance thereon. 

In connection with our audit of the financial statements, our responsibility is to read the other 

information and consider whether a material inconsistency exists between the other information 

and the financial statements, or the other information otherwise appears to be materially misstated. 

If, based on the work performed, we conclude that an uncorrected material misstatement of the 

other information exists, we are required to describe it in our report. 

Report on Internal Control over Financial Reporting 

In connection with our audits of CFTC’s financial statements, we considered CFTC’s internal 

control over financial reporting, consistent with our auditor’s responsibilities discussed below. 

Results of Our Consideration of Internal Control over Financial Reporting 

Our consideration of internal control was for the limited purpose described below and was not 

designed to identify all deficiencies in internal control that might be material weaknesses or 

significant deficiencies4 or to express an opinion on the effectiveness of CFTC’s internal control 

over financial reporting. Given these limitations, during our audit, we did not identify any 

deficiencies in internal control over financial reporting that we consider to be material weaknesses. 

However, material weaknesses or significant deficiencies may exist that have not been identified. 

Basis for Results of Our Consideration of Internal Control over Financial Reporting 

We performed our procedures related to CFTC’s internal control over financial reporting in 

accordance with U.S. generally accepted government auditing standards. 

Responsibilities of Management for Internal Control over Financial Reporting 

CFTC management is responsible for designing, implementing, and maintaining effective internal 

control over financial reporting relevant to the preparation and fair presentation of financial 

statements that are free from material misstatement, whether due to fraud or error. 

Auditor’s Responsibilities for Internal Control over Financial Reporting 

In planning and performing our audit of CFTC’s financial statements as of and for the fiscal year 

ended September 30, 2022, in accordance with U.S. generally accepted government auditing 

standards, we considered CFTC’s internal control relevant to the financial statement audit in order 

to design audit procedures that are appropriate in the circumstances, but not for the purpose of 

expressing an opinion on the effectiveness of CFTC’s internal control over financial reporting. 

Accordingly, we do not express an opinion on CFTC’s internal control over financial reporting. 

We are required to report all deficiencies that are considered to be significant deficiencies or 

material weaknesses. We did not consider all internal controls relevant to operating objectives, 

4 A significant deficiency is a deficiency, or a combination of deficiencies, in internal control over financial reporting that is less 

severe than a material weakness, yet important enough to merit attention by those charged with governance.

FY 2022 Agency Financial Re

 Commodity Futures Trading Commission 5

F I N A N C I A L S E C T I O N
such as those controls relevant to preparing performance information and ensuring efficient 

operations. 

Definition and Inherent Limitations of Internal Control over Financial Reporting 

An entity’s internal control over financial reporting is a process effected by those charged with 

governance, management, and other personnel, the objectives of which are to provide reasonable 

assurance that (1) transactions are properly recorded, processed, and summarized to permit the 

preparation of financial statements in accordance with U.S. generally accepted accounting 

principles, and assets are safeguarded against loss from unauthorized acquisition, use, or 

disposition, and (2) transactions are executed in accordance with provisions of applicable laws, 

including those governing the use of budget authority, regulations, contracts, and grant 

agreements, noncompliance with which could have a material effect on the financial statements. 

Because of its inherent limitations, internal control over financial reporting may not prevent, or 

detect and correct, misstatements due to fraud or error. 

Intended Purpose of Report on Internal Control over Financial Reporting 

The purpose of this report is solely to describe the scope of our consideration of CFTC’s internal 

control over financial reporting and the results of our procedures, and not to provide an opinion on 

the effectiveness of CFTC’s internal control over financial reporting. This report is an integral part 

of an audit performed in accordance with U.S. generally accepted government auditing standards 

in considering internal control over financial reporting. Accordingly, this report on internal control 

over financial reporting is not suitable for any other purpose. 

Report on Compliance with Laws, Regulations, Contracts, and Grant Agreements 

In connection with our audits of CFTC’s financial statements, we tested compliance with selected 

provisions of applicable laws, regulations, contracts, and grant agreements consistent with our 

auditor’s responsibilities discussed below. 

Results of Our Tests for Compliance with Laws, Regulations, Contracts, and Grant Agreements 

Our tests for compliance with selected provisions of applicable laws, regulations, contracts, and 

grant agreements disclosed no instances of noncompliance for fiscal year 2022 that would be 

reportable under U.S. generally accepted government auditing standards. However, the objective 

of our tests was not to provide an opinion on compliance with laws, regulations, contracts, and 

grant agreements applicable to CFTC. Accordingly, we do not express such an opinion. 

Basis for Results of Our Tests for Compliance with Laws, Regulations, Contracts, and Grant 

Agreements 

We performed our tests of compliance in accordance with U.S. generally accepted government 

auditing standards. Our responsibilities under those standards are further described in the Auditor’s 

Responsibilities for Tests of Compliance section below. 

FY 2022 Agency Financial Re

52 Commodity Futures Trading Commissio
Responsibilities of Management for Compliance with Laws, Regulations, Contracts, and Grant 

Agreements 

CFTC management is responsible for complying with laws, regulations, contracts, and grant 

agreements applicable to CFTC.

Auditor’s Responsibilities for Tests of Compliance with Laws, Regulations, Contracts, and Grant 

Agreements 

Our responsibility is to test compliance with selected provisions of applicable laws, regulations, 

contracts, and grant agreements applicable to CFTC that have a direct effect on the determination 

of material amounts and disclosures in CFTC’s financial statements, and to perform certain other 

limited procedures. Accordingly, we did not test compliance with all laws, regulations, contracts, 

and grant agreements applicable to CFTC. We caution that noncompliance may occur and not be 

detected by these tests. 

Intended Purpose of Report on Compliance with Laws, Regulations, Contracts, and Grant 

Agreements 

The purpose of this report is solely to describe the scope of our testing of compliance with selected 

provisions of applicable laws, regulations, contracts, and grant agreements, and the results of that 

testing, and not to provide an opinion on compliance. This report is an integral part of an audit 

performed in accordance with U.S. generally accepted government auditing standards in 

considering compliance. Accordingly, this report on compliance with laws, regulations, contracts, 

and grant agreements is not suitable for any other purpose. 

Washington, District of Columbia

November 10, 2022

FY 2022 Agency Financial Re

 Commodity Futures Trading Commission 5

F I N A N C I A L S E C T I O N
Commodity Futures Trading Commission

Balance Sh

As of September 30, 2022 and 2021

2022 2021

ASSETS

Intragovernmental:

Fund Balance with Treasury (Note 2) $ 174,854,209 $ 207,788,240

Federal Investments (Note 3) 286,000,000 –

Advances and Prepayments (Note 1H) 3,383,000 9,706,678

Total Intragovernmental $ 464,237,209 $ 217,494,918

With the Public:

Accounts Receivable, Net:

Custodial Fines and Interest Receivable, Net (Note 4) $ 659,190,181 $ 34,377,723

Accounts Receivable, Net (Note 4) 27,175 26,983

General Property, Plant, and Equipment, Net (Note 5) 39,477,653 25,618,531

Advances and Prepayments (Note 1H) 3,257,433 3,988,894

Total With the Public $ 701,952,442 $ 64,012,131

TOTAL ASSETS $1,166,189,651 $ 281,507,049

LIABILITIES

Intragovernmental:

Accounts Payable $ 5,512,199 $ 3,392,772

Other Liabilities:

Employer Contributions and Payroll Taxes Payable 2,099,711 1,779,989

Unfunded FECA and Unemployment Liability (Note 1N) 83,864 89,587

Other Liabilities (Without Reciprocals) 307,247 286,668

Deferred Lease Liabilities (Note 7) 4,394,626 725,714

Liability to the General Fund of the U.S. Government for Custodial Assets 659,190,181 34,377,723

Total Intragovernmental $ 671,587,828 $ 40,652,453

With the Public:

Accounts Payable $ 11,090,625 $ 7,815,877

Federal Employee Benefits Payable:

Actuarial FECA Liabilities (Note 1N) 499,005 533,782

Unfunded Annual Leave 17,747,317 18,531,860

Funded Employee Benefits 403,232 339,165

Other Liabilities:

Accrued Funded Payroll 8,610,471 7,560,778

Liability for Non-Fiduciary Deposit Funds 73,353 595,476

Deferred Lease Liabilities (Note 7) 11,308,599 15,200,011

Liability for Whistleblower Awards (Note 8) 45,000 203,970,000

Total With the Public $ 49,777,602 $ 254,546,949

Total Liabilities $ 721,365,430 $ 295,199,402

 Contingent Liabilities (Note 9)

Principal Financial Statemen

 continued on next page

54 Commodity Futures Trading Commissio
2022 2021

NET POSITION

Unexpended Appropriations – Funds from Other than Dedicated Collections $ 137,086,524 $ 87,459,663

Total Unexpended Appropriations $ 137,086,524 $ 87,459,663

Cumulative Results of Operations – Funds from Dedicated Collections $ 301,921,114 $ (92,073,033)

Cumulative Results of Operations – Funds from Other than Dedicated Collections 5,816,583 (9,078,983)

Total Cumulative Results of Operations $ 307,737,697 $ (101,152,016)

Total Net Position $ 444,824,221 $ (13,692,353)

TOTAL LIABILITIES AND NET POSITION $1,166,189,651 $ 281,507,049

The accompanying notes are an integral part of these financial statements. 

Balance Sheets continued from previous page

FY 2022 Agency Financial Re

 Commodity Futures Trading Commission 5

F I N A N C I A L S E C T I O N
Commodity Futures Trading Commission

Statemets 

For the Years Ended September 30, 2022 and 2021

2022 2021

NET COST BY GOAL

STRATEGIC GOAL 1: STRENGTHEN DERIVATIVES MARKETS & FOSTER THEIR VIBRANCY

Gross Costs $ 56,528,423 $ 54,950,470

Less: Earned Revenue (8,464) –

NET COST OF OPERATIONS – STRATEGIC GOAL 1 $ 56,519,959 $ 54,950,470

STRATEGIC GOAL 2: REGULATE DERIVATIVES MARKETS IN INTEREST OF ALL AMERICANS

Gross Costs $ 55,247,419 $ 46,228,173

Less: Earned Revenue (8,272) –

NET COST OF OPERATIONS – STRATEGIC GOAL 2 $ 55,239,147 $ 46,228,173

STRATEGIC GOAL 3: ENCOURAGE INNOVATION & ENHANCE REGULATORY EXPERIENCE OF ALL

Gross Costs $ 44,375,305 $ 44,016,448

Less: Earned Revenue (6,644) –

NET COST OF OPERATIONS – STRATEGIC GOAL 3 $ 44,368,661 $ 44,016,448

STRATEGIC GOAL 4: BE TOUGH ON THOSE WHO BREAK THE RULES

Gross Costs $ 84,373,035 $ 285,505,184

Less: Earned Revenue (12,629) –

NET COST OF OPERATIONS – STRATEGIC GOAL 4 $ 84,360,406 $ 285,505,184

STRATEGIC GOAL 5: FOCUS ON UNIQUE MISSION & IMPROVE OPERATIONAL EFFECTIVENESS

Gross Costs $ 87,962,299 $ 84,201,315

Less: Earned Revenue (13,170) –

NET COST OF OPERATIONS – STRATEGIC GOAL 5 $ 87,949,129 $ 84,201,315

GRAND TOTAL

Gross Costs $ 328,486,481 $ 514,901,590

Less: Earned Revenue (49,179) –

TOTAL NET COST OF OPERATIONS $ 328,437,302 $ 514,901,590

The accompanying notes are an integral part of these financial statements. 

FY 2022 Agency Financial Re

56 Commodity Futures Trading Commissio
Commodity Futures Trading Commission

Statemets of Changes i

For the Years Ended September 30, 2022 and 2021

2022 DEDICATED 

COLLECTIONS

ALL OTHER 

FUNDS

CONSOLIDATED 

TOTAL

UNEXPENDED APPROPRIATIONS:

BEGINNING BALANCES $ – $ 87,459,663 $ 87,459,663

Appropriations Received – 382,000,000 382,000,000

Other Adjustments (+/-) – (1,750,242) (1,750,242)

Appropriations Used – (330,622,897) (330,622,897)

Net Change in Unexpended Appropriations – 49,626,861 49,626,861

TOTAL UNEXPENDED APPROPRIATIONS, ENDING $ – $ 137,086,524 $ 137,086,524

CUMULATIVE RESULTS OF OPERATIONS:

BEGINNING BALANCES $ (92,073,033) $ (9,078,983) $ (101,152,016)

Appropriations Used – 330,622,897 330,622,897

Nonexchange Interest Revenue (Note 3) 1,350,097 – 1,350,097

Financing Sources Transferred in from 

Custodial Statement Collections (Note 12) 398,498,439 – 398,498,439

Transfers In/Out Without Reimbursement – – –

Imputed Financing Sources (Note 1M) – 6,855,582 6,855,582

Net Cost of Operations (5,854,389) (322,582,913) (328,437,302)

Net Change in Cumulative Results of Operations 393,994,147 14,895,566 408,889,713

TOTAL CUMULATIVE RESULTS OF OPERATIONS, ENDING $ 301,921,114 $ 5,816,583 $ 307,737,697

NET POSITION $ 301,921,114 $ 142,903,107 $ 444,824,221

2021 DEDICATED 

COLLECTIONS

ALL OTHER 

FUNDS

CONSOLIDATED 

TOTAL

UNEXPENDED APPROPRIATIONS:

BEGINNING BALANCES $ – $ 86,262,124 $ 86,262,124

Appropriations Received – 304,000,000 304,000,000

Other Adjustments (+/-) – (3,057,910) (3,057,910)

Appropriations Used – (299,744,551) (299,744,551)

Net Change in Unexpended Appropriations – 1,197,539 1,197,539

TOTAL UNEXPENDED APPROPRIATIONS, ENDING $ – $ 87,459,663 $ 87,459,663

CUMULATIVE RESULTS OF OPERATIONS:

BEGINNING BALANCES $ 117,027,972 $ (9,637,096) $ 107,390,876

Appropriations Used – 299,744,551 299,744,551

Nonexchange Interest Revenue (Note 3) 53,886 – 53,886

Financing Sources Transferred in from 

Custodial Statement Collections (Note 12) – – –

Transfers In/Out Without Reimbursement – 12,419 12,419

Imputed Financing Sources (Note 1M) – 6,547,842 6,547,842

Net Cost of Operations (209,154,891) (305,746,699) (514,901,590)

Net Change in Cumulative Results of Operations (209,101,005) 558,113 (208,542,892)

TOTAL CUMULATIVE RESULTS OF OPERATIONS, ENDING $ (92,073,033) $ (9,078,983) $ (101,152,016)

NET POSITION $ (92,073,033) $ 78,380,680 $ (13,692,353)

The accompanying notes are an integral part of these financial statements. 

FY 2022 Agency Financial Re

 Commodity Futures Trading Commission 5

F I N A N C I A L S E C T I O N
Commodity Futures Trading Commission

Statemets of Budget

For the Years Ended September 30, 2022 and 2021

2022 2021

BUDGETARY RESOURCES

Unobligated Balance from Prior Year Budget Authority, Net (Note 10A) $ 52,805,900 $ 51,006,213

Appropriations 382,000,000 304,000,000

Spending Authority from Offsetting Collections 377,106,348 63,234

TOTAL BUDGETARY RESOURCES $ 811,912,248 $ 355,069,447

STATUS OF BUDGETARY RESOURCES

New Obligations and Upward Adjustments $ 511,348,819 $ 303,467,595

Unobligated Balance, End of Year

Apportioned, Unexpired Accounts 350,040,567 123,018,339

Unapportioned, Unexpired Accounts (57,983,358) (80,060,414)

Unexpired Unobligated Balance, End of Year 292,057,209 42,957,925

Expired Unobligated Balance, End of Year 8,506,220 8,643,927

Unobligated Balance, End of Year (Total) 300,563,429 51,601,852

TOTAL BUDGETARY RESOURCES $ 811,912,248 $ 355,069,447

OUTLAYS, NET

Outlays, Net $ 126,661,665 $ 314,164,705

Distributed Offsetting Receipts (15,850) (37,264)

AGENCY OUTLAYS, NET $ 126,645,815 $ 314,127,441

The accompanying notes are an integral part of these financial statements.

FY 2022 Agency Financial Re

58 Commodity Futures Trading Commissio
Commodity Futures Trading Commission

Statemets of Custo

For the Years Ended September 30, 2022 and 2021

2022 2021

TOTAL CUSTODIAL REVENUE

SOURCES OF CASH COLLECTIONS:

Registration and Filing Fees $ 1,141,644 $ 1,310,369

Fines, Penalties, and Forfeitures 603,561,798 545,527,184

General Proprietary Receipts 15,850 37,264

Total Cash Collections 604,719,292 546,874,817

Change in Custodial Receivables 624,812,458 (588,956,235)

TOTAL CUSTODIAL REVENUE $ 1,229,531,750 $ (42,081,418)

DISPOSITION OF COLLECTIONS

AMUNS

Department of the Treasury $ (206,220,853) $ (546,874,817)

CFTC Customer Protection Fund (398,498,439) –

Total Disposition of Collections (604,719,292) (546,874,817)

Change in Custodial Liabilities (624,812,458) 588,956,235

NET CUSTODIAL ACTIVITY $ – $ –

The accompanying notes are an integral part of these financial statements.

FY 2022 Agency Financial Re

 Commodity Futures Trading Commission 5

F I N A N C I A L S E C T I O N
Note 1. Summary of Significant 

Accounting Policies

A. Reporting Entity

The Commodity Futures Trading Commission (CFTC or 

Commission) is an independent agency of the executive 

branch of the Federal government. Congress created the

CFTC in 1974 under the authorization of the Commodity 

Exchange Act (CEA) with the mandate to regulate commodity 

futures and option markets in the United States. The agency’s

mandate was renewed and expanded under the Futures 

Trading Acts of 1978, 1982, and 1986; the Futures Trading 

Practices Act of 1992; the CFTC Reauthorization Act of 1995; 

the Commodity Futures Modernization Act of 2000; and the 

Dodd-Frank Wall Street Reform and Consumer Protection 

Act of 2010 (Dodd-Frank Act, or the Act). Congress passed

the Food, Conservation, and Energy Act of 2008, which 

reauthorized the Commission through FY 2013. In the

absence of formal reauthorization, the CFTC has continued 

to operate through annual appropriations

The CFTC is responsible for ensuring the economic utility of 

futures markets by encouraging their competitiveness and 

efficiency, ensuring their integrity, and protecting market 

participants against manipulation, abusive trade practices, 

and fraud

The Dodd-Frank Act significantly expanded the powers and 

responsibilities of the CFTC. According to Section 748 of

the Act, there is established in the U.S. Department of th

Treasury (Treasury) a revolving fund known as the CFTC 

Customer Protection Fund. The Customer Protection Fund

shall be available to the Commission, without further 

appropriation or fiscal year limitation, for the payment 

of awards to whistleblowers; and the funding of customer 

education initiatives designed to help customers protect 

themselves against fraud or other violations of this Act or 

the rules and regulations thereunder

B. Basis of Presentation

The financial statements have been prepared to report the 

financial position and results of operations for the CFTC, as 

required by the Accountability of Tax Dollars Act of 2002

They are presented in accordance with the form and content 

requirements contained in OMB Circular A- 136, Financial 

Reporting Requirements

The financial statements have been prepared in all material 

respects in conformity with U.S. generally accepted accountin

principles (GAAP), as prescribed for the Federal government 

by the Federal Accounting Standards Advisory Board (FASAB)

The application and methods for applying these principles 

are appropriate for fairly presenting the entity’s assets, liabilities, financial position, net cost of operations, changes in 

net position, budgetary resources, and custodial activities

Accounting standards require all reporting entities to disclose 

that accounting standards allow certain presentations and 

disclosures to be modified, if needed, to prevent the disclosure 

of classified information

The books and records of the agency served as the source 

of information for preparing the financial statements in the 

prescribed formats. All agency financial statements and reports

used to monitor and control budgetary resources are prepared 

from the same books and records. The statements should be

read with the understanding that they are for a component of 

the U.S. governme

The Balance Sheets present the financial position of the agency

The Statements of Net Cost present the agency’s operating 

results and the Statements of Changes in Net Position display 

the changes in the agency’s net position. The Statements of

Budgetary Resources present the sources, status, and uses of the 

agency’s resources and follow the rules for the Budget of the 

U.S. governmen.  The Statements of Custodial Activity prese

the sources and disposition of collections for which the CFTC 

is the fiscal agent, or custodian, for the Treasury General Fund 

Miscellaneous Receipt accounts

FY 2022 Agency Financial Re

60 Commodity Futures Trading Commissio

Notes to the Financial Statem

As of and for the Years Ended September 30, 2022 and 2021
D. Entity and Non-Entity Assets 

Assets consist of entity and non-entity assets. Entity assets

are those assets that the CFTC has authority to use for its 

operations. Non-entity assets are those held by the CFTC

that are not available for use in its operations, such as deposit 

fund balances and custodial fines, interest, penalties, and 

administrative fees receivable

E. Fund Balance with Treasury 

Fund Balance with Treasury is the aggregate amount of the 

CFTC’s funds with Treasury in general, receipt, revolving, 

and deposit fund accounts. Appropriated funds recorded in

general fund expenditure accounts are available to pay current 

liabilities and finance authorized purchases. Custodial

collections recorded in the deposit fund and miscellaneous 

receipts accounts of the Treasury are not available for agency 

use. At fiscal year-end, receipt account balances that have

not been transferred to the Customer Protection Fund are 

returned to Treasury

The CFTC does not maintain bank accounts of its own, has 

no disbursing authority, and does not maintain cash held 

outside of Treasury. Treasury disburses funds for the agency

on demand. Spending authority from offsetting collections is

recorded in the agency’s expenditure account and is available 

for agency use subject to certain limitations. Additional

information regarding the CFTC’s Fund Balance with Treasury 

is provided in Note 2, Fund Balance with Treasury

F. Investments

The CFTC is authorized to invest the portion of the 

Customer Protection Fund that is not, in the Commission’s 

judgment, required to meet the current needs of the Fund

The Commission invests available funds through the 

U.S. Department of the Treasury’s Bureau of the Fiscal Servi

Investments are carried at their historical cost basis which 

approximates fair value due to their short-term nature

Interest earned on the investments is a component of the 

Fund and is available to be used for expenses of the Customer 

Protection Fund. Additional information regarding Customer

Protection Fund investments are provided in Note 3, 

Investments.

Throughout these financial statements, assets, liabilities, 

revenues and costs have been classified according to the 

type of entity with whom the transactions were made

Intragovernmental assets and liabilities are those from 

or to other federal entities. Intragovernmental earned

revenues are collections or accruals of revenue from other 

federal entities, and intragovernmental costs are payments 

or accruals to other federal entities for goods and/or services 

provided. The CFTC does not transact business among its

own operating units, and therefore, intra-entity eliminations 

were not needed

C. Budgetary Resources and Status

The CFTC is funded through congressionally approved 

appropriations. The CFTC is responsible for administering

the salaries and expenses of the agency through the execution 

of these appropriations

Congress annually enacts appropriations that provide 

the CFTC with the authority to obligate funds within the 

respective fiscal year for necessary expenses to carry out 

program activities. All appropriations are subject to quarterly

apportionment as well as Congressional restrictions

The CFTC’s budgetary resources for FY 2022 consist of: 

■ Unobligated balances of resources brought forward 

from the prior year, 

■ Recoveries of obligations made in prior years, and 

■ New resources in the form of appropriations and 

spending authority from offsetting collections

Unobligated balances associated with resources expiring 

at the end of the fiscal year remain available for five years 

after expiration only for upward adjustments of prior year 

obligations, after which they are canceled and may not be 

used. All unused monies related to canceled appropriations

are returned to Treasury and the canceled authority is 

reported on the Statements of Budgetary Resources and the 

Statements of Changes in Net Position

FY 2022 Agency Financial Re

 Commodity Futures Trading Commission 6

F I N A N C I A L S E C T I O N
G. Accounts Receivable, Net 

The CFTC’s accounts receivable generally consists of amounts 

due from the public. The bulk of the CFTC’s accounts

receivable arise from the Civil Monetary Sanctions program 

and are reported on the Balance Sheet as “Custodial Fines 

and Interest Receivable, Net.” The CFTC is responsible for

collection, and recognizes a receivable, when an order of 

the Commission or a federal court directs payment to the 

CFTC. See Note 1T for additional information on the CFTC’s

custodial activity

The remainder of the CFTC’s accounts receivable, reported 

on the Balance Sheet as “Accounts Receivable, Net,” consists 

of amounts owed to the CFTC by other federal agencies and 

employees. The CFTC’s accounts receivable is valued net of

an allowance for uncollectible amounts that is based on past 

experience in the collection of receivables and analysis of the 

outstanding balances. Additional information is provided in

Note 4, Accounts Receivable, Net

H. Advances and Prepayments

Advances and Prepayments consist of payments to federal and 

non-federal sources in advance of the receipt of goods and 

services. These payments are recorded as prepayments and

recognized as expenses when the related goods and services 

are received. Intragovernmental prepayments reported on the

Balance Sheet were made primarily to the U.S. Department o

Interior for contract support. Prepayments to the public were

primarily for software maintenance and subscription services

I. General Property, Plant, and Equipment, Net

Furniture, fixtures, equipment, information technology 

hardware and software, and leasehold improvements are 

capitalized and depreciated or amortized over their useful lives

The CFTC capitalizes assets annually if they have useful lives of 

at least two years and an individual value of $25,000 or more

Bulk or aggregate purchases are capitalized when the individual 

useful lives are at least two years and the purchase is a value of 

$25,000 or more. Property, plant, and equipment that do not

meet the capitalization criteria are expensed when acquired

Depreciation for equipment and amortization for software is 

computed on a straight-line basis using a 5-year life. Leasehold

improvements are amortized over the remaining life of the 

lease. The Commission’s assets are valued net of accumulated

depreciation or amortization. Additional information is

provided in Note 5, General Property, Plant, and Equipment, Net

J. Liabilities

The CFTC’s liabilities include actual and estimated amounts 

that are likely to be paid as a result of transactions covered 

by budgetary resources for which Congress has appropriated 

funds or are otherwise available from reimbursable 

transactions to pay amounts due

In addition to those liabilities covered by budgetary resources 

in existing legislation, the CFTC’s liabilities also include those 

not requiring budgetary resources, and those not yet covered 

by budgetary resources. The CFTC liabilities not requiring

budgetary resources include deferred lease liabilities, deposit 

funds, and custodial revenue deemed collectible but not yet 

collected at fiscal year-end. Liabilities that are not yet covered

by budgetary resources but will require budgetary resources 

in the future include: 

■ Intragovernmental Federal Employees’ Compensation 

Act (FECA) liabilities,

■ Annual leave benefits that will be funded by annual 

appropriations as leave is taken,

■ Actuarial FECA liabilities,

■ Liability for whistleblower awards,

■ Contingent liabilities, and

■ Advances received for reimbursable services yet to 

be provided

Additional information is provided in Note 6, Liabilities not 

Covered by Budgetary Resources

K. Accounts Payable

Accounts payable consists primarily of liabilities for amounts 

due for goods and services received as of the end of the 

reporting period but not yet paid and whistleblower awards 

finalized by the Commission but not yet paid.

FY 2022 Agency Financial Re

62 Commodity Futures Trading Commissio
L. Accrued Payroll and Benefits 

and Annual Leave Liability

The accrued payroll liability represents amounts for salaries 

and benefits owed for the time since the payroll was last paid 

through the end of the reporting period. Total accrued payroll

is composed of amounts to be paid to CFTC employees as 

well as the related intragovernmental payable for employer 

contributions and payroll taxes. The annual leave liability is

the amount owed to employees for unused annual leave as of 

the end of the reporting period. At the end of each quarter,

the balance in the accrued annual leave account is adjusted 

to reflect current balances and pay rates. Sick leave and other

types of non-vested leave are expensed as taken

The agency’s employees participate in the Civil Service 

Retirement System (CSRS) or the Federal Employees’ 

Retirement System (FERS). On January 1, 1987, FERS went

into effect pursuant to Public Law 99-335. Most employees

hired after December 31, 1983, are automatically covered by 

FERS and Social Security. Employees hired prior to January 1,

1984, could elect to either join FERS and Social Security or 

remain in CSRS

For employees under FERS, the CFTC contributes an amount 

equal to one percent of the employee’s basic pay to the 

tax-deferred Thrift Savings Plan and matches employee 

contributions up to an additional four percent of pay. FERS and

CSRS employees can contribute a portion of their gross earnings 

to the plan up to Internal Revenue Service limits; however, 

CSRS employees receive no matching agency contribution

M. Retirement Plans and Other Employee Benefits

The CFTC imputes costs and the related financing sources for 

its share of retirement benefits accruing to its employees that 

are in excess of the amount of contributions and withholdings 

from the CFTC and its employees, which are mandated by 

law. The Office of Personnel Management (OPM), which

administers federal civilian retirement programs, provides 

the cost information to the CFTC. The CFTC recognizes the

government’s portion of the full cost of providing future 

pension and Other Retirement Benefits (ORB) for current 

employees as required by Statement of Federal Financial 

Accounting Standards (SFFAS) 5, Accounting for Liabilities of 

the Federal Government

Full costs include pension and ORB contributions paid out of 

the CFTC’s appropriations as well as costs financed by OPM

The amount financed by OPM is recognized as an imputed 

financing source. Reporting amounts such as plan assets,

accumulated plan benefits, or unfunded liabilities, if any, is 

the responsibility of OPM

Liabilities for future pension payments and other future 

payments for retired employees who participate in the 

Federal Employees Health Benefits Program and the Federal 

Employees Group Life Insurance Program are reported by 

OPM rather than CFTC

N. FECA and Unemployment Liabilities

FECA provides income and medical cost protections to covered 

federal civilian employees injured on the job, to employees 

who have incurred work-related occupational diseases and to 

beneficiaries of employees whose deaths are attributable to 

job-related injuries or occupational diseases. The FECA program

is administered by the U.S. Department of Labor (DOL), whic

pays valid claims against the CFTC and subsequently seeks 

reimbursement from the CFTC for these paid claims. DOL’s

Unemployment Compensation For Federal Employees (UCFE) 

program provides unemployment compensation for Federal 

employees who lost their employment through no fault of their 

own. Accrued FECA and unemployment liabilities represent

amounts due to DOL for claims paid on behalf of the agency

In addition, the Commission’s actuarial FECA liability 

represents the liability for future workers compensation 

benefits, which includes the expected liability for death, 

disability, medical, and miscellaneous costs for approved 

cases. The Commission records an estimate for the FECA

actuarial liability using the DOL’s FECA model. The model

considers the average amount of benefit payments incurred by 

the Commission for the past three fiscal years, multiplied by 

the medical and compensation liability to benefits paid ratio 

for the whole FECA program

O. Leases 

The CFTC does not have any capital lease liabilities. The

operating leases consist of commercial property for the 

CFTC’s headquarters and regional offices. Lease expenses are

recognized on a straight-line basis. Additional information

is provided in Note 7, Leases. 

FY 2022 Agency Financial Re

 Commodity Futures Trading Commission 6

F I N A N C I A L S E C T I O N
P. Deposit Funds 

Deposit funds are expenditure accounts used to record monies 

that do not belong to the Federal government. They are

held awaiting distribution based on a legal determination 

or investigation. The CFTC Deposit Fund is used to collect

and later distribute collections of monetary awards to the 

appropriate victims as restitution.  The cash collectio

recorded in this fund are offset by a Deposit Fund liability

Activities in this fund are not fiduciary in nature because they 

are not legally enforceable against the government.

Q. Net Position

Net position consists of unexpended appropriations and 

cumulative results of operations. Unexpended appropriations

are appropriations that have not yet been used to acquire 

goods and services or provide benefits. Appropriations are

considered expended, or used, when goods and services have 

been acquired by the CFTC or benefits have been provided 

using the appropriation authority, regardless of whether 

monies have been paid or payables for the goods, services, 

or benefits have been established

Cumulative results of operations represent the excess of 

financing sources over expenses since inception. Cumulative

results of operations are derived from the net effect of 

capitalized assets, expenses, and revenue and the balance can 

be negative when unfunded expenses exceed appropriations 

and other financing sources received as of the end of the 

reporting period

R. Revenues

The CFTC receives reimbursement and earns revenue for the 

following activities:

■ Reimbursement for travel, subsistence, and related 

expenses from non-federal sources for attendance at 

meetings or similar functions that an employee has been 

authorized to attend in an official capacity on behalf of 

the Commission; 

■ Reimbursement for Intergovernmental Personnel Act 

Mobility Program assignments from state and local 

governments, institutions of higher education, and other 

eligible organizations for basic pay, supplemental pay, 

fringe benefits, and travel and relocation expenses; and

■ Reimbursement from non-federal sources for registration 

fees to cover the cost of expenses related to the CFTC’s 

annual International Regulators Conference

S. Net Cost of Operations 

Net cost of operations is the difference between the CFTC’s 

expenses and its earned revenue. The presentation of program

results by strategic goal is based on the CFTC’s current Strategic 

Plan established pursuant to the Government Performance 

and Results Act of 1993 (GPRA)

The mission of the CFTC is to promote the integrity, resilience, 

and vibrancy of the U.S. derivatives markets through soun

regulation. For FY 2022, this mission was accomplished

through the following five strategic goals, each focusing on a 

vital area of regulatory responsibility:

■ Strategic Goal 1: Strengthen Derivatives Markets & Foster 

Their Vibrancy 

■ Strategic Goal 2: Regulate Derivatives Markets in Interest 

of All Americans

■ Strategic Goal 3: Encourage Innovation and Enhance 

Regulatory Experience of All 

■ Strategic Goal 4: Be Tough on Those Who Break the Rules 

■ Strategic Goal 5: Focus on Unique Mission and Improve 

Operational Effectiveness

T. Custodial Activity

The CFTC collects penalties and fines levied against firms 

for violation of laws as described in the CEA as codified 

at 7 U.S.C. § 1, et seq, and the Commodities Futur

Modernization Act of 2000, Appendix E of Public Law 

106-554, 114 Stat. 2763  Unpaid fines, penalties an

FY 2022 Agency Financial Re

64 Commodity Futures Trading Commissio
accrued interest are reported as custodial receivables, 

with an offsetting custodial liability, and therefore do not 

affect CFTC’s net cost or net position. The receivables

and the liability are reduced by amounts determined to 

be uncollectible. Revenues earned and the losses from

uncollectible accounts are reported to Treasury

Collections made by the CFTC during the year are deposited 

and reported into designated Treasury miscellaneous receipt 

accounts for: 

■ Registration and filing fees, 

■ Fines, penalties and forfeitures, and

■ General proprietary receipts

At fiscal year-end, custodial collections made by the CFTC 

that were not transferred to the Customer Protection Fund are 

returned to Treasury. The CFTC does not retain any portion

of custodial collections including reimbursement of the cost 

of collection

U. Use of Management Estimates 

The preparation of the accompanying financial statements in 

accordance with accounting principles generally accepted in 

the United States of America requires management to make 

certain estimates and assumptions that directly affect the results 

of reported assets, liabilities, revenues, expenses, and custodial 

activities. Actual results could differ from these estimate

V. Reconciliation of Net Outlays 

and Net Cost of Operations 

In accordance with OMB Circular A-136, the Commission 

reconciles its budgetary outlays with its net cost of operations 

(see Note 11)

W. Funds from Dedicated Collections

The Customer Protection Fund was established to operate 

a whistleblower program and support customer education 

initiatives. See Note 1A for a description of the purpose of the

Customer Protection Fund and its authority to use applicable 

financing sources. Deposits into the Customer Protection

Fund are credited from monetary sanctions collected by the 

Commission in a covered judicial or administrative action 

where the full judgment is in excess of $1,000,000 and the 

collection is not otherwise distributed to victims of a violation 

of the Dodd-Frank Act or the underlying rules and regulations, 

unless the balance of the Customer Protection Fund at the 

time the monetary judgment is collected exceeds $100,000,000

No new legislation was enacted as of September 30, 2022, that 

significantly changed the purpose of the Fund or redirected 

a material portion of the accumulated balance. On July 6,

2021, Public Law 117-25 set aside $10,000,000 from the 

Fund in a separate account to fund non-whistleblower costs 

when the unobligated balance of the Fund is insufficient

The $10,000,000 will be available until the account expires, 

at which time all unobligated amounts will be returned to 

the Fund

In October 2021, the Commission issued a final whistleblower 

award of nearly $200,000,000, resulting in an obligation that 

exceeded the available balance of the Fund. The Commission

has the authority to make obligations for whistleblower awards 

without taking into consideration the available balance of the 

Fund under the provisions of the Dodd-Frank Act. As a result,

the Commission obligated non-whistleblower costs from this 

separate account until the negative balance in the Fund was 

offset by current year collections of eligible sanctions

Additional information is provided in Note 12, Funds from 

Dedicated Collections.

X. Reclassifications 

Available and unavailable Fund Balance with Treasury amounts 

reported in the FY 2021 Note 2 have been reclassified to disclose 

amounts apportioned for subsequent quarters as “Unavailable” 

and unobligated amounts in expired accounts as “Available” 

for upward adjustments only

Narrative has been added to Note 2 to disclose the components 

contained within each of these categories, as required by OMB 

Circular A-136

FY 2022 Agency Financial Re

 Commodity Futures Trading Commission 6

F I N A N C I A L S E C T I O N
Note 2. Fund Balance with Treasury

A. Reconciliation to Treasury

There are no differences between the fund balances reflected 

in the CFTC Balance Sheets and the balances in the Treasury 

accounts

B. Fund Balance with Treasury

Fund Balance with Treasury as of September 30, 2022, and 

2021, consisted of the following:

2022 2021

Unobligated Fund Balance

Available $ 86,909,654 $ 105,677,826

Unavailable 9,134,931 26,667,767

Obligated Balance Not Yet Disbursed 78,736,271 74,847,171

Non-Budgetary Fund Balance with Treasury 73,353 595,476

TOTAL FUND BALANCE WITH TREASURY $ 174,854,209 $ 207,788,240

Obligated and unobligated balances reported for the status 

of Fund Balance with Treasury differ from the amounts 

reported in the Statement of Budgetary Resources due to the 

fact that budgetary balances are supported by amounts other 

than Fund Balance with Treasury. These amounts include

Customer Protection Fund investments and unfunded lease 

obligations

Available unobligated balances as of September 30, 2022, 

and 2021, include amounts available for new obligations 

of $78,403,435 and $96,350,572, respectively, as well as 

amounts in expired funds that are available only for upward 

adjustments to prior year obligations of $8,506,219 and 

$8,643,928, respectively. Available unobligated balances as

of September 30, 2021, also include temporarily sequestered 

funds in the Customer Protection Fund that are available for 

investment but not obligation of $683,326

Unavailable unobligated balances as of September 30, 2022, 

and 2021, include amounts that have been apportioned 

for use in subsequent reporting periods of $229,846 and 

$16,667,767, respectively, as well as funds that have been 

set aside in a separate account to fund non- whistleblower 

costs only when the unobligated balance of the Customer 

Protection Fund is insufficient of $8,881,977 and 

$10,000,000, respectively. Unavailable unobligated balances

as of September 30, 2022, also includes unapportioned 

amounts of $23,108

FY 2022 Agency Financial Re

66 Commodity Futures Trading Commissio
Note 3. Investments

The CFTC invests amounts deposited in the Customer 

Protection Fund in Treasury one-day certificates of 

indebtedness that are issued with a stated rate of interest 

to be applied to their par amount, mature on the business 

day immediately following their issue date, are redeemed 

at their par amount at maturity, and have interest payable 

at maturity

The interest rates or prices of the one-day certificates of 

indebtedness are calculated based on market yields of 

Treasury financial instruments issued and trading in the 

Secondary Market (exchanges and over-the-counter markets 

where securities are bought and sold subsequent to original 

issuance). The Commission may invest in other short-term

or long-term Treasury securities at management’s discretion

During FY 2021, the Commission redeemed $117,000,000 in 

investments to make funds readily available for the needs of 

the Fund. Such redemptions resulted in the liquidation of

investments owned at September 30, 2020. In FY 2022, the

Commission began investing again once there were sufficient 

funds to satisfy all outstanding whistleblower obligations

The Commission’s investments as of September 30, 2022, 

were $286,000,000 and related nonexchange interest 

revenue for the years ended September 30, 2022, and 2021, 

was $1,350,097 and $53,886, respectively

Intragovernmental Investments in Treasury Securities

The Federal government does not set aside assets to pay 

future claims or other expenditures associated with funds 

from dedicated collections deposited into the Customer 

Protection Fund. The dedicated cash receipts collected

by the Commission as a result of monetary sanctions are 

deposited in the Treasury, which uses the cash for general 

Government purposes. As discussed above and in Note 1F,

the Commission invests the majority of funds not needed 

for current operations of the Customer Protection Fund in 

Treasury securities. These Treasury securities are an asset of

the Commission and a liability of the Treasury. Because the

Commission and the Treasury are both components of the 

Government, these assets and liabilities offset each other 

from the standpoint of the Government as a whole. For this

reason, the investments presented by the Commission do 

not represent an asset or a liability in the U.S. governmentwide financial statemen

Treasury securities provide the Commission with authority to 

draw upon the Treasury to pay future claims or other expenditures. When the Commission requires redemption of these

securities to make expenditures, the Government finances 

those expenditures out of accumulated cash balances, by 

raising taxes or other receipts, by borrowing from the public 

or repaying less debt, or by curtailing other expenditures

This is the same manner in which the Government finances 

all expenditures

FY 2022 Agency Financial Re

 Commodity Futures Trading Commission 6

F I N A N C I A L S E C T I O N
Note 4. Accounts Receivable, Net

Accounts receivable consist of amounts owed the CFTC by 

other Federal agencies and the public. Accounts receivable

are valued at their net collectible values. Non-custodial

accounts receivable (entity assets) primarily arise from 

unused advances to other agencies and repayment of 

employee benefits. Historical experience has indicated that

most of the non-custodial receivables are collectible and that 

there are no material uncollectible amounts

Custodial receivables (non-entity assets) are those for 

which fines and penalties have been assessed and levied 

against businesses or individuals for violations of the CEA 

or Commission regulations. Violators may be subject to a

variety of sanctions including fines, injunctive orders, bars or 

suspensions, rescissions of illegal contracts, and disgorgements

An allowance for uncollectible accounts has been established 

and included in accounts receivable on the balance sheets

Although historical experience has indicated that a high 

percentage of custodial receivables prove uncollectible, the 

Commission determines the collectability of each individual 

judgment based on knowledge of the financial profile of the 

debtor obtained through the course of the investigation and 

litigation of each case, including efforts to identify and freeze 

assets at the beginning of cases, when any remaining assets 

are most likely to be recoverable. Accounts are re-estimated

quarterly based on account reviews and the agency’s determination that changes to the net realizable value are needed

Accounts receivable, net consisted of the following as of 

September 30, 2022, and 2021:

2022 2021

Custodial Receivables, Net:

Civil Monetary Penalties, Fines, and Administrative Fees $ 1,674,333,533 $ 564,068,210

Civil Monetary Penalty Interest 6,397,718 752,519

Registration and Filing Fees 1,367,648 1,185,107

Less: Allowance for Loss on Penalties, Fines, and Administrative Fees (1,016,734,491) (530,927,060)

Less: Allowance for Loss on Interest (6,174,227) (701,053)

Less: Allowance for Loss on Registration and Filing Fees – –

TOTAL CUSTODIAL RECEIVABLES, NET $ 659,190,181 $ 34,377,723

Other Accounts Receivable 27,175 26,983

TOTAL ACCOUNTS RECEIVABLE, NET $ 659,217,356 $ 34,404,706

FY 2022 Agency Financial Re

68 Commodity Futures Trading Commissio
Note 5. General Property, Plant, and Equipment, Net

Property, Plant, and Equipment as of September 30, 2022, and 2021, consisted of the following:

2022

Service Life and Method Cost

Accumulated 

Amortization/

Depreciation

Net Book 

Major Class Value

Equipment 5 Years/Straight Line $ 38,367,021 $ (28,818,135) $ 9,548,886

IT Software 5 Years/Straight Line 29,944,820 (26,988,898) 2,955,922

Software in Development Not Applicable 5,946,778 – 5,946,778

Leasehold Improvements Remaining Life of Lease/Straight Line 38,057,517 (17,033,641) 21,023,876

Construction in Progress Not Applicable 2,191 – 2,191

TOTAL GENERAL PROPERTY, PLANT, AND EQUIPMENT, NET $ 112,318,327 $ (72,840,674) $ 39,477,653

2021

Service Life and Method Cost

Accumulated 

Amortization/

Depreciation

Net Book 

Major Class Value

Equipment 5 Years/Straight Line $ 41,886,926 $ (36,273,805) $ 5,613,121

IT Software 5 Years/Straight Line 29,052,822 (26,121,269) 2,931,553

Software in Development Not Applicable 5,425,314 – 5,425,314

Leasehold Improvements Remaining Life of Lease/Straight Line 32,953,470 (24,624,583) 8,328,887

Construction in Progress Not Applicable 3,319,656 – 3,319,656

TOTAL GENERAL PROPERTY, PLANT, AND EQUIPMENT, NET $ 112,638,188 $ (87,019,657) $ 25,618,531

Note 6. Liabilities Not Covered by Budgetary Resources

As of September 30, 2022, and 2021, the following liabilities were not covered by budgetary resources:

2022 2021

Liabilities Not Requiring Budgetary Resources:

Intragovernmental – Liability to the General Fund of the U.S. Government 

for Custodial Assets $ 659,190,181 $ 34,377,723

Intragovernmental – Deferred Lease Liabilities 4,394,626 725,714

Deferred Lease Liabilities 11,308,599 15,200,011

Liability for Non-Fiduciary Deposit Funds 73,353 595,476

Total Liabilities Not Requiring Budgetary Resources $ 674,966,759 $ 50,898,924

Other Liabilities Not Covered by Budgetary Resources:

Intragovernmental – Unfunded FECA and Unemployment Liability $ 83,864 $ 89,587

Unfunded Annual Leave 17,747,317 18,531,860

Actuarial FECA Liabilities 499,005 533,782

Liability for Whistleblower Awards 45,000 203,970,000

TOTAL LIABILITIES NOT COVERED BY BUDGETARY RESOURCES $ 693,341,945 $ 274,024,153

Liabilities not covered by budgetary resources of $693,341,945 and $274,024,153 represent 96.12 and 92.83 percent of th

Commission’s total liabilities of $721,365,430 and $295,199,402 as of September 30, 2022, and 2021, respectively

FY 2022 Agency Financial Re

 Commodity Futures Trading Commission 6

F I N A N C I A L S E C T I O N
Note 7. Leases

The CFTC has operating leases for its locations in Washington 

D.C., Chicago, New York, and Kansas Cit.  The CFTC has 

real property. Future estimated minimum lease payments

are not accrued as liabilities and are expensed on a straightline basis

As of September 30, 2022, future estimated minimum lease 

payments are as follows:

Fiscal Year Non-Federal

(Non-Cancellable)

Federal

(Cancellable) Total

2023 $ 17,880,606 $ 2,515,223 $ 20,395,829

2024 18,239,105 2,539,897 20,779,002

2025 18,603,371 2,539,897 21,143,268

2026 – 2,539,897 2,539,897

2027 – 2,539,897 2,539,897

Thereafter – 11,776,369 11,776,369

Total Future Scheduled Rent Payments $ 54,723,082 $ 24,451,180 $ 79,174,262

Future Lease-Related Operating Costs (Estimated) 3,283,384 10,972,649 14,256,033

TOTAL FUTURE MINIMUM LEASE PAYMENTS $ 58,006,466 $ 35,423,829 $ 93,430,295

The amounts in the table above include the future minimum 

lease payments for the Commission’s existing lease arrangements described by location on the following page. In

2016, the Commission executed a memorandum of understanding with the General Services Administration (GSA) 

to address all of its future space needs. In its FY 2020 and

2022 appropriations, the Commission received an additional 

$31,000,000 and $62,000,000, respectively, for move, replication, and related costs associated with replacement leases for 

the Commission’s facilities. As of September 30, 2022, the

Commission has entered into occupancy agreements with 

GSA for space in Kansas City, Chicago, and New York. These

agreements may be cancelled with 120 days’ notice. The last

remaining location to transition from a non-cancellable nonfederal lease to a cancellable federal occupancy agreement 

(Washington, DC) is planned for FY 2025

CFTC recognizes lease expenses on a straight-line basis 

because the Commission’s lease payment amounts vary 

at negotiated times and reflect increases in rental costs, 

allowances or credits from landlords, and financed tenant 

improvements. Consistent with the utility of its office space,

the Commission records deferred lease liabilities representing 

expense amounts in excess of payments to date. Federal

deferred lease liabilities as of September 30, 2022, and 2021, 

were $4,394,626 and $725,714, respectively. Non-federal

deferred lease liabilities as of September 30, 2022, and 2021, 

were $11,308,599 and $15,200,011, respectively

The table on the following page describes the Commission’s 

existing lease arrangements for buildings and multifunction 

devices, including major asset categories by location and 

associated lease terms

continued on next page

FY 2022 Agency Financial Re

70 Commodity Futures Trading Commissio
Buildings (Federal, Cancellable)

LOCATION LEASE TERMS

Kansas City Occupancy Agreement with GSA for office space from February 1, 2021, through January 31, 2036.

New York Occupancy Agreement with GSA for office space from February 28, 2022, through February 27, 2032.1

Chicago Occupancy Agreement with GSA for office space from March 1, 2022, through February 28, 2032.1

Buildings (Non-Federal, Non-Cancellable)

LOCATION LEASE TERMS

Washington, D.C. Lease of office space from October 5, 1995, through September 30, 2025, subject to annual escalation 

amounts2 and including allowances for leasehold improvements and rent offsets.

Multifunction Devices (Federal)

LOCATION LEASE TERMS

Washington, D.C., 

New York, 

Chicago, and 

Kansas City 

One-year rental of multifunction printers through the U.S. Government Publishing Office with four one-year options 

to renew.

Note 8. Liability for Whistleblower Awards

As mentioned in Note 1A, the Customer Protection Fund will 

be used to pay awards to whistleblowers if they voluntarily 

provide original information to the CFTC that leads to the 

successful enforcement by the CFTC of a covered judicial or 

administrative action in which monetary sanctions exceeding 

$1,000,000 are imposed. Whistleblowers are entitled to

appeal any decisions by the Commission in regards to claims 

made against the Fund

At the time the whistleblower voluntarily provides 

information to CFTC, they have no guarantee or promise 

that the Commission will exchange funds in return for 

that information. In accordance with federal accounting

standards, the Commission records liabilities for these 

nonexchange transactions when they are due and payable

The Commission therefore records a liability for pending 

whistleblower payment after the whistleblower has been 

formally notified of an award and the related sanction, or 

some portion thereof, has been collected. The liability will

be paid when the appeal period has ended, the whistleblower 

has provided necessary banking information, and, in cases 

where the related sanction was collected in a prior year and 

subsequently swept by Treasury, or collected by a third party, 

the award will be paid as future collections become available

As of September 30, 2022, and September 30, 2021, the 

Commission recorded liabilities for pending payments to 

whistleblowers of approximately $45,000 and $203,970,000, 

respectively. During FY 2022, the Commission disbursed

$203,323,824 in whistleblower awards, which primarily 

consisted of $203,300,000 from pending payments at the 

end of FY 2021. Accounts payable as of September 30, 2022,

and 2021, includes $626,476 and $1,476, respectively, for 

awards that have been finalized as of the end of the reporting 

period

As of September 30, 2022, the Commission has 16 awards 

in pending or paid status for which the full collections have 

not been received, including four final $0 awards for which 

no collections have been received to date. While additional

collections on these matters are considered remote, the 

1 In FY 2022, the Commission entered into Occupancy Agreements with GSA for space in New York and Chicago that serve as replacements for the leases the 

Commission held with non-federal vendors that ended in FY 2022.

2 If market rent were $100 per square foot with a 10 percent annual escalation and a $10 operating expense base, then 98 percent of the applicable 

market rent would be $98 per square foot with a 10 percent escalation and a $10 operating base.

continued on next page

Note 7 continued from previous page

FY 2022 Agency Financial Re

 Commodity Futures Trading Commission 7

F I N A N C I A L S E C T I O N
Commission would be required to pay whistleblowers an 

additional $28,281,924 if all collections were received on 

these matters. In addition to the pending and potential

payments to whistleblowers, the Commission had 30 

additional whistleblower claims currently under review as of 

September 30, 2022. These additional claims, depending

on whether the whistleblowers are determined to be eligible 

for an award and the related sanctions have been collected, 

could result in total future payments ranging from $0 to 

$579,038,350

Note 9. Contingent Liabilities

The CFTC records contingent liabilities for legal cases in 

which payment has been deemed probable and for which the 

amount of potential liability has been estimated, including 

judgments that have been issued against the agency and which 

have been appealed. Additionally, the Commission discloses

legal matters in which an unfavorable outcome is reasonably 

possible. As of September 30, 2022, the Commission was

involved in a matter where an unfavorable outcome is deemed 

reasonably possible, and the potential loss is estimated to 

range from $0 to $75,000

Note 10. Statements of Budgetary Resources

The Commission corrected a violation of the recording statute 

in FY 2016 by recording its obligations for all future building 

lease payments in accordance with OMB Circular A-11. The

recording of these previously unrecorded obligations resulted 

in negative unobligated balances in its salaries and expenses 

general expenditure funds because budgetary resources have 

not been made available to the Commission to fund these 

multi-year leases (see the Combining Statements of Budgetary 

Resources in the Required Supplementary Information section 

immediately following the notes). The effect on the status

of the Commission’s budgetary resources and reconciliation 

to the U.S. Budget is detailed in the note disclosures belo

A. Net Adjustments to Unobligated Balance Brought Forward, October 1

The Unobligated Balance Brought Forward from the prior 

fiscal year has been adjusted for recoveries of prior year paid 

and unpaid obligations and other changes such as canceled 

authority. The Adjustments to Unobligated Balance Brought

Forward, October 1, as of September 30, 2022, and 2021, 

consisted of the following:

2022 2021

Unobligated Balance Brought Forward, October 1 $ 51,601,852 $ 47,584,244

Recoveries of Prior Year Obligations 2,954,290 6,479,879

Other Changes in Unobligated Balance (1,750,242) (3,057,910)

UNOBLIGATED BALANCE FROM PRIOR YEAR BUDGET AUTHORITY, NET $ 52,805,900 $ 51,006,213

continued on next page

Note 8 continued from previous page 

FY 2022 Agency Financial Re

72 Commodity Futures Trading Commissio
B. Undelivered Orders

The amount of budgetary resources obligated for undelivered orders as of September 30, 2022, and 2021, consisted of the 

following:

2022 2021

Undelivered Orders – Federal

Paid $ 3,383,000 $ 9,706,678

Unpaid 5,896,535 14,688,689

Total Undelivered Orders – Federal $ 9,279,535 $ 24,395,367

Undelivered Orders – Non-Federal

Paid $ 3,257,433 $ 3,988,894

Unpaid 102,822,715 119,043,648

Total Undelivered Orders – Non-Federal $ 106,080,148 $ 123,032,542

TOTAL UNDELIVERED ORDERS $ 115,359,683 $ 147,427,909

The amount of undelivered orders represents the value of 

unpaid and paid obligations recorded during the fiscal year, and 

upward and downward adjustments of obligations that were 

originally recorded in a prior fiscal year. Non-federal unpaid

undelivered orders include the Commission’s unfunded future 

lease payments as of September 30, 2022, and 2021, as follows:

2022 2021

Unfunded Lease Obligations Brought Forward, October 1 $ 80,060,414 $ 103,626,536

Change in Unfunded Lease Obligations (22,053,948) (23,566,122)

TOTAL REMAINING UNFUNDED LEASE OBLIGATIONS $ 58,006,466 $ 80,060,414

Note 10 continued from previous page

continued on next page

FY 2022 Agency Financial Re

 Commodity Futures Trading Commission 7

F I N A N C I A L S E C T I O N
C. Explanations of Differences Between the Statement of Budgetary Resources 

and Budget of the United States Government

The CFTC had material differences between the amounts 

reported in the Statement of Budgetary Resources dated 

September 30, 2021, and the actual amounts reported in the 

Budget of the U.S. Government for FY 2021.  These differe

are related to unfunded lease obligations that are being funded 

each fiscal year through annual appropriations (see table 

below). These unfunded obligations will cease to be a reconciling difference when the last unfunded lease ends in FY 202

Budgetary 

Resources

CFTC FY 2021 Statement of Budgetary Resources $ 355,069,447

Less Amounts in Customer Protection Fund (119,938,478)

Less Amount in Expired Accounts (9,975,972)

Less New Budget Authority Used to Liquidate Deficiencies (23,566,122)

Plus Unfunded Lease Obligations Brought Forward, October 1 103,626,536

Plus Rounding to Nearest Million (+/-) (215,411)

BUDGET OF THE U.S. GOVERNMENT $ 305,000,000

The Budget of the U.S. Government with actual numbers for FY 2022 has not yet been publishe.  The expected publish date 

February 2023. A copy of the Budget may be obtained from OMB’s websit

D. Distributed Offsetting Receipts 

Distributed offsetting receipts are amounts that an agency 

collects from the public or from other Government agencies 

that are used to offset or reduce an agency’s budget outlays

The Commission’s distributed offsetting receipts generally 

consist of miscellaneous collections for such items as 

Freedom of Information Act requests, vendor refunds, 

and lost or damaged property that cannot be applied to 

other funds

Note 10 continued from previous page

FY 2022 Agency Financial Re

74 Commodity Futures Trading Commissio
Note 11. Reconciliation of Total Net Cost of Operations to Net Outlays

Budgetary and financial accounting information differ

Budgetary accounting is used for planning and control 

purposes and relates to both the receipt and use of cash, as 

well as reporting the federal deficit. Financial accounting is

intended to provide a picture of the government’s financial 

operations and financial position so it presents information 

on an accrual basis. The accrual basis includes information

about costs arising from the consumption of assets and 

the incurrence of liabilities.  The reconciliation of n

outlays, presented on a budgetary basis, and the net cost, 

presented on an accrual basis, provides an explanation of 

the relationship between budgetary and financial accounting 

information. This reconciliation serves not only to identify

costs paid for in the past and those that will be paid in the 

future, but also to assure integrity between budgetary and 

financial accounting

The schedule presented in this note reconciles the Total Net 

Cost of Operations reported in the Statements of Net Cost 

(accrual basis) with Net Outlays reported in the Statements 

of Budgetary Resources (budgetary basis). Differences

between net costs and net outlays are primarily the result 

of timing differences and paying for assets that are used over 

more than one reporting period

2022 2021

TALNET CO ST OF OPERATION S $ 328,

Components of Net Cost That Are Not Part of Net Outlays:

Depreciation and Amortization of Property, Plant, and Equipment $ (6,365,293) $ (8,047,809)

Amortization of Deferred Lease Liabilities 4,068,055 3,481,497

Gain/(Loss) on Disposal (771,131) (34,252)

Increase/(Decrease) in Assets:

Accounts Receivable 192 (25,649)

Decrease in Advances and Prepayments (7,055,139) –

(Increase)/Decrease in Liabilities:

Accounts Payable (5,394,175) (3,006,512)

Salaries and Benefits (1,454,061) 424,597

Liability for Whistleblower Awards 203,925,000 (200,342,973)

Other Liabilities (Unfunded Leave, Unfunded FECA, Actuarial FECA) 825,043 (2,766,640)

Other Financing Sources:

Federal Employee Retirement Benefit Costs Paid by OPM and Imputed to CFTC (6,855,582) (6,547,842)

Transfers (In)/Out Without Reimbursement – (12,419)

Total Components of Net Cost That Are Not Part of Net Outlays $ 180,922,909 $ (216,878,002)

Components of Net Outlays That Are Not Part of Net Cost:

Acquisition of Capital Assets $ 17,149,990 $ 7,847,406

Increase in Advances and Prepayments – 8,347,597

Nonexchange Interest Revenue (Excluding Interest Receivable) (1,350,097) (53,886)

Financing Sources Transferred in from Custodial Statement Collections (398,498,439) –

Total Components of Net Outlays That Are Not Part of Net Cost $ (382,698,546) $ 16,141,117

Outlays, Net $ 126,661,665 $ 314,164,705

Distributed Offsetting Receipts (15,850) (37,264)

AGENCY OUTLAYS, NET $ 126,645,815 $ 314,127,441

FY 2022 Agency Financial Re

 Commodity Futures Trading Commission 7

F I N A N C I A L S E C T I O N
Note 12. Funds from Dedicated Collections

Funds from dedicated collections arise from disgorgement 

and penalty collections and are transferred to the Customer 

Protection Fund, established by the Dodd-Frank Act. The

collections are transferred from the custodial receipt account 

if they are found to be eligible before the end of each fiscal 

year. In cases where the collection has been returned to

Treasury in error, the Commission can recover the funds. The

collections will fund the Commission’s whistleblower awards 

program and customer education initiatives

The Dodd-Frank Act provides that whistleblower awards shall 

be paid under regulations prescribed by the Commission

The Commission most recently issued revised regulations 

effective July 31, 2017

Eligible collections of $398,498,439 were transferred into 

the Fund during FY 2022. The following table presents the

Fund’s balance sheets, statements of net costs, and statements 

of changes in net position as of and for the years ended 

September 30, 2022, and 2021:

2022 2021

BALANCE SHEETS

Fund Balance with Treasury $ 18,162,873 $ 113,344,846

Investments 286,000,000 –

Advances and Prepayments 7,396 7,844

TOTAL ASSETS $ 304,170,269 $ 113,352,690

Accounts Payable $ 1,647,537 $ 898,447

Accrued Funded Payroll 211,452 200,819

Unfunded Annual Leave 345,166 356,457

Liability for Whistleblower Awards 45,000 203,970,000

Total Liabilities $ 2,249,155 $ 205,425,723

Cumulative Results of Operations – Funds from Dedicated Collections 301,921,114 (92,073,033)

Total Net Position $ 301,921,114 $ (92,073,033)

TOTAL LIABILITIES AND NET POSITION $ 304,170,269 $ 113,352,690

STATEMENTS OF NET COST

Gross Costs $ 5,854,389 $ 209,154,891

TOTAL NET COST OF OPERATIONS $ 5,854,389 $ 209,154,891

STATEMENTS OF CHANGES IN NET POSITION

Beginning Cumulative Results of Operations $ (92,073,033) $ 117,027,972

Nonexchange Interest Revenue 1,350,097 53,886

Transfers In/(Out) Without Reimbursement 398,498,439 –

Net Cost of Operations (5,854,389) (209,154,891)

Net Change in Cumulative Results of Operations $ 393,994,147 $ (209,101,005)

TOTAL NET POSITION, ENDING $ 301,921,114 $ (92,073,033)

FY 2022 Agency Financial Re

76 Commodity Futures Trading Commissio
continued on next page

Commodity Futures Trading Commission

Combining Statemnts of Budgetary Resou

For the Years Ended September 30, 2022 and 2021

2022

CUSTOMER 

PROTECTION 

FUND

SALARIES AND 

EXPENSES

INFORMATION 

TECHNOLOGY COMBINED

BUDGETARY RESOURCES

Unobligated Balance from Prior Year Budget Authority, Net (Note 10A) $ 111,143,311 $ (59,919,104) $ 1,581,693 $ 52,805,900

Appropriations – 382,000,000 – 382,000,000

Spending Authority from Offsetting Collections 377,057,169 49,179 – 377,106,348

TOTAL BUDGETARY RESOURCES $ 488,200,480 $ 322,130,075 $ 1,581,693 $ 811,912,248

STATUS OF BUDGETARY RESOURCES

New Obligations and Upward Adjustments $ 209,525,546 $ 301,791,260 $ 32,013 $ 511,348,819

Unobligated Balance, End of Year

Apportioned, Unexpired Accounts 278,674,934 71,365,633 – 350,040,567

Unapportioned, Unexpired Accounts – (57,983,358) – (57,983,358)

Unexpired Unobligated Balance, End of Year 278,674,934 13,382,275 – 292,057,209

Expired Unobligated Balance, End of Year – 6,956,540 1,549,680 8,506,220

Unobligated Balance, End of Year (Total) 278,674,934 20,338,815 1,549,680 300,563,429

TOTAL BUDGETARY RESOURCES $ 488,200,480 $ 322,130,075 $ 1,581,693 $ 811,912,248

OUTLAYS, NET

Outlays, Net $ (190,818,027) $ 317,476,350 $ 3,342 $ 126,661,665

Distributed Offsetting Receipts – (15,850) – (15,850)

AGENCY OUTLAYS, NET $ (190,818,027) $ 317,460,500 $ 3,342 $ 126,645,815

 Commodity Futures Trading Commission 7

Required Supplementary Informa

(Unaudited
Combining Statements of Budgetary Resources by Major Account continued from previous page

Commodity Futures Trading Commission

Combining Statemnts of Budgetary Resou

For the Years Ended September 30, 2022 and 2021

2021

CUSTOMER 

PROTECTION 

FUND

SALARIES AND 

EXPENSES

INFORMATION 

TECHNOLOGY COMBINED

BUDGETARY RESOURCES

Unobligated Balance from Prior Year Budget Authority, Net (Note 10A) $ 119,887,663 $ (70,827,132) $ 1,945,682 $ 51,006,213

Appropriations – 304,000,000 – 304,000,000

Spending Authority from Offsetting Collections 50,815 12,419 – 63,234

TOTAL BUDGETARY RESOURCES $ 119,938,478 $ 233,185,287 $ 1,945,682 $ 355,069,447

STATUS OF BUDGETARY RESOURCES

New Obligations and Upward Adjustments $ 8,862,632 $ 294,598,457 $ 6,506 $ 303,467,595

Unobligated Balance, End of Year

Apportioned, Unexpired Accounts 111,075,846 11,942,493 – 123,018,339

Unapportioned, Unexpired Accounts – (80,060,414) – (80,060,414)

Unexpired Unobligated Balance, End of Year 111,075,846 (68,117,921) – 42,957,925

Expired Unobligated Balance, End of Year – 6,704,751 1,939,176 8,643,927

Unobligated Balance, End of Year (Total) 111,075,846 (61,413,170) 1,939,176 51,601,852

TOTAL BUDGETARY RESOURCES $ 119,938,478 $ 233,185,287 $ 1,945,682 $ 355,069,447

OUTLAYS, NET

Outlays, Net $ 9,006,707 $ 303,469,727 $ 1,688,271 $ 314,164,705

Distributed Offsetting Receipts – (37,264) – (37,264)

AGENCY OUTLAYS, NET $ 9,006,707 $ 303,432,463 $ 1,688,271 $ 314,127,441

FY 2022 Agency Financial Re

78 Commodity Futures Trading Commissio
Other Information

Section Page

INSPECTOR GENERAL’S 

FY 2022 ASSESSMENT 80

SUMMARY OF AUDIT AND 

MANAGEMENT ASSURANCES 84

PAYMENT INTEGRITY 

INFORMATION ACT REPORTING 85

CIVIL MONETARY PENALTY 

ADJUSTMENT FOR INFLATION 87
U.S. COMMODITY FUTURES TRADING COMMISSION

OFFICE OF INSPECTOR GENERAL

Three Lafayette Centre

1155 21st Street, NW, Washington, DC 20581

TO: Rostin Behnam, Chairman

Kristin Johnson, Commissioner

Christy Goldsmith Romero, Commissioner

Summer Mersinger, Commissioner

Caroline Pham, Commissioner

FROM: A. Roy Lavik, Inspector General 

DATE: September 26, 2022 

SUBJECT: Inspector General’s Assessment of the Most Serious 

Management and Performance Challenges Facing 

the Commodity Futures Trading Commission FY

2022

The Reports Consolidation Act of 2000 (RCA)1 requires the Inspector General to 

summarize the “most serious management and performance challenges facing the

agency” and briefly assess the Agency’s progress in addressing those 

challenges.2 Management challenges are “programs or management functions, 

within or across agencies, that have greater vulnerability to waste, fraud, abuse, 

and mismanagement (such as issues identified by the Government Accountability 

Office as high risk or issues identified by an Inspector General) where failure to 

perform well could seriously affect the ability of an agency to achieve its mission or 

goals.”3 This memorandum fulfills our duties under the RCA. 

To complete our assessment, we relied on data contained in the CFTC financial 

statement audit and Agency Financial Report, representations by agency 

management, and our knowledge of industry trends and CFTC operations. 

 1 P.L. 106-531, § 3, 114 STAT. 2537 (Nov. 22, 2000), codified at 31 U.S.C. § 3516(a). All links last accessed 

on September 26, 2022.

2 Id.

3 Government Performance and Results Modernization Act of 2010, P.L. 111-352, § 3, 124 STAT. 3866 

(Jan. 4, 2011), codified at 31 U.S.C. § 1115(h)(5). 

Inspector General’s FY 2022 As

111-352

106-531

80 Commodity Futures Trading Commissio
FY 2022 Agency Financial Re

 Commodity Futures Trading Commission 8

OTHER INFORMATION

2 

CFTC’s Progress on FY 2021 Management and Performance Challenges

For FY 2021, we highlighted information technology (IT) modernization and data 

governance as management challenges, and recognized the Agency appointed

a new Chief Information Officer (CIO) and established the position of Chief Data 

Officer (CDO). During FY 2022, we recognize that the CIO is completing CFTC’s

migration to a cloud environment and the CDO is advancing the analytic use of

structured and unstructured data to detect potential misconduct, including 

manipulation of markets. We will continue to monitor the progress of CFTC’s

technological initiatives. 

Fiscal Year (FY) 2022 Management and Performance Challenges

We also highlighted three other management challenges for FY 2021 which 

remain for FY 2022, as discussed below.

Climate Change

Climate change impacts the CFTC’s mission, its physical assets and 

infrastructure, as well as the businesses of market participants. In this regard, 

we note Chairman Behnam launched the CFTC Climate Risk Unit (CRU) in 

March 20214 and is evaluating the Financial Stability Oversight Council 

recommendations5 related to climate change financial risks in collaboration with 

the Commission. We recognize that CFTC is currently evaluating responses to

its June 2022 Request for Information on Climate-Related Financial Risk.6 We 

also recognize the Supreme Court’s recent holding that, under the "major 

questions doctrine," a federal regulatory agency may not adopt rules that are 

"transformational" to the economy unless Congress has specifically authorized 

such a transformative rule to address a specific problem, like climate change.7

Management of IT (Cybersecurity)

Threats to system information, including Personally Identifiable Information 

(PII), are a continuing management challenge. CFTC is updating its security 

 

4 CFTC Release No. 8368-21, CFTC Acting Chairman Behnam Establishes New Climate Risk Unit, March 

17, 2021. 

5 FSOC Report on Climate-Related Risk, October 21, 2021. 6 87 FR 34856, June 8, 2022. 7 West Virginia v. Environmental Protection Agency, No. 20-1530, p. 20, 597 U.S. ___ (June 2022). 

8368-21

Report

87 FR 34856

No. 20-1530
FY 2022 Agency Financial Re

82 Commodity Futures Trading Commissio

3 

policies to comply with new requirements and continues to devote resources to 

its real-time cyber threat response program. 

Emerging in this area are the intersections of privacy and enterprise risk 

management requirements that integrates them into business objectives. We 

recognize that CFTC is integrating privacy controls with systems controls to 

prevent loss. However, we believe the Privacy Office may be challenged by 

staffing shortages for an increasing workload. 

Enterprise Risk Management

As it relates to Enterprise Risk Management (ERM), CFTC’s ERM program can 

become an operational asset for the Commission to prioritize and respond to a 

variety of internal and external risks, including cyber related risks. In March 

2021, the CFTC hired its first Chief Risk Officer (CRO), who reports directly to 

the head of the Division of Administration (DA). We recognize that CFTC’s 

2022-2026 Strategic Plan shows a commitment to ERM. However, the CRO is 

organizationally distant from the Commission, and may be under resourced, 

which may challenge the program’s governance, culture, and operational 

success. We will continue to monitor this area. 

Efficient Leased Space Following the Establishment of Post-Pandemic Telework 

and Remote Work Policies

The fourth management challenge is new for FY 2022. CFTC’s four leased 

facilities have been underutilized since March 2020.8 We note that until the 

Chairman finalizes a post-pandemic policy for telework and remote work, and 

updates office space requirements accordingly, taxpayers continue to 

needlessly pay for unused space. Space needs may decrease as a result of 

expanded post-Pandemic telework/remote work policy following negotiations 

with the Union.9 While space utilization may return to prior levels, or even 

increase, if CFTC is given additional regulatory responsibilities, that is not the 

 

8 On March 13, 2020, the CFTC Office of the Executive Director (OED) announced that, effective March 16, 

2020, and until further notice, all CFTC offices will be open and all employees will have the option of 

unscheduled leave or unscheduled telework until further notice. CFTC began a Phase I reopening on 

October 1, 2021, with participation 100% voluntary. In June 2022, OED announced a Phase II reopening, 

which “allows the 100% voluntary return to the CFTC’s office of a limited number of staff, and provides 

procedures in limited cases where staff may be directed to a CFTC office to perform a specific task.” 

However, the June 2022 communication stated that Phase II will only take place “following negotiations with 

the Union.” Negotiations were not completed (and announced to staff) as of Friday, September 23, 2022. 9 See fn.8.

CFTC’s

2022-2026 Stragegic Plan
FY 2022 Agency Financial Re

 Commodity Futures Trading Commission 8

OTHER INFORMATION

4 

current situation and we note that CFTC has a history of spending taxpayer 

funds on underutilized lease space.10 We are currently conducting an inspection 

and evaluation of leased space utilization at CFTC, and will continue our work 

in what may be a period of significant change for CFTC’s space needs. 

The management challenges relating to CFTC’s cloud migration, ERM efforts, 

cyber response program, establishment of the CRU, and its evolving space 

needs, all address risk-related priorities communicated in several Executive 

Orders.11 We will continue to monitor the progress of CFTC’s risk related 

programs as they mature.

Cc: 

David Gillers, Chief of Staff

Bruce Fekrat, Chief Counsel

Joseph R. Cisewski, Chief of Staff and Senior Counsel

Chris Lucas, Chief of Staff and Counsel 

Meghan Tente, Chief of Staff

Laura Gardy, Acting Executive Director

Janaka Perera, Acting Executive Director

Robert Schwartz, General Counsel

Joel Mattingley, Chief Financial Officer

John Rogers, Senior Advisor

 

10 In 2016 GAO reported: “CFTC did not make cost-effective decisions consistent with leading government 

guidance for lease procurement and internal controls when planning for additional space in fiscal years 

2008–2015.” GAO, Commodity Futures Trading Commission Needs Better Guidance to Improve CostEffectiveness, GAO-16-434 (April 18, 2016). See also, CFTC OIG, A Review of Leasing and Occupancy 

Levels of the Kansas City Regional Office of the Commodity Futures Trading Commission, June 2014

(between 2010 and at least June 2014, CFTC leased space for 75 workers in one field office while 

maintaining only approximately 27 workers). 11 Executive Order on Protecting Americans’ Sensitive Data from Foreign Adversaries, EO 14034, June 9, 

2021; Executive Order on Improving the Nation’s Cybersecurity, EO 14028, May 12, 2021; Executive Order 

on Climate-Related Financial Risk, EO 14030, May 2021; and OMB M-21-25, Integrating Planning for A 

Safe Increased Return of Federal Employees and Contractors to Physical Workplaces with Post-Reentry 

Personnel Policies and Work Environment, June 21, 2021. 

GAO-16-434

Executive Order on Protecting Americans’ Sensitive Data from Foreign Adversaries

Executive Order on Improving the Nation’s Cybersecurity Executive Order 

on Climate-Related Financial Risk M-21-25

June 2014
Summary of FY 2022 Financial Statement Audit

Audit Opinion: Unmodified

Restatement: No

MATERIAL WEAKNESSES BEGINNING BALANCE NEW RESOLVED CONSOLIDATED ENDING BALANCE

Total Material Weaknesses 0 0

Summary of Management Assurances

EFFECTIVENESS OF INTERNAL CONTROL OVER FINANCIAL REPORTING (FMFIA § 2)

Statement of Assurance: Unmodified

MATERIAL WEAKNESSES BEGINNING BALANCE NEW RESOLVED CONSOLIDATED REASSESSED ENDING BALANCE

Total Material Weaknesses 0 0

EFFECTIVENESS OF INTERNAL CONTROL OVER OPERATIONS (FMFIA § 2)

Statement of Assurance: Unmodified

MATERIAL WEAKNESSES BEGINNING BALANCE NEW RESOLVED CONSOLIDATED REASSESSED ENDING BALANCE

Total Material Weaknesses 0 0

CONFORMANCE WITH FEDERAL FINANCIAL MANAGEMENT SYSTEM REQUIREMENTS (FMFIA § 4)

Statement of Assurance: Federal systems conform to financial management system requirements

NON-CONFORMANCES BEGINNING BALANCE NEW RESOLVED CONSOLIDATED REASSESSED ENDING BALANCE

Total Non-Conformances 0 0

COMPLIANCE WITH SECTION 803(A) OF THE FEDERAL FINANCIAL MANAGEMENT IMPROVEMENT ACT (FFMIA)

Agency Auditor

1. Federal Financial Management System Requirements No lack of compliance noted

2. Applicable Federal Accounting Standards No lack of compliance noted

3. USSGL at Transaction Level No lack of compliance noted

DEFINITION OF TERMS

Beginning Balance: The beginning balance must agree 

with the ending balance from the prior year

New: The total number of material weaknesses/

non-conformances identified during the current year

Resolved: The total number of material weaknesses/

non-conformances that dropped below the level of 

materiality in the current year

Consolidated: The combining of two or more findings

Reassessed: The removal of any finding not attributable 

to corrective actions (e.g., management has reevaluated an

determined that a finding does not meet the criteria for 

materiality or is redefined as more correctly classified under 

another heading (e.g., Section 2 to a Section 4 and vice versa

Ending Balance: The year-end balance that will be the 

beginning balance of next year

Summary of Audit an

Management Assur

84 Commodity Futures Trading Commissio
The Payment Integrity Information Act of 2019 

(PIIA) updated government-wide improper 

payment reporting requirements by repealing 

and replacing the Improper Payments Information Act of 

2002, the Improper Payments Elimination and Recovery Act 

of 2010, the Improper Payments Elimination and Recovery 

Act of 2012, and the Fraud Reduction and Data Analytics 

Act of 2015. The PIIA-related OMB guidance provided

in Circular A-136, Financial Reporting Requirements, and 

Appendix C, Requirements for Payment Integrity Improvement, 

of Circular A-123, Management’s Responsibility for Enterprise 

Risk Management and Internal Control, requires agencies report 

detailed information related to the Commission’s efforts to 

eliminate improper payments, which is summarized below

Additional information about the Commission’s payment 

integrity reporting may be found at paymentaccuracy.gov

Payment Integrity Reporting

The Commission does not administer grant, benefit or loan 

programs. For FY 2022, CFTC’s most significant payments

were for monetary awards to eligible whistleblowers who 

voluntarily provided the CFTC with original information 

about violations of the CEA that led the CFTC to bring 

enforcement actions that resulted in monetary sanctions 

exceeding $1 million. CFTC’s other most significant

payments in FY 2022 were for payroll and benefits for its 

employees, which are administered by the U.S. Departmen

of Agriculture’s National Finance Center (NFC) and the OPM, 

and payments to vendors for goods and services used during 

the course of normal operations

Significant erroneous payments are defined as annual 

erroneous payments in the program exceeding both 

$10 million and 1.5 percent, or $100 million of total annual

program payments. Although the Commission disbursed

$203.3 million in whistleblower payments during FY 2022,

the review of each individual award by the Commission’s 

Claims Review Staff limits the likelihood that the whistleblower award program would be susceptible to significant 

improper payments. In addition, based on the results of

transaction testing applied to a sample of FY 2022 vendor 

payments, consideration of risk factors, and reliance on the 

internal controls in place over the payment and disbursement 

processes, the Commission has determined that none of its 

programs and activities carried out in the normal course of 

business are susceptible to significant improper payments at 

or above the threshold levels set by OMB

In accordance with Appendix C of Circular A-123, the 

Commission is not required to determine a statistically 

valid estimate of erroneous payments or develop a corrective 

action plan if the program is not susceptible to significant 

improper payments

Recapture of Improper Payments

As stated above, the Commission does not administer grant, 

benefit or loan programs. Implementation of recapture

auditing, if determined to be cost-effective, would apply to the 

Commission’s contract payments because payments to vendors 

total more than $10 million annually. The Commission determined that implementing a payment recapture audit program

for contract payments is not cost-effective. In making this

determination, the Commission considered its low improper 

payment rate based on testing conducted over the previous 

three years and determined that the costs of implementing and 

overseeing a payment recapture audit program, including staff 

time and payments to contractors, would exceed any benefits 

or recaptured amounts that might result

Payment Integrit

Information Act Repo

 Commodity Futures Trading Commission 8
The Commission utilizes cost-efficient matching techniques 

to review all vendor payments to identify significant overpayments at a low cost per overpayment. The Commission has

not identified a significant number or amount of improper 

payments since it began its analysis.

In addition to contract payments, recapture auditing may 

also be considered for the Commission’s monetary awards 

to whistleblowers, if determined to be cost-effective, when 

payments to whistleblowers total more than $10 million 

annually. The amount of whistleblower awards will vary

depending on the number and amount of covered enforcement 

actions in a given year, as well as the extent of original 

information provided by whistleblowers that led to the actions

However, the Commission has determined that implementing 

a payment recapture audit program for monetary awards to 

whistleblowers would not be cost-effective due to the effective 

design and operation of the internal controls in place for the 

program. As noted above, the review of each individual award

by the Commission’s Claims Review Staff limits the likelihood 

that the whistleblower award program would be susceptible 

to significant improper payments or that payment recapture 

audits would be beneficial

The Commission will continue to monitor the potential 

for improper payments across all programs and activities 

it administers and assess whether implementing payment 

recapture audits for each program would be cost-effective

Governmentwide Do Not Pay Initiative

The Do Not Pay (DNP) solution is a governmentwide 

initiative to screen payment recipients before a contract 

award or payment is made in order to eliminate payment 

errors before they occur. The Commission has integrated

the solution into its existing processes as part of efforts to 

identify and prevent improper payments. The Commission’s

shared services provider utilizes the DNP Business Center, 

on the Commission’s behalf, to perform online searches 

and screen payments against the DNP databases to augment 

data analytics capabilities. Based on the results of the

reviews to date, the DNP initiative has not identified any 

improper payments

Table 1. Results of the Do Not Pay Initiative in Preventing Improper Payments 

($ in thousands)

NUMBER (#) 

OF PAYMENTS 

REVIEWED 

FOR POSSIBLE 

IMPROPER 

PAYMENTS

DOLLARS ($) 

OF PAYMENTS 

REVIEWED 

FOR POSSIBLE 

IMPROPER 

PAYMENTS

NUMBER (#) 

OF PAYMENTS 

STOPPED

DOLLARS ($) 

OF PAYMENTS 

STOPPED

NUMBER (#) 

OF POTENTIAL 

IMPROPER 

PAYMENTS 

REVIEWED AND 

DETERMINED 

ACCURATE

DOLLARS ($) 

OF POTENTIAL 

IMPROPER 

PAYMENTS 

REVIEWED AND 

DETERMINED 

ACCURATE

2,623 $303,127 0 $– 0 $–

86 Commodity Futures Trading Commissio
The Federal Civil Penalties Inflation Adjustment 

Act of 1990 (FCPIA) requires agencies to 

periodically adjust civil penalties for inflation 

if either the amount of the penalty or the maximum penalty 

is set by law. The Federal Civil Penalties Inflation Adjustment

Act Improvements Act of 2015 (2015 Act) amended the 

FCPIA and required the Commission to: make an initial 

“catch-up” inflation adjustment in FY 2016, and adjust 

for inflation going forward under guidance of the OMB, 

potentially on an annual basis

The Commission administers the following sections of the 

CEA that provide for civil monetary penalties:

■ Section 6(c) of the CEA, 7 U.S.C. 9—Prohibition Regardi

Manipulation and False Information;

■ Section 6b of the CEA, 7 U.S.C. 13a—Non-Enforcement 

Rules of Government or Other Violations; Cease and Desist 

Orders, Fines and Penalties, Imprisonment, Misdemeanor, 

Separate Offenses; and

■ Section 6c of the CEA, 7 U.S.C. 13a-1—Enjoining 

Restraining Violations

Pursuant to this authority, the Commission seeks penalties 

against person(s) or entity(s) for a host of violations, including: 

fraud, false statements to the Commission, misappropriation, 

price manipulation, use of a manipulative or deceptive 

device, disruptive trading practices, false reporting, accounting 

violations, registration and fitness violations, failure to 

maintain or produce required records, failure to make required 

reports, a registrant’s failure to supervise, failure to comply 

with business conduct standards, and illegal off-exchange 

activity. The CEA provides for heightened sanctions in two

circumstances: (1) when the violation involves manipulation 

or attempted manipulation; and (2) when the defendant/

respondent is a registered entity (e.g., an exchange, clearin

organization, or swap data repository) or any director, officer, 

agent, or employee of any registered entity

In addition, in May 2020 the CFTC issued new guidance 

outlining factors the DOE considers in recommending civil 

monetary penalties (CMPs) to the Commission to be imposed 

in CFTC enforcement actions. The guidance memorializes the

existing practice within DOE and has been incorporated into 

the DOE Enforcement Manual. This was the first DOE CMP

guidance issued publicly since the Commission published 

its penalty guidelines in 1994. The full CFTC press release

on this significant action can be found at https://www.cftc.gov/

PressRoom/PressReleases/8165-20

Details about the current penalty level and the date of the 

most recent inflationary adjustment for each civil monetary 

penalty within the jurisdiction of the Commission are 

reflected in the tables on the following page

13

13 Criminal authorities may also seek fines for criminal violations of the CEA (See Sections 6(d), 9, 7 U.S.C. 13, 13(c),13(d),13(e), and 13(b). The FCPIA does not 

affect criminal penalties.

Civil Monetary Penalty

Adjustment for Inflat

 Commodity Futures Trading Commission 8
Penalty 

(Name of Penalty)

Authority 

(Statute)

Date of 

Previous 

Adjustment

Date of 

Current 

Adjustment

Current 

Penalty Level

($ Amount)14

Location for 

Penalty Update 

Details

CIVIL MONETARY PENALTIES IMPOSED BY THE COMMISSION IN AN ADMINISTRATIVE ENFORCEMENT ACTION

For a civil penalty 

against any person 

(other than a 

registered entity, as 

that term is defined 

in Section 1a(4) of 

the CEA)

Section 6(c) of 

the Commodity 

Exchange Act

(7 U.S.C. 9)

2/12/2021 1/13/2022 For penalties imposed by the 

Commission to administrative 

enforcement proceedings for 

violations from November 

2015 to present, not more 

than the greater of $180,714 

(for non-manipulation 

violations) or $1,303,559 

(for manipulation or attempted 

manipulation violations) or 

triple the monetary gain to 

such person for each such 

violation.

Federal Register 

Vol. 87, Page 2033 

(January 13, 2022)

https://www.cftc.gov/sites/

default/files/2022/01/2022-

00595a.pdf

For a civil monetary 

penalty against any 

registered entity or 

any director, officer, 

agent, or employee 

of any registered 

entity, as that term 

is defined in Section 

1a(40) of the CEA

Section 6b of 

the Commodity 

Exchange Act

(7 U.S.C. 13a)

2/12/2021 1/13/2022 For penalties imposed by the 

Commission in administrative 

enforcement proceedings for 

violations from November 

2015 to present, not more 

than the greater of $995,471 

(for non-manipulation 

violations) or $1,303,559 

(for manipulation or attempted 

manipulation violations) or 

triple the monetary gain to 

such person for each such 

violation.

Federal Register 

Vol. 87, Page 2033

(January 13, 2022)

https://www.cftc.gov/sites/

default/files/2022/01/2022-

00595a.pdf 

CIVIL MONETARY PENALTIES IMPOSED BY A DISTRICT COURT IN A CIVIL INJUNCTIVE ENFORCEMENT ACTION

For a civil monetary 

penalty assessed 

against any person

Section 6c of 

the Commodity 

Exchange Act

(7 U.S.C. 13a-1)

2/12/2021 1/13/2022 For penalties imposed by a 

District Court in civil injunctive 

enforcement proceedings for 

violations from November 

2015 to present, not more 

than the greater of $199,094 

(for non-manipulation 

violations) or $1,303,559

(for manipulation or attempted 

violations) or triple the 

monetary gain to such person 

for each such violation.

Federal Register 

Vol. 87, Page 2033 

(January 13, 2022)

https://www.cftc.gov/sites/

default/files/2022/01/2022-

00595a.pdf

Additional information regarding inflation adjusted civil monetary penalties is available on the Commission’s website: 

https://www.cftc.gov/LawRegulation/Enforcement/InflationAdjustedCivilMonetaryPenalties/index.htm

14 These adjusted penalties apply only with respect to violations occurring on or after November 2, 2015, the effective date of the 2015 Act.

FY 2022 Agency Financial Re

88 Commodity Futures Trading Commissio
Appendix

Section Page

CFTC CUSTOMER PROTECTION FUND 90

WHY ARE THE MARKETS IMPORTANT TO ME? 94

CFTC OVERSIGHT OF REGULATED ENTITIES 97

CFTC LIST OF ABBREVIATIONS 

AND ACRONYMS 100
Section 748 of the Dodd-Frank Act established 

the CFTC Customer Protection Fund (CPF). The

CPF is a permanent appropriation, but must 

be apportioned annually by OMB. Customer Protection

Funds are available for the payment of whistleblower awards 

and education efforts that focus on helping the public to 

protect themselves against fraud and other violations of 

the CEA. The CFTC is authorized to deposit civil monetary

penalties, disgorgements, and interest it collects in covered 

administrative or judicial enforcement actions into the CPF, 

whenever the balance in the fund at the time of the deposit 

is less than or equal to $100 million

In 2012, the Commission established the WBO and the 

OCEO to administer the Whistleblower and Customer 

Education Programs

15 See https://www.whistleblower.gov.

16 See, e.g., Things To Know: https://www.whistleblower.gov/news/thingstoknow.

FY 2022 Highlights of the Whistleblower Program

The WBO raises awareness and increases the public’s 

understanding of the Whistleblower Program through 

outreach to various stakeholders. These include industry

and professional groups, other government agencies, SROs, 

academia, and potential whistleblowers; who may be traders, 

hedgers, farmers, ranchers, producers, and commercial end 

users. WBO staff exhibit or speak at industry conferences,

answer questions about the program posed directly to the 

WBO by whistleblowers or their counsel, and distribute 

written materials in person at conferences or through the 

Whistleblower Program website

15 This website educates 

the public about the Whistleblower Program, serving 

as a comprehensive resource for information to answer 

frequently asked questions and to offer helpful guidance 

on navigating the program

16

During FY 2022, the WBO continued using its website to 

publicize Whistleblower Alerts on trending topics. Previous

alerts, posted in FYs 2019 through 2021, covered Bank Secrecy

Act/anti-money laundering, corrupt practices (both foreign 

CFTC Customer Protect ion 

90 Commodity Futures Trading Commissio
and domestic), insider trading, crypto/digital assets, and 

spoofing

17 These trending topic alerts inform members of 

the public about how they can make themselves eligible for 

both financial awards and certain protections, while helping 

stop violations of the CEA. These alerts also raise awareness of areas of particular interest to the DOE  In addition

the WBO continued to post CFTC Customer Advisories to 

a special section on the Whistleblower Program’s website 

landing page. One advisory focused on romance scams and

another on fraud against seniors

In FY 2022, as part of ongoing efforts to make the 

Whistleblower Program more accessible, the WBO updated 

the “Frequently Asked Questions” section of its website 

and posted new fillable PDF versions of the Form TCR 

(Tip, Complaint or Referral) and Form WB-APP (award 

application)

WBO staff gave virtual presentations at four public events 

attended by members of the global futures, options, and 

cleared swaps industry; corporate counsel; the whistleblower 

bar; and potential whistleblowers. These presentations aim

to raise the profile and enhance stakeholders’ understanding 

of the program.

On October 21, 2021, the Commission announced an award 

of nearly $200 million to a whistleblower who provided 

information that significantly contributed to a Commission 

action, as well as to two related actions brought by a U.

federal regulator and a foreign regulator. At the time of the

writing of this report, the award was the largest Dodd-Frank 

whistleblower award ever issued. Beyond that historic award,

in FY 2022 the Commission granted nine other applications 

for whistleblower awards, totaling more than $12 million, 

to be paid to individuals who voluntarily provided original 

information or analyses that led to successful enforcement 

actions. The five Final Orders include awards granted to

multiple whistleblowers in a single matter—specifically, some 

who provided information and assistance to the Commission 

jointly, some who provided information leading the CFTC 

to open the relevant investigation, and some who provided 

the highest level of ongoing assistance and cooperation with 

the CFTC as the matter progressed. Since the inception of

the Whistleblower Program, the CFTC has issued 36 orders 

17 Whistleblower Alerts are available on the Whistleblower Program website’s main landing page, https://www.whistleblower.gov, as well as on a dedicated alerts page, 

https://www.whistleblower.gov/whistleblower-alerts.

granting a total of more than $330 million in awards. To date,

the total sanctions ordered in enforcement actions associated 

with those awards exceeds $3 billion.

In FY 2022 and beyond, the WBO will continue to publicize 

and explain the Whistleblower Program through customer 

advisories and alerts on its website, and by speaking and 

exhibiting at relevant industry conferences. The WBO

continues to look for ways to ensure the DOE is receiving 

the maximum benefit from each whistleblower tip, and for 

ways to ensure whistleblowers are timely and fairly rewarded 

when they bring the Commission information that leads to 

successful enforcement actions

Customer Education and Outreach

The OCEO administers the CFTC’s customer and public 

education initiatives. Among its duties, the OCEO supports

the Commission by creating and distributing financial education messages and materials designed to help customers 

spot, avoid, and report fraud and other violations of the CEA

An agency reorganization in FY 2022 included OCEO in 

OPA. The transition was made to increase outreach opportunities and capabilities as CFTC complaint data indicated

a sharp rise in customer complaints about frauds and scams 

involving digital assets. The office responded by focusing

on multi-agency strategies and tactics to amplify its outreach 

capabilities, including: 

■ A monthlong awareness-raising effort to combat romance 

scams that led victims into illegitimate digital-asset, or 

over-the-counter (OTC) foreign exchange or precious 

metals trading schemes; and 

■ Leading the establishment of a digital assets working 

group within FLEC to coordinate educational efforts 

among FLEC agencies.

OCEO continued to interact with customers and stakeholders 

through advisories, web articles, social media and other means 

online. The office also published eight new one-pagers,

advisories, and other educational materials, and marked 

significant increases in social media and online engagement

FY 2022 Agency Financial Re

 Commodity Futures Trading Commission 9

A P P E N D I X
Dating or Defrauding? was a monthlong awareness-raising 

effort to educate the public about romance scams that were 

originating on dating apps and social media platforms

Posing as potential romantic interests, the criminals who 

operate these frauds persuade victims over weeks or months 

to send money to unregistered digital asset or forex trading 

platforms. Many victims reported losing their life savings, as

well as borrowing from friends, family, and financial institutions to participate in these schemes. At least $547 million

were lost to romance scams in 2021,18 and they showed no 

sign of slowing in early 2022

The educational campaign ran from February 7 through 

March 11 to coincide with the Valentine’s Day holiday and 

involved 10 federal agencies, including law enforcement

19

The effort provided a steady drumbeat of anti-fraud socialmedia messaging from, as well as a landing page of government resources

20 In all, the effort reached of more than 

205,000 people as measured by views, impressions, and 

engagements from social media, email marketing, and other 

bilingual campaign platforms

21 The Dating or Defrauding? 

landing page attracted approximately 2,300 pageviews over 

the course of the campaign

During the month of February, traffic to CFTC.gov’s Learn

and Protect section (https://www.cftc.gov/LearnAndProtect) 

also experienced a 33 percent year-over-year increase in 

pageviews. Traffic to CFTC.gov was further aided by a

86.6 percent increase in social media referral traffic during

the effort. Social media posts by the participating agencies

achieved more than 106,000 impressions and 2,525 engagements, including comments, likes, shares, and retweets. The

effort also reached approximately 71,000 people through two 

USAGov email deliveries, which generated more than 1,300 

clicks to campaign materials and resources.

18 FTC Data Show Romance Scams Hit Record High; $547 Million Reported Lost in 2021 (Feb. 10, 2022), https://www.ftc.gov/news-events/news/press-releases/2022/02/

ftc-data-show-romance-scams-hit-record-high-547-million-reported-lost-2021.

19 Participating in the Dating or Defrauding? social media messaging campaign were the CFTC, Consumer Financial Protection Bureau (CFPB), Federal Deposit 

Insurance Corp. (FDIC), The U.S. Treasury Financial Crimes Enforcement Network (FinCEN), Federal Trade Commission (FTC), U.S. Immigration and Customs 

Enforcement (ICE) Homeland Security Investigations (HSI), and U.S. Postal Inspection Service. The effort was further supported by the General Services Administration’s 

USAGov, Federal Bureau of Investigation (FBI), and Department of Defense Office of Financial Readiness (FINRED).

20 See https://connect.usa.gov/dating-or-defrauding

21 Reach does not reflect retweets or other forms of amplification on social media, a main tactic for the effort.

22 In addition to the CFTC, members of the Digital Assets Working Subgroup include, Consumer Financial Protection Bureau (CFPB), Department of Labor Employee 

Benefits Security Administration (DOL/EBSA), Department of Defense Office of Financial Readiness (DoD FinRED), Department of Treasury, Federal Deposit Insurance 

Corp. (FDIC), Federal Trade Commission (FTC), National Credit Union Administration (NCUA), Office of the Comptroller of the Currency (OCC), Office of Personnel 

Management (OPM), and Securities and Exchange Commission (SEC).

As a result of the effort, approximately 30 news outlets and 

websites ran stories about the issue of romance frauds using 

social media, dating apps, and digital assets to steal from 

victims

For the year, the Learn and Protect section of CFTC.gov

experienced a 54.5 percent increase in pageviews over the

previous fiscal year, and pageviews for all educational articles 

and customer advisories on the website increased 98 percent

To help facilitate a government-wide discussion about 

addressing digital-asset anti-fraud education, OCEO 

approached the FLEC to establish a working group to explore 

digital-asset education issues. The Digital Asset Working

Group (a subunit of FLEC’s Retirement Saving and Investor 

Education Working Group) was announced at FLEC’s 

March 8 public meeting. OCEO leads the group, which

currently consists of members representing 10 other federal 

agencies

22 The goals of the group are to:

■ Increase knowledge and understanding of digital assets 

among Federal agency financial educators; 

■ Assess needs and gaps based on input from FLEC 

agencies, policy makers, stakeholders, and the public; 

■ Encourage consistency to minimize confusion in 

educational materials; and

■ Develop educational resources to be shared by FLEC 

members.

To date, OCEO has helped coordinate a monthly digital asset 

speaker series for FLEC-member staff. These presentations,

conducted in cooperation with CFTC’s Office of Technology 

Innovation, subject matter experts from other agencies, and 

members of the private sector, have covered topics ranging 

from introductions to blockchain technologies and various 

FY 2022 Agency Financial Re

92 Commodity Futures Trading Commissio
types of digital assets, to trends in digital asset-related frauds

The subgroup has also completed an inventory of existing 

digital asset educational materials across FLEC agencies, and 

will be adding links to publicly available resources to FLEC’s 

consumer website, MyMoney.gov  The group also will b

instrumental in coordinating future cross-agency educational development work and meeting goals established 

under Executive Order 14067

23

OCEO also discussed digital-asset related frauds and scams, 

during several national, international, and local events, 

including:

■ Cryptocurrency: How It Works, Current Research, and 

Avoiding Scams, Military Families Learning Network, 

approximately 100 participants

■ Virtual Currency Fraud Risk Webinar hosted by the 

National Futures Association, more than 60 participants

■ World Investor Week Global Fraud Forum, organized by 

the International Organization of Securities Commissions 

(IOSCO) and hosted by the Jersey Financial Services 

Commission, more than 300 participants

■ NAAGTRI Webinar on Romance Scams, hosted by the 

National Association of Attorneys General Training and 

Research Institute, 240 participants

■ Introduction to Cryptocurrency and Avoiding Digital 

Assets Scams, hosted by Howard County Money Matters 

program, 20 participants

Throughout the fiscal year, OCEO published the following 

publications, customer advisories, and joint bulletins:

■ Curious About Crypto? Watch Out for Red Flags24

23 In Crypto-Assets: Implications for Consumers, Investors, and Businesses (Sept. 2022), a report developed per Executive Order 14067 on Ensuring Responsible Development 

of Digital Assets; Section 5(b)(i), Treasury recommends that FLEC should, as appropriate: 1.) Coordinate and promote consumer education efforts on crypto-assets that 

are consumer-friendly, trustworthy, consistent, accessible, and inclusive, to the maximum extent possible; 2.) Consider using existing surveys to collect new or additional 

data about digital asset use; and 3.) Engage with industry leaders, academics, and other relevant parties to promote and coordinate public and private strategies for 

financial education outreach to consumers. See https://home.treasury.gov/system/files/136/CryptoAsset_EO5.pdf.

24 https://www.cftc.gov/sites/default/files/2022-09/DigitalAssetRedFlags.pdf

25 https://www.cftc.gov/sites/default/files/2022-09/DigitalAssetRisks.pdf

26 https://www.cftc.gov/sites/default/files/2022-09/KeyTerms.pdf

27 https://www.cftc.gov/LearnAndProtect/AdvisoriesAndArticles/CustomerAdvisory_MustKnowForex.html

28 https://www.cftc.gov/LearnAndProtect/AdvisoriesAndArticles/CustomerAdvisory_WorldElderAbuseAwarenessDay.html

29 https://www.cftc.gov/LearnAndProtect/AdvisoriesAndArticles/CustomerAdvisory_RomanceScam.html

30 https://www.cftc.gov/sites/default/files/2022-02/BitcoinETF.pdf

31 https://www.cftc.gov/LearnAndProtect/AdvisoriesAndArticles/keytopicsforworldinvestorweek2021

■ 14 Digital Asset Risks to Remember25

■ 10 Digital Asset Terms You Should Know26

■ Eight Things You Should Know Before Trading Forex27

■ Be Alert and Share Information to Help Seniors Avoid 

Fraud28

■ Avoid Forex, Precious Metals, and Digital Asset Romance 

Scams29

■ What is a Bitcoin Futures ETF?30

■ Key Topics for World Investor Week 202131

In FY 2023 and beyond, the OCEO looks forward to 

continuing its efforts to add fraud prevention content to 

CFTC.gov, as well as highlight and share that information 

with customers on social media and in the press. OCEO

plans to further develop its efforts focused on agricultural 

customers, and to explore additional programming that 

focuses on retail speculators, specifically in the areas of 

digital assets, OTC foreign exchange trading, precious metals 

investing and binary options. The OCEO expects to engage

more with active-duty and reserve military members as well 

as veterans and retirees who might be targeted by fraudsters

The OCEO uses its healthy network of stakeholders across 

the financial education spectrum to quickly ramp up 

customer education and outreach activities when resources 

and opportunities become available. The OCEO further

plans to explore engagement with certain institutional investors that may need guidance to help them identify and avoid 

unregistered entities, fraud, or abusive practices. And, the

OCEO will continue to build its relationships with public 

and private sector financial educators and organizations

FY 2022 Agency Financial Re

 Commodity Futures Trading Commission 9

A P P E N D I X
A Primer in Futures Markets

A futures contract is an agreement to purchase or sell a 

commodity for delivery in the future: 1) at a price that is 

determined at initiation of the contract; 2) that obligates each 

party to the contract to fulfill the contract at the specified 

price; 3) that is used to assume or shift price risk; and 4) that 

may be satisfied by delivery or offset. The CEA generally

requires futures contracts to be traded on regulated exchanges, 

with futures trades cleared and settled through clearinghouses, 

referred to as DCOs. To that end, futures contracts are standardized to facilitate exchange trading and clearin

Although a futures contract agreement is set today, the 

person selling (for example, a farmer marketing bushels of 

Agriculture

Precious Metals

Interest Rate

Foreign Exchange

Energy

Equity Index

All Other

wheat) will not receive payment and the buyer (in this case, 

a bakery) will not receive goods purchased until the predetermined delivery date agreed to in the contract, which in 

this example, is December 1. The farmer benefits from this

agreement because he is certain as to the amount of money 

he will earn from the farming operation, even if the price of 

wheat changes between today and December 1. Similarly,

the bakery buying the wheat also benefits by knowing how 

much the wheat will cost on December 1 and it will be better 

positioned to estimate its baking costs and set prices for its 

products. Finally, even though the actual price of wheat on

December 1 (when the contract is fulfilled) may be greater or 

less than the price agreed upon in the December 1 contract, 

the contract price is fixed and both the farmer and the bakery 

are bound by their agreement. Most futures contracts are not

Why Are the Markets Important to 

94 Commodity Futures Trading Commissio
settled with the actual physical delivery of the commodity, but 

by entering into opposite (offsetting) futures contracts, which 

serve to close out the original positions, with profits or losses 

dependent on the direction in which the price of the contracts 

have moved relative to those positions

Speculators may also buy or sell such futures contracts. The

speculator buying a futures contract for December wheat 

believes the value of the wheat in December will be higher 

than the price he or she is paying for the contract today. As

time passes, and December draws closer, traders may try 

to predict whether the cost of December wheat will rise or 

fall, and this may cause the value of that futures contract to 

fluctuate. For example, if traders expect an especially bad

harvest, then the price of December wheat will rise, and the 

speculator can sell that futures contract for December wheat 

for more than he or she paid

Over the years, the futures markets have become increasingly 

diversified from their agricultural beginnings. Futures based

on other physical commodities, such as metals, beginning 

in the 1970s, and energy products, during the 1980s, were 

developed. Since being introduced in the 1970s, financial

futures contracts based on interest rates, foreign currencies, 

Treasury bonds, security indexes, and other products have far 

outgrown the agricultural contracts in trading volume

A Primer in Swaps Markets

Generally speaking, a swap is an exchange of one set of 

cash flows for another, typically netted. Swaps can be used

to hedge risks arising from changing commodity prices, 

interest rates, credit spreads, foreign exchange rates, and 

other economic quantities

For example, a company that manufactures metal bottles 

plans to buy 50 metric tons of aluminum from its regular 

suppliers in six months, but wants to hedge against the risk 

of rising aluminum prices. It can enter into a one-year swap,

agreeing in six months to pay $2,000 per metric ton for 

50 tons of aluminum, or $100,000, in exchange for receiving 

the price of 50 metric tons of aluminum that prevails in 

FY 2022 Agency Financial Re

 Commodity Futures Trading Commission 9

A P P E N D I X
Terms of the 

Swap Contract

Two Possible Outcomes 

of the Swap Transaction

Tons of Aluminum: 50 50 50

Price/Metric Ton: $2,000 $2,500 $1,500

Contract Price: $100,000

Manufacturer Pays Fixed Price: $100,000 $100,000

Manufacturer Receives Floating Price: $125,000 $75,000

Manufacturer’s Net Receipt or Payment Depending 

on Prevailing Price on Agreed Upon Date of Swap: $25,000 ($25,000)

6 months. This swap, which is separate from the purchase

of aluminum, locks in a cost of $100,000 for the aluminum 

needs of this manufacturer in six months

If the price of aluminum at the end of the six months 

happens to be $2,500 per ton, the manufacturer will buy 

the 50 tons from its suppliers at that prevailing price, for 

a total of $125,000. At the same time, as specified by the

swap, the manufacturer will pay the agreed upon $100,000 

and receive the price of 50 tons at the prevailing price, that 

is, $125,000. Because the swap payments are netted, the

manufacturer receives $25,000. The $25,000 proceeds from

the swap offset the price increase in aluminum, so the manufacturer’s total cost of obtaining the aluminum is $100,000

If, on the other hand, the price of aluminum at the end of 

the six months happened to fall to $1,500 per ton, then the 

manufacturer buys 50 tons from its suppliers at that price, for 

a total of $75,000. The manufacturer then settles the swap

by paying $25,000, which is the difference between $100,000 

(fixed by the terms of the swap) and receiving the market 

price of $1,500 on 50 tons, or $75,000. Once again, the total

cost of obtaining the aluminum is $100,000. Hence, because

of the swap, whether the price of aluminum rises or falls, the 

manufacturer’s realized cost is $100,000. Note that, in the

case when the price turns out to be $1,500 per ton, it appears 

that the manufacturer loses money on the swap—it pays the 

difference between $100,000 and $75,000—but that is just 

part of the hedging strategy that locks in a cost of $100,000

Before the Dodd-Frank Act, swaps were traded OTC and were 

mostly bilateral, that is, strictly between the two counterparties to the swap. Since then, as envisioned by the DoddFrank Act, much of the swaps market trades on regulated

execution facilities; is reported to regulators; and—particularly in the case of interest rate swaps and credit default 

swaps—is centrally cleared, that is, the two counterparties 

to a swap legally face a clearinghouse. These changes have

greatly enhanced the Commission’s ability to monitor 

trading activity and risk in swap markets. Considerable effort

is expended at the CFTC to improve its ability to process, 

understand, and analyze the swaps market data it receives

FY 2022 Agency Financial Re

96 Commodity Futures Trading Commissio
Which Entities Does CFTC Regulate?

Associated Person—A natural person who is associated in 

certain capacities with a futures commission merchant, retail 

foreign exchange dealer, introducing broker, commodity pool 

operator, commodity trading advisor, leverage transaction 

merchant, or swap dealer or major swap participant and who 

engages in the solicitation or acceptance of orders, funds/

property, or swaps; or the supervision of any person or 

persons so engaged

Commodity Pool Operator—A person engaged in a business 

in the nature of a commodity pool, investment trust, 

syndicate, or similar form of enterprise, and who solicits or 

accepts funds, securities, or property for the purpose of trading 

commodity futures contracts or commodity options. The

commodity pool operator either itself makes trading decisions 

on behalf of the pool or engages a commodity trading advisor 

to do so

Commodity Trading Advisor—A person who, for compensation or profit, engages in the business of advising others 

as to the value or advisability of commodity futures or 

options, security futures products, swaps, retail foreign 

exchange contracts, or leverage transactions; or who, for 

compensation or profit, and as part of a regular business, 

issues or promulgates analyses or reports concerning any of 

the foregoing, subject to certain exclusions

Derivatives Clearing Organization (DCO)—An entity that, 

in respect to a contract (1) enables each party to the contract 

to substitute, through novation or otherwise, the credit of 

the derivatives clearing organization for the credit of the 

parties; (2) arranges or provides, on a multilateral basis, 

for the settlement or netting of obligations resulting from 

such contracts; or (3) otherwise provides clearing services or 

arrangements that mutualize or transfer among participants 

in the derivatives clearing organization the credit risk arising 

from such contracts. Also called a clearing house, clearing

organization, or central counterparty

Designated Contract Market—A board of trade or exchange 

designated by the CFTC to trade futures or options under 

the CEA

Exempt Derivatives Clearing Organization—A derivatives 

clearing organization that has been exempted by the 

Commission from registration for the clearing of swaps 

because the Commission has determined that the derivatives 

clearing organization is subject to comparable, comprehensive 

supervision and regulation by appropriate government 

authorities in the derivatives clearing organization’s home 

country, as permitted by the CEA

Floor Broker—A person who, in any pit, ring, post, or other 

place provided by an exchange for the meeting of persons 

similarly engaged, purchases or sells for another person any 

futures contract, commodity option, security futures product 

or swap

Floor Trader—A person who, in any pit, ring, post, or other 

place provided by an exchange for the meeting of persons 

similarly engaged, purchases or sells for their own account, 

any futures contract, commodity option, security futures 

product or swap

CFTC Oversightof Regulated 

 Commodity Futures Trading Commission 9
Foreign Board of Trade—A foreign board of trade means a 

board of trade, exchange or market located outside the U.S.

its territories or possessions, whether incorporated or unincorporated, where foreign futures or foreign options transactions 

are entered into

Futures Commission Merchant—An individual, association, 

partnership, corporation, or trust that solicits or accepts orders 

for the purchase or sale of any futures contract, commodity 

option contract, security futures contract, commodity option 

contract, security futures contract, swap, retail foreign 

exchange transaction, or leverage transaction (or who acts 

as a counterparty to a retail foreign exchange transaction), 

and who accepts payment from or extends credit to margin, 

guarantee or secure any trades resulting from the activity

Introducing Broker—A person (except any of the following, 

acting in their capacity as such: Futures commission 

merchants, floor brokers, associated persons, commodity pool 

operators, or commodity trading advisors) who, for compensation or profit, is engaged in soliciting or accepting orders 

for the purchase or sale of any futures contract, commodity 

option contract, security futures product, retail foreign 

exchange transaction, leverage transaction, or swap, and who 

does not accept any money, securities, or property to margin, 

guarantee, or secure any trades or contracts that result

Major Swap Participant—A person who maintains a substantial position in any of the major swap categories, excluding 

positions held for hedging or mitigating commercial risk 

and positions maintained by certain employee benefit plans 

for hedging or mitigating risks in the operation of the plan, 

or whose outstanding swaps create substantial counterparty 

exposure that could have serious adverse effects on the financial stability of the U.S. banking system or financial markets

or any financial entity that is highly leveraged relative to the 

amount of capital such entity holds and that is not subject 

to capital requirements established by an appropriate Federal 

banking agency and that maintains a “substantial position” 

in any of the major swap categories

Retail Foreign Exchange Dealer— A person that is, or that 

offers to be, the counterparty to a retail forex transaction, 

except for a counterparty, or person offering to be a counterparty, that is a U.S. financial institution, a broker or deale

registered with the SEC, an associated person of a broker or 

dealer registered with the SEC, a futures commission merchant 

registered with the CFTC, or a financial holding company

Swap Data Repository—Swap data repositories are entities 

created by the Dodd-Frank Wall Street Reform and Consumer 

Protection Act (Dodd-Frank Act) to provide a central facility 

for swap data reporting and recordkeeping

Swap Dealer— Any person who holds itself out as a dealer in 

swaps; makes a market in swaps; regularly enters into swaps 

with counterparties as an ordinary course of business for 

its own account; or engages in any activity causing it to be 

commonly known in the trade as a dealer or market maker in 

swaps, unless that person only engages in a de minimis amount 

of swap dealing activity

Swap Execution Facility—A trading facility that operates 

under the regulatory oversight of the CFTC for the trading 

and processing of swaps

Systemically Important Derivatives Clearing Organization—A 

derivatives clearing organization registered with the CFTC 

that has been designated as systematically important by the 

Financial Stability Oversight Council and for which the CFTC 

acts as the Supervisory Agency pursuant to Title VIII of the 

Dodd-Frank Act

FY 2022 Agency Financial Re

98 Commodity Futures Trading Commissio
Entity Description and Number CFTC Role

TRADING 

ENTITIES

• Designated Contract Market (DCM)—Exchanges 

designated to trade futures or options.

– Number of DCMs as of 9/2022: 16

• Swap Execution Facility (SEF)—A trading facility that 

trades and processes swaps.

– Number of SEFs as of 9/2022: 19

• Foreign Board of Trade (FBOT)—Any board of trade, 

exchange or market located outside of the U.S. where 

foreign futures or foreign options transactions are entered.

– Number of FBOTs as of 9/2022: 24

CFTC Role: CFTC registers new 

exchanges and foreign boards of trade, 

conducts examinations of exchange 

compliance programs, including system 

safeguards, reviews products listed by 

exchanges and rules and rule amendments 

submitted by exchanges. CFTC shares 

regulatory authority with the FBOT’s home 

regulator authority regarding oversight 

over direct access trading. CFTC also 

oversees DCMs in their SRO capacity.

CLEARING 

ENTITIES

• Derivatives Clearing Organization (DCO)—Enables parties 

to a contract to substitute the credit of the derivatives 

clearing organization for the credit of the parties, arranges 

for the settlement or netting of obligations, or provides 

clearing services.

– Number of Registered DCOs as of 9/2022:15

• Exempt DCO—A non-U.S. clearing organization clearing 

proprietary positions of U.S. persons may be exempt DCO from 

registration, subject to conditions established by the CFTC.

– Number of Exempt DCOs as of 9/2022: 4

• Systemically Important DCOs (SIDCO)—A registered 

DCO that has been designated by the Financial Stability 

Oversight Council to be systemically important for which 

the CFTC is the Supervisory Agency.

– Number of SIDCOs as of 9/2022: 2

CFTC Role: Develops regulations, 

orders, and guidance regarding DCOs; 

reviews applications for DCO registration 

and exemptions from DCO registration; 

reviews DCO rule changes; conducts 

examinations to ensure compliance 

by DCOs with the CEA and CFTC 

regulations; performs ongoing risk 

surveillance of DCOs and their 

clearing members.

DATA 

REPOSITORIES

• Swap Data Repository (SDR)—Any person that collects and 

maintains information or records with respect to transactions 

or positions in, or the terms and conditions of, swaps entered 

into by third parties for the purpose of providing a centralized 

recordkeeping facility for swaps.

– Number of SDRs as of 9/2022: 4

CFTC Role: Registers SDRs, conducts rule 

enforcement reviews to ensure compliance 

with core principles and Commission 

regulations, reviews filings and application 

amendments, and receives direct electronic 

access to swap data. 

REGISTERED 

FUTURES 

ASSOCIATION

• National Futures Association (NFA)—An independent 

self-regulatory organization (SRO) for U.S. futures and 

derivatives markets.

– Number of Registered Futures Associations as of 9/2022:1

CFTC Role: Oversees and examines NFA 

and other self-regulatory organizations.

REGISTERED 

MARKET 

PARTICIPANTS

• Certain market participants must generally be registered with

the CFTC to participate in the commodity derivatives markets. 

The CFTC registration process is handled through the NFA.

– Number of Futures Commission Merchants as of 9/2022: 58

– Number of Major Swap Participants as of 9/2022: 0

– Number of Retail Foreign Exchange Dealers as of 9/2022: 4

– Number of Swap Dealers as of 9/2022:107

– Number of Commodity Pool Operators as of 9/2022:1,256

– Number of Commodity Trading Advisors as of 9/2022:1,686

– Number of Associated Persons as of 9/2022: 42,790

– Number of Introducing Brokers as of 9/2022:993

– Number of Floor Brokers as of 9/2022: 1,086

– Number of Floor Traders as of 9/2022: 114

CFTC Role: Develops regulations, orders, 

and interpretive statements with respect 

to swap dealers, futures commission 

merchants and other registered market 

participants. The CFTC conducts 

varying levels of review of regulatory 

applications, financial and other business 

data, and examinations to determine 

compliance with the CEA and Commission 

regulations. NFA, an SRO, conducts 

a direct examination program for swap 

dealers and other registered market 

participants. The Commission thereby 

leverages the significant resources of NFA 

to meet examination workload demands, 

while preserving and focusing finite CFTC 

resources. Through its direct oversight 

of NFA, the CFTC receives the results 

of NFA examinations.

Entities Under CFTC Regulation

FY 2022 Agency Financial Re

 Commodity Futures Trading Commission 9

A P P E N D I X
U.S. Federal Laws

CEA .................Commodity Exchange Act

DATA Act .........Digital Accountability and Transparency 

Act of 2014

Dodd-Frank ......Dodd-Frank Wall Street Reform and Consumer 

Protection Act

FCPIA ..............Federal Civil Penalties Inflation Adjustment Act

FECA ................Federal Employees’ Compensation Act

FIRREA .............Financial Institutions, Reform, 

Recovery and Enforcement Act

FISMA ..............Federal Information Security Management Act

FFMIA ..............Federal Financial Management 

Improvement Act

FMFIA ..............Federal Managers’ Financial Integrity Act

GPRA ...............Government Performance and Results Act

RCA .................The Reports Consolidation Act of 2000

Because the acronyms of many words and phrases used throughout the futures and swaps industries are not readily available in standard references, the Commission’s OPA compiled a glossary to assist members of the 

public. A guide to the language of the futures and swaps industry is located online at

https://www.cftc.gov/ConsumerProtection/EducationCenter/CFTCGlossary/glossary_uv.html

Please note that List of Abbreviations and Acronyms included below and the CFTC’s online glossary are not all-inclusive, 

nor are general definitions intended to state or suggest the views of the Commission concerning the legal significance, or 

meaning of any word or term. Moreover, no definition is intended to state or suggest the Commission’s views concerning

any trading strategy or economic theory

CFTC List of Abbreviat ions and Ac

CFTC Divisions and Offices

CRU .............Climate Risk Unit

DA ...............Division of Administration

DCR .............Division of Clearing and Risk

DMO ............Division of Market Oversight

DOD ............Division of Data

DOE .............Division of Enforcement

MPD ............Market Participants Division

OCE ............Office of the Chief Economist

OCEO ..........Office of Customer Education and Outreach

OGC ............Office of the General Counsel

OIA ..............Office of International Affairs

OIG ..............Office of the Inspector General

OLIA ............Office of Legislative and Intergovernmental Affairs

OMWI ..........Office of Minority and Women Inclusion

OPA .............Office of Public Affairs

OTI ...............Office of Technology Innovation

WBO ............Whistleblower Office 

100 Commodity Futures Trading Commissio
U.S. Federal Departments and Agencies

CFTC ...............U.S. Commodity Futures Trading Commission

DHS .................U.S. Department of Homeland Security

DOL .................U.S. Department of Labor

ESC ..................U.S. Department of Transportation’s Enterprise 

Services Center

FDIC ................Federal Deposit Insurance Corporation

GAO .................U.S. Government Accountability Office

GSA .................U.S. General Services Administration

NIST .................National Institute of Standards and Technology

OMB ................Office of Management and Budget

OPM ................Office of Personnel Management

SEC ..................U.S. Securities and Exchange Commission

Treasury ...........U.S. Department of the Treasury

USDA ...............U.S. Department of Agriculture

Other Abbreviations and Industry Terms

AP ....................Associated Person 

CCP .................Central Counterparty

CMEG ..............CME Group 

CMP ................Civil Monetary Penalties 

CPF ..................Customer Protection Fund 

CPO .................Commodity Pool Operator

CSRS ...............Civil Service Retirement System

CTA ..................Commodity Trading Advisor

DCM ................Designated Contract Market

DCO ................Derivatives Clearing Organization

DQP .................Data Quality Plan

EMIR ................European Market Infrastructure Regulation

ERM .................Enterprise Risk Management

DSRO ..............Designated Self-Regulatory Organization

ENN .................Entity-Netted Notional

EU ....................European Union

FASAB .............Federal Accounting Standards Advisory Board 

FBOT ...............Foreign Board of Trade

FCM .................Futures Commission Merchant

FERS ................Federal Employees Retirement System 

FILAC ...............Filings and Actions Database

FinTech ............Financial Technology

FLEC ................Financial Literacy and Education Commission

FSB ..................Financial Stability Board

FTE ...................Full-time Equivalent

FY ....................Fiscal Year

GAAP ...............U.S. Generally Accepted Accounting Principles

GAGAS ............Generally Accepted Government Auditing 

Standards

GFIN ................Global Financial Innovation Network

IB .....................Introducing Broker

ICE ...................Intercontinental Exchange

ICC ..................Ice Clear Credit LCC

ICOR ................Internal Controls over Reporting

IOSCO .............International Organization of Securities 

Commissions

IR .....................Interest Rate

IRS ...................Interest Rate Swap

ISDA ................International Swaps and Derivatives Association

IT ......................Information Technology

MOU ................Memorandum of Understanding

MIB ..................Market Intelligence Branch

MSP .................Major Swap Participant

NFA ..................National Futures Association

NFC .................National Finance Center

ORB .................Other Retirement Benefits

OTC .................Over-the-Counter

PP&E ................Property, Plant, and Equipment

RED .................Registration Deficient List

RegTech ...........Regulatory Technology

RFED ...............Retail Foreign Exchange Dealer

S&E ..................Salarieas and Expenses

SBR ..................Statement of Budgetary Resources

SD ....................Swap Dealer

SDR .................Swap Data Repository

SEF ..................Swap Execution Facility

SFFAS ..............Statement of Federal Financial Accounting 

Standards

SIDCO .............Systemically Important DCO

SPPS ...............Special Payment Processing System

SRO .................Self-Regulatory Organization

SSE ..................System Safeguards Examination

TCR ..................Tip, Complaint, or Referral Form

TMA .................Targeted Maturity Assessment

UK ....................United Kingdom

UPI ...................Unique product identifiers

USSGL .............U.S. Standard General Ledger

UTI ...................Unique transaction identifiers

WBO APP ........Whistleblower Application Form

FY 2022 Agency Financial Re

 Commodity Futures Trading Commission 10

A P P E N D I X
We Welcome Your Comments

Thank you for your interest in the CFTC’s FY 2022 Agency Financial Report. We welcome your

comments on how we can make the report more informative for our readers. Please send feedback

to dfrederickson@cftc.gov or to:

CFTC

Financial Management Branch

Three Lafayette Centre

1155 21st Street, N.

Room 4406

Washington, DC 20581

This FY 2022 Agency Financial Report and prior year documents are available on the CFTC 

website at: https://www.cftc.gov/About/CFTCReports/index.htm

This report is in the public domain. Authorization to reproduce it in whole or in part is grante

While permission to reprint this publication is not necessary, the citation should be: Commodity 

Futures Trading Commission, FY 2022 Agency Financial Report, Washington, D.C. 205

Page Photo Credits

Photographs in this document are proprietary and prior permission from the photographer is 

required for any use or reproduction of the photographs

CFTC Photos; Pages II, 1, 2, 4, 7, 12, 15, 16, and 21

Clark Day Photography; Pages 8, 10, 19, 22, and 46

Stock Images; Pages Cover, I, 1, 5, 14, 42, 45, 79, 89, 95, and 98

102 Commodity Futures Trading Commissio
Certificate of Excellence in

Accountability Reporting®

in recognition of outstanding effort in preparing the 

Agency Financial Report for fiscal year 2021

presented to the

Ann M. Ebberts, MS, PMP

Chief Executive Officer, AGA

Diane L. Dudley, CGFM, CPA

Chair, CEAR Board

U.S. Commodity Futures 

Trading Commission

C O M M O D I T Y F U T U R E S T R A D I N G C O M M I S S I O N

Certificate of Excelle

Accountability R

“In recognition of outstanding efforts in preparing the 

Commodity Futures Trading Commission Agency Financial 

Report for the fiscal year ended September 30, 2021”

Association of Government Accountants (AGA)

Awards the
C O M M O D I T Y F U T U R E S T R A D I N G C O M M I S S I O N

Three Lafayette Cente •  1155 21st Street, N.W. • Washinton, 

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