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While I respectfully dissent on this budget submission, I do support increases in the Commission’s budget that are tied to a strategic plan that identifies a five-year investment strategy and makes technology a top priority. However, with the strategic plan still incomplete and no documents to guide the Commission on its technology and workforce investment strategy, I cannot endorse this budget recommendation for FY 2015.
It is my hope that increases in funding for FY 2014 and FY 2015 would enable the Commission to invest in new technology infrastructure consistent with the strategic plan and to focus on hiring people with key expertise to meet its critical priorities. New technology infrastructure would allow the Commission to fully automate the intake of market data and to increase the use of automation to perform critical analytics for illegal trading behavior, intermediary and clearing house risk exposures. As a result, the Commission would be more effective and efficient in policing the modern electronic financial markets. As I stated in my testimony before the United States House Committee on Appropriations, if the Commission is going to keep pace with the growth and technological innovation in the financial markets, automated surveillance must be an integral part of its mission.1
I remain hopeful that the Commission will make progress in developing a strategic plan for FY 2014-2018 that will clearly define our technology investment and oversight objectives. In FY 2014, the Commission must also develop a technology and workforce deployment plan that will inform the FY 2015 appropriations cycle and supplement the lack of specific priorities outlined in this budget request. To the extent that the strategic plan identifies a technology and workforce investment strategy that holds the Commission accountable for completing its investment priorities, I will gladly support budget increases above current levels over the next several years that are consistent with such specific priorities.
Failure to develop a fully transparent strategic plan that includes future investment priorities for both technology and our workforce, and that holds the Commission accountable, will undermine the work that has been done to implement a comprehensive reform of the derivatives markets. I recognize, however, that the Commission’s mission cannot be achieved by just investing in technology. The Commission should also make the necessary investments in a technologically-savvy workforce, but we must do so in a consistent, transparent, and accountable manner.
As drafted, the FY 2015 proposed budget request fails to provide the necessary fidelity, accuracy, and accountability that would earn the confidence and support of Congress, which is being asked to make a large investment in a very tight budget environment. Certainly, what I have asked for in a strategic plan is not unfamiliar to any business or household seeking an investment or a loan. The budget must outline specific goals and explain how we will achieve these goals. These are not unreasonable requests.
1 Testimony of CFTC Commissioner Scott D. O’Malia before the U.S. House Committee on Appropriations, Subcommittee on Agriculture, Rural Development, Food and Drug Administration, and Related Agencies, Washington, DC (April 12, 2013).
