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Report File
Date Issued
Submitting OIG
Commodity Futures Trading Commission OIG
Agencies Reviewed/Investigated
Commodity Futures Trading Commission
Report Number
24-AU-05
Report Description

We contracted with Williams, Adley & Company-DC, LLP (Williams Adley) to examine the effectiveness of the CFTC’s ERM process as well as its maturity. Williams Adley conducted the audit in accordance with Generally Accepted Government Auditing Standards (GAGAS) and is responsible for the attached audit report and the conclusions expressed therein.1 The OIG monitored the auditor’s progress throughout the performance audit and reviewed the respective audit report and related documentation.

Report Type
Audit
Agency Wide
Yes
Number of Recommendations
20
Questioned Costs
$0
Funds for Better Use
$0
Report updated under NDAA 5274
No

Open Recommendations

This report has 20 open recommendations.
Recommendation Number Significant Recommendation Recommended Questioned Costs Recommended Funds for Better Use Additional Details
ERM-24-01 - Recommendation 1 No $0 $0

Establish a Risk Management Committee and include key personnel and stakeholders from different CFTC Divisions.

ERM-24-01 - Recommendation 2 No $0 $0

Create the Governance Charter and hold regular meetings with the Risk Management Committee.

ERM-24-01 - Recommendation 3 No $0 $0

Update and finalize an ERM roadmap from 2020 which includes estimated and actual completion dates.

ERM-24-01 - Recommendation 4 No $0 $0

Develop Annual Risk Analysis Reports and distribute to the various divisions.

ERM-24-01 - Recommendation 5 No $0 $0

Implement an Enterprise Governance, Risk and Compliance (eGRC) Tool which will help aggregate risks across the enterprise and map them to strategic objectives.

ERM-24-01 - Recommendation 6 No $0 $0

Enhance ERM communication channels and hold regular meetings between the ERM team and departments.

ERM-24-01 - Recommendation 7 No $0 $0

Increase CFTC leadership support and conduct regular briefings and workshops, and actively participate in ERM activities.

ERM-24-01 - Recommendation 8 No $0 $0

Foster a collaborative environment by appointing ERM liaisons within each division.

ERM-24-01 - Recommendation 9 No $0 $0

Conduct training sessions to educate employees about the ERM program and its benefits.

ERM-24-02 - Recommendation 10 No $0 $0

Develop a formal ERM policy that outlines the framework, objectives, and scope of the program. This policy should be approved by senior management and communicated across the organization.

ERM-24-02 - Recommendation 11 No $0 $0

Create standardized procedures to conduct ERM assessments including guidelines for risk identification, assessment, mitigation, and monitoring.

ERM-24-02 - Recommendation 12 No $0 $0

Define its ERM risk rating methodology to consistently evaluate and prioritize risks and align this methodology with the organization’s risk appetite and tolerance levels.

ERM-24-02 - Recommendation 13 No $0 $0

Maintain a centralized risk register to document all identified risks as well as the risk owners, mitigation strategies, and monitoring plans.

ERM-24-02 - Recommendation 14 No $0 $0

Establish a timeline and criteria for conducting regular risk assessments and continuously monitoring and managing risk with at least an annual risk assessment.

ERM-24-02 - Recommendation 15 No $0 $0

Regularly review and update the ERM program to incorporate best practices and lessons learned to strive for continuous improvement.

ERM-24-03 - Recommendation 16 No $0 $0

Enhance its ERM team capacity and prioritize hiring skilled ERM professionals and provide ongoing training to existing staff.

ERM-24-03 - Recommendation 17 No $0 $0

Ensure ERM considerations are integrated into the strategic planning process with active involvement from senior executives.

ERM-24-03 - Recommendation 18 No $0 $0

We suggest CFTC to also Improve its processes by investing in technology that supports ERM activities, such as risk assessment tools and data analytics platforms.

ERM-24-03 - Recommendation 19 No $0 $0

Address budget constraints by reevaluating the resources dedicated to the ERM program and exploring cost-effective solutions and tools to enhance the ERM program without significant financial investment.

ERM-24-03 - Recommendation 20 No $0 $0

Strengthen its organizational resilience by conducting regular risk awareness and training sessions for all employees to build a risk-aware culture and establish a feedback loop to continuously assess and improve the ERM program based on lessons learned and emerging best practices.

Commodity Futures Trading Commission OIG

United States