Summary of OCR Final Rule
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”). 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, as further discussed in No-Action Letter 14-95.
Staff No-Action Letter 14-95
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’s No-Action Letter 14-95 and the related Press Release 6965-14.
Mandatory 2014 Testing Schedule
As the Commission prepares to receive OCR reporting in accordance with the dates outlined in No-Action Letter 14-95, the Commission’s Office of Data and Technology (ODT) will continue testing the submission of Form 102 A/B/S through the CFTC Portal and the Secure FTP Process. To foster this testing effort, ODT has established the following required dates for data submission testing:
October 15, 2014: All reporters MUST have set up their account through the CFTC Portal. See below for further information on the CFTC Portal.
October 31, 2014: All reporters MUST have submitted a test file, either through the Portal or through FTP, to the Commission.
January 6, 2015: All reporters MUST have submitted a test file containing production-level 102 A/B/S data to the Commission, either through the Portal or through FTP. We define a production level submission as containing data that would be production-ready if the Commission migrated it into our large trader data systems.
If a reporting party is unable to meet these dates, they must contact the Commission at OCRTechSupport@cftc.gov and specify when they will be able to meet these testing requirements. Note that the no-action relief provided in No-Action Letter 14-95 is subject to the condition that reporting parties cooperate with ODT staff as requested to test and implement any information technology standards or systems associated with the OCR Final Rule. During this testing period, reporting parties must provide all test data or form filings requested by ODT staff, in the form and manner requested by staff.
Technical Guidance Document
Staff has prepared a technical guidance document in connection with the OCR Final Rule. 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:
April 29, 2014
July 1, 2014
Blackline between version 3 and version 4
XML Schema Definitions and Rule Validations
Staff has also prepared 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. 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.
Information on CFTC Portal
Reporting firms can provide email addresses through the CFTC Portal at https://portal.cftc.gov. 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.
Information on CFTC Calls to Discuss OCR Final Rule
Commission staff is hosting telephone conference calls with reporting parties regarding technical implementation of the OCR Final Rule. 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. Commission staff 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
Passcode for all participants: 9983251
How to Contact the Commission with Questions
If you have any technical questions regarding the format, content, or transmission of OCR data to the Commission, please email the Commission at OCRTechSupport@cftc.gov
Important Disclosure Regarding Technical Guidance Document
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: January 12, 2015