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.
Staff No-Action Letter 15-03
On February 10, 2015, the Commission’s Division of Market Oversight issued a no-action letter related to the OCR Final Rule. View Press Release 7119-15 and CFTC staff’s No-Action Letter 15-03, which extends certain electronic reporting obligations under the OCR Final Rule. Existing reporting methods will remain in place until the dates discussed in No-Action Letter 15-03. All reporting parties should review the no-action letter for important additional information.
Mandatory 2015 Testing Schedule
As the Commission prepares to receive OCR reporting in accordance with the dates outlined in No-Action Letter 15-03, 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 dates for data submission testing outlined on the OCR Testing page.
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: February 11, 2015