POSITION ENTRY FOR REPORTABLE TRADERS USERS’ MANUAL Prepared by Commodity Futures Trading Commission Division of Economic Analysis November 1998 Table of Contents Page Overview 1 Position Entry Screen 1 Notice and XFC Data Screen 2 Flex Options Screen 2 Getting Started 3 Navigating the System 3 Entering Position Data 4 Field Entry Specifications 5 Entering Notices and XFCs 7 Identifying Flex Options 7 Validating Positions 8 Printing and Saving Records 9 Creating a CFTC File 10 Sending Position Data 10 FEDFTP Application 11 Appendix A - Instructions for Preparing and Filing Reports on Trader Positions Who Should Report To Determine if an Account is Reportable What to Report When to Report Appendix B - Updating Exchange and Commodity Codes Appendix C - FEDFTP Messages POSITION ENTRY FOR REPORTABLE TRADERS The Position Entry for Reportable Traders (PERT) system consists of two stand-alone applications. The first is used to prepare traders’ futures and option position data for reporting to the Commodity Futures Trading Commission (CFTC). In this application, you can enter reportable data, save it to a file, and call the second application, FEDFTP, to send the data to the CFTC. Installation: The two applications are loaded from a CD-ROM or can be downloaded from the internet at http://www.cftc.gov/dea/pert/pert.htm in two self-extracting zip files. If you are loading the applications from a CD-ROM, insert the CD-ROM in your player and use Windows Explorer to select the directory for the CD drive. You will see two folders; PERT Install and FEDFTP Install. There are several files in the PERT Install folder including a Read Me text file. This file contains instructions for installing the application. Double click on the file to open it in Notepad. If you wish to print it while in Notepad, select File, then Print. The FEDFTP Install folder also contains a Read Me text file which contains instructions for installing the application. If you are loading the applications from the internet, the PERT application and the FEDFTP application are in separate files. Both files must be downloaded. Once the files are downloaded, double click on them to create the directories “C:\Program Files\PERT\Install” and “C:\Program Files\FEDFTP\Install.” This also places the installation programs in these folders. You can then double click on the Install folder to access the Read Me file which contains further instructions for installing the two applications. Before you attempt to send data to the CFTC using the PERT system, you must contact a CFTC representative listed on page 2 to obtain your firm’s code number. Overview Appendix A contains guidelines to help you determine whether futures and option positions are reportable and reviews the overall scope of the information that must be reported. Three screens are available for entering these data. Use the Position Entry screen to enter reportable positions. Use the Notice and XFC Data screen to report delivery notices issued or stopped and transactions concerning exchanges of futures for cash (XFC). Use the Flex Options screen to supply additional information needed to identify flexible options. An explanation of the data entered in each screen is shown below: Position Entry Screen Firm Name : The name of the reporting firm. Use this field to distinguish between divisions if the firm has multiple firm codes (optional). Firm Code : A three-character firm code assigned by the CFTC. Report Date : The date for which the positions are being reported. Account Number : A unique number assigned by the firm for each account. Exchange Code : An alphabetic code assigned by the CFTC for each exchange. Commodity Code : A commodity code assigned by an exchange to identify futures or option contracts. Expiration Year : The year the contract expires. Expiration Month : The month the contract expires. Expiration Day : The day the contract expires. This is required for flex instruments. Put or Call : An indicator whether an option contract is a Put(P) or Call(C). For a futures contract, leave this field blank. Strike Price : An option contract’s strike price. For futures contracts, leave this field blank. Exercise Style : An indicator of the exercise style of an option contract (American(A) or European(E)). For a futures contract, leave this field blank. Positions Long : Long positions open at the end of the trading day. Positions Short : Short positions open at the end of the trading day. Record Type : An indicator whether the reported record is an Add(A), Change(C), or Delete(D). Flex Indicator: A check box used to specify that the record is a flex option. Notice and XFC Data Screen Delivery Notices Issued: The number of short futures positions offset due to notices of delivery issued by or on behalf of a trader. Delivery Notices Stopped: The number of long futures positions offset due to notices of delivery stopped by or on behalf of a trader. XFCs Bought: Purchases of futures contracts in connection with an XFC. XFCs Sold: Sales of futures contracts in connection with an XFC. Flex Options Screen Data on this screen identify the contract exercised into from the flex option. This includes the commodity code assigned by the exchange and the expiration year and month of the contract. The calendar day is also required, if the contract exercised into from the flex option is also a flexible instrument. The remaining sections of this manual provide instructions for entering data in the above fields, for saving the data to a file, and for transmitting this data to the CFTC. You can also view topics discussed herein on the help screens in the PERT application when entering data or in the FEDFTP application when sending data. Click the Help button with the mouse to display the contents and an index of topics for PERT. If you have additional questions or experience problems with the PERT application, one of the following persons in the CFTC’s Division of Economic Analysis can be of assistance: Thomas Purcell, New York (212) 466-2083 Susan Donlan, New York (212) 466-2092 Monty Reese, Washington (202) 418-5310 Judith Sepsey, Chicago (312) 353-9028 Margaret Sweet, Chicago (312) 353-0691 If you have additional questions or experience problems with the FEDFTP application, contact Karen Marshall at (202) 418-5299 or send a description of the problem via electronic mail to pert/fedftp@cftc.gov. Getting Started When PERT is run for the first time, a blank Position Entry screen is displayed. First, you must enter a firm code. This code is assigned by the CFTC. Firm name is optional, so no entry into this field is required. However, for firms that have more than one assigned firm code, the Firm Name field is an excellent way to distinguish between the different divisions represented by each firm code. The Firm Code field does require an entry and no position data can be saved without a firm code being specified. After the firm name and code are entered, they are saved to the database when you move the cursor from the Firm Code field. Note that clicking on the Save Position button on the toolbar (or the Save command from the file drop-down menu) to save the firm code will result in a message being displayed on the screen if no data other than the firm code are entered. The intended use of this button is to save position records and edit for missing information. You can tell if the firm code has been saved to the database if it appears in the drop-down list below the firm code. Placing the mouse pointer over the arrow next to the Firm Code field and clicking will cause this list to appear. Once a firm code has been entered, it cannot be deleted. If a different firm code is needed, it must be added to the system. The new code can then be selected from the drop-down list. After a firm code is entered and saved to the database, you can begin entering the firm’s positions. On subsequent uses of the system, the Position Entry screen will display the last positions entered for the first alphabetical firm code. All you need to do is set the new report date and alter the displayed data to reflect the new position data. You can enter changes to the positions previously entered, delete positions that are no longer reportable, and add new position records. You cannot, however, change the firm code for positions that have been retrieved. Positions must be re-entered if the firm code changes. Navigating the System A toolbar can be found at the top of the PERT Position Entry screen and is pictured below. Each button on the toolbar causes an action to occur when the mouse pointer is placed on it and the left mouse button is clicked. The action that occurs for each button is described below. The actions may also be initiated from the File, Edit, and Entry menus located above the toolbar. Insert Row Inserts a blank row in the Position Entry screen beneath the row with the cursor. If the cursor is not on a position record, a row will be inserted beneath the last record that contained the cursor. Delete Row Deletes the row with the cursor. If the cursor is not on a position record, the last record that contained the cursor will be deleted. Clear All Rows Deletes all displayed position records. Change Report Date Displays the Set Report Date screen. From this screen, the report date for all displayed position records can be changed. Notices and XFCs Displays the Notices and XFCs Data screen. Notices stopped or issued, or exchanges of futures for cash bought or sold can be specified for the current futures record. Flex Options Displays the Flex Options Data screen. Flex options information can be specified for the current option record. Print Positions Prints all the data for the displayed position records. Validate Entries Checks position records for errors and automatically fills skipped fields with entries from the above record. Save Positions Saves the displayed position records to the CFTC file hold area which can contain positions from multiple firm codes. This is used to create the CFTC position file. Create CFTC File Generates a file from the saved position records in a location specified by the user. Send File to CFTC Transmits the position file created during the current session to the CFTC using the FEDFTP application that was distributed with PERT. Exit Exits PERT. Entering Position Data Once a firm code is entered, you can begin to input the firm's position data. You can navigate from field to field by using the tab key or the mouse pointer. You can position the mouse pointer over a field and click the left mouse button to place the cursor in that field, or tab until the desired field is reached. The system is not case-sensitive, so either small or capital alphabetic letters may be entered. All applicable fields in the first position record must contain data. When entering subsequent records, only the data that differs from the preceding record need to be entered. For example, when entering futures position data for the same account and for the same commodity, but for a different expiration year and month, only the year and month and the futures position need to be entered. This feature is illustrated below. Example – On 10/20/98, account number 1 has positions in Chicago Board of Trade (CBT) wheat for both the December 1998 and March 1999 futures. The following data entry is required. Report Account Exchange Comm Expiration Put Strike Exc Positions Date Number Code Code Year Mon Day Call Price Sty Long Short 10/20/1998 1 CBT W 1998 12 100 10/20/1998 1999 3 100 In this example, reporting the position in the March 1999 future requires only entry of the expiration year and month and the short position of 100 contracts. The missing fields will be filled in when you click on the Validate Entries button. Note: If the year and month are not entered, all identifying fields in the previous record will be copied and will result in a “duplicate” error message. The Delete Row button eliminates an entire row from the Position Entry screen. The Clear All Rows button deletes all of the position records. You will be asked if this action should be completed, since the data will be removed from the system. Upon responding Yes to this question, the entire Position Entry screen will be cleared. Guidelines for entering data into each field are shown in the next section. Field Entry Specifications The Report Date field is the first field that requires an entry on the main portion of the Position Entry screen. If this is the first time you have used the system, the first position record will appear after you save the firm code. The report date as well as the Positions Long and Short fields will be zero-filled. If you have previously saved a file, the data you previously entered will be retrieved, but the report date will be zero-filled. You can set the report date for all positions appearing on the Position Entry screen by clicking on the Change Report Date button. When this button is clicked, the Set Report Date screen appears, showing a default report date based on your system’s clock. Change the default date and click on the Apply button. Alternatively, you can move the cursor to the Report Date field and change the date. The report date must be after October 1, 1998, and on or before the current date. In addition, the date must be for a weekday. When inputting the year of the report date, the system will not accept anything other than a 0, 1, or 2 in the first position. As you enter new position records, the report date will default to the report date of the record above it. Use the firm-assigned account number in the Account Number field. The maximum length for an account number is 12 alphanumeric characters. The Exchange Code field can only be filled from the drop-down list of codes. When you tab to this field, an arrow appears next to the field and a drop-down list of the valid exchange codes appears. The list of exchange codes will appear and disappear when the arrow next to the field is clicked. An exchange code can be selected by clicking on it in the list. Exchange codes and commodity codes reside in a text file, commodity.txt, in the PERT or other user-specified folder. Updating this file is described more fully in appendix B of the manual. New codes can be obtained from an updated file of exchange and commodity codes on the internet at www.cftc.gov/dea/frcodes.htm. The Commodity Code field also has a drop-down list that appears beneath the field. This list consists of all the exchange-assigned commodity codes for the exchange code that you selected. If no exchange code is selected, all commodity codes are listed. The list is sorted by name and can be accessed by clicking the arrow next to the field. You can select a commodity code either by clicking on it from the list, or by entering a commodity code that does not appear in the list. With the exception of the year 2000, the Expiration Year field can be filled with either a four- digit or two-digit year. The system will automatically change two-digit years into four digits. When entering the year 2000, you must enter all four digits. Years after the year 2000 can be entered using two digits. Although only the second number will appear, the system will convert the year to four digits. Fill the Expiration Month field with the month that the contract expires. The Expiration Day field is an optional field. It needs to be entered only if a full date is necessary to identify the contract that is being entered (i.e., flex contracts). You cannot tab to this field, because it is not always used. If you wish to enter an expiration date, you must position the arrow in this field and click to place the cursor in it. Fill the Put or Call field with a P (put) or C (call), if an option contract is being entered. If a futures contract is being entered, leave this field blank. You can select from the drop-down list beneath the field, or type a P or C. If the record above is an option record, and you wish to enter a futures record, a blank must be entered in this field. You can either choose the blank from the list or hit the space bar in this field to indicate that the above put or call indicator should not be carried down. Fill the Strike Price field with the contract's strike price in the format specified by the CFTC. If a futures contract is being entered, leave this field blank. When the cursor is in the Strike Price field, an example of the strike price format is displayed in the status bar in the lower left-hand corner of the screen. Leading zeros will not be shown in this field. Fill the Exercise Style field with an "A" if the option is an American style option, or an "E" if the option is a European style option. You can either select the indicator from the drop-down list or you can type it. If you are entering a futures record, leave this field blank. Fill the Positions Long and Short fields with the number of contracts open at the end of the trading day specified in the Report Date field. If a position is closed out, enter a zero in both the Positions Long and the Positions Short fields to indicate this situation. Fill the Record Type field with an indicator that appropriately specifies whether the record is a new record (Add), a change to a record that has been sent (Change), or a record that should be deleted (Deleted). If you make no entry in this field, the value in the field will default to “add’ when the positions are saved or validated. Entering Notices and XFCs If reportable traders have stopped or issued delivery notices or bought or sold futures contracts in connection with XFCs, this information must be entered into the system. Place the cursor in the record that the additional data applies to by left-clicking the mouse in one of the fields of that record. Then click the Notices and XFC button on the toolbar. If any record has errors, you must correct the errors before entering notices or XFCs. When no errors exist on the Position Entry screen, and the current record is a futures record, then the Notice and XFC screen will be displayed when you click on that button. Confirm that the identification information displayed at the top of the screen is correct for the additional data being supplied. If the correct information is not displayed, click on the Cancel button to return to the Position Entry screen without entering data. If the record information is correct, enter the notice and/or XFC data and click on the OK button to save the data. If you wish to remove all of the notice or XFC data, click on the Clear Data button. Once you enter notice and/or XFC data and click the OK button, the Notice and XFC Data screen will close. A diamond will display at the end of each record having notice or XFC information. The diamond can be clicked to display the additional data for viewing or editing. Identifying Flex Options In addition to the information required for all options, you must also enter information concerning the futures contract that flexible options exercise into. In order to display the screen for entering the additional information, click on the option box in the flex field or place the cursor in a field of the record for which additional data is needed, and click the Flex Options button on the toolbar. If any record has errors, you must correct the errors before you can enter the additional flex option information. Only option records can have flex options specified. If the cursor resides in a futures record when the Flex Options button is clicked, you will be notified that flex options data cannot be entered for that record. When no errors exist on the Position Entry screen, and the current record is an option record, the Flex Options Data screen will be displayed. Confirm that the identifying information displayed at the top of the screen is correct for the record that needs the additional data. If the correct information is not displayed, click the Cancel button to return to the Position Entry screen without saving any entered data. If the information is correct, enter the flex options data and click the OK button to save the data. If you wish to remove flex options data that has been saved, click the Clear Data button. You must enter the exchange and commodity codes as well as the expiration year and month of the contract the flex options exercise into. The expiration day need only be entered if the flex option exercises into another flexible instrument. With the exception of the year 2000, the Expiration Year field can be filled with either a four- digit or two-digit year. The system will automatically change two-digit years into four digits. When entering the year 2000, you must enter all four digits. Years after the year 2000 can be entered using two digits. Although only the second number will appear, the system will convert the year to four digits. Once flex options data has been entered and the OK button clicked, the Flex Options Data screen will be closed and a diamond will display at the end of the altered record, indicating that the record has additional data. The diamond can be clicked to display the additional data for viewing or editing. The following example shows the two screens necessary to identify a flex option. Example - In this example, a position in a flexible option in the Treasury bond contract on the Chicago Board of Trade is being reported. The option expires on November 28, 1998, and exercises into the December 1998 future. Position Entry screen Report Account Exchange Comm Expiration Put Strike Exc Positions Rec Date Number Code Code Year Mon Day Call Price Sty Long Short Type Flex 10/20/1999 1 CBT 52 1998 11 28 C 12918 A 100 A ? ? Flex screen Comm Expiration Code Year Mon Day 17 T-bonds 1999 03 Validating Positions Before position data can be saved, it must be inspected for errors. Data will be validated when you click on either the Validate Entries or the Save Positions button. The following is a list of errors that must be corrected before the displayed positions are saved. After you have corrected the errors, click again on the Validate Entries button. Error Corrective Action No firm code entered If no firm codes appear in the firm code list, enter the firm code assigned by the CFTC and click the Validate Entries button on the toolbar. If firm codes do appear in the list, enter a firm code, tab to the positions section, reenter the data, and click the Validate Entries button on the toolbar. Invalid report date or expiration date Enter a valid date and click the Validate Entries button on the toolbar. Report date is greater than the current date Enter a report date that is less than the current date and click the Validate Entries button on the toolbar. Report date is earlier than October 1, 1998 Enter a report date greater than October 1, 1998, and click the Validate Entries button on the toolbar. Missing account number, exchange code, commodity code, expiration year, expiration month entered, strike price, put or call, or exercise style entered for an option Enter the missing data and click the Validate Entries button on the toolbar. The field that is missing data will be highlighted so you will know immediately which field needs correction. Invalid expiration year Enter a valid two-digit or four-digit year and click the Validate Entries button on the toolbar. Invalid expiration month Enter a number between 1 and 12 in the Month field and click the Validate Entries button on the toolbar. Invalid expiration day Enter a number between 1 and 31 in the Day field and click the Validate Entries button on the toolbar. Negative positions entered Negative signs are not allowed. Remove the negatives signs, re-enter the positions as needed, and click the Validate Entries button on the toolbar. Eight-digit strike price entered Enter a seven-digit strike price and click the Validate Entries button on the toolbar. The eighth position in this field is allocated for a sign. Duplicate record entered Records with the same report date, account number, exchange code, commodity code, expiration year, expiration month, and expiration day (also strike price for option records) are not allowed. Change one of the fields, or delete one of the records, and click the Validate Entries button on the toolbar. Same record has been entered with a different record type Delete the record that contains the wrong record type and click the Validate Entries button on the toolbar. You cannot, for example, save in the same file records that both add and delete a position. No expiration day entered for a flex option Enter an expiration day between 1 and 31, if the record is for a flex option. Printing and Saving Records If you would like a printout of the records displayed on the Position Entry screen, then the Print Positions button should be clicked. Only the positions for the firm code displayed in the Firm Code field will be included on the printout. To print positions for another firm code, the user must select the desired firm code from the drop-down list beneath the Firm Code field and click the Print Positions button. The print-out will contain all the data for each record including notice and XFC data and flex options data. Once all positions for a firm code have been entered and validated and are free of indicated errors, the data can be saved. The data are saved by clicking the Save Positions button. The CFTC position file will be created when you click the Yes button in response to the question, "Would you like to create the CFTC position file?” If you want to enter positions for another firm code and save the positions for all firm codes in the same file, the No button should be clicked. When the No button is clicked, the positions are saved to the database and added to a temporary file which is used to create the CFTC file. This temporary file is empty when the application is started and contains only the positions that have been saved during the current use of the application. Data will also be saved to the data base when you close the Position Entry screen or exit the application and answer Yes to the message, “Do you want to save any changes?” In this circumstance, however, the temporary file is cleared. Positions that should be included in the file to be sent to the CFTC must be resaved to the temporary file. If you previously saved the data, it resides in the data base and does not need to be re-entered. You only need to select the firm code of the data to be included in the file, reset the report date, and click the Save Positions button to add the displayed positions to the temporary file. If you are entering data for multiple firms, process each firm code separately. Enter all of the positions for a specific firm and save them. When you are ready to enter the position records for another firm code, enter the new firm code into the Firm Code field or select it from the drop- down list. Positions belonging to this firm code can then be entered and saved. Save the data for each firm to the same temporary file. When the CFTC file is subsequently created, it will contain all the data for all the firm codes. Creating a CFTC File Once position data has been saved, a CFTC position file can be created. To create a CFTC file, you can either click the Create CFTC File button or click the Yes button on the Create CFTC File message box that is displayed after saving positions. A CFTC file cannot be created if position data has not been saved during a session. You can identify this situation by the appearance of the Create CFTC File button in the toolbar. If the button's picture appears gray, no position data has been saved. The button will not respond when clicked. When you choose to create a CFTC position file, the Create Position File screen will appear. You can use the top portion of the screen to specify where the position file should be saved. The Save In field displays the directory where the file will be saved. A directory entitled “Position” has been created in the PERT directory for the purpose of holding the position files. If you double click this folder, it will open and appear in the top Save In field. Although this directory has been provided, it does not need to be used. The lower portion of the screen can be used to specify the name of the position file. The name that appears in the File Name field is the default file name. The default file name is made up of the letters PO (for position), and the report date on the first position record. An alternative file name can be specified by typing it into the File Name field. The only type of file that can be created by the system is a text file (extension .txt). Click the Save button to save the specified position file. If you want to discontinue the file creation process, click the Cancel button. Keep in mind that, if a file already exists in the Save In directory with the same name as the one that appears in the File Name field, the previous file will be overwritten. This means that, if two CFTC position files are created on the same day with the same report date and the default position file names are used, only the last-saved position file will still exist. In order to avoid this situation, give each file a different name. Once the CFTC position file is created and the window for creating the file is no longer displayed, the user will notice that an exclamation point (!) appears at the left side of each position record that was included in the CFTC file. This exclamation point is the file indicator informing you that the record has been included in the CFTC file. When you make a change to a record that has a file indicator, the indicator is removed. This denotes that the record no longer reflects the data that was included in the CFTC file. Sending Position Data Once a CFTC file has been created, you can transmit position data to the CFTC by clicking the Send File to CFTC button. You must have an Internet Service Provider(ISP) and you must be connected through a dial-up or dedicated line before attempting to send a file to the CFTC. When you click the Send Data button, the FEDFTP application is started with a request to send the last CFTC file created during the current session. The FEDFTP program will connect to the CFTC FTP site, login to the site, transmit the file, and disconnect from the CFTC site. The FEDFTP application will display the status of these tasks in its main window. Depicted below is the main window before and after a file has been successfully transmitted to the CFTC. Before transmission After successful transmission The file has been successfully transmitted when all of the indicator lights turn green. If an error occurs during transmission, an error message will be displayed describing the problem. The next section contains instructions for dealing with error messages. Once the file transmission is completed, the FEDFTP program can be closed. Once a file has been sent to the CFTC using the FEDFTP application, the file is moved from its original location on the user’s machine to another folder containing all files sent to the CFTC. In the above example, file “aaa101.txt” will be moved to “C:\Program Files\PERT\Position\Sent” when the transmission is complete. FEDFTP Application FEDFTP is an application designed to send a single file from a client computer to the CFTC host server. All commands can be executed from the main window menu bar or the button bar. These commands are as follows: Select File - Identifies source file to be transferred. Send - Begins file transfer process. Help - Context sensitive help information. Settings - Establishes program options and defaults. Info - Opens read-only window that logs session information. Exit - Exits and terminates FEDFTP application. Select File - Displays a dialog window to facilitate file selection. If the FEDFTP application is started from the PERT application by clicking the Send file to CFTC button, the last file that you created in PERT will be listed in the dialogue box. If the FEDFTP application is started in any other manner, the dialogue box will display the default directory listed under SETTINGS. The file can then be selected from this directory. Send - Begins the file transfer process using FTP protocols. Help - Covers the following topics: Menu Commands The Button Bar Setting Defaults and Options Selecting the File Sending Files Connection Information and Logs FTP Messages and Errors Settings - FEDFTP is distributed with system defaults and options already preset. Under normal conditions, there is no need to ever change this information. The capability to make changes has been included in the software should CFTC network or server changes necessitate modification. FEDFTP Settings options include: Default File Name, Default Data Directory, Default File Extension, FTP Host Name, FTP User ID, FTP User Password, and FTP Host Directory. If you choose to save PERT files in a directory other than “Pert,” you may wish to change the default directory. Changing other presets may cause communication problems. Info – Use the Connection Information screen to view detailed session information. This feature was added to the software to facilitate potential communications problem solving and technical support. The contents of this screen will contain messages generated during the session, including those that are displayed if you encounter problems. Associated with each message is a user action. A list of these messages is provided in appendix C. Click on Save Log to save the contents of the Connection Information screen to the FEDFTP program directory in the file named FEDFTP.LOG. Click on OK to close the window. Error Handling – If an error condition occurs and your file is not sent to the CFTC, first check the error message and suggested user action in appendix C to determine if you can clear the error. If this is not possible, save the contents of the Connection Information screen and contact technical staff in the Commission’s Office of Information Resources. The best method for doing this is by electronic mail to pert/fedftp@cftc.gov with a brief paragraph describing the problem. Alternatively, you may contact by telephone one of the persons listed on page 2. To save the contents of the Connection Information screen, click on the Info button and then the Save Log button. APPENDIX A INSTRUCTIONS FOR PREPARING AND FILING REPORTS ON TRADER POSITIONS WHO SHOULD REPORT: Each futures commission merchant and foreign broker carrying an account for others (including officers and partners of the carrying firm) and each clearing member clearing their own trades whose open futures or option contracts at the close of business in such account equal or exceed the amount fixed for reporting at the close of business. TO DETERMINE IF AN ACCOUNT IS REPORTABLE: Combine all accounts owned or controlled by a trader and treat them as a single account. For the combined accounts, determine the net long or short position or the gross long or short position open in each futures or option expiration month of a commodity on any one contract market as of the close of the market on the day of the report. Net open long or short positions should be used except for the following positions which should be gross: (1) Positions in an omnibus account. (2) Positions in accounts owned or held jointly with another person or persons. (3) Positions in multiple accounts subject to trading control by the trader. (4) Positions in accounts reported gross long and gross short to the clearinghouse of any contract market for the purpose of calculating open interest. A position is reportable if, at the close of business, it equals or exceeds the quantity specified in section 15.03 of the Commission’s regulations in: (1) any one future of any commodity on any one contract market, OR (2) long or short put or call options that exercise into the same future month of any one commodity on any contract market. Current reporting levels are posted on the internet at www.cftc.gov/dea/rlevel.htm. WHAT TO REPORT: Once you have determined that a position is reportable for a trader in a particular commodity on a contract market, report ALL futures and ALL option positions for that trader that pertain to the commodity, regardless of size. In addition, for the same commodity, report all delivery notices issued or stopped on behalf of the trader and all exchanges of futures for physicals transacted by the trader. WHEN TO REPORT: Daily after the close of the market each business day and not later than 9:00 a.m. on the following business day. APPENDIX B UPDATING EXCHANGE AND COMMODITY CODES Drop-down boxes on the Position Entry screen list valid exchange codes and commodity codes. Examples for the Philadelphia Board of Trade (PBOT) are shown below. Report Account Exchange Comm Expiration Put Strike Exc Positions Rec Date Number Code Code Year Mon Day Call Price Sty Long Short Type Flex 11/03/1998 123 PBOT ? ZC 1998 12 5 P 658 A 0 125 A ? ? MGE ? NYCE NYFE NYMEX PBOT ? Report Account Exchange Comm Expiration Put Strike Exc Positions Rec Date Number Code Code Year Mon Day Call Price Sty Long Short Type Flex 11/03/1998 123 PBOT ZC ? 1998 12 5 P 658 A 0 125 A ? ? ZC Canadian Dollar ? ZD Deutsche Mark ZF French Franc ZJ Japanese Yen ZB Pound Sterling ? ? ? The information in these lists is contained in a tab de-limited text file, “commodity.txt,” that was supplied as a part of the PERT system. The file contains the following fields: Exchange Code: Code numbers for each exchange in general use by the industry. Exchange Initials: Exchange initials assigned by the CFTC. Commodity Description: Name of the contract. Commodity Code: Code assigned by the exchange. Strike Example: Example of a strike price per unit of the commodity traded; i.e., $2.60 per bushel. Strike Format: Example of the correct format for a strike price. Information in this file was complete as of the release date of this software. As new commodities begin trading, you may wish to update this file. The Commission maintains an updated list of commodity codes on the internet at www.cftc.gov/dea/frcodes.htm. A list of valid exchange codes is shown below. You can view all of the commodity codes on the internet site and use the information to manually update the text file. In the near future, you will be able to download a new file from the internet and replace the existing text file. Instructions for doing this will be forwarded when the new file is available. Exchange Codes * Initials Exchange Industry Code Chicago Board of Trade CBT 01 Chicago Mercantile Exchange CME 02 Comex Division of NYMEX CMX 07 Coffee, Sugar, and Cocoa Exchange CSCE 06 Kansas City Board of Trade KCBT 08 MidAmerica Commodity Exchange MCE 03 Minneapolis Grain Exchange MGE 09 New York Cotton Exchange NYCE 13 New York Futures Exchange NYFE 15 New York Mercantile Exchange NYMEX 12 Philadelphia Board of Trade PBOT 10 Care must be taken when manually updating the “commodity.txt” file because, if it is done incorrectly, the PERT application will not function properly. For this reason, it is important that you back up this file before attempting to update it. Below are the instructions for manually updating the commodity file. (1) Locate the file “commodity.txt” in the “C:\Program Files\PERT” folder. If you choose to install the application in a different location, use Explorer to locate the file. (2) Back up this file before you proceed. Make a copy of the original file and place it in a different directory or give it a new name so it will still be available, if needed. (3) Open the file with “Notepad.” Do Not use “Word,” even though it is capable of saving files in a text format. Using “Word” may corrupt the file when it is saved. (4) The data in the files are arranged in the order listed below. Each line represents information for an individual commodity. Each column must be separated by one and only one “TAB” character which is created by pressing the Tab key. An example of a data row follows the file layout for wheat traded on the Chicago Board of Trade. In the example below, the symbol is an indicator that the Tab key should be pressed to place a tab between two fields. File Layout Exchange Code; Exchange Initials; Commodity Description; Commodity Code; Strike Example; Strike Format Example - Data 01CBTWheatW$2.60/bu0000260 (5) To update an existing line of data, locate the row with the exchange initials and commodity that require a change and make the necessary modification. (6) To add a commodity, insert a blank line and enter the appropriate information in the order and method described in step 4. All fields must have an entry. If you do not have information to fill all fields, N/A (not applicable) can be entered for Commodity Description, Strike Example, and Strike Format. Do not add a record without an Exchange Code, Exchange Initials, or Commodity Code. Do not add blank lines to the file. (7) Save the changes after the data has been updated. APPENDIX C FEDFTP MESSAGES MESSAGE ACTION 110 Restart marker reply. None. Process restarted. 120 Service ready in nnn minutes. Retry after nnn minutes. Server may be down. 125 Data Connection already open; transfer starting. None. Data transfer taking place. 150 File status okay; about to open data connection. None. Informational. 200 Command okay. None. Informational. 202 Command not implemented, superfluous at this site. None. Should not occur. Contact CFTC. 211 System status, or system help reply. None. Informational. 213 File status. None. Informational. 214 Help message. None. Informational. 215 NAME system type. None. Informational. 220 Service ready for new user. None. Informational. 221 Service closing control connection. Logged out, if appropriate. If connection is lost, retry connection to server. 225 Data connection open; no transfer in progress. None. Informational. Connection okay. 226 Closing data connection. Requested file action successful (for example, file transfer or file abort). None. Informational. Operation okay. 227 Entering passive mode (h1, h2, h3, h4, p1, p2). None. Informational. Waiting for more transfers. 230 User logged in, proceed. None. Informational. Successful log- in to server. 250 Requested file action okay, completed. None. Informational. Successful transfer. 257 “PATHNAME” created. None. Informational. Directory created on server. 331 User name okay, need password. Log-in failure. User ID has been accepted, but is incorrect. Check settings. 332 Need account for log-in. Log-in failure. Possible corruption of user ID or password. Check settings. 350 Requested file action pending further information. None. Informational 421 Service not available, closing control connection. (This may be the reply to any command, if the service knows it must shut down.) Server shut down. Retry later. 425 Cannot open data connection. Communication error. Retry. 426 Connection closed; transfer aborted. Communication error. Retry. 450 Requested file action not taken. File unavailable (e.g., file busy). None. Server error. Contact CFTC. 451 Requested action aborted; local error in processing. Possible error in transmission. Retry. 452 Requested action not taken. Insufficient storage space in system. None. Server error. Contact CFTC. 500 Syntax error, command unrecognized. None. Not applicable or server error. Contact CFTC if server error. 501 Syntax error in parameters or arguments. None. Should not occur. Contact CFTC. 502 Command not implemented. None. Should not occur. Contact CFTC. 503 Bad sequence of commands. None. Should not occur. Contact CFTC. 504 Command not implemented for that parameter. None. Should not occur. Contact CFTC. 530 Not logged in. Connection lost. Reset and retry. 532 Need account for storing files. None. Should not occur. Contact CFTC. 550 Requested action not taken. File unavailable (e.g., file not found, no access). None. Possible server error. Contact CFTC. 551 Requested action aborted; page type unknown. None. Should not occur. Contact CFTC. 552 Requested file action aborted. Exceeded storage allocation (for current directory). None. Possible server error. Contact CFTC. 553 Requested action not taken. File name not allowed. None. Should not occur. Contact CFTC. * Although you only see exchange initials in the drop-down box on the Position Entry screen, the file you create to send to the CFTC identifies exchanges by the industry code. If you report futures or option positions for contracts trading on a new exchange, you must update the text file with both the new exchange initials and the new industry code. You can only enter the new exchange initials on the Position Entry screen by selecting from the drop-down list. 8