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
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`Strategic Plan
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`IBG 1072
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`IBG V. TT
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`CBM2016-00054
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`IBG 1072
`IBG v. TT
`CBM2016-00054
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`Table of ConTenTs
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`M E S S A G E F R O M T H E A C T I N G C H A I R M A N 3
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`I NTRODUCTION 4
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`MISSION STATEMENT, STR ATEGIC GOALS & OUTCOMES 5
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`K EEPI NG PACE WITH CH A NGE: TH EMES & PRIORITI ES FOR 20 07-2012 9
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`ACH I E VI NG SUCCESS: BUSI N ESS PROCESSES, ME A N S & STR ATEGI ES 13
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`FORWARD LOOK I NG — FUTURE BUSI N ESS TREN DS & CH ALLENGES 16
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`EFFECTI NG SUCCESS: COORDI N ATION ON CROSS - CUT TI NG ISSU ES 19
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`ME ASURI NG SUCCESS: PERFORMA NCE STRUCTURE 22
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`PROGR AM E VALUATION S: PAST, PRESENT & FUTURE 26
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`APPEN DIX 27
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`U S Commodity Exchanges & Derivatives Clearing Organizations 27
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`Commodity Futures Trading Commission History at a Glance 28
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`Contract Markets Designated by the CFTC, 2002 – 2007 32
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`Number of CFTC-Registered Derivatives Clearing Organizations, 2002 – 2007 33
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`Exempt Commercial Markets, 2002 – 2007 34
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`Exempt Boards of Trade, 2002 – 2007 35
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`Growth in Volume of Futures & Option Contracts Traded & CFTC FTEs, 1997 – 2007 36
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`Actively Traded Futures & Option Contracts, 1997 – 2007 37
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`Preservation of Market Integrity and Protection of Market Users 38
`
`Growth of Foreign Commodity Trading 39
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`Customer Funds Held in Futures Commission Merchant Accounts, 1997 – 2007 39
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`Number of Registrants 40
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`Outcomes & Business Processes by Strategic Goal 41
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`List of Acronyms 45
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`Publications & Information 48
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`CFTC Contact Information 49
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`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
`COMMODITY FUTURES TRADING COMMISSION
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`Strategic Plan
`STRATEGIC PLAN
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`2007-2012
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`Protecting market users and the public from fraud, manipulation,
`
`and abusive trading practices and fostering open, competitive,
`
`and financially sound markets.
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`A MessAge FroM The ACTing ChAirMAn
`
`Beyond a doubt, the largest structural change
`
`affecting the oversight of financial markets in the
`last decade is global competition brought on by
`the cyber-revolution. Without leaving their desks, traders
`now have a variety of choices on where to trade financial
`instruments,
`regardless of physical borders. This
`competition has significantly lowered costs and spurred
`innovation. More than ever, commercial entities, traders,
`and consumers are using U.S. derivatives markets to
`manage risk and discover prices for the greater benefit of
`the economy.
`
`Technology allows a world marketplace to exist but for
`the laws and regulations that limit its development.
`Unfortunately, regulation often lags behind these global
`market trends, and regulators frequently find themselves
`playing defense as problems unfold. Regulators may
`attempt to meet these challenges by adopting detailed
`rules, but the breakneck pace of innovation inevitably
`changes the landscape, making the rules outdated almost
`upon enactment.
`
`Fortunately, Congress, during the Commodity Futures
`Trading Commission’s (CFTC) reauthorization in 2000,
`anticipated this change and enacted a less prescriptive,
`principles-based regulatory regime in the Commodity
`Futures Modernization Act (CFMA). During the past 10
`years, volume on U.S. futures exchanges has quintupled.
`In 2006, trading of U.S. futures and options accounted for
`38 percent of global volume in these markets. By all
`measures, this industry has been enormously successful
`competing on a global scale.
`
`As we submit our strategic plan for fiscal year (FY) 2007
`through FY 2012, we recognize both the dramatic growth
`of the futures industry since the passage of the CFMA and
`the succeeding market developments that now shape the
`debate surrounding current CFTC reauthorization. In
`addressing these trends, the CFTC must continue to
`modernize its technological infrastructure and empower
`its employees to embrace the risk-based, flexible regulatory
`structure provided by Congress to meet these global
`developments.
`
`The Commission is keenly aware of the importance of
`energy and agricultural prices and supplies to our Nation’s
`consumers, producers, and economy in general. For that
`reason, the Commission continues to surveil closely all
`markets in our charge and commits to working closely
`with Congress, other regulators, and market participants
`to ensure that our regulatory structure keeps pace with
`the ever changing global marketplace.
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`Walter L. Lukken
`Acting Chairman
`
`September 30, 2007
`
`CFTC
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`inTroduCTion
`
`Today, as the futures industry experiences unprecedented
`growth and as trading instruments and mechanisms
`increase in complexity, the CFTC is responsible for
`overseeing the economic utility of futures markets by
`encouraging
`their competitiveness, efficiency, and
`integrity and by protecting market participants against
`manipulation, abusive trade practices, and fraud. Through
`effective oversight regulation, the CFTC enables the
`commodity futures markets to serve their important
`function in the Nation’s economy by providing a
`mechanism for price discovery and a means of offsetting
`price risk. n
`
`T he CFTC was created as an independent agency
`
`by Congress in 1974 under the authorization of
`the Commodity Exchange Act (CEA or the Act)
`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 Act of 1978, 1982, and 1986; the Futures Trading
`Practices Act of 1992; and the CFTC Reauthorization Act
`of 1995. The CFMA reauthorized the Commission
`through FY 2005.
`
`Futures contracts for agricultural commodities have been
`traded in the United States for 150 years and have been
`under Federal regulation since the 1920s. In recent years,
`futures trading has expanded rapidly into many new
`markets, beyond the domain of traditional physical and
`agricultural commodities. Futures and option contracts
`are now offered on a vast array of financial instruments,
`including foreign currencies, U.S. and foreign government
`securities, and U.S. and foreign stock indices.
`
`1
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`
`
` Commodity Exchange Act, as amended (7 U S C , Section 1, et seq )
`
`CFTC
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`Mission sTATeMenT,
`sTrATegiC goAls & ouTCoMes
`
`Mission Statement
`
`In December 2000, the CFMA transformed the
`
`Commission from a front-line regulatory agency to
`an oversight regulator. Although the Commission’s
`approach to regulation has consequently changed, its
`mission remains the same—to protect market users and
`the public from fraud, manipulation, and abusive prac-
`tices related to the sale of commodity futures and options,
`and to foster open, competitive, and financially sound
`commodity futures and option markets.
`
`Strategic Goals & Outcomes
`
`Since the development of the Commission’s first Strategic
`Plan in 1997, the mission of the CFTC has been expressed
`and measured through three strategic goals, each focus-
`ing on a vital area of regulatory responsibility. With this
`Strategic Plan for FY 2007 through FY 2012, the Commis-
`sion has adopted a fourth strategic goal, which focuses on
`assessing and measuring organizational and management
`excellence.
`
`Establishing this fourth strategic goal will allow the
`Commission to extend its performance and management
`framework—which requires the Agency to establish and
`measure its progress in achieving outcome objectives and
`strategic goals—beyond strictly program performance to
`the performance of the organization itself.
`
`Strategic Goal One—Ensure the economic vitality
`of the commodity futures and option markets.
`
`In order for commodity futures and option markets to
`fulfill their vital role in the national and global economy,
`they must operate efficiently, accurately reflect the forces
`of supply and demand, and serve market users by fulfill-
`ing an economic need. Through direct market surveil-
`lance and through oversight of the surveillance efforts of
`the exchanges themselves, the Commission works to
`ensure that markets operate free of manipulation or
`congestion.
`
`The heart of the Commission’s direct market surveillance
`is a large-trader reporting system, under which clearing
`members of exchanges, futures commission merchants
`(FCMs), and foreign brokers electronically file daily
`reports with the Commission. These reports show all
`trader positions above specific reporting levels set by
`CFTC regulations. Because a trader may carry futures
`positions through more than one FCM and a customer
`may control more than one account, the Commission
`routinely collects information that enables its surveil-
`lance staff to aggregate information across FCMs and for
`related accounts.
`
`Using these reports, the Commission’s surveillance staff
`closely monitor the futures and option market activity of
`all traders whose positions are large enough to potentially
`impact the orderly operation of a market. For contracts,
`which at expiration are settled through physical delivery,
`such as contracts in the energy complex, staff carefully
`analyze the adequacy of potential deliverable supply.
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`CFTC
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`M I S S I O N S TAT E M E N T, S T R AT E G I C G O A L S & O U T C O M E S
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`In addition, staff monitor futures and cash markets for
`unusual movements in price relationships, such as cash/
`futures basis relationships and inter-temporal futures
`spread relationships, which often provide early indica-
`tions of a potential problem.
`
`• Markets that are monitored effectively and efficiently
`so that the Commission receives early warning of
`potential problems or issues that could adversely affect
`their economic vitality.
`
`The Commissioners and senior staff are kept apprised of
`market events and potential problems at weekly surveil-
`lance meetings and more frequently when needed. At
`these meetings, surveillance staff brief the Commission
`on broad economic and financial developments and on
`specific market developments in futures and option
`markets of particular concern.
`
`If indications of attempted manipulation are found, the
`Commission investigates and prosecutes alleged viola-
`tions of the Act or regulations. Subject to such actions are
`all individuals who are or should be registered with the
`Commission, those who engage in trading on any domes-
`tic exchange, and those who improperly market commod-
`ity futures or option contracts. The Commission has
`available to it a variety of administrative sanctions against
`wrongdoers, including revocation or suspension of regis-
`tration, prohibitions on futures trading, cease and desist
`orders, civil monetary penalties, and restitution orders.
`The Commission may seek Federal court injunctions,
`restraining orders, asset freezes, receiver appointments,
`and disgorgement orders. If evidence of criminal activity
`is found, matters may be referred to state authorities or
`the U.S. Department of Justice (DOJ) for prosecution of
`violations not only of the Act, but also of state or Federal
`criminal statutes, such as mail fraud, wire fraud, and con-
`spiracy. Over the years, the Commission has brought
`numerous enforcement actions and imposed sanctions
`against firms and individual traders for attempting to
`manipulate prices,
`including
`the well-publicized
`attempted manipulation cases by several energy compa-
`nies and the market power manipulation of worldwide
`copper prices.
`
`Outcomes for Strategic Goal One are:
`
`• Markets that accurately reflect the forces of supply and
`demand for the underlying commodity and are free of
`disruptive activity.
`
`Strategic Goal Two—Protect market users and the
`public.
`
`The focus of the second goal is protection of the firms and
`individuals—market users—who come to the market-
`place to fulfill their business and trading needs. Market
`users must be protected from possible wrongdoing on the
`part of the firms and commodity professionals with whom
`they deal to access the marketplace, and they must be
`confident that the marketplace is free of fraud, manipula-
`tion, and abusive trading practices.
`
`The Commission has promulgated requirements that
`mandate appropriate disclosure and customer account
`reporting, as well as fair sales and trading practices by reg-
`istrants. The Commission has sought to maintain appro-
`priate sales practices by screening the fitness of industry
`professionals and by requiring proficiency
`testing,
`continuing education, and supervision of these persons.
`Extensive record-keeping of all futures transactions is
`required. The Commission also monitors compliance
`with those requirements and supervises the work of the
`exchanges and the National Futures Association (NFA) in
`enforcing the requirements.
`
`The Commission plays an important role in deterring
`behavior that could affect market users’ confidence by
`investigating and taking action against unscrupulous
`commodity professionals who engage in a wide variety of
`fraudulent sales practices against the public.
`
`Outcomes for Strategic Goal Two are:
`
`• Violations of Federal laws concerning futures and
`option contracts are detected and prevented.
`
`• Commodity professionals meet high standards.
`
`• Customer complaints against persons or firms regis-
`tered under the Act are handled effectively and
`expeditiously.
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`CFTC
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`M I S S I O N S TAT E M E N T, S T R AT E G I C G O A L S & O U T C O M E S
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`Strategic Goal Three—Ensure market integrity in order
`to foster open, competitive, and financially sound
`markets.
`
`In fostering open, competitive, and financially sound
`markets, the Commission’s two main priorities are to
`avoid disruptions to the system for clearing and settling
`contract obligations and to protect the funds that custom-
`ers entrust to FCMs. Clearing organizations and FCMs are
`the backbone of the exchange system—together, they
`protect against the financial difficulties of one trader
`becoming a systemic problem for other traders. Several
`aspects of the oversight framework that help the
`Commission achieve this goal with respect to traders are:
`1) requiring that market participants post margin to
`secure their ability to fulfill obligations; 2) requiring
`participants on the losing side of trades to meet their
`obligations, in cash, through daily (sometimes intraday)
`margin calls; and 3) requiring FCMs to segregate customer
`funds from their own funds.
`
`The Commission works with the exchanges and the NFA
`to monitor closely the financial condition of the FCMs
`themselves, who must provide
`the Commission,
`exchanges, and NFA with various monthly, quarterly, and
`annual financial reports. The exchanges and NFA conduct
`annual audits and daily financial surveillance of their
`respective member FCMs. Part of this financial surveil-
`lance involves looking at each FCM’s exposure to losses
`from large customer positions that it carries. As an over-
`sight regulator, the Commission not only reviews the
`audit and financial surveillance work of the exchanges
`and NFA, but also monitors the health of FCMs directly,
`as appropriate. The Commission also periodically reviews
`clearing organization procedures for monitoring risks
`and protecting customer funds.
`
`The Commission investigates and prosecutes FCMs
`alleged to have violated financial and capitalization
`requirements or to have committed other supervisory or
`compliance failures in connection with the handling of
`customer business. Such cases can result in substantial
`remedial changes in the supervisory structures and
`systems of FCMs and can influence the way particular
`firms conduct business. This is an important part of
`fulfilling the Commission’s responsibility for ensuring
`that FCMs follow sound practices and that markets
`
`remain financially sound. The Commission also seeks
`to ensure market integrity by investigating a variety of
`trade and sales practice abuses. For example, the
`Commission brings actions alleging unlawful trade
`allocations, trading ahead of customer orders, misappro-
`priating customer trades, and non-competitive trading.
`
`Outcomes for Strategic Goal Three are:
`
`• Clearing organizations and firms holding customer
`funds have sound financial practices.
`
`• Commodity futures and option markets are effectively
`self-regulated.
`
`• Markets are free of trade practice abuses.
`
`• Regulatory environment is flexible and responsive to
`evolving market conditions.
`
`Strategic Goal Four—Facilitate Commission perfor-
`mance through organizational and management excel-
`lence, efficient use of resources, and effective mission
`support.
`
`The fulfillment of the Commission’s mission and the
`achievement of its goals are tied to a foundation of sound
`management and organizational excellence. This founda-
`tion is essential to support the work of the Commission at
`the Washington D.C. headquarters and regional offices in
`Chicago, Kansas City, and New York. The Commission is
`committed to maintaining a well-qualified workforce
`supported by a modern support infrastructure that
`enables the Commission to achieve its programmatic
`goals. Building this foundation will require significant
`investment in people, management initiatives, systems,
`and facilities.
`
`The Offices of the Chairman and the Commissioners
`provide executive direction and
`leadership to the
`Commission—specifically, as it develops and adopts
`Agency policy that implements and enforces the CEA and
`amendments to that Act, including the CFMA. Passed by
`Congress and signed by President Clinton in December
`2000, the CFMA reauthorized the Commission through
`FY 2005. The Commission is currently working with the
`Administration and the Congress on issues related to the
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`M I S S I O N S TAT E M E N T, S T R AT E G I C G O A L S & O U T C O M E S
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`reauthorization of the Commission. To this end, the
`Commission’s policy is designed to: 1) foster the financial
`integrity and economic utility of commodity futures
`and option markets for hedging and price discovery;
`2) conduct market and financial surveillance; and
`3) protect the public and market participants against
`manipulation, fraud, and other abuses.
`
`In order for the Commission to carry out its mission suc-
`cessfully and to realize the first three strategic goals, the
`Office of the Executive Director (OED) provides critical
`administrative support through the effective and efficient
`management and utilization of key strategic resources, as
`follows:
`
`Human Resources. In order for the United States to main-
`tain its role as the world leader in setting the standard for
`ensuring market integrity and protection for market users,
`the Commission must attract, train, promote, and retain
`a workforce that is not only professional, but also knowl-
`edgeable, diverse, and productive. To support this effort,
`the Commission has embarked on a comprehensive
`Strategic Management of Human Capital Initiative with
`the overall goals of effectively managing the size, skills,
`and composition of the Commission’s workforce.
`
`Information Technology. The Commission’s ability to fulfill
`its mission successfully depends on a secure modern
`information technology (IT) infrastructure that enables
`the collection, analysis, communication, and presenta-
`tion of information in forms useful to the Commission
`and its stakeholders—including the industry it regulates,
`other Federal, state, and international agencies; the
`Congress; and the American public. The Commission
`continues to apply commercial best practices in its
`enhancements of
`two mission-critical
`information
`systems: the Integrated Surveillance System (ISS), which
`supports market surveillance; and the Exchange Database
`System (EDBS), which provides an efficient means of
`collecting market exchange data. Two new systems—the
`Filings and Actions System and Project eLaw—will
`support the Commission’s market oversight objectives
`as well as its investigative, trial, and appellate work
`processes, respectively.
`
`Management Operations. The Commission’s logistical
`operations are supported by ensuring the timely delivery
`of products and services, ensuring safety and security of
`all employees, and maintaining the facilities at headquar-
`ters and the regional offices. Improvements in critical
`operational service areas will continue with the develop-
`ment of a property management system for non-capital-
`ized, sensitive items; and the testing, training, and
`evaluation of all security programs—including the
`Occupant Emergency Plan, Shelter
`in Place, and
`Continuity of Operations Plan (COOP).
`
`Financial Management. Ensuring that the Commission
`deploys judiciously and manages well its financial
`resources is achieved through effective financial manage-
`ment systems and services that facilitate Commission
`performance,
`improve
`its accountability, and earn
`unqualified audit opinions. The publication of the annual
`Performance and Accountability Report (PAR) informs
`the public about how well Commission programs perform
`and the costs incurred to achieve that performance.
`The Commission’s PAR for the fiscal year ending
`September 30, 2006 received the prestigious Certificate
`of Excellence in Accountability Reporting from the Associa-
`tion of Government Accountants (AGA).
`
`Outcomes for Strategic Goal Four are:
`
`• A productive, technically competent, and diverse
`workforce that takes into account current and future
`technical and professional needs of the Commission.
`
`• A modern and secure information portfolio that reflects
`the strategic priorities of the Commission.
`
`• An organizational infrastructure that efficiently and
`effectively responds to and anticipates both routine
`and emergency business needs of the Commission.
`
`• That financial resources are allocated, managed, and
`accounted for in accordance with the strategic priorities
`of the Commission.
`
`• That the Commission’s mission is fulfilled and goals are
`achieved through sound management and organiza-
`tional excellence provided by executive leadership. n
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`CFTC
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`Keeping pACe wiTh ChAnge:
`TheMes & prioriTies For 200-2012
`
`T he Commission has identified the following
`
`strategic themes2 and priorities, which will serve
`as key indicators of its success in its effort to keep
`pace with the many changes affecting the futures and
`option markets:
`
`Strategic Themes:
`
`1. CFTC must act in real time to address how the markets
`are functioning and evolving.
`
`Strategic theme 1: CFTC must act in real time to
`address how the markets are functioning and
`evolving.
`
`Strategic Priority 1.1: Enhance technological capability
`and data standards to recognize, understand, and adapt
`to market changes early on.
`
`Tasks:
`1.1.1: Upgrade ISS to get real-time market position
`information.
`
`2. CFTC must influence international approaches to over-
`seeing/regulating the global commodity markets.
`
`1.1.2: Develop capability to provide real-time margin
`and settlement information.
`
`3. CFTC must effectively direct Commission resources to
`achieve its mission.
`
`4. CFTC must employ best practices in business
`management.
`
`5. CFTC must employ an assertive external communica-
`tion and outreach program to articulate CFTC mission
`and strategic goals to inform legislative/regulatory
`policy.
`
`1.1.3: Promote data standards.
`
`1.1.4: Develop/implement trade surveillance system.
`
`1.1.5: Develop automated capability to analyze and
`integrate off-exchange data as it relates to
`investigations.
`
`Strategic Priority 1.2: Enhance in-house human analytical
`and decision-making capability to recognize, understand,
`and adapt to market changes early on.
`
`Tasks:
`1.2.1: Develop a recruitment plan to address required
`skills.
`
`1.2.2:
`
`Identify needed competencies and develop train-
`ing plan that empowers employees to react quickly
`in understanding and
`resolving
`regulatory
`matters.
`
`2
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`The priorities listed herein are also referred to as “general goals,” which are described in Office of Management and Budget (OMB) Circular A-11 as
`those that allow a future assessment to be made on whether or not the goals were or are being achieved
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`CFTC
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`• organizational structure and function
`•
`staff expertise required
`• budgetary investment required
`
`Strategic Priority 2.2: Sustain personal relationships with
`CFTC counterparts in nations with developed markets,
`and enhance relationships where new growth is likely to
`be concentrated.
`
`Tasks:
`2.2.1: Cultivate relationships with U.S.-based interna-
`tional aid organizations to leverage their resources
`so CFTC can provide technical assistance to
`foreign institutions.
`
`2.2.2: Upgrade and expand role in the International
`Organization of Securities Commissions (IOSCO)
`and other targeted international organizations
`and conferences.
`
`2.2.3: Expand relationships with international market
`authorities to develop interpersonal relationships
`in nations with priority markets through on-site
`visits.
`
`Strategic Priority 2.3: Promote CFTC’s flexible, principles-
`based regulatory philosophy with robust enforcement
`and global recognition capabilities.
`
`Tasks:
`2.3.1: Provide more technical training to foreign market
`regulators.
`
`2.3.2: Develop and maintain a library of training and
`reference materials.
`
`Strategic Priority 2.4: Improve U.S. access to global
`markets.
`
`Tasks:
`2.4.1:
`
`Identify and understand perceived obstacles to
`U.S. access to foreign markets.
`
`2.4.2: Engage U.S. government and foreign market
`authorities to improve access to foreign markets.
`
`Strategic Priority 1.3: Systematically use stakeholders,
`such as the self-regulatory organizations (SROs), domes-
`tic and foreign entities, media, academia, and market par-
`ticipants, as extended sources of market intelligence.
`
`Tasks:
`1.3.1: Conduct regular multi-divisional meetings with
`targeted groups.
`
`1.3.2: Develop business process to mobilize internal
`resources to capture external knowledge.
`
`Strategic Priority 1.4: Foster meaningful, integrated, and
`timely communication across CFTC divisions and
`offices.
`
`Tasks:
`1.4.1: Develop internal communications plan.
`
`1.4.2: Develop internal personnel mobility plan.
`
`1.4.3: Develop standard operating procedures to ensure
`routine operational, cross-divisional
`coordination.
`
`Strategic Priority 1.5: Foster a culture of creative problem
`solving to promote innovation in the marketplace.
`
`Tasks:
`1.5.1: Create inter-divisional, issue-specific teams to
`analyze high-level policy questions and make
`recommendations to the leadership group.
`
`1.5.2: Host workshops with outside experts to keep staff
`knowledge at the cutting edge.
`
`Strategic theme 2: CFTC must influence interna-
`tional approaches to overseeing/regulating the
`global commodity markets.
`
`Strategic Priority 2.1: Enhance CFTC’s international
`program capability.
`
`Task:
`2.1.1: Produce option paper for Commission on
`enhancement of the international program
`focusing on:
`
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`Strategic theme 3: CFTC must effectively direct
`Commission resources to achieve its mission.
`
`Strategic Priority 3.1: Formalize process for analyzing
`risk, setting priorities, and allocating resources.
`
`Tasks:
`3.1.1: Conduct regular divisional and inter-divisional
`meetings around risk to make informed resource
`allocation decisions.
`
`3.1.2: Based on regular inter-divisional risk discussions,
`implement a multi-divisional targeted approach
`to selected market sectors/segments.
`
`Strategic Priority 3.2: Seek cooperative external working
`relationships to leverage resources.
`
`Task:
`3.2.1: Develop plan for implementing cooperative exter-
`nal working relationships, emphasizing leverag-
`ing technology.
`
`Strategic Priority 4.2: Implement multi-division process
`for technology investment decisions and acquisition
`planning.
`
`Task:
`4.2.1: Develop formal internal policy and role defini-
`tions to manage technology investments.
`
`Strategic Priority 4.3: Align human capital management
`with strategic mission to recruit, develop, retain, and
`deploy staff with appropriate competencies.
`
`Tasks:
`4.3.1: Continue to develop and implement a total
`rewards program (pay, benefits, and quality of
`work-life initiatives) under the Agency’s Pay Parity
`legislation.
`
`4.3.2: Develop formal process to assess and plan for
`CFTC staff training needs.
`
`4.3.3: Refine current management tools and formalize
`process to help managers implement succession
`planning.
`
`Strategic theme 4: CFTC must employ best practices
`in business management.
`
`Strategic Priority 4.4: Develop a systemic approach to
`knowledge management.
`
`Tasks:
`4.4.1: Establish CFTC alumni group.
`
`4.4.2: Seek re-employed annuitant waiver of salary
`offset.
`
`4.4.3: Develop a plan to recapture retiree knowledge.
`
`4.4.4:
`
`Institutionalize a records management program.
`
`Strategic Priority 4.1: Formalize framework for manage-
`ment accountability, organizational performance, and
`control.
`
`Tasks:
`4.1.1: Develop internal policy and role definitions to
`implement a management framework for meeting
`statutory management requirements.
`
`4.1.2: Develop additional outcome-related performance
`measures that more fully demonstrate the effec-
`tiveness of the Commission’s enforcement activi-
`ties in meeting its overall strategic goals.
`
`4.1.3: Explore additional record-keeping options and
`procedures for documenting surveillance, anti-
`fraud, and anti-manipulation inquiries.
`
`CFTCCFTC
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`
`Strategic theme 5: CFTC must employ an assertive
`external communication and outreach program to
`articulate CFTC mission and strategic goals to inform
`legislative/regulatory policy.
`
`Strategic Priority 5.1: Educate the general public and other
`stakeholders on the importance of commodity markets
`and CFTC’s role in regulating them.
`
`Tasks:
`5.1.1:
`
`Increase benefits derived from industry events by
`coordinating content of speeches, attendance, and
`participation.
`
`Strategic Priority 5.2: Take a leadership role in all legisla-
`tive and public policy issues affecting the commodities
`and derivatives markets.
`
`Tasks:
`5.2.1: Develop and communicate CFTC legislative goals
`on policy issues.
`
`5.2.2: Use roundtables, analytical products, and other
`CFTC expertise to engage stakeholder groups in
`policy discussions to
`inform the
`legislative
`process.
`
`5.1.2:
`
`Identify new media/business associations to
`address.
`
`Strategic Priority 5.3: Use external communications to
`influence industry behavior to achieve desired outcomes.
`
`Task:
`5.3.1: Follow private communications with public
`expression of CFTC concern (speeches, Op-Ed
`pieces, press releases). n
`
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`
`CFTC
`
`

`

`AChieving suCCess:
`Business proCesses, MeAns & sTrATegies
`
`Business Processes
`
`Commission
`
`key business
`staff perform
`processes—collections of specific activities and
`strategies—that provide the means for producing
`the desired outcomes and achieving the Commission’s
`strategic goals.
`
`While each outcome of the Commission’s four strategic
`goals is supported by a specific set