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The Commission’s over-arching information technology (IT) strategy is to manage data as an enterprise asset, promote and adopt industry data standards, give priority to services that provide the greatest mission benefit, architect services using small components that can be assembled and reassembled with agility, and deliver solutions in short, iterative phases. The Dodd-Frank Act expanded the regulatory scope of the CFTC nearly eight fold and the effective use of information technology will help the CFTC exercise this unprecedented increase in authority by providing staff with information and tools that serve as force multipliers.

The Commission has organized its IT investments into three areas: Surveillance, Enforcement, and Infrastructure.  The Surveillance Investment supports market oversight, trade practice oversight, and financial and risk oversight.  Surveillance is highly dependent on the ability to acquire large volumes of data and the development of sophisticated analytics to identify trends and/or outlying events that warrant further investigation.  The Commission’s ability to view aggregated data across the futures and swaps landscape is essential.  Surveillance technology receives and processes seven to eight million transaction per day and alerts Commission staff to questionable activity. The details of each individual trade are collected from exchanges overnight and loaded and processed for reporting, analysis, and profiling, providing staff with greater efficiency and flexibility by performing sophisticated pattern recognition and data mining, helping detect novel and complex abusive practices. Alerts of potential trade practice violations are generated for review by market compliance and surveillance staff.  Surveillance technology also allows staff to identify large traders whose positions may pose financial risk to the industry or a clearing firm, analyze an owner's holdings and project the effect of market moves on these holdings, perform "what if" stress testing and risk scenarios to determine the effect of market movement on margin, and evaluate overall portfolio risk under different market conditions. It allows staff to monitor intermediaries by storing and analyzing monthly financial statements and annual reports provided to the Commission to report net capital positions and other financial information. 

The Enforcement Investment provides a variety of critical automated litigation support services to Commission staff that facilitate the overall management of documents and data:

• Provides the ability to rapidly query and retrieve information about investigations and litigation;
  
  
• Provides recurrent and ad hoc analytics;
  
  
• Provides a collaborative electronic work environment across geographically dispersed locations (Washington, Chicago, Kansas City, and New York);
  
  
• Manages client contacts, leads, investigations, litigation and trial schedules;
  
  
• Provides mobile access to and presentation of documentary and analytic evidence;
  
  
• Supports digital-based trial presentations; and
  
  
• Tracks forensics information on seized computer equipment.

The investment also supports the Commission's defensive litigation, internal investigations, the processing of privacy and Freedom of Information Action (FOIA) requests, and the preservation of electronically stored information that is subject to a "litigation hold" or other preservation obligations.

Both the Surveillance and Enforcement depend on the Infrastructure and Management, which provides the underlying infrastructure for IT services including messaging and communications, network security, database administration, IT business continuity, and data storage management. The investment also provides transparency through the CFTC.gov website, staff collaboration and knowledge management through the CFTCnet intranet, Commission-wide document and records management, and internal management and administrative systems that supplement Commission use of financial and human resource services provided by government service providers. 

• The Commission planned spending for FY 2012 is $45.0 Million for services and $16.2 Million for  FTE.
  
  
• Surveillance:
  
  
  • Implement software to load swaps data into a Commission data warehouse for use by CFTC staff for market surveillance, risk monitoring, enforcement, and economic analysis.
    
    
  • Work with industry to define data standards and will develop data loading software to support Commission systems for swaps data.
    
    
  • Integrate NFA systems and data stored at NFA with CFTC systems and data.
    
    
  • Implement futures and swaps risk management software to enable the CFTC to analyze margin requirements; determine price impact on portfolios; conduct margin trend analyses and back testing; and stress test swaps positions - including interest rate swaps, energy swaps and credit default swaps.
    
    
  • Modify current financial and risk surveillance systems to monitor volatility, variation margin, and increased financial reporting.
    
    
• Enforcement:
  
  
  • Complete eDiscovery implementation and FOIAExpress integration to manage improve litigation, reduce litigation risk, and improve transparency through FOIA.
    
    
  • Complete FIS software implementation to improve acquisition of case-specific financial data.
    
    
  • Continue to refresh Enforcement COTS to adapt to financial industry adoption of new technology.
    
    
• Infrastructure and Management:
  
  
  • Begin the phased deployment of a web-based registration to allow for the direct registration of entities, registration of foreign boards of trade, submission of rules and products, and requests for Commission actions or interpretations and to flow information directly into internal CFTC systems.
    
    
  • Host on CFTC.gov an Online Submission and Communication Portal to and provide industry users with an account-specific view of their submissions to the CFTC to improve transparency of CFTC processes and procedures, providing automated notifications to external accounts regarding required actions.
    
    
  • Receive electronic forms from traders, reporting firms, and exchanges to improve data quality and decrease industry costs for providing the information and CFTC costs for ingesting the information.
    
    
  • Scale communication, processing, and storage infrastructure to meet demand.
    
    
  • Continue business continuity and security control automation (continuous monitoring) implementation to reduce operational risk.

• The Commission’s request for FY 2013 is $70.0 Million for services and $26.2 Million for FTE.
  
  
• Surveillance:
  
  
  • Enhance surveillance systems to collect and incorporate that data into analyses covering both swaps and futures markets.
    
    
  • Develop new models to generate alerts, thereby facilitating market and financial surveillance.
    
    
  • Modify large trader reporting and financial risk surveillance systems to support new swaps data analysis, internal reporting requirements, and transparency reporting on CFTC.gov.
    
    
  • Begin using market order data to monitor disruptive trading activities and conduct additional automated market surveillance activities such as identifying withheld orders.
    
    
  • Augment or modify financial and risk surveillance systems to monitor Commodity Pool Operators and Commodity Trading Advisors.
    
    
• Enforcement:
  
  
  • Provide support for enforcement tips, referrals and early case assessment to exercise new authority.
    
    
  • Expand case management component to support enterprise-wide case management and integrate surveillance referrals into the ingestion process for enforcement cases.
    
    
  • Update Forensics, eDiscovery, deposition management, trial support, and analytics to support both a higher volume of investigations and more effective measurement of program results.
    
    
• Infrastructure and Management:
  
  
  • Implement Enterprise Search (including integrated search of unstructured investigative-related and structured surveillance data) and automate electronic records management processes to improve productivity.
    
    
  • Support Integrated Strategic, Budget, Operating Plan Processes and BPAC Modernization initiatives to improve resource prioritization and utilization.
    
    
  • Scale communication, processing, and storage infrastructure to meet demand.
    
    
  • Continue business continuity and security control automation (continuous monitoring) implementation to reduce operational risk.

DME – Costs related to the development, modernization, and enhancement of technology.
O&M – Costs related to the operations and maintenance of technology.
FTE – Costs of government personnel.
IT – Hardware, software, and contracted data and technology services and labor.

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