U.S. COMMODITY FUTURES TRADING COMMISSION

OFFICE OF INSPECTOR GENERAL

Three Lafayette Centre

1155 21st Street, NW, Washington, DC 20581

1 

TO: Heath P. Tarbert, Chairman 

Brian D. Quintenz, Commissioner 

Rostin Behnam, Commissioner

Dawn Stump, Commissioner

Dan Berkovitz, Commissioner

FROM: Miguel A. Castillo, CPA, CRMA

Assistant Inspector General for Auditing

DATE: October 23, 2019 

SUBJECT: Audit of the CFTC Customer Protection Fund Financial Statements 

(Fiscal Year 2019) 

Annually the Office of the Inspector General (OIG) engages an independent public 

accountant (IPA) to perform an audit of the CFTC Customer Protection Fund (Fund) 

financial statements. The balance of the Fund1 as of September 30, 2019, was 

$125,439,162. We contracted Allmond & Company, LLC (Allmond & Co.) to audit the

financial statements of the Fund as of September 30, 2019, and for the year then 

ended, to provide negative assurance on internal control and compliance with laws and 

regulations for financial reporting. We required that the audit be done in accordance 

with U.S. Generally Accepted Government Auditing Standards (GAGAS).

In its audit of the Fund, Allmond & Co. found:

• The financial statements were fairly presented, in all material respects, in 

conformity with U.S. Generally Accepted Accounting Principles. 

In connection with the contract, we reviewed Allmond & Company’s report and related 

documentation and inquired of its representatives. Our review, as differentiated from 

an audit of the financial statements in accordance with U.S. generally accepted 

government auditing standards, was not intended to enable us to express, and we do 

not express, opinions on CFTC’s financial statements or internal control over financial 

reporting, or on compliance with laws and other matters. Allmond & Co. is responsible 

for the attached auditor’s report dated October 18, 2019 and the conclusions 

expressed therein. However, our review disclosed no instances where Allmond & Co.

did not comply, in all material respects, with GAGAS. 

 

1 Total net position. 
2 

Attached is a copy of Allmond & Co.’s unmodified (clean) opinion. Please call me if any 

questions at (202)418-5084.

Cc:

Jamie Klima, Chief of Staff

Kevin S. Webb, Chief of Staff

John Dunfee, Chief of Staff

Daniel Bucsa, Chief of Staff

Erik Remmler, Chief of Staff

Christopher Ehrman, Director. Whistleblower Office

Anthony C. Thompson, Executive Director

Keith A. Ingram, Accounting Officer

Melissa Jurgens, Chief, Executive Secretariat Branch

A. Roy Lavik, Inspector General

Judith A. Ringle, Deputy Inspector General and Chief Counsel
1 

Independent Auditors’ Report

Chairman and Inspector General of

U.S. Commodity Futures Trading Commission: 

 

Report on the Financial Statements

We have audited the accompanying financial statements of the U.S. Commodity Futures Trading 

Commission (CFTC) Customer Protection Fund (CPF), which comprise the balance sheets as of 

September 30, 2019 and 2018; the related statements of net cost, changes in net position, and budgetary 

resources for the fiscal years then ended; and the related notes to the financial statements (hereinafter 

referred to as the financial statements).

Management’s Responsibility for the Financial Statements

Management is responsible for the preparation and fair presentation of these financial statements in 

accordance with accounting principles generally accepted in the United States of America; this 

responsibility includes the design, implementation, and maintenance of 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 Responsibility

Our responsibility is to express an opinion on the fiscal year 2019 and 2018 financial statements of CPF 

based on our audits. We conducted our audits in accordance with auditing standards generally accepted in 

the United States of America; the standards applicable to financial audits contained in Government 

Auditing Standards issued by the Comptroller General of the United States; and the Office of 

Management and Budget (OMB) Bulletin No. 19-03, Audit Requirements for Federal Financial 

Statements. Those standards and OMB Bulletin No. 19-03 require that we plan and perform the audit to 

obtain reasonable assurance about whether the financial statements are free of material misstatement. 

An audit involves performing procedures to obtain audit evidence about the amounts and disclosures in 

the financial statements. The procedures selected depend on the auditors' judgment, including the 

assessment of the risks of material misstatement of the financial statements, whether due to fraud or error. 

In making those risk assessments, the auditor considers internal control relevant to the entity’s preparation 

and fair presentation 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 entity' s 

internal control. Accordingly, we express no such opinion.
2 

An audit also includes evaluating the appropriateness of the accounting policies used and the 

reasonableness of significant accounting estimates made by management, as well as the overall 

presentation of the financial statements.

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

our audit opinion. 

Opinion

In our opinion, the financial statements referred to above present fairly, in all material respects, the 

financial position of U.S. Commodity Futures Trading Commission Customer Protection Fund as of 

September 30, 2019 and 2018, and its net cost of operations, changes in net position, and budgetary 

resources for the fiscal years then ended in accordance with accounting principles generally accepted in 

the United States of America.

Other Matter

Required Supplementary Information

The information in CPF’s Annual Report to Congress and the Cash Flow Analysis are not a required part 

of the basic financial statements, but are supplementary information required by the Dodd-Frank Wall 

Street Reform and Consumer Protection Act. We have applied certain limited procedures, which 

consisted principally of inquiries of management regarding the methods of preparing the information and 

comparing the information for consistency with management’s responses to our inquiries, the basic 

financial statements, and other knowledge we obtained during our audit of CPF’s financial statements. 

However, we did not audit this information and, accordingly, we express no opinion on it. 

Other Reporting Required by Government Auditing Standards

Internal Control over Financial Reporting

In planning and performing our audit of CPF’s financial statements as of and for the year ended 

September 30, 2019, in accordance with generally accepted government auditing standards, we 

considered CPF’s internal control over financial reporting as a basis for designing audit procedures that 

are appropriate in the circumstances for the purpose of expressing our opinion on the financial statements, 

but not for the purpose of expressing an opinion on the effectiveness of CPF’s internal control over 

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

reporting. We limited internal control testing to those necessary to achieve the objectives described in 

OMB Bulletin No. 19-03. We did not test all internal control relevant to operating objectives as broadly 

defined by the Federal Managers’ Financial Integrity Act of 1982.

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 misstatement on a timely basis. A material weakness is a deficiency, or combination of 

deficiencies, 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 significant 

deficiency is a deficiency or a combination of deficiencies, in internal control that is less severe than a 

material weakness yet important enough to merit the attention by those charged with governance. 

Our consideration of internal control over financial reporting was for the limited purpose as described in 
3 

the first paragraph of this section, and was not designed to identify all deficiencies in internal control over 

financial reporting that might be material weaknesses or significant deficiencies and therefore material 

weaknesses or significant deficiencies may exist that were not identified. Given these limitations, during 

our fiscal year 2019 audit we did not identify any deficiencies in internal control over financial reporting 

that we considered to be a material weakness, as defined above. However, material weaknesses may exist 

that have not been identified.

Compliance and Other Matters

As part of obtaining reasonable assurance about whether CPF’s fiscal year 2019 financial statements are 

free of material misstatements, we performed tests of CPF’s compliance with certain provisions of 

applicable laws, regulations, contracts, and grant agreements, which noncompliance could have a direct 

and material effect on the determination of material amounts and disclosures in CPF’s financial 

statements, and certain provisions of other laws specified in OMB Bulletin No. 19-03. However, 

providing an opinion on compliance with those provisions was not an objective of our audit, and 

accordingly, we do not express such an opinion. 

The results of our tests of compliance as described in the preceding paragraph, disclosed no instances of 

noncompliance or other matters that are required to be reported herein under Government Auditing 

Standards or OMB Bulletin No. 19-03. 

Purpose of the Other Reporting Required by Government Auditing Standards

The purpose of the communication described in the Other Reporting Required by Government Auditing 

Standards section is solely to describe the scope of our testing of internal control and compliance with 

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

testing, and not to provide an opinion on the effectiveness of CPF's internal control or on compliance. 

This communication is an integral part of an audit performed in accordance with U.S. generally accepted 

government auditing standards in considering in internal controls and compliance with laws, regulations, 

contracts, and grant agreements which could have a material effect on CPF’s financial statements. 

Accordingly, this communication is not suitable for any other purpose.

 

Allmond & Company, LLC Lanham, MD 

October 18, 2019 
4 

FINANCIAL STATEMENTS FOR THE 

CUSTOMER PROTECTION FUND

REPORT TO CONGRESS

September 30, 2019 
2

U.S. Commodity Futures Trading Commission 

Customer Protection Fund Report to Congress: Financial Statements

Table of Contents

Financial Statements ....................................................................................................................... 3 

Notes to the Financial Statements ................................................................................................... 7 

Supplementary Schedule:

Cash Flow Analysis...........................................................................................................13 
3

Commodity Futures Trading Commission 

Customer Protection Fund

Balance Sheets

As of September 30, 2019 and 2018 

2019 2018

Assets

Intragov ernmental:

Fund Balance With Treasury (Note 2) $ 13,148,336 $ 7,293,399

Inv estments (Note 3) 141,300,000 157,518,375

Prepay ments 221,818 -

Total Intragovernmental 154,670,154 164,811,774

General Property , Plant and Equipment, Net (Note 4) 50,126 93,090

Total Assets $ 154,720,280 $ 164,904,864

Liabilities

Intragov ernmental:

Employ er Contributions and Pay roll Tax es Pay able 28,667 21,750

Total Intragovernmental 28,667 21,750

Accounts Pay able 8,670,172 1,361,602

Accrued Pay roll 112,825 89,881

Accrued Annual Leav e 189,308 180,158

Liability for Whistleblower Awards (Note 5) 20,280,146 4,913,875

Total Liabilities 29,281,118 6,567,266

Contingent Liabilities (Note 6)

Net Position

Cumulativ e Results of Operations - Funds from Dedicated Collections 125,439,162 158,337,598

Total Net Position 125,439,162 158,337,598

Total Liabilities and Net Position $ 154,720,280 $ 164,904,864

The accompanying notes are an integral part of these financial statements.
4

Commodity Futures Trading Commission 

Customer Protection Fund

Statements of Net Cost

For the Years Ended September 30, 2019 and 2018 

2019 2018

Net Costs of Operations

Gross Costs $ 36,104,893 $ 41,446,286

Total Net Cost of Operations $ 36,104,893 $ 41,446,286

The accompanying notes are an integral part of these financial statements.
5

Commodity Futures Trading Commission 

Customer Protection Fund

Statements of Changes in Net Position 

For the Years Ended September 30, 2019 and 2018 

2019 2018

CumulativeResults of Operations

Beginning Balances, October 1

Budgetary Financing Sources:

$ 158,337,598 $ 196,336,209

Nonex change Interest Rev enue 3,206,457 3,447,675

Total Financing Sources 3,206,457 3,447,675

Net Cost of Operations (36,104,893) (41,446,286)

Net Change (32,898,436) (37,998,611)

Total Cumulative Results of Operations, September 30 $ 125,439,162 $ 158,337,598

The accompanying notes are an integral part of these financial statements.
6

Commodity Futures Trading Commission 

Customer Protection Fund

Statements of Budgetary Resources

For the Years Ended September 30, 2019 and 2018 

2019 2018

BUDGETARY RESOURCES

Unobligated Balance from Prior Year Budget Authority , Net (Note 7) $ 159,272,922 $ 236,280,890

Spending Authority from Offsetting Collections 3,024,893 3,209,206

Total Budgetary Resources $ 162,297,815 $ 239,490,096

STATUS OF BUDGETARY RESOURCES

New Obligations and Upward Adjustments $ 20,862,226 $ 80,540,550

Unobligated Balance, End of Year

Apportioned, Unex pired Accounts 141,435,589 158,636,895

Unapportioned, Unex pired Accounts - 312,651

Unobligated Balance, End of Year (Total) 141,435,589 158,949,546

Total Budgetary Resources $ 162,297,815 $ 239,490,096

OUTLAYS, NET

Agency Outlay s, Net $ 10,345,063 $ 76,767,593

The accompanying notes are an integral part of these financial statements.
7

Notes to the Financial Statements

For the Years Ended September 30, 2019 and 2018 

Note 1. Summary of Significant Accounting Policies

A. Reporting Fund

The Commodity Futures Trading Commission (CFTC or the Commission) is an independent agency of the 

executive branch of the Federal Government. Its mission is to “protect market users and the public from 

fraud, manipulation, and abusive practices related to the sale of commodity futures and options, and to 

foster open, competitive, and financially sound commodity futures and options markets.”

On July 21, 2010, the “Dodd-Frank Wall Street Reform and Consumer Protection Act” (the Dodd-Frank 

Act, or the Act) was signed into law, significantly expanding the powers and responsibilities of the CFTC. 

According to Section 748 of the Act, there is established in the Treasury of the United States a revolving 

fund known as the “Commodity Futures Trading Commission Customer Protection Fund” (the Fund). 

The Fund shall be available to the Commission, without further appropriation or fiscal year limitation, for 

a) the payment of awards to whistleblowers; and b) 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. 

The Act requires CFTC to transmit to the Committee on Agriculture, Nutrition and Forestry of the Senate, 

and the Committee on Agriculture of the House of Representatives a report which includes a complete set 

of audited financial statements and supplementary information, including balance sheet, income 

statement, and cash flow analysis, no later than October 30, of each year.

B. Basis of Presentation 

The financial statements have been prepared to report the financial position and results of operations for 

the Fund, as required by the Dodd-Frank Act. These statements have been prepared from the Fund’s 

books and records, which are a component of the Commission’s books and records, in conformity with

U.S. generally accepted accounting principles (GAAP), as prescribed for the Federal government by the 

Federal Accounting Standards Advisory Board (FASAB) and in accordance with the form and content 

requirements contained in Office of Management and Budget (OMB) Circular A-136, Financial Reporting 

Requirements, as amended. Accounting standards allow certain presentations and disclosures to be 

modified, if needed, to prevent the disclosure of classified information.

The Fund was established in July 2010 and funded by transfers from CFTC’s Civil Monetary Penalties, 

Fines and Administrative Fees receipt account. These transfers do not meet the criteria of reportable 

revenue as defined by the Statement of Federal Financial Accounting Standards (SFFAS) 7, Accounting 

for Revenue and Other Financing Sources and Concepts for Reconciling Budgetary and Financial 

Accounting. 

The financial statements report on the Fund’s financial position, changes in net position, net cost and 

budgetary resources. The books and records of the Fund served as the source of information for preparing 

the financial statements in the prescribed formats. All Fund financial statements and reports used to 

monitor and control financial resources are prepared from the same books and records. The statements 

should be read with the understanding that they relate to a fund controlled by CFTC, a component of the

U.S. Government, a sovereign entity.

The Balance Sheet presents the financial position of the Fund. The Statement of Net Cost presents the 

Fund’s operating results. The Statement of Changes in Net Position displays the changes in the Fund’s net 

position, and the Statement of Budgetary Resources shows the spending authority of the Fund derived 

from the deposits eligible from civil monetary collections.
8

C. Fund Balance with Treasury

Fund Balance with Treasury is the aggregate amount of the Fund’s balance with the U.S. Treasury. The 

balance in the Fund is available to pay current liabilities and finance authorized operations.

The Fund does not maintain bank accounts of its own, has no disbursing authority, and does not maintain 

cash held outside of Treasury. Treasury makes disbursements for the Fund.

D. Investments in U.S. Government Securities

The CFTC has authority to invest amounts in the Customer Protection Fund in market-based U.S. 

Treasury securities. Market-based Treasury securities are debt securities that the U.S. Treasury issues to 

Federal entities without statutorily determined interest rates. Although the securities are not marketable, 

the terms (prices and interest rates) mirror the terms of marketable Treasury securities. Investments are 

carried at their historical cost basis which approximates fair value due to their short-term nature. 

The interest earned on the investments is a component of the Fund and is available to be used for 

expenses of the Fund. Additional details regarding investments are provided in Note 3.Investments.

E. General Property, Plant and Equipment, Net

The Commission 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. The Commission’s assets 

are valued net of accumulated depreciation or amortization.

As of September 30, 2019, the Commission has capitalized as software the costs for development of a 

website for the CFTC Whistleblower Office. Additional details regarding general property, plant, and 

equipment are provided in Note 4. General Property, Plant and Equipment, Net.

F. Liabilities

The Fund’s liabilities consist of actual and estimated amounts that are likely to be paid as a result of 

transactions covered by the Whistleblower Incentives and Protection regulation, and will be paid from 

available balances remaining in the Fund. In addition, the salaries and operating expenses of the 

Whistleblower’s Office and Office of Customer Education and Outreach were funded through the Fund. 

Total accrued payroll is composed of amounts to be paid to Fund employees as well as the related 

intragovernmental payable for employer contributions and payroll taxes. The accrued 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 Fund’s 

liabilities are considered current liabilities.

G. Funds from Dedicated Collections

The Fund contains dedicated collections that can only be used to operate a whistleblower program and 

support customer education initiatives. See Note 1.A. for a description of the purpose of the Fund and its 

authority to use the revenues and other financing sources. Deposits into the Fund are credited from 

monetary sanctions collected by the Commission in covered judicial or administrative actions not 

otherwise distributed to victims of a violation of the Dodd-Frank Act or the rules and regulations 

underlying such action, unless the balance of the Fund at the time the monetary judgment is collected 

exceeded $100 million. No new legislation was enacted as of September 30, 2019, that significantly 

changed the purpose of the dedicated collections or redirected a material portion of the accumulated 

balance.
9

H. Revenues and Other Financing Sources

The CFTC Customer Protection Fund is funded through monetary sanctions resulting from judicial or 

administrative action brought by the Commission under the Commodity Exchange Act. All collections are 

deposited into a receipt account. Eligible collections are transferred into the Fund from the CFTC’s Civil 

Monetary Penalties, Fines and Administrative Fees receipt account.

Congress enacted the Dodd-Frank Act that provides the CFTC with the authority to establish the Fund. 

The Fund is available to the Commission, without further appropriation or fiscal year limitation. These 

funds are considered financing sources under U.S. Treasury Department guidelines. Per the Act, no 

sanction collected by the Commission can be deposited into the Fund if the Fund’s balance exceeds $100 

million. The CFTC may request the Secretary of the Treasury to invest Fund amounts in Treasury 

obligations. No eligible collections have been transferred into the Fund since it reached its legislative 

maximum during FY 2014.

I. Intra- and Inter-Agency Relationships

The CFTC is an independent Federal agency. The Commodity Futures Trading Commission Customer 

Protection Fund is a fund within the CFTC, and these financial statements present a segment of the CFTC 

financial activity. The financial events of the Fund are consolidated into the CFTC annual financial 

statements.

J. Use of Management Estimates

In addition to accruals for goods and services, management estimates were used to calculate overhead 

expenses in the amount of $1,487,000 and $1,092,000 that were allocated to the Fund for the years ended 

September 30, 2019, and 2018. These amounts were derived by multiplying management’s estimated 

overhead cost per full-time equivalent (FTE) by the number of FTE charged to the Fund.

K. Limitations of the Financial Statements 

The principal financial statements included in this report have been prepared to report the financial 

position and results of operations of the Fund, pursuant to the requirements of Section 748 of the DoddFrank Consumer Protection Act. While the statements have been prepared from the books and records of 

the CFTC in accordance with GAAP for Federal entities, these statements are in addition to the reports 

used to monitor and control the financial activity of the CFTC, which are prepared from the same books 

and records. The statements should be read with the understanding that they are for the Customer 

Protection Fund, a single fund within the CFTC. 

Note 2. Fund Balance with Treasury

A. Reconciliation to Treasury

There are no differences between the fund balance reflected in the Fund’s Balance Sheet and the balance 

in the Treasury account.
10

B. Fund Balance with Treasury

Fund Balance with Treasury as of September 30, 2019, and 2018, consisted of the following:

2019 2018

Unobligated Fund Balance

Av ailable $ 751,948 $ 1,865,965

Obligated Balance Not Yet Disbursed 12,396,388 5,427,434

Total Fund Balance with Treasury $ 13,148,336 $ 7,293,399

Note 3. Investments

The CFTC invests amounts deposited in the Fund in overnight short-term Treasury securities. Treasury 

overnight certificates of indebtedness 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 overnight certificates are Treasury securities whose interest rates or prices are determined based on 

the interest rates or prices of Treasury-related financial instruments issued or trading in the market, 

rather than on the interest rates or prices of outstanding marketable Treasury securities. The Commission 

may invest in other short-term or long-term Treasury securities at management’s discretion

The Commission’s investments as of September 30, 2019, and 2018, were $141,300,000 and

$157,518,375, respectively. Related nonexchange interest revenue for the years ended September 30, 

2019, and 2018, was $3,206,457 and $3,447,675, 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 U.S. Treasury, 

which uses the cash for general Government purposes. As discussed above and in Note 1.D., the 

Commission invests the majority of these funds in Treasury securities. These Treasury securities are an 

asset of the Commission and a liability of the U.S. Treasury. Because the Commission and the U.S. 

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. Government-wide financial statements.

Treasury securities provide the Commission with authority to draw upon the U.S. 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. 
11

Note 4. General Property, Plant and Equipment, Net

Property, Plant and Equipment as of September 30, 2019, and 2018, consisted of the following: 

2019

Major Class Service Life and Method Cost

Accumulated

Amortization/ 

Depreciation Net Book Value

IT Software 5 Years/Straight Line 214,824 (164,698) 50,126

$ 214,824 $ (164,698) $ 50,126

2018

Major Class Service Life and Method Cost

Accumulated 

Amortization/

Depreciation Net Book Value

IT Software 5 Years/Straight Line 214,824 (121,734) 93,090

$ 214,824 $ (121,734) $ 93,090

Note 5. Liability for Whistleblower Awards

As mentioned in Note 1A, the 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 million 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 and the 

whistleblower has provided necessary banking information. As of September 30, 2019, and September 30, 

2018, the Commission recorded liabilities for pending payments to whistleblowers of approximately

$20,280,146 and $4,913,875, respectively. During FY 2019, the Commission disbursed $8,384,664 in 

whistleblower awards, which included $3,783,174 from pending payments at the end of FY 2018 and 

$4,601,490 in new awards issued during the year. Accounts payable includes approximately $7,000,000 

for awards that have been finalized as of September 30, 2019.

In addition to the pending payments to whistleblowers, the Commission had 14 additional whistleblower 

claims currently under review as of September 30, 2019. 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 $29,286,750.

Note 6. Contingencies

Unasserted claims are actions or potential actions the Commission is aware of in which future events may 

result in claims against the Fund.

In accordance with Federal accounting standards, CFTC records contingent liabilities for any unasserted 

claim in which payment has been deemed probable and for which the amount of potential liability can be 

estimated. The Commission also discloses all claims for which payment is reasonably possible. There 

were no unasserted claims deemed probable or reasonably possible as of September 30, 2019. 
12

Note 7. Statement of Budgetary Resources: 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. The Adjustments to Unobligated Balance Brought Forward, 

October 1, as of September 30, 2019, and 2018, consisted of the following:

2019 2018

Unobligated Balance Brought Forward, October 1 $ 158,949,546 $ 234,774,938

Recov eries of Prior Year Obligations 323,376 1,505,952

Unobligated Balance from Prior Year Budget Authority, Net $ 159,272,922 $ 236,280,890
13

Supplementary Schedule

Commodity Futures Trading Commission 

Customer Protection Fund

Cash Flow Analysis

For the Period from October 1, 2018 to September 30, 2019

Cash as of October 1, 2018 $ 7,293,399

Cash flows from operating activities

Paid Ex penses for Whistleblower and Consumer Education andOutreach Offices $ (13,570,465) 

Refunds collected 570

Net cash flows from operating activities $ (13,569,895)

Cash flows from investing activities

Redemptions of US Treasury Securities $ 16,200,000

Interest collected from inv esting in US Treasury Securities 3,224,832

Net cash flows from investing activities $ 19,424,832

Net increase/(decrease) in cash and cash equivalents $ 5,854,937

Cash as of September 30, 2019 $ 13,148,336