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Ownership and Control Reporting (OCR)

  • On November 18, 2013, the Commodity Futures Trading Commission (“Commission”) published new ownership and control rules and related forms to enhance its identification of futures and swap market participants (the “OCR Final Rule”).  Commission staff will be hosting telephone conference calls with reporting parties regarding technical implementation of the OCR Final Rule.  Please review the OCR Final Rule in the Federal Register (2013-26789) or review the PDF copy of the OCR Final Rule.  Note that Section VI of the OCR Final Rule includes information on data submission standards and procedures, including the requirement that reporting parties provide such test data as may be requested by Commission staff.  Existing reporting methods will remain in place until further notice by the Commission or its staff.

    During the calls, staff also expects to discuss an OCR technical guidance document prepared by staff. The technical guidance document provides detailed instructions on submitting data in connection with the OCR Final Rule via FTP to the Commission, including a data dictionary for mapping data elements to an OCR submission. The chart below includes links to the current version of the technical guidance document, along with the prior version and a blackline between the two versions:


    Publication date



    April 29, 2014

    Technical guidance document; version 3


    July 1, 2014

    Technical guidance document; version 4

    Blackline between version 3 and version 4

    Also published is a zip file containing XML Schema Definitions (XSDs) for use in generating valid XML for OCR submissions as described in the technical guidance document. The two XSD files define batch and form level elements and shared attribute types that may be reused during a form submission.

    A spreadsheet is available describing the rule validations that will be performed against every 102 submission as they are processed by CFTC data loaders.  The spreadsheet details a description of each rule, the associated attribute(s) in the XSD and the error message that will be returned if the submission does not pass validation.  The rule validations identified in this spreadsheet will be available for testing effective September 2, 2014.  Reporting parties should review the spreadsheet in conjunction with the technical guidance document, which includes detailed instructions and other important information regarding the data submission process pursuant to the OCR Final Rule.

    Reporting firms can provide email addresses through the CFTC Portal at  The Commission will use these email addresses to provide feedback to reporting parties on their form 102 file submissions during the testing process.  A PDF is available describing the notification email registration process.

    The calls began on Wednesday, January 22, 2014, and will occur every other Wednesday at 11:30am E.T. on an as-needed basis. The current call schedule is located here.  Persons participating in the calls will be required to identify themselves, and calls may not be recorded.  The Commission will host the calls at the following dial-in number:

    Toll-free dial-in number for U.S. participants: 1-866-844-9416

    Toll dial-in number for U.S. participants: 1-203-369-5026

    Dial-in numbers for international participants

    Passcode for all participants: 9983251

    If you have any technical questions regarding the format, content, or transmission of OCR data to the Commission, please email the Commission at

    On July 23, 2014, the Commission’s Division of Market Oversight issued a no-action letter related to the OCR Final Rule.  View CFTC’s Staff No-Action Letter 14-95 and the related Press Release 6965-14

    The technical guidance document was drafted consistent with the OCR Final Rule, and all relevant communications from Commission staff are also intended to be consistent with the OCR Final Rule.  In the event of any conflict between the requirements of the OCR Final Rule (including the questions and instructions on the reporting forms attached thereto) and (a) the technical guidance document, (b) any verbal communications by Commission staff regarding the technical guidance document or the OCR Final Rule or (c) responses from Commission staff to technical questions sent to the email address listed above, the OCR Final Rule controls. Any necessary revisions to the technical guidance document identified following its publication will be reflected in an updated version of the document.

    The OMB control number for the collection of information pursuant to the OCR Final Rule is 3038-0103.  Please be advised that pursuant to 5 CFR § 1320.5(b)(2)(i), you are not required to respond to the collection of information pursuant to the OCR Final Rule unless it displays a currently valid OMB control number.

    Last Updated: August 27, 2014