Ownership & Control Reporting (OCR)

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. 

Reporting Bitcoin (or Other Virtual Currency) Trading in Response to Question 18 on Form 40

A reporting trader who trades or expects to trade Bitcoin and/or one or more other virtual currencies should select “OTHER (SPECIFY)” in response to question 18 on Form 40 and should specify Bitcoin and/or the other virtual currency(ies) that the reporting trader trades or expects to trade.

Staff No-Action Letters 17-45 and 17-16 and Staff Guidance

On September 25, 2017 and March 10, 2017, respectively, the Commission’s Division of Market Oversight (DMO) issued the following no-action letters related to the OCR Final Rule:

Press Release 7617-17 provides information regarding No-Action Letter 17-45. The Letter extends current relief and provides additional time-limited relief from several reporting obligations on the OCR forms.

Press Release 7534-17 provides information regarding No-Action Letter 17-16. The Letter provides time-limited relief permitting reporting parties with reporting obligations on OCR Forms 102A and 102B to mask certain identifying information, subject to certain conditions.

All reporting parties should review the two no-action letters for important additional information.

• As discussed in Press Release 7357-16, DMO also issued Guidance related to the OCR Final Rule on April 8, 2016. The Guidance reproduces ownership and control questions asked in OCR Forms 102A and 102B, and responds directly to questions raised by reporting parties regarding the terms “owner” and “controller,” as used in these questions.

Form 102 Refresh Process

By December 15, 2017, reporting firms should have submitted an electronic version of the Form 102A or Form 102S for all of their active special and consolidated accounts. The submissions must be received via FTP or the CFTC Portal and must follow the standards and required data fields identified in the OCR rule. Once a reporting firm has submitted an electronic version of the Form 102A or Form 102S by December 15, 2017, it may rely on the no-action relief from refresh updates set forth in Section II.A.4. on pages 9-10 of Staff No-Action Letter 17-45. As a reminder, that relief is subject to the condition that a reporting firm relying on the relief files timely and complete change updates required by the OCR rule.

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:


Publication date



July 1, 2014

Technical guidance document; version 4


May 25, 2016

Technical guidance document; version 5.1

Blackline between version 4 and version 5.1

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 PDF 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.  Calls will occur quarterly 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: 1-877-951-7311

Toll dial-in number for U.S. participants: 1-203-607-0666

Dial-in numbers for international participants

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 [email protected]

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.