E-FCL

SISS Betsy Bruinsma

Elizabeth.bruinsma@dss.mil

Work phone # (210) 824-1546 ext 224

mailto:Elizabeth.bruinsma@dss.mil

E-FCL Outline

• History

• When to Submit

• Initial Submission

• Common Issues

• Updates to e-FCL

• Conclusion

E-FCL History

• DSS first started using e-FOCI – Dept. of Energy (DOE) program

• Effective January 19, 2010, DSS modeled their own program using e-FOCI

• If a facility completed an initial submission through e-FOCI, data was migrated to e-FCL

• Electronic - Facility Clearance (e-FCL) – purpose is to improve efficiency, paperless and a repository for facility information

When to Submit

• New facility being processed for a Facility Security

Clearance (FCL)

• Facility has a change on the SF 328 – Certificate

Pertaining to Foreign Interest

• Key Management Personnel changes

• Ownership change

• Facility address change

• Facility name change

• General rule – before submitting first confirm with

your Industrial Security Representative (ISR)

Initial Submission

• Defined as never submitting a complete e-FOCI or e-FCL submission before.

• First you will need a user name and password.

• New facility being processed for a FCL will automatically be registered by the Facility Clearance Branch.

• Facility with a current FCL will be registered by your ISR.

• Once registered, an e-mail will be sent to your facility point of contact. This person will then create their own user name and password.

Initial Submission (cont.)

• Recommend downloading the DSS User Submission Site User Guide at: http://www.dss.mil/diss/documents/eFCLSubmissionSiteUserGuideV607Sept2010.pdf

• Before starting, review guide.

• Facility can access the e-FCL program from the DSS website or going directly to the e-FCL website: https://submission.dssfcl.anl.gov

• Only one user can be assigned for your facility through DSS, but the facility can assign another user internally. What does this mean to you???

http://www.dss.mil/diss/documents/eFCLSubmissionSiteUserGuideV607Sept2010.pdfhttp://www.dss.mil/diss/documents/eFCLSubmissionSiteUserGuideV607Sept2010.pdfhttps://submission.dssfcl.anl.gov/

Initial Submission (cont.)

• Program only takes pdf files.

• Single file can be no larger than 5 MBs.

• Forms completed within e-FCL like the KMP list and SF 328, must be printed, signed, converted to a pdf file then uploaded into your submission.

• All forms requiring a signature need to be signed.

• Key when first starting your submission is annotating your correct organizational structure – why???

Initial Submission (cont.)

• Once all of the information has been uploaded,

you will submit your e-FCL package for review.

• At this time, you will not be able to make any

changes to your e-FCL submission.

• ISR will review your submission and if additional

items are needed, you will get an e-mail through

e-FCL to tell you what information is required

and that your e-FCL package has been unlocked.

Common Issues

• Not selecting the correct type of organization (LLC, General Partnership, Sole Proprietorship, Corporation, Branch/Division).

• Missing and incomplete information on the Summary Data Sheet. – No website listed (if you have one)

– Stock information not listed

– Missing previous business names

– Missing tier parents

– Number of directors not matching articles of organization or bylaws

– Previous addresses going back 10 yrs not listed

Common Issues (cont.)

• Incomplete information being provided for a “yes” answer on the SF 328. The program explains what information must be provided for a “yes” response.

• The SF 328 not completed correctly on the backside of form. – Corporation – complete the “CERTIFICATION”

section, but not the witnesses section. Complete also the “CERTIFICATE” section and apply corporate seal.

– Not a Corporation – complete only the “CERTIFICATION” section, two witnesses sign and print their names.

SF 328

Common Issues (cont.)

• Who goes on the KMP list – discuss vs guide???

• KMP list missing information

– Names are not completely spelled out

– KMP list not signed – FSO signature is fine

– Date for excluded KMPs is the date exclusion resolution signed

– Social security number not required for excluded KMPs

– KMPs do not match the articles of organization, bylaws or amendments

Common Issues (cont.)

• Corporate documents not loaded

– Examples – articles of organization, bylaws,

amendments and meeting minutes changing corporate

documents

• Shareholder Agreements

– If company has stocks, listing of stocks issued to

persons or companies owning 5% or more

• Not loading documents under the correct

headings – files

Updates to e-FCL

• Select Change Condition

• Significant changes – discuss???

– ISL_2009_03_December_09

• Change of KMPs

• Change of address

• Change of ownership

• Change from a “yes” to “no” or opposite

Conclusion

• Before submitting an e-FCL submission, talk

with your ISR to confirm the submission is

required.

• Be exact, read your articles of organization and

bylaws.

• If having issues, either call your ISR, e-FCL help

desk as noted in the help guide or read common

e-FCL Q&As -

http://www.dss.mil//diss/efcl_faqs.html

http://www.dss.mil//diss/efcl_faqs.html

Questions?