ocr data service user guide - fia tech · chapter 1 provides an overview of the fia tech ocr data...

OCR Data Service

User Guide

20 May 2015

OCR202 v.8 FIA Tech OCR Data Service User Guide

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Confidential. Copyright © 2015, FIA Technology Services, Inc. All rights reserved.

Copyright

Unpublished work © 2015 FIA Technology Services (FIA Tech)

This OCR DATA SERVICE USER GUIDE (USER GUIDE) is an unpublished, copyrighted work and contains confidential information intended for the users of the FIA Tech OCR Data Service. Any unauthorized use, disclosure, reproduction, or dissemination, in full or in part, in any media or by any means, without the prior written permission of FIA Tech may subject the unauthorized party to civil and criminal penalties.

Trademarks

OCR Data Service™ is a trademark of FIA Tech.

Use Restrictions

Use of this FIA Tech OCR DATA SERVICE USER GUIDE is authorized for purposes consistent with the Terms & Conditions for use of the OCR Data Service or any Master Services Agreement in place between the User and FIA Tech that has superseded the Terms & Conditions. Use of this USER

GUIDE shall not be contrary to any third-party contract restrictions, any laws, regulations or rules governing the use of the OCR Data Service.

Each user upon initially accessing of the FIA Tech OCR Data Service must agree to be bound by and acknowledge, as a condition for access, the Terms & Conditions for use of the OCR Data Service.

To the extent anything in this FIA Tech OCR DATA SERVICE USER GUIDE is inconsistent with or conflicts with the Terms & Conditions or any Master Services Agreement between the User and FIA Tech, the Terms & Conditions or any Master Services Agreement between the User and FIA Tech shall control.

Limited Warranty and Disclaimer

This FIA Tech OCR DATA SERVICE USER GUIDE may be updated or amended from time to time and at any time by FIA Tech at its sole and absolute discretion and without notice thereof. Please regularly check the FIA Tech OCR Data Service website to obtain the current version of this USER

GUIDE.

http://fia-tech.com/home/


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Introduction to this USER GUIDE

The FIA Tech OCR Data Service establishes a means for Participant firms and their Clients to ensure that their owner and controller data reported to the Commodity Futures Trading Commission is complete, accurate, and properly formatted for review by industry regulators.

This USER GUIDE provides an introduction to the FIA Tech OCR Data Service and is intended to serve as a training and reference document for users. The USER GUIDE includes approximately 200 screenshots, many of which are supported by annotations at Appendix A .

The content of the USER GUIDE is organized as follows:

Chapter 1 provides an overview of the FIA Tech OCR Data Service.

Chapter 2 contains a Site Map showing the structure of functions performed by users.

Chapter 3 describes the FIA Tech User Hub, which is used to access the FIA Tech OCR Data Service.

Chapter 4 is intended for Clients using the FIA Tech OCR Data Service to establish Profiles containing owner and controller information.

Chapter 5 is intended for Third Party Controllers who establish Profiles for their own firms and identify their personnel who will be reported as Controllers.

Chapter 6 is intended for Reporting Firm Users of the FIA Tech OCR Data Service who create Accounts within the system and associate their Accounts to Profiles of Owners and Controllers and other information maintained within the system for reporting to the CFTC.

Chapter 7 is intended for Reporting Firm Administrators who manage user and administrative access within each Participant firm.

Chapter 8 describes Reporting Firm actions that ensure timely ownership and control reporting to the CFTC based on their data reflecting volume of trades.

Chapter 9 provides information about FIA Tech OCR Data Service processes and notifications for all users.

Chapter 10 addresses troubleshooting of FIA Tech OCR Data Service for all user functions.

Chapter 11 provides contact information for all users requiring assistance with specific issues not addressed in this USER GUIDE.

Appendix A provides annotations to certain screenshots used in this document. Hyperlinks are provided within each annotated figure to the annotations in Appendix A . In addition, a hyperlink is provided within Appendix A to return to the figure containing the screenshot.

Appendix B provides a description of the Third Party Controller integration as it relates to tasks performed by Client users, users of firms acting as Third Party Controllers, and users within the Reporting Firms.

Appendix C provides a statement of rules governing Automatic Permission Inheritance that apply to Profiles.

Appendix D provides revision history information for this document.



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Table of Contents

Introduction to this USER GUIDE ................................................................................................................. 3

Chapter 1 Overview ................................................................................................................................ 7 1.1 Overview of the FIA Tech OCR Data Service .................................................................................. 7 1.2 Categories of Users ......................................................................................................................... 7

1.2.1 Clients of Reporting Firms ................................................................................................. 7 1.2.2 Users within a Third Party Controller ................................................................................. 8 1.2.3 Users within a Reporting Firm ........................................................................................... 8

1.3 User Functions ................................................................................................................................. 8 1.3.1 Functions Performed by Clients ........................................................................................ 8 1.3.2 Functions Performed by Third Party Controller Users ....................................................... 9 1.3.3 Functions Performed by Reporting Firm Users ................................................................. 9 1.3.4 Functions Performed by Reporting Firm Administrators ................................................... 9

1.4 Key Terms Used in this Document .................................................................................................. 9

Chapter 2 Site Map ............................................................................................................................... 10

Chapter 3 FIA Tech User Hub .............................................................................................................. 11 3.1 Register for Access to the FIA Tech User Hub .............................................................................. 11 3.2 Log in to the FIA Tech User Hub ................................................................................................... 13 3.3 Recover a Forgotten Password ..................................................................................................... 14 3.4 Verify and Edit User Data............................................................................................................... 18 3.5 Reset Your Password .................................................................................................................... 20 3.6 Access FIA Tech Applications ....................................................................................................... 22 3.7 Log Out of the FIA Tech User Hub ................................................................................................ 23

Chapter 4 OCR Data Service for Clients............................................................................................. 24 4.1 Accept Terms and Conditions ........................................................................................................ 24 4.2 OCR Dashboard for Clients ........................................................................................................... 24 4.3 Create Profiles for Your Clients ..................................................................................................... 25

4.3.1 Search Current Profiles ................................................................................................... 26 4.3.2 Enter Client Profile ........................................................................................................... 30

4.4 Assign Permissions to a Profile ..................................................................................................... 44 4.5 Save the Profile .............................................................................................................................. 45 4.6 Add Account Controllers to Profiles of Owners .............................................................................. 49

4.6.1 Select Existing Account Controller Profile ....................................................................... 50 4.6.2 Create New Account Controller Profile ............................................................................ 53 4.6.3 Verification of Account Controller Added ......................................................................... 56

4.7 Update Profile Data from within a Profile ....................................................................................... 58 4.7.1 Locate the Profile or Profiles to be Updated .................................................................... 59 4.7.2 Edit Legal Entity and Main Contact Information in a Profile ............................................ 61 4.7.3 Edit Natural Person and Employer Information in a Profile ............................................. 62 4.7.4 Edit Account Controller Information in a Profile ............................................................... 65 4.7.5 Edit Permissions within in a Profile .................................................................................. 66

4.8 Manage Reporting Firm Access to Multiple Profiles ...................................................................... 67 4.8.1 Add Permissions to Multiple Profiles ............................................................................... 70 4.8.2 Revoke Permissions from Multiple Profiles ..................................................................... 73

4.9 Delete a Profile ............................................................................................................................... 77 4.10 Return to the FIA Tech User Hub .................................................................................................. 78

Chapter 5 OCR Data Service for Firms Acting as Third Party Controllers ..................................... 79 5.1 Accept Terms and Conditions ........................................................................................................ 79 5.2 OCR Dashboard for Firms Acting as Third Party Controllers ........................................................ 79 5.3 Create a Legal Entity Profile for Your Firm .................................................................................... 80



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5.3.1 Enter Your Firm’s Legal Entity Information ...................................................................... 83 5.3.2 Enter Your Firm’s Main Contact Information ................................................................... 84

5.4 Assign Permissions to Your Firm’s Profile ..................................................................................... 89 5.5 Save Your Firm’s Profile ................................................................................................................ 90 5.6 Enter Information about Your Firm’s Personnel Who Direct Trading ............................................ 92

5.6.1 Enter Natural Person Information .................................................................................... 94 5.6.2 Enter Employer Information ............................................................................................. 94 5.6.3 Review Permissions ........................................................................................................ 95

5.7 Maintain Your Firm’s Profile Information ........................................................................................ 98 5.7.1 Locate the Profile or Profiles to Review and Update ....................................................... 99 5.7.2 Edit Your Firm’s Profile Information ............................................................................... 100 5.7.3 Edit Information in Your Firm’s Main Contact and Account Controller Profiles ............. 100 5.7.4 Remove and Replace an Account Controller ................................................................ 100 5.7.5 Edit Permissions within in a Profile ................................................................................ 103 5.7.6 Delete a Profile .............................................................................................................. 105

Chapter 6 OCR Data Service for Reporting Firm Users.................................................................. 106 6.1 Accept Terms & Conditions as Required ..................................................................................... 106 6.2 OCR Dashboard for Reporting Firm Users .................................................................................. 106 6.3 Manage Reporting Firm Market Roles ......................................................................................... 108

6.3.1 Access Market Roles ..................................................................................................... 108 6.3.2 Establish Global Roles Applicable to All Markets .......................................................... 110 6.3.3 Identify Roles Specific to an Individual Market .............................................................. 110 6.3.4 Save Market Roles ........................................................................................................ 112

6.4 Review the Owner, Controller Profiles that You Will Use for Reporting ...................................... 113 6.5 Enter Accounts ............................................................................................................................. 120 6.6 Add Profile Associations to Accounts (102A, 102B, and 102S) .................................................. 123

6.6.1 Associate Profiles within Trading Accounts ................................................................... 124 6.6.2 Associate Profiles within Special Accounts ................................................................... 129 6.6.3 Associate Profiles within Consolidated Accounts .......................................................... 140 6.6.4 Create Profiles as Needed for Association to Accounts ................................................ 144

6.7 Add Special Account Associations to a Trading Account (102B) ................................................ 145 6.7.1 Search Accounts ............................................................................................................ 147

6.8 Add Trading Account Associations to a Special Account (102A) ................................................ 148 6.9 Add Market Associations to a Trading Account (102B) ............................................................... 151 6.10 Add Paired Swaps/Swaptions Details to a Consolidated (102S) Account ................................... 153 6.11 Edit Accounts ............................................................................................................................... 155

6.11.1 Edit Account Information in Accounts (102A, 102B, and 102S) .................................... 156 6.11.2 Remove Associations from Accounts (102A, 102B, and 102S) .................................... 159 6.11.3 Edit Certain Fields in Trading Accounts (102B)............................................................. 160 6.11.4 Edit Paired Swaps / Swaptions Details in Consolidated (102S) Accounts .................... 163

6.12 Deactivate and Reactivate an Account ........................................................................................ 165 6.12.1 Deactivate an Account ................................................................................................... 165 6.12.2 Reactivate an Account ................................................................................................... 167

6.13 Return to the FIA Tech User Hub ................................................................................................ 170

Chapter 7 Reporting Firm Administrator Functions ....................................................................... 172 7.1 Access Administrator Functions ................................................................................................... 172 7.2 Search Reporting Firm Records of Users and Administrators for Review ................................... 173 7.3 Create Reporting Firm Users and Administrators ........................................................................ 175

7.3.1 Add a New User to the System ..................................................................................... 175 7.3.2 Verify User Status and Resend Verification Email Message ......................................... 177

7.4 Assign New Users to Participant Organization ............................................................................ 178 7.5 Establish User and Administrator Roles ...................................................................................... 179

7.5.1 Establish Reporter Entity Administrator roles ................................................................ 180 7.5.2 Establish Reporter Entity User roles .............................................................................. 180



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7.6 Edit User Information ................................................................................................................... 181 7.7 Deactivate and Reactivate User Access ...................................................................................... 183

7.7.1 Deactivate a User .......................................................................................................... 183 7.7.2 Reactivate a User .......................................................................................................... 184

Chapter 8 Reporting of Data on Volume of Trades ......................................................................... 187 8.1 Third Party Transmission of Daily Trading Data .......................................................................... 187 8.2 Reporting Firm Uploading of Daily Trading Data ......................................................................... 187 8.3 Reporting Firm Manual Generation of Ownership and Control Reports ...................................... 187

8.3.1 Initiate Reporting of an Account .................................................................................... 187 8.3.2 Select the Destination for the Report ............................................................................. 189 8.3.3 Identify the Markets to be Reported, if Required ........................................................... 189 8.3.4 File the Report ............................................................................................................... 190

Chapter 9 System Functions and Notifications ............................................................................... 194 9.1 FIA Tech OCR Data Service Reporting to the CFTC .................................................................. 194 9.2 Automated System Notifications to Users .................................................................................... 194

9.2.1 Notifications of Ownership and Control Reports Filed with the CFTC .......................... 194 9.2.2 File Load Notifications Related to Importing of FIABatch Files ..................................... 195 9.2.3 Notification of a FIABatch File Export ............................................................................ 196

9.3 Additional Notifications ................................................................................................................. 197

Chapter 10 Troubleshooting ................................................................................................................ 199 10.1 OCR User Portal Browser Functionality ....................................................................................... 199 10.2 OCR User Portal Logs You Out ................................................................................................... 199 10.3 Email Registration Instructions Not Received by Client ............................................................... 199 10.4 Email Registration Instructions Not Received by New Reporting Firm User ............................... 199 10.5 Log In Issues ................................................................................................................................ 200 10.6 Lock Out After Multiple Failed Login Attempts ............................................................................. 200 10.7 Access to Profiles ......................................................................................................................... 200 10.8 Foreign Broker Unable to Associate Profile of Domestic FCM .................................................... 200

Chapter 11 Obtain Additional OCR Data Service Support ............................................................... 201 11.1 Immediate Support ....................................................................................................................... 201 11.2 General Inquiries .......................................................................................................................... 201

Appendix A – Annotations to Selected Screenshots .......................................................................... 202

Appendix B – Third Party Controller Integration ................................................................................. 220

Appendix C – Automatic Permission Inheritance ................................................................................ 223

Appendix D – Change History................................................................................................................ 229



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Chapter 1 Overview Welcome to the FIA Tech OCR Data Service (“OCR Data Service” or “Service”) Portal. This section provides an overview of the Service and describes the primary functions of the Service that can be performed within the FIA Tech OCR Portal.

1.1 Overview of the FIA Tech OCR Data Service

The FIA Tech OCR Data Service is a web-based application that allows Reporting Firms such as Futures Commission Merchants (FCM), clearing organizations, foreign brokers, and swap dealers to capture and store client data needed for regulatory reporting purposes and automatically file ownership and control reports (OCR) to the Commodity Futures Trading Commission (CFTC) based on volume thresholds and or certain triggering events. These filing requirements are set forth in the CFTC’s new ownership and control rules for identification of futures and swap market participants (“OCR Final Rule” or “Final Rule”) that were established on November 18, 2013.

The FIA Tech OCR Data Service supports creation of client data Profiles expressly designed for submission of ownership and control data that may be entered and managed by Clients. By using the OCR Portal to create their owner and controller Profiles, Clients benefit by having the ability to manage their owner and controller data in one central location and provide permission for multiple Reporting Firms with whom they have accounts to use their data for submission of the required reports. This benefit pertains to the initial data collection phase of the new expanded reporting and throughout the trading relationship. Should a Client update his or her information at any time, Reporting Firms having permission to use the Client’s Profiles are automatically notified of the update. To ensure that information in Profiles is kept current, Clients also receive requests from FIA Tech to update their owner and controller information maintained in the OCR Portal at least once a year.

The FIA Tech OCR Data Service is the product of collaboration by Reporting Firm IT, compliance, and onboarding departments and data security services to ensure complete and accurate reporting of required data to the CFTC. The FIA Tech OCR Data Service affords both Clients and Reporting Firm Users a reporting system with a high level of security and resiliency.

FIA Tech has published separately a document containing answers to frequently asked questions about the OCR Data Service of interest to all users. OCR Data System Frequently Asked Questions is available for download from the OCR Dashboard.

1.2 Categories of Users

Users of the FIA Tech OCR Data Service are differentiated based on the purpose for which they use the system. User categories are listed below:

1.2.1 Clients of Reporting Firms

Clients using the FIA Tech OCR Data Service are typically asset managers, development funds, and other kinds of organizations or individuals who have relationships with Reporting Firms, including Commodity Pool Operators (CPO) and Investment Advisors (IA). Clients may be the Owner of an account or the Controller of an account under power of attorney or other agreement with the Owner that authorizes them to make trading decisions for the Owner. Clients can also be both the Owner and Controller if they authorize the trading of their own assets.

Clients permit the firms and organizations with which they have a trading relationship, which are considered “Reporting Firms” within the meaning of the OCR Final Rule, to use information in their information contained in Profiles to file the required reports.



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1.2.2 Users within a Third Party Controller

Users within firms that manage all or part of a fund or account for Clients of a Reporting Firm are considered third parties and are designated “Third Party Controllers” within the OCR Data System. Such Third Party Controllers are typically commodity trading advisors or other advisors with expertise in a specific industry, asset class, or commodity sector.

Third Party Controller users create a Profile for their firm and identify employees within their firm as individual Controllers. The firm’s Profile information is then used by Client users, CPOs and IAs, who need to designate the firm as a Controller. Reporting Firms that are permitted access to the Profile use it to obtain the additional information that they are required to report.

1.2.3 Users within a Reporting Firm

1.2.3.1 Reporting Firm Users

FCMs, clearing organizations, foreign brokers, and swap dealers are Reporting Firms under the OCR Final Rule and are required to report certain OCR data to the CFTC in accordance with the Rule. As Reporting Firms, these firms and organizations are organized as Participants in the FIA Tech OCR Data Service and their employees with access to the Service are considered Reporting Firm Users. Reporting Firm Users use information in the Profiles that Client Users have established, based on permissions set by the Client Users, to perform the firm or organization’s required owner and controller reporting.

If a Client has not yet created Profiles within the OCR Data Service, a Reporting Firm User may do so to the best of its ability to ensure that any current required reporting to the CFTC is timely. The Reporting Firm is later notified if the Client establishes a Profile that the Reporting Firm will be able to use in future reports.

1.2.3.2 Reporting Firm Administrators

Reporting Firm Administrators are designated individuals within a Participant organization who establish and manage the organization’s OCR Data Service users. Administrators establish access for the Participant organization’s brokers, managers, and others as needed and assign roles that designate these users as Reporting Firm Users or additional Administrators. Reporting Firm Administrators may also perform all of the functions that Reporting Firm Users perform.

1.3 User Functions

Functions that may be performed by users of the FIA Tech OCR Data Service are governed by the category of user. All of the functions listed within this section may be performed within the OCR Portal.

1.3.1 Functions Performed by Clients

Clients of the FIA Tech OCR Data Service perform the following functions:

Register for access to OCR through the FIA Tech User Hub.

Verify and maintain their personal user data.

Create owner and controller Profiles for use in reporting.

Ensure that Controllers are added to Profiles of Owners.

Assign permissions within their Profiles enabling Reporting Firms with which the Client has an established a trading relationship to use the Profiles for reporting.

When changes occur or annually at a minimum, update user Profile information to ensure that it is current and accurate.



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1.3.2 Functions Performed by Third Party Controller Users

Create Profile for the Legal Entity serving as a Third Party Controller.

Add Profiles of individual personnel who serve as Natural Person Controllers for reporting by the Reporting Firms.

Assign permissions as needed to enabling Reporting Firms to report required controller information for their Accounts.

1.3.3 Functions Performed by Reporting Firm Users

Reporting Firm Users perform the following functions necessary for owner and controller reporting in accordance with the Final Rule:

Verify their personal user data to ensure its correctness.

Identify the Market Roles for the markets in which the Reporting Firm trades.

Access and view owner and controller Profiles created by Clients based on permissions set by the Clients recognizing the Participant as a Reporting Firm for their trading activities.

Enter Trading Accounts, Special (102A) Accounts, and Consolidated Accounts into the FIA Tech OCR Data Service, including account numbers and Short Codes used by the firm for the client’s trades.

Associate Profiles to Accounts that have been entered and establish additional Associations as required.

Create Profiles as needed in the event that Profiles needed were not created by Clients.

1.3.4 Functions Performed by Reporting Firm Administrators

Reporting Firm Administrators perform the following specific administrator functions:

Establish access to the OCR Data Service for individual brokers and managers and Reporting Firm Users and Reporting Firm Administrators.

Assign Participant organization to the users.

Establish Roles for the users to designation their Reporting Firm User or Reporting Firm Administrator status.

1.4 Key Terms Used in this Document

See the OCR Data Service Glossary for definitions of key terms used in within the OCR Data Service and in this USER GUIDE to discuss actions performed using the OCR Portal. The OCR Data Service Glossary is available for download from the OCR Dashboard.



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Chapter 2 Site Map The following diagram provides a map of functions supported by FIA Tech OCR Data Service and performed within the OCR Portal within their hierarchical structure.

Level 1 functions provide access to Level 2.

Level 2 functions are subordinate to Level 1.

Level 3 functions are sub functions accessible within Level 2.

User information

Review and Edit User Details

OCR

Profiles

Create Profilefor Legal Entity

Create Profile for Natural Person

Add Employer Information

Change Password

Accounts

Level 1

Level 2

Client Users

Create Special 102A Account

Create Consolidated102S Accounts

User Hub

Search Profiles

Search Accounts

Associate Accounts with Profiles, other Accounts,

Markets, and Swap Details

Review Viewable Profiles

Administration

Add Permissions

Add Main Contact

Add Controllers

Search Users

Create Users, Assign Roles and

Participants

Activate/Deactivate Users

Create TradingAccount

APPS

Level 3

Legend

Reporting Firms Administrators

Level 1

Level 2

Level 3

Level 1

Level 2

Level 3

Create Accounts

Note: Administrators may perform all OCR functions related to Profiles and account records as needed, in addition to administrative functions.

Note: Reporting Firms may perform OCR functions related to Profiles as needed, in addition to functions related to creation and management of account records.

Assign Market Roles

Manually File Ownership and Control Reports



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Chapter 3 FIA Tech User Hub The FIA Tech User Hub provides users a single point of access for all FIA Tech applications, including the OCR Portal. If you were not registered by your organization, use the FIA Tech User Hub to register for access to FIA Tech applications, to enter or edit your user data, and to manage your password.

Procedures for use of the FIA Tech User Hub are described in this section. Topics are as follows:

Registration

Password recovery

Verification and updating of your user information

Password reset

NOTE: Many Reporting Firm Administrative functions are performed within the FIA Tech User Hub. These functions are addressed in Chapter 7.

3.1 Register for Access to the FIA Tech User Hub

Registration is required for all users of FIA Tech applications. Users who are employees of Participant firms are registered by their organizations. Individuals or employees of other firms, including Clients of Reporting Firms who have been asked to set up Profiles in the system, may register by accessing the FIA Tech User Hub at myapps.fia-tech.com. Personnel of firms that act as Third Party Controllers must also register to gain access to the OCR Data Service in order to set up a Profile for their firm.

On the Welcome to FIA Tech User Hub screen, click on Register. See Figure 1.

Figure 1

On the Sign up for a new account screen, complete the following required fields as shown in Figure 2.

o First Name

o Last Name


https://myapps.fia-tech.com/


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o Email Address

o User Account Name

o Password

o Confirm Password

o Company

o Location

o CAPTCHA text

NOTE: A User Account Name is auto generated by the system and may be accepted as is or changed. If you change the User Account Name and the system detects that your edited User Account Name is not available, you will be prompted to select a different User Account Name.

NOTE: When you enter your password in the Password field, a password strength bar will indicate whether your password choice is weak, medium, strong, or very strong.

Figure 2

After you have entered the required information on the Registration screen, click on the Register button to register your user access.



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You will see the confirmation message indicating your registration was successful as shown Figure 3. Shortly thereafter, you will also receive an email message sent to the email address that you entered when registering with further instructions to complete the registration process.

NOTE: If you are unable to register, contact FIA Tech for assistance with the registration process. See Chapter 11.

NOTE: If, after registering, you did not receive a confirmation email, check your spam box in case the message was routed to spam. Contact FIA Tech for further assistance if needed.

Figure 3

Complete your registration process by clicking on the link in the email verification message, which will return you to the FIA Tech User Hub.

NOTE: The link in the email verification message that you will receive after registering becomes invalid after 48 hours. Be sure to respond to the message by clicking on the link and completing the registration process within 48 hours after you receive the message.

3.2 Log in to the FIA Tech User Hub

To log in to the FIA Tech User Hub, perform the following steps:

Enter your User Account Name and Password that were established during the registration process, as shown in Figure 4.

NOTE: You may also log in with your email address in the User Account Name field instead of your assigned User Account Name.

Click on the Log in button.



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Figure 4

NOTE: If you are unable to log in, verify that your User Name and Password are correct.

CAUTION: Five failed attempts to log in to the FIA Tech User Hub will cause your account to be locked. If you believe your account has been locked, contact FIA Tech for assistance using the contact information in Chapter 11.

After logging in to the FIA Tech User Hub, you will be directed immediately to the OCR Portal and will to review and accept Terms & Conditions for the OCR Application (“Terms & Conditions”) for use of the Service prior to accessing the system. See Section 4.1.

NOTE: After you have accepted the Terms & Conditions, you may return to the User Hub at any time from within the OCR Portal. See Section 4.10 and Section 6.13, where access back the User Hub is described.

3.3 Recover a Forgotten Password

If you have forgotten your FIA Tech User Hub password, use the Forgot your password? link on the FIA Tech User Hub shown in Figure 5 to access the password recovery function.



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Figure 5

Click on the link to be directed to the Forgot Password screen as shown in Figure 6.

o Enter your User Name or Email address in the User Name field.

o Enter the CAPTCHA text shown in the graphic.

o Click on the Continue button to execute your password recovery request.

Figure 6

After clicking on the Continue button, you will receive a confirmation of your request and be referred to your email for further instructions. See Figure 7.



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Figure 7

Click on the link provided in the email message to create a new password as shown in Figure 8.

NOTE: The link in the email message invalid after 2 hours. Be sure to respond to the message by clicking on the link and creating a new password within 2 hours after you receive the message.

Figure 8

Enter your new password in the form provided.

Click Save to save your new password. See Figure 9.



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Figure 9

After saving your new password, you will be directed to the Login screen shown in Figure 10 and see a confirmation message stating that your password was successfully changed.

Figure 10

Use your new password to log in to the FIA Tech User Hub.



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3.4 Verify and Edit User Data

The FIA Tech User Hub serves as a central location or management of user information for FIA Tech Applications. All users of the FIA Tech User Hub should review their user information periodically to ensure that the information is current.

To manage your user information, click on the My User Account icon on the Welcome screen, your personalized welcome message, or the My User Account button. See Figure 11.

Figure 11

You will be directed to a My Details screen such as the ones shown in Figure 12 or Figure 13. These screens display user information and information about the user’s FIA Tech User Hub registration.

o Figure 12 represents information that Clients see when viewing their My Details screen.

o Figure 13 represents information that a Reporting Firm Users see when viewing their My Details screen.

NOTE: Boxes labeled My Participants and My Roles in Figure 13 contain statuses designated by Reporting Firm Administrators for their users. These designations do not apply to Clients.

To edit your user information as needed, click on the Edit button. See Figure 13.

Figure 12

FIGURE 12 ANNOTATIONS



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Figure 13

For both Clients and Reporting Firm Users, changes may be made to the following fields as shown in Figure 14, including certain information that could not be entered during the registration process and can only be added after logging in:

o Email Address

o First Name

o Last Name

o Title

o Business #

o Mobile #

o Fax #

o Company

o Location

o Default App

NOTE: By editing the Default App field, you can change the screen to which you are directed each time you log in. By default, the OCR is selected in the Default App field.

Enter any changes or additions to your user information for the fields shown.

To change your Default App setting to User Hub, select User Hub from the drop-down list shown in Figure 14.




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Figure 14

Use the Save button to save your changes.

The message Account updated successfully confirms that your changes were saved. See Figure 15. Note that any changes or new information added will be shown.

Figure 15

3.5 Reset Your Password

Resetting of a FIA Tech User Hub password is performed on the My Details screen within the My User Account tab.

To locate the My Details screen, access My User Account from the Welcome screen. See Figure 11.

When the My Details screen appears, click on the Change Password button. See Figure 16.



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Figure 16

When Change Password screen appears, enter and confirm your new password using the New Password and Confirm Password fields provided. See Figure 17.

Click on the Save button to save your password change. See Figure 17.

Figure 17

The following message confirms that your password was changed. See Figure 18.



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Figure 18

Log back in to the FIA Tech User Hub by entering your User Name or Email Address and using your new password in the Password field.

3.6 Access FIA Tech Applications

Registered users who have accessed the FIA Tech User Hub may return to their applications by clicking on the My Apps button as shown in Figure 19.

When the drop-down list appears, select the application to be accessed from the available options.

NOTE: The OCR Data Service is available to all users and is listed within My Apps by default. To the extent that access to other applications within the User Hub has been arranged, those applications will also appear in the drop-down list.



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Figure 19

3.7 Log Out of the FIA Tech User Hub

After logging in to the FIA Tech User Hub, users may log out of the system from any User Hub screen. The Log off icon is located in the top right hand corner of all screens. See Figure 20.

Click on the Log off button to log out of the FIA Tech User Hub.

Figure 20

After logging off, you will be directed to the FIA Tech User Hub Welcome screen shown in Figure 5.



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Chapter 4 OCR Data Service for Clients This section describes initial access to the OCR Data Service by Clients and use of the OCR Portal for creation of Profiles and assignment of Permissions. Specific topics are as follows:

Terms & Conditions

Creation of Profiles

Specify permissions for Reporting Firms to view Profiles

Update owner and controller information in Profiles when changes occur or annually at a minimum

These topics are addressed in the following sections.

4.1 Accept Terms and Conditions

Registered users who log in to the OCR Data Service for the first time as described in Section 3.6 are prompted to review and accept Terms & Conditions for the OCR Application (“Terms & Conditions”) for use of the Service prior to accessing the system.

Scroll though the agreement and use the Submit button to accept the agreement.

If you wish to obtain a copy of the Terms & Conditions for your records, click on the link to the agreement on the FIA Tech website at fia-tech.com/OCR/ to do so.

NOTE: If at any time the Terms & Conditions are revised you will be asked to review and agree to the new Terms & Conditions at your next login.

After accepting the Terms & Conditions, you will be directed to a Dashboard screen that welcomes you to ownership and control reporting. See Section 4.2 and Figure 21 below.

4.2 OCR Dashboard for Clients

The OCR Dashboard provides access to functions performed by Clients involving creation and maintenance of Profiles within the FIA Tech OCR Data Service. Access to these functions is via the Profile tab or Profiles icon shown below in Figure 21.

In addition, the Dashboard has been constructed to provide for notification to Clients of issues related to their Profiles that may require attention or of the need to update Profiles as required on an annual basis.

NOTE: At this time, the notification feature for Clients has not been implemented. This USER

GUIDE will be updated to provide more information about notices to Clients in a future release.


http://fia-tech.com/OCR/


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Figure 21

For Clients, the default icon on the Dashboard screen is Profiles, as shown in Figure 21, which is used to access Search and Create functions.

Below the Notification section of the Dashboard screen, links are provided to the following important and highly useful documents, including the most up-to-date version of this OCR DATA SERVICE USER

GUIDE:

o OCR PORTAL QUICK START GUIDE FOR CLIENTS

o OCR DATA SERVICE GLOSSARY

o OCR DATA SERVICE FREQUENTLY ASKED QUESTIONS

o APPLICATION RELEASE NOTES

NOTE: For an initial overview of actions required for creation of Profiles, refer to the OCR

PORTAL QUICK START GUIDE FOR CLIENTS.

4.3 Create Profiles for Your Clients

Creation of Profiles is necessary to ensure that client information and relationships are correctly entered in the OCR Data Service and can be reliably used by the Reporting Firms for ownership and control reporting to the CFTC. The Reporting Firms should be able to guide you if you need assistance as to the specific Profile information required.

NOTE: Creating a Profile establishes you as the manager of the Profile. As manager of a Profile, only you can edit the Profile and only you can determine which Reporting Firms will see the Profile and use it for reporting. You will manage any Profile that you create and keep the information in the Profile up to date. Other Clients will be unable to access your Profiles. Likewise, you will be unable to see Profiles created by other Clients.

REMEMBER: You are the manager of the Profiles that you create.



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REMEMBER: Reporting Firms can view your Profiles only with your permission. If Reporting Firms have questions about Profiles you have created, they will contact you at the email address shown the Profiles that you manage. See below at Figure 26, where the email address of Russell Warren, the Profile Manager, is shown at the bottom of a Profile.

4.3.1 Search Current Profiles

When creating Profiles, it is advisable to perform a search of your existing Profiles to verify whether a new Profile is needed, especially if you have created a large number of Profiles already. The procedure for searching your Profiles is described in this section.

From the Dashboard, click on Search within the Profiles box or from the drop-down list in the Profiles tab. See Figure 22.

Figure 22

4.3.1.1 Enter and Execute Search

Enter the name of the individual or entity whose Profile you will search, or, if you wish to review all Profiles, leave the search box empty. See Figure 23.

To limit your search to Profiles that you have created, select the owned by me option in the Show Profiles drop-down box.

NOTE: For Clients, Profiles that are visible to you include both Profiles that you created are Profiles of certain users acting as Third Party Controllers, a portion of whose information is visible to all users of the system. To limit your search results to Profiles that you created, you should choose the owned by me option.

For Reporting Firm users, it can be useful to distinguish between visible Profiles that were created by Clients and Third Party Controllers as distinct from owned Profiles that the Reporting Firm created. A Reporting Firm user intending to search Profiles that his or her firm created should select the owned by me option.

Click on the Search button.



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Figure 23

4.3.1.2 View and Search Results

Search results are displayed with data in sortable columns to facilitate review of a large number of retrieved Profiles. In the example shown in Figure 24, three Profiles were responsive to the search term entered, “Walker.” Each Profile may be opened to verify of the Profile Details by clicking on the OCR Profile ID. See Figure 24.

Figure 24

When a search returns a long list of search results, the results can be filtered using the down arrow icon in certain columns. See Figure 24. In the OCR Profile ID field, the Profile Name field, and the Email field, filtering limits the results displayed to those equal to or not equal to the criteria stated. In the Profile Type field, filtering limits the results displayed to either Legal Entities or Natural Persons. See Figure 25.

NOTE: It is possible to apply filters to more than one column of data in your search results.

NOTE: When a filter has been applied to a column, the column is marked to show that filtering has been applied. See Figure 25, where the Profile Type column has been set to display only Natural Persons.

CAUTION: Be sure to clear any filters you have set prior to performing subsequent searches.



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Figure 25

Click on the number in the OCR Profile ID column to access the Profile Details. See Figure 25.

The Profile Details for the “Walker, Jeffrey” Profile with OCR Profile ID OCR2597 are shown in Figure 26. See next page.



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Figure 26

If the Profile found is for the client whose Profile you intended to create and the details are correct, no further actions are needed. If any details are incorrect, edit the Profile Details using the procedure described in Section 4.6.2.3.

Note that in the example shown below in Figure 27, the search results are empty because no Profiles were found in response to a search for a client named “Strategic.”




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Figure 27

If no results are obtained in response to your search and you believe that a Profile matching your search was previously created, check the Show Inactive box in the lower part of the search results list to include inactivated Profiles in the search. See Figure 28.

NOTE: In any results displayed when the Show Inactive box is checked, the active or inactive status of each Profile will be shown as Yes or No in the Active column. See Figure 28.

If you cannot locate any existing Profile that matches your search, proceed with creation of a new Profile as described below in Section 4.3.2.

Access to the Create Profile function from within the Search function is shown in Figure 28.

Figure 28

4.3.2 Enter Client Profile

To create a Profile for the individual or entity that may need to be reported, you will need to access the Create a new Profile screen.

To access the Create a new Profile screen:

o From the Search Profiles screen, click on Create within the Profiles tab or click on the Create Profile button as shown in Figure 28.

o From the Dashboard, click on Create within the Profiles menu or the Profiles icon, as shown in Figure 29.



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Figure 29

On the Create a New Profile screen, choose the type of entity to be entered.

o Click on the Legal Entity button to create a Profile for a client that is a corporation, partnership, association, or other legal entity. See Figure 30.

o Click on the Natural Person button if the client is an individual. See Figure 30.

NOTE: After you click on the Legal Entity button or the Natural Person button, specific fields to be completed will appear in the remaining parts of the form.



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Figure 30

4.3.2.1 Create Profile for a Legal Entity

4.3.2.1.1 Enter Legal Entity Information

Information about a Legal Entity client is entered in the fields listed below and as shown in the upper box in Figure 31. The fields are as follows:

Legal Entity Name

Profile Name - auto generates

Legal Entity ID (LEI) – 20 character alphanumeric ending in two digits

Supplied by LEI - checkbox

Website

NFA ID (if known)

Email

Phone (direct and without extension, may not contain letters)

Street

Suite

City

State or Province

Postal Code

Country



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Figure 31



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Enter the client information indicated in the Legal Entity Information section in Figure 31 using the formats and drop-down selections provided and making optional use of the Supplied by LEI checkbox.

Do not place a check mark in the 3rd Party Controller checkbox. The 3rd Party Controller checkbox is reserved for use by firms acting as Third Party Controllers to designate their own firm’s Profile. See Appendix B for more information about the Third Party Controller relationships.

NOTE: The drop-down list within the State or Province field relates to the choice you make from the Country drop-down list. You should select the Country before you select the State or Province.

NOTE: If you supply the client’s Legal Entity Identifier (LEI) in the Legal Entity ID field and put a check in the Supplied by LEI checkbox, certain information from the LEI record will be accessed and incorporated into your information reported via the OCR Data Service. Because information is accessed from the LEI record, the following fields within the Profile do not need to be completed if the Supplied by LEI checkbox is checked: Street, City, State or Province, Postal Code, and Country. Figure 32 shows an example of a Profile for Fox Creek Gas and Electric Utility, Inc. that is being created with the Supplied by LEI box checked. The fields pulled from the LEI record in both the Legal Entity Information section have been left blank.

Figure 32

Contact the Reporting Firms that will report the information contained in your Profiles if you have questions about specific information that you should include in your Profiles.

4.3.2.1.2 Enter Main Contact Information

After the Legal Entity Information has been entered, the Main Contact Information section of the form should be completed. The information in this section is stored by the system in a separate Profile that remains visible within the Profile that you are creating for the Legal Entity. See the lower box in Figure 31.




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To provide information about the Main Contact for the Profile, select one of the following two options:

o Profile already exists for the Main Contact (Section 4.3.2.1.2.1)

o Create New Profile for the Main Contact (Section 4.3.2.1.2.2)

NOTE: The option None is not available when data is entered in the OCR Portal even though a None button appears to be selectable. See Figure 31. In certain cases when large quantities of data were uploaded into the system and a Main Contact was not specified, None was supplied by the system by default. Legal Entity Profiles with None in the Main Contact box should be updated to include the Main Contact information. See Section 4.7.2 for information about updating Profiles.

4.3.2.1.2.1 Profile Already Exists for the Main Contact

Click on the Choose existing button if there is already an existing Profile for the Main Contact. This option will enable you to incorporate the existing Profile for the Main Contact into your new Profile.

A list of the Profiles that you have created will appear on the following screen. See example in Figure 33.

NOTE: The unique OCR Profile ID is assigned to by the system to each Profile and displayed in the OCR Profile ID field of the search results.

If necessary, use the search feature described in Section 4.3.1 to locate the appropriate Profile in the list.

Click on the line containing the name of the Main Contact for the Legal Entity and click on the Select button to bring the point of contact information into Legal Entity Profile. See Figure 33.

Figure 33

When you click on the Select button, the attachment is formed and the Main Contact Information section of your new Profile will show information from the selected Profile as the Main Contact. See example in Figure 34.

Enter the requested information in the Relationship to Legal Entity field. See Figure 34.

Enter the requested information in the Title or Position at Legal Entity field. See Figure 34.



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Figure 34

4.3.2.1.2.2 Create New Profile for the Main Contact

A new Profile should be established if the Main Contact for your client does not yet have a Profile. The Profile for the Main Contact contains the following fields:

First Name

Middle Name

Last Name

Name Suffix


Legal Entity ID (LEI)1 - 20 character alphanumeric ending in two digits


Website

NFA ID (if known)

Email


Street

Suite

City

State or Province

Postal Code

Country

Employed by this Legal Entity - checkbox

Relationship to the Legal Entity

Title or Position at Legal Entity

Click on the Create New button to create a new Profile for the Main Contact.

If the address fields in the Profile for the Legal Entity were completed manually, follow the steps described below in Section 4.3.2.1.2.2.1.

If the Profile for the Legal Entity included a checkbox in the Supplied by LEI field, follow the steps described below in Section 4.3.2.1.2.2.2.

1 If an LEI has not been assigned or is not available, the Legal Entity ID field should be left blank.



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4.3.2.1.2.2.1 Create Main Contact Profile Using Auto Filled Fields

In the Main Contact Information section, fields will appear for entry of data with certain fields auto filled based on the Legal Entity information already entered. See Figure 35.

NOTE: By default, the Main Contact is identified as an employee of the Legal Entity. This employee status can be changed if needed by unchecking the Employed by this Legal Entity checkbox and removing the word Employee from the Relationship to Legal Entity box. See Figure 35.

If any information in the auto filled fields is incorrect or inapplicable to the Main Contact, correct the auto filled fields as needed.

Figure 35

Enter the remaining information required in the Main Contact Information section shown in Figure 35 using the formats and drop-down selections provided.



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4.3.2.1.2.2.2 Create Main Contact Profile Using “Supplied by LEI” Checkbox

If an LEI was provided for the Legal Entity and the Supplied by LEI checkbox was checked in the Legal Entity Information section of the Profile, address information is not auto filled in the Main Contact Information when a new Profile for the Main Contact is created.

Instead, when the Profile for the Main Contact is created, the same LEI that was entered in the Profile of the Legal Entity may also be entered within the Main Contact Information and the Supplied by LEI box may also be checked. See Figure 36.

NOTE: If the Supplied by LEI box is checked in the Main Contact Information section, the following fields for the Main Contact may be left blank: Street, City, State or Province, Postal Code, and Country.

To have address fields in the Profile of the Main Contact pulled from the Legal Entity’s LEI, enter or copy and paste the LEI number that was entered in the Legal Entity Information section into the Legal Entity ID (LEI) field of the Main Contact Information.

Figure 36 shows an example of a Profile for Fox Creek Gas and Electric Utility, Inc. that was created with the Supplied by LEI box checked for both the Legal Entity and the Main Contact.

NOTE: Even when the Supplied by LEI box is checked, the Phone and Email fields must be filled in for the Legal Entity and the Main Contact. See Figure 36.



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Figure 36

4.3.2.2 Create Profile for a Natural Person

If the Profile that you need to create is for an individual (or “natural person”) and the Natural Person option was selected for creation of the new Profile at Section 4.3, the form shown in shown below in Figure 37 appears and calls for the information indicated in two sections, which are addressed below in turn.




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Figure 37

4.3.2.2.1 Enter Natural Person Information

Information about individual Natural Persons is entered as shown in the upper box shown above in Figure 37.

The fields are as follows:



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First Name

Middle Name

Last Name

Name Suffix

Profile Name (auto generates)



Website

NFA ID (if known)

Email

Phone (direct and without extension)

Street

Suite

City

State or Province

Postal Code

Country

Enter the information indicated in the Natural Person Information section in Figure 37 using the formats and drop-down selections provided.


4.3.2.2.2 Enter Employer Information

Individual Natural Person Profiles support incorporation of employer information in the event that the person identified in the Profile is employed. See the Employer Information section marked by the lower box in Figure 37.

NOTE: Information about an Employer is not required within Profiles of Owners.

The information in this section is stored by the system in a separate Profile that remains visible within the Profile that you are creating for the Natural Person.

Select one of the following three options:

4.3.2.2.2.1 Individual Does Not Have Employer

Leave the None button if the individual does not have an employer, is self-employed, or the employer is not known.

4.3.2.2.2.2 Profile Already Exists for the Individual’s Employer

Click on the Choose existing button if there is a previously created Profile for the individual’s employer. Use this option to incorporate the latter Profile into your new Natural Person Profile.

After you click on the Choose existing button, a list of all the Profiles that you have created will appear on the following screen. See example in Figure 38.




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NOTE: A unique OCR Profile ID is assigned to by the system to each Profile and displayed in the OCR Profile ID field of the search results.

If necessary, use the search feature described in Section 4.3.1 to locate the appropriate Profile in the list, filtering the results as needed.

Identify the individual’s employer in the list, click on the line containing the information to select it, and click on the Select button to bring the employer information into your Natural Person Profile. See Figure 38.

Figure 38

When you click on the Select button, the attachment is formed and the Employer section of your new Profile shows that the individual is employed by the firm whose Profile was selected. See example in Figure 39.

Enter the requested information in the Relationship to Employer field. See Figure 39.

Enter the requested information in the Title or Position at Employer field. See Figure 39.

Figure 39

In the example used, Jeffrey Walker Enterprises was designated as the employer for Jeffrey Walker, whose Relationship to Employer is Owner and Title or Position at Employer is President. See also Figure 26, where the completed Profile is shown.

4.3.2.2.2.3 Create New Profile for the Employer

A new Profile should be established for the individual’s employer if the employer does not yet have a Profile. The new Profile for the employer contains the following fields listed below and shown in Figure 40:

Legal Entity Name


Legal Entity ID (LEI) - 20 character alphanumeric ending in two digits



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Website

NFA ID (if known)

Email


Street

Suite

City

State or Province

Postal Code

Country

Relationship to Employer

Title or Position at Employer

To create a new Profile for the employer, see the Employer Information section marked in Figure 37 and click on the Create New button.

In the Employer Information section, fields will appear for entry of data with certain fields auto filled based on the Natural Person information already entered. See Figure 40, where the auto filled employer fields are shown.

If any information in the auto filled fields is incorrect or inapplicable to the employer, correct the auto filled fields as needed.



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Figure 40

Enter the remaining employer information indicated in the Employer Information box shown in Figure 40 using the formats and drop-down selections provided and making optional use of the Supplied by LEI checkbox.


NOTE: If you supply the employer’s Legal Entity Identifier (LEI) in the Legal Entity ID field and put a check in the Supplied by LEI checkbox, address information from the LEI record will be used to perform ownership and control reporting. The address fields in the Employer Information section of the Create a new Profile screen may be left blank. See Figure 31, where analogous fields were left blank in the Profile of a Legal Entity after the Supplied by LEI box was checked.

4.4 Assign Permissions to a Profile

Permission to use the Profile is assigned by you, the Client who created the Profile, to Reporting Firms that execute transactions for you on behalf of entity or individual described in the Profile. Only



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firms permitted by you to view the Profile have access to the information contained in the Profile and may use the information.

In addition, Reporting Firms permitted to see a Profile that you created see only the Profile information and the indication of their permitted status. They do not see the permitted status of any other firm.

Permissions are entered in the lower part of the Create a New Profile screen as shown in Figure 31 and Figure 37.

In the example of entered permissions shown in Figure 41, four Reporting Firm firms have been permitted to use the specific Profile for an ownership and control report.

Check the appropriate checkboxes to assign permission to Reporting Firms listed to use the information in the Profile for ownership and control reporting purposes.

If needed, click on Uncheck All button to clear all check marks from the Profile Permissions section of the form. See Figure 41.

Figure 41

When you add Permissions to your Profile, the same Permissions will automatically inherit to the Main Contact, if the Profile is for a Legal Entity, or Employer, if the Profile is for a Natural Person. See Appendix C for further information about Automatic Permission Inheritance.

4.5 Save the Profile

To save the Profile, click on the Create Profile button at the bottom of the form. See Figure 31 and Figure 37.

NOTE: The data in your new Profile is not saved until you click on the Create Profile button.

After you click on the Create Profile button, you will be prompted to address any fields in your new Profile with incomplete or nonconforming information. Warning flags in orange designate fields where



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information should be added or corrected. Error flags in dark red show fields in which information is deficient and correction of the deficiency is required.

An example of a Profile with a warning flag and an error flag is shown in Figure 42.

Figure 42

Once any errors flags have been remedied and warning flags have been addressed to the extent possible, click the Create Profile button again to override any remaining warnings and save the Profile.




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NOTE: The override option becomes available when the Create Profile button shown in Figure 42 has been clicked again and changes to an orange Ignore Warnings and Create Profile button. See Figure 43.

Figure 43

As soon as the new Profile has been created, you will see a new, darkened Profile Details screen showing the information that was entered and including an OCR Profile ID that uniquely identifies the Profile. See Figure 44.

A message will appear briefly at the top of the screen confirming that the Profile was created successfully. See Figure 44.

An additional message in the center of the screen will ask whether the Profile “represents the Owner of an account.” See Figure 44.



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Figure 44

If the new Profile is for an Owner of an account, click Yes.

If for any reason the Profile that you have created is not for an Owner of an account, click No.

If you clicked Yes, you will be directed back to the Profile Details screen for the saved Profile, where a warning flag will prompt you to enter the Account Controllers. See Figure 45.

If you clicked No, you will be directed to the Profile Details screen for the saved Profile, and no Account Controller will be required.



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Figure 45

NOTE: The process for adding Account Controllers is described in Section 4.6.

NOTE: From the Profile Details screen, you may edit the Profile as needed as described in Section 4.6.2.3.

NOTE: You may also delete the Profile if needed as described in Section 4.9.

4.6 Add Account Controllers to Profiles of Owners

The Account Controllers section on the Profile Details screen supports assignment of Account Controllers to owner Profiles. Assignment of Account Controllers ensures that Reporting Firms can perform reporting to the CFTC in accordance with the OCR Final Rule based on controller information within the Owner’s Profile.



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Account Controllers may include the individuals in your firm who make trading decisions for an account as wells as firms that you work with as third party advisors, to the extent that the latter are also decision makers. In either of the above cases, your firm may also act in the role of Controller for an Owner.

NOTE: Profiles created for entities or individuals who are not Owners of an account, such as secondary Profiles for third party contacts or employers, do not require entry of an Account Controller. Account Controllers are added only to Profiles of Owners.

When Account Controllers are added to owner Profiles, their Permissions should be reviewed to ensure that they include the Permissions assigned to the Owner to the extent needed. In certain cases, a controller Profile may need to have some, but not all, of the Owner’s Permissions, depending on which Reporting Firms the Controller is working with.

To add an Account Controller for an owner Profile, click on the Add button in the Account Controllers section of the Profile. See Figure 45 and Figure 46.

NOTE: Adding an Account Controller to a Profile for an Owner associates the Account Controller’s Profile to the Profile of the Owner.

Figure 46

When you add an Account Controller to an owner Profile, you may create a new Profile or use an existing Profile if a Profile for the Controller was already created. Therefore, after you click on the Add button, two options are shown: Select Profile and Create new Profile. See Figure 47.

Figure 47

To select an existing Profile for an Account Controller, follow the steps described below in Section 4.6.1.

To create a new Profile for an Account Controller, follow the steps described below in Section 4.6.2.

4.6.1 Select Existing Account Controller Profile

To add an Account Controller for whom a Profile was previously created, perform the following steps:



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Click on the Select Profile button to select the Account Controller from a list of Profiles that are visible to you, which includes your previously created Profiles.

When the list appears, choose the Profile of the Account Controller from the list as shown in Figure 48.

NOTE: If a large number of Profiles are listed, use the search feature described in Section 4.3.1 to locate the appropriate Profile in the list, filtering the results as needed.

o If you act as a decision maker for the Owner, select your own Profile.

o If a colleague in your company acts as a decision maker for the Owner, select your colleague’s Profile.

o If your firm acts as decision makers for the Owner, select your firm’s Profile.

o If another company is acting as a decision maker for the Owner, select that firm’s Profile.

See Figure 48, where Russell V. Warren has selected his own Profile as the Natural Person Account Controller to be added to the Profile. Click on the Select button to add the selected Profile and identify the Account Controller for the owner Profile you are creating. See Figure 48.

Figure 48

4.6.1.1 Verify Additional Account Controller Permissions, if Needed

After you click on the Select button, if the Owner has Permissions that the Controller you are adding does not have, you will be directed to a pop-up box called Add Owner Permissions to Account Controller, followed by the OCR Profile ID number of the Account Controller that you selected. See Figure 49.

Otherwise, if the Account Controller already has the same Permissions as the Owner, you will be directed back to the Account Controllers box, where you will indicate the Relationship to Owner as described in Section 4.6.1.2.

Within the Add Owner Permissions to Account Controller box, if it appears, additional Permissions that the Account Controller will acquire for the new Profile are shown and need to be reviewed. In the example shown in the Add Owner Permissions to Account Controller box in Figure 49, only one new Permission will be added to the Controller’s Profile, which is a Permission for Norwelton Securities.

Unless this check mark in the checkbox for the new Permission is removed, the Controller’s Profile will become visible to the new Reporting Firm based on this Permission inherited from the Owner.



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Remove any check marks for Reporting Firms listed in the Add Owner Permissions to Account Controller box if the Account Controller does not actually work with the Reporting Firm.

NOTE: Removing a check mark from a Controller’s Permissions does not impact the Owner’s Permissions. The Profile of the Owner will remain visible to all Reporting Firms that were indicated.

Figure 49

After you have removed any new Permissions that do not apply to the Account Controller you are adding, click on the Continue button, which will take you back to the Account Controllers box. See Figure 49.

4.6.1.2 Supply the Relationship of the Controller to the Owner

Specify the Relationship to Owner for the Controller selected. See Figure 50, where Russell Warren’s name and OCR Profile ID are displayed based on your selection. See also Figure 52, where a Third Party Controller was identified with the Relationship to Owner of Financial Advisor.

Figure 50

If you wish to remove the added Account Controller and add another Account Controller instead, use the Change Profile button to return to your list of Profiles. See Figure 50.

To save the Account Controller you have added, click on the Save button shown in Figure 50.

If needed, repeat the steps set forth in this section to add additional Controllers using Profiles that were already created.

In the example shown in Figure 51, Russell Warren has added both his own Profile and the Profile of his firm as Controllers.



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Figure 51

In the example shown in Figure 52, Marcia Finley has designated herself and another firm, Ocean Bay Commodity Advisors, as Controllers for an owner. Ocean Bay Commodity Advisors is considered a Third Party Controller as described in Appendix B .

Figure 52

To add additional Account Controllers for whom Profiles have not been created, as long as the Controllers are not Third Party Controllers, follow the steps described below in Section 4.6.2.

NOTE: If you need include another firm as a Third Party Controller for one of your Owners and you are unable to locate the firm’s Profile, you should contact the firm and verify whether the Profile has been created. Third Party Controllers are users of the OCR Data Service and each creates a Profile for their firm.

4.6.2 Create New Account Controller Profile

To add an Account Controller for whom a Profile needs to be created, perform the following steps:

From the screen shown in Figure 47, click on the Create New Profile button to open the Create Profile screen shown in Figure 53.




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Figure 53

4.6.2.1 Account Controller to be Added is a Legal Entity

If the Controller to be added is a Legal Entity, click on the Legal Entity button in the Create Profile screen shown in Figure 53.

When the Create New Profile screen appears (see Figure 31), complete the Legal Entity Information in the upper section following the steps described in Section 4.3.2.1.

Enter Main Contact information for the Legal Entity following the procedure described in Section 4.3.2.1.2.

4.6.2.2 Account Controller to be added is a Natural Person

Click on the Natural Person button in the Create Profile screen shown in Figure 53 if the Controller to be added is an individual (Natural Person).

When the Create New Profile screen appears (see Figure 37), complete the Natural Person Information in the upper section following the steps described in Section 4.3.2.2.

Add Employer information for the Account Controller following the procedure described in Section 4.3.2.2.2.

NOTE: When a Profile is created for an Account Controller, Employer information is required.

NOTE: If the Account Controller is an employee within your firm, your firm’s Profile may also be added as an Account Controller. See example in Figure 51.

4.6.2.3 Verify the New Account Controller Permissions

Within the Profile Permissions section of Create Profile screen, Permissions for the Account Controller are preselected based on Permissions assigned to the Profile of the Owner. Each Permission that Account Controller will acquire based on the Owner’s Permissions is labeled Please review!.



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All inherited Permissions labeled Please review! in the Profile Permissions section should be reviewed. If the Controller does not actually work with a Reporting Firm labeled Please review!, the Permission should be removed from the Controller’s Profile.

Remove any check marks for Reporting Firms marked Please review! in the Profile Permissions box if the Account Controller does not actually work with the Reporting Firm.

Unless the check mark in the box labeled Please review! is removed, the Controller’s Profile will become visible to the new Reporting Firm based on this Permission inherited from the Owner.

NOTE: Removing a check mark from a selection labeled Please review! does not impact the Owner’s Permissions. The Profile of the Owner will remain visible to all Reporting Firms that were indicated in its Profile.

In the example shown in Figure 54, both Norwelton Securities and International Bank, Ltd were labeled Please review!. The check mark in the box for International Bank, Ltd has been removed because the Controller does not work with that Reporting Firm. The Controller does work with Norwelton Securities; therefore, Norwelton Securities remains selected and the Controller’s Profile will be accessible to Norwelton Securities for reporting.

Figure 54

After you have reviewed the inherited Permissions and removed any check marks for Permissions not applicable to the Controller, save your new Profile by clicking on the Create Profile button. See Figure 54.



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4.6.3 Verification of Account Controller Added

After adding an Account Controller to the Profile of an Owner, you may wish to verify that the relationship to the Owner is also reflected in the Controller’s Profile. This section describes how to verify that the Controller’s Profile properly indicates the Controller’s relationship to an Owner.

In the screen detail shown in Figure 55, note that both Russell Warren and Great Lakes National Insurance Trust were added as Controllers to the Profile of the account Owner, Health Fund, Inc.

Figure 55

To verify that the Profiles for the Controllers reflect owner information reciprocally, access the Profiles Details screen for each Controller in turn by clicking on their OCR Profile ID numbers. See Figure 55.

Within the Controlled Accounts box of the Profile Details screen for the Controller, the Profile of the Owner is listed together with any other Profiles to which the Controller was also added.

In the example shown below in Figure 56, the Profile for Great Lakes National Insurance Trust shows its controller relationship to Health Fund, Inc. Specifically, the status of Health Fund, Inc as an Owner for whom Great Lakes National Insurance Trust is a Controller is shown in the Profile of Great Lakes National Insurance in the Controlled Accounts box. The Controlled Accounts box also shows that the firm is a Controller for Jeffrey Walker’s account. See Figure 56.



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Figure 56

The example shown in Figure 57 reflects the fact that Ocean Bay Commodity Advisors was added as a Controller to the Profile of StratCap Aggressive Futures Fund. Therefore, Ocean Bay Commodity Advisors includes StratCap Aggressive Futures Fund within its Controlled Accounts box when viewed by Marcia Finley, who manages the Profile of StratCap Aggressive Futures Fund. See Figure 57.

NOTE: Profile data for firms acting as Third Party Controllers has limited visibility. In the Profile of Ocean Bay Commodity Advisors, Marcia Finley sees only Profiles of Owners that that she manages. She does not see Profiles of Owners entered by other Client users that also work with Ocean Bay Commodity Advisors. In addition, although Profile Manager for Ocean Bay Commodity Advisors is shown, information about its Main Contact is not disclosed. To the extent that Ocean Bay Commodity Advisors has identified Controllers within its Profile, the names of those individuals are also not disclosed. See Figure 57 and Appendix B .




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Figure 57

NOTE: The Controlled Accounts box contains data only if the Profile is for a Controller. When an Account Controller is added to a Profile of an Owner, the Owner’s Profile information automatically appears in the Controller’s Profile in the Controlled Accounts box.

For discussion of use of the how to use the Controlled Accounts box to update all Profiles that share a common Controller, see Section 4.7.1.2.

4.7 Update Profile Data from within a Profile

Information in Profiles is accessed with your permission by specific Reporting Firms and incorporated into their reporting to the CFTC. Accuracy of the regulatory reporting relies on the correctness of information in Profiles as initially entered and maintained.

In the event that information in a Profile was incorrectly entered or has recently changed, you as the Client who created the Profile should update the Profile as needed to ensure its correctness.



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Reporting Firms that have created Profiles also need to regularly ensure that their Profiles are current and bring them up to date as needed.

Within the Profile Details screen for a Profile, the following information can be edited:

Legal Entity Information and Main Contact Information (in Profiles of Owners or Controllers that are Legal Entities)

Natural Person Information and or Employer Information (in Profiles of Owners or Controllers who are Natural Persons)

Account Controller

Permissions

NOTE: The Profile Managers within a Profile cannot be edited. You as the Client who created the Profile are the Profile Manager and the only person who can edit the Profile. If a Reporting Firm creates a Profile, the Reporting Firm User who created the Profile is the Profile Manager.

4.7.1 Locate the Profile or Profiles to be Updated

Profiles that require updating may be revised individually or collectively if one Controller is assigned to all of the Profiles to be updated.

Access Profiles as follows:

4.7.1.1 Search for a Specific Profile

To edit a specific Profile and update or correct the information the Profile contains, perform a search as described in Section 4.3.1 to locate and select the Profile to be updated.

NOTE: Search results, such as those shown in Figure 24, include the Reporting Firms have you have permitted to use the Profile. See Figure 24. Updating of Permissions is described in Section 4.7.5 and Section 4.8.

4.7.1.2 Search for All Profiles Controlled by a Specific Controller

Alternatively, to access all Profiles to which a specific Account Controller was added, search for the Profile of the Controller as described in Section 4.3.1.

On the Profile Details screen of the Controller’s Profile, note the owner Profiles listed within the Controlled Accounts box.

Click the OCR Profile ID for each Owner to select the Profiles to be edited in turn.

See example in Figure 58, where the Controlled Accounts box for Russell V. Warren’s Profile shows that Russell V. Warren is the Controller for accounts for two Owners, Jeffrey Walker and Health Fund, Inc. The Profiles for both Owners can be accessed for editing within the Controlled Accounts box for Russell V. Warren’s Profile.



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Figure 58

Follow the steps set forth below to edit your Profiles after accessing the Profile Details screen for each Profile.

NOTE: If an individual is the Controller for a large number of owner Profiles and the Profiles need to be updated for any reason, it may be convenient to access the owner Profiles



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together as a group through the Controller’s Profile rather than by performing separate searches for each owner Profile.

4.7.2 Edit Legal Entity and Main Contact Information in a Profile

If the Profile is for a Legal Entity, edit the Legal Entity Information and the Main Contact Information as follows:

To access the Edit Profile screen, click on the Edit button in the Legal Entity Information section of the Profile Details screen shown in Figure 55.

From the Edit Profile screen that appears, enter new or corrected information in the editable fields. See Figure 59.

To change the Main Contact Information, the Choose Existing button, or the Create New button and follow the procedure set forth in Section 4.3.2.1.2 to establish a new Main Contact.

NOTE: If the Main Contact has not changed but certain information in the Profile of the Main Contact needs to be corrected or updated, return to the Profile Details screen and access the Main Contact’s Profile by clicking on the OCR Profile ID number shown in the Profile Details screen. See Figure 55. Perform the steps described Section 4.7.3 to update the information in the Natural Person Profile of the Main Contact.



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Figure 59

Save your changes by clicking on the Save button shown in Figure 59.

4.7.3 Edit Natural Person and Employer Information in a Profile

If the Profile that requires updating is for a Natural Person, edit the Natural Person Information and the Employer Information as follows from the Profile Details screen:

To access the Edit Profile screen, click on the Edit button in the Natural Person Information section of the Profile Details screen shown in Figure 60.



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Figure 60

From the Edit Profile screen that appears, enter new or corrected information in the editable fields. See Figure 61.



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To change the Employer Information, use the None button, the Choose Existing button, or the Create New button and follow the procedure set forth in Section 4.3.2.1.2 to establish a new Main Contact that will represent the Employer.

NOTE: If the Employer has not changed but certain information in the Profile of the Employer needs to be corrected or updated, return to the Profile Details screen and access the Employer’s Profile by clicking on the OCR Profile ID number shown in the Profile Details screen. See Figure 60. Perform the steps described Section 4.7.2 to update the information in the Legal Entity Profile of the Employer.

NOTE: If you edit the Profile of an Employer that is a Legal Entity, you will be asked to provide a Main Contact for the Employer, if a Main Contact was not previously identified. The Main Contact will inherit the Permissions of the Employer in accordance with Automatic Permission Inheritance rules described at Appendix C .

Figure 61

Save your changes by clicking on the Save button shown in Figure 61.



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4.7.4 Edit Account Controller Information in a Profile

Account Controller information is updated from the Account Controller section of the Profile Details screens shown in Figure 58 and Figure 60.

To update Account Controller information, perform the following steps:

o If you wish to remove an Account Controller, click on the X at the right of the line containing the Controller that will be removed. See Figure 62.

NOTE: Permissions that were established for a Controller do not update automatically when the Controller is removed from an owner Profile. After you have removed an Account Controller, be sure to remove any permissioning within the Controller’s Profile that no longer applies. See Section 4.7.5.

o If you wish to edit the Relationship to Owner field for a Controller, click on the Edit icon to the left of X. See Figure 62.

Enter the new Relationship to Owner data. See Figure 63.

Click on the Save button to save your changes. See Figure 63.

Figure 62

Figure 63

o To add a new Account Controller with an existing Profile, click on the Add button and follow the steps described in Section 4.6.1.

o To add a new Account Controller for whom a Profile has not yet been created, click on the Create New Profile button and follow the steps described in Section 4.6.2.

To save the Account Controller you have added and make no further additions, click on the Save button shown in the Account Controller section of the Change Profile screen shown Figure 63.



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4.7.5 Edit Permissions within in a Profile

Permissions assigned to a Profile are changed from the Profiles Permissions section of the Profile Details screen shown Figure 58 and Figure 60. Perform the following steps:

Click on the Edit button within the Profiles Permissions section. See Figure 64.

Figure 64

When you click on the Edit button, the Edit Profile Permissions pop-up screen shown in Figure 65 will appear showing the current Permissions.

Place check marks in additional checkboxes to add permissions for additional Reporting Firms to access and use the Profile.

Remove any current check marks for permissions that are being removed.

If needed, click on Uncheck All button to clear all check marks from the Profile Permissions section of the form.

Figure 65

After all changes have been made, click on the Save button at the bottom of the Edit Profile Permissions pop-up screen to save your changes to the permissions.



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After you click on the Save button, any Permissions that you added to a Profile are saved automatically not only for that Profile but for any Profile that is Secondary to it. See Appendix B , Automatic Permission Inheritance. Therefore, if the Profile that you are updating is for an Owner or Controller, any new Permissions will also be applied automatically to their Main Contacts or Employers. The latter Profiles do not need to be updated separately.

In contrast, if your change removed Permissions from a Profile, clicking on the Save button revokes the Permissions only from that Profile.

If you have removed one or more Permissions from a Profile, be sure to also update any other Profiles related to it that should also have the Permission or Permissions removed.

NOTE: If you have updated an Owner’s Profile with Permission changes, regardless of whether the changes are addition of new Permissions or removal of Permissions, be sure to also update the Permissions for the Owner’s Controllers, if needed. New permissioning and revocation of Permissions do not cascade from Owners to Controllers and must be updated separately in the Controller’s Profile. See Appendix C .

If you need to edit Permissions for a large number of Profiles, you may enter your changes in a grid format that supports editing multiple Profiles within a single display. See Section 4.8 below for details.

4.8 Manage Reporting Firm Access to Multiple Profiles

Permissions for a single Profile may be adjusted within the Profile to ensure that the information in the Profile is available to the Reporting Firms that require it, as described above in Section 4.7.5. In the event that your firm no longer works with a permissioned Reporting Firm and needs to remove permissioning from a large number of Profiles, or assign Permissions to a new Reporting Firm for a large number of Profiles, the OCR Portal also enables you to review and manage your Permissions within a grid format and make changes to Permissions for multiple Profiles at the same time.

Features enabling you to edit Permissions for multiple Profiles are available from the Manage Permissions selection within the Profiles drop-down list shown in Figure 66 and are described in this section.

To update multiple Profiles within a grid format, click on Permissions within the Profiles drop-down menu or in the Profiles icon, as shown Figure 66.



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Figure 66

After you click on Manage Profiles, you will be brought to the Profile Permission Management screen and a search form shown in Figure 67. This search form enables you to search for a specific Profile (Search by Profiles) or view all Profiles permissioned to a specific Reporting Firm (“… filter by Participants”).

To search by Profile, enter any part of the Profile name.

To filter by Participants, use the drop-down list shown in Figure 67 to limit the number of columns that will display in the grid. In Figure 67, two Participants have been selected, International Bank, Ltd (INTL) and Norwelton Securities (NORS), so only those two Participants will be displayed.

If you select a Participant from the drop-down list in error, remove it by clicking on the x next to its Participant Code within the search box. See Figure 67.

Figure 67

Click the Search button to obtain a display of the results of your search. See Figure 67.

When your search results appear, rows will list the Profiles that you own and columns will list each Participant with blue check marks where Permission has already been granted. See Figure 68, where an empty search generated a complete list of Profiles create by Russell Warren with scrollable



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columns for more than 30 Participant organizations. The blue check marks indicate Permissions that Russell Warren has already assigned.

Figure 68

NOTE: For easiest use of the Manage Permissions function and to limit horizontal scrolling, filter your search to display only the Reporting Firms whose Permissions you wish to edit. The filter by Participants box expands to enable you to enter multiple rows of Participants. See 69, where filtering will limit the search results to 10 Participants with their Permissions displayed in 10 vertical columns. Without filtering, your search results are likely to display numerous columns not relevant to your task.

Figure 69

Within Figure 70, filtering has limited the display to only two Participant organizations with Permissions that Russell Warren will be editing: International Bank, Ltd and Norwelton Securities. See Figure 70.



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Figure 70

NOTE: Within your search results, the same Profile may appear on multiple rows to reflect its relationships as Main Contact, Employer, or Account Controller in other Profiles. Granting Permission for a Profile in makes one row causes check marks to appear in all rows that the Profile occupies. See Figure 70.

4.8.1 Add Permissions to Multiple Profiles

To add a Permission to multiple Profiles at the same time, perform the following steps:

For each row containing a Profile to which you are going to add a Permission, place a check mark in the checkbox within the column of the Reporting Firm that you are permissioning.

When you grant a Permission to a Profile, the Permission inherits automatically to any Employers or Main Contacts of that Profile. See Appendix C , Automatic Permission Inheritance. In the example shown in Figure 71, Russell Warren has added Permission for Norwelton Securities to use Jeffrey Walker’s Profile. At the same time blue check marks also appeared automatically for the Profile for Jeffrey Walker’s employer, Jeffrey Walker Enterprises, which is in a Primary-Secondary relationship with the Profile of Jeffrey Walker.

NOTE: As described in Appendix C , Automatic Permission Inheritance applies only within Primary-Secondary Profile Relationships. The example in Figure 71 demonstrates that when Jeffrey Walker’s Employer, Jeffrey Walker Enterprises, inherited a Permission, the Main Contact of his Employer, Caroline Feldman, did not. Caroline Feldman’s Profile is not in a Primary-Secondary Relationship with the Profile of Jeffrey Walker.

If Automatic Permission Inheritance did not apply and you also wish to make the Profile of an Employer’s Main Contact or a Main Contact’s third party Employer available to a Reporting Firm, place an additional blue check mark in the appropriate checkbox.



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Figure 71

NOTE: Owners and Controllers are never in a Primary-Secondary relationship and Automatic Permission Inheritance does not apply to Controllers. See Appendix C . An example is shown in Figure 71, where the three Controllers directing trading for Jeffrey Walker did not automatically inherit the new Norwelton Securities permissioning. Especially if an Owner works with multiple Controllers, certain Controllers may direct trades with different Reporting Firms on the Owner’s behalf. Therefore, for each Controller who directs trading for an Owner, Permissions granted to the Reporting Firms must be independently established.

NOTE: If an Owner directs its own trading and functions as its own Controller, the Owner and Controller share one Profile and Permission to use the Profile is granted once for both. This is unique case when Permissions for a Controller do not need to be independently established and do “inherit” automatically from the Owner.

If you have added Permissions to an Owner, verify which Controllers require the same new Permissions, and place check marks to permission the Controllers accordingly.

In the event that an Owner works with only one Controller, be sure to add the Owner’s new Permission to that Controller.

For the example shown in Figure 72, Russell Warren has established a Permission for Norwelton Securities to use Eleanora Ericson’s controller Profile for reporting. Automatic Permission Inheritance applied and her employer, Great Lakes National Insurance Trust, was also granted the same Permission. Russell Warren is also a Controller for Jeffrey Walker, but he does not work with Norwelton Securities. Norwelton Securities does not need access to Russell Warren’s Profile and his Profile is not being permissioned to Norwelton Securities. See Figure 72.



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Figure 72

After you have finished placing check marks for Permissions you are adding, click the Save button to update the new Permissions to your Profiles. See Figure 72.

After you click on the Save button, you will be asked to confirm your changes within a Permission Change Summary screen as shown in Figure 73, where two Permission changes are being made.

Figure 73

If the changes shown are not what you intended, you may cancel your changes and return to the Profile Permission Management grid and correct the changes by clicking on Cancel. See Figure 73.

If the changes are correct, click the Save button again to save the Permissions you are granting. See Figure 73.



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Once you have saved your changes on the Permission Change Summary screen, you will be returned to the Profile Permission Management screen and see a confirmation message that your Permission changes were successfully saved. See Figure 74.

Figure 74

4.8.2 Revoke Permissions from Multiple Profiles

Permissions may be removed from multiple Profiles at the same time from the Profile Permission Management screen. To do so, perform the following steps:

For each row containing a Profile with a Permission to a Reporting Firm that you need to revoke, remove the check mark in the checkbox within the column of that Reporting Firm. See Figure 75, where Permission to Norwelton Securities to use Jeffrey Walker’s Profile for compliance reporting was removed.

NOTE: Removing a Permission from the Profile of the Owner does not remove the Permission from a Main Contact, Employer, or any Account Controllers. Therefore, as Figure 75 demonstrates, when the Norwelton Securities Permission was removed from Jeffrey Walker’s Profile, it was not automatically removed from Jeffrey Walker Enterprises, his employer, or from the Controllers who direct his trades.



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Figure 75

If Permissions need to be removed from a Main Contact, Employer, or any Account Controllers, remove check marks as needed from the appropriate checkboxes.

WARNING: Use caution when removing Permissions from Profiles of Employers and Main Contacts. If Permissions from Profiles of Employers and Main Contacts are removed within the Profile Permission Management grid, the same Permissions are also removed from any Profiles to which they are Secondary within a Primary-Secondary relationship. See the discussion of Primary-Secondary Profile Relationships at Appendix B , Rule 1. See also the example shown in Figure 76, where removing the Norwelton Securities Permission for Great Lakes National Insurance Trust, Eleanor Erickson’s Employer, automatically removes the same Permission from her Profile and also from the Profile of Russell Warren, another employee of the firm.



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Figure 76

After removing Permissions for Main Contacts or Employers, review all instances where check marks were removed as a result of your changes to ensure no Permissions have been unintentionally revoked.

After you have finished removing check marks for Permissions you are revoking, click the Save button to update the removed Permissions. See Figure 75.

After you click on the Save button, you will be asked to confirm your changes within a Permission Change Summary screen as shown in Figure 77, where two Permissions are being revoked.



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Figure 77

If the changes shown are not what you intended, cancel your changes and return to the Profile Permission Management grid and correct the changes by clicking on Cancel. See Figure 77.

If the changes are correct, click the Save button again to save the Permissions you are granting. See Figure 77.

Once you have saved your changes on the Permission Change Summary screen, you will be returned to the Profile Permission Management screen and see a confirmation message that your Permission changes were successfully saved. See Figure 78.

Figure 78



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4.9 Delete a Profile

A Profile may be deleted from the Profile Details screens shown in Figure 79 using the Delete Profile function.

To delete a Profile, click on the Delete Profile text button.

Figure 79

A Confirm Delete pop-up message will appear and verify your intent to delete the Profile. See Figure 80.

Figure 80

Click Yes, Delete to delete the Profile and No, Cancel to back out of the deletion.



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After you click on Yes, Delete, you will be directed to the Search Profile screen and a message will appear confirming your deletion. See Figure 81.

Figure 81

CAUTION: If the Reporting Firm has already established an Account related to the Profile in question and attached your Profile to the Account, you will receive an error message when you attempt to delete the Profile. Request that the Reporting Firm remove its Profile Association before you perform the deletion.

NOTE: In the event that a Profile was deleted in error, a new Profile can be created and a new OCR Profile ID will be assigned.

4.10 Return to the FIA Tech User Hub

The My Apps drop-down menu in the top right of every FIA Tech OCR Data Service screen provides an option to return to the FIA Tech User Hub. See example in Figure 82.

To return to the FIA Tech User Hub, click UserHub from within the drop-down list.

Figure 82

After clicking on UserHub, you will be directed to the Welcome screen shown in Figure 1.



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Chapter 5 OCR Data Service for Firms Acting as Third Party Controllers

This section describes initial access to the OCR Data Service by firms acting as Third Party Controllers and use of the OCR Portal for creation of the firm’s Profile and identification of its Controllers for use by Reporting Firms. Specific topics are as follows:

Terms & Conditions

Creation of Profile for the Firm

Assignment of Permissions to Reporting Firms

Identification of the Firm’s Personnel who Direct Trading

Maintenance of the Firm’s Profile and Controller information

These topics are addressed in the following sections.

See Appendix B for details about how data from Third Party Controller Profiles is integrated with data from other Profiles when accounts are reported by the Reporting Firms.

5.1 Accept Terms and Conditions

Firms acting as Third Party Controller, like other registered users who log in to the OCR Data Service for the first time as described in Section 3.6, are prompted to review and accept Terms & Conditions for the OCR Application (“Terms & Conditions”) for use of the Service prior to accessing the system.


If you wish to obtain a copy of the Terms & Conditions for your records, click on the link to the agreement on the FIA Tech website at fia-tech.com/OCR/ to do so.

NOTE: If at any time the Terms & Conditions are revised you will be asked to review and agree to the new Terms & Conditions at your next login.

After accepting the Terms & Conditions, you will be directed to a Dashboard screen that welcomes you to ownership and control reporting. See Section 5.2 and Figure 83 below.

5.2 OCR Dashboard for Firms Acting as Third Party Controllers

The OCR Dashboard provides access to functions performed by firms acting as Third Party Controllers related to establishment and maintenance of the firm’s Profile within the FIA Tech OCR Data Service. Access to these functions is via the Profile tab or Profiles icon shown below in Figure 83.

In addition, the Dashboard has been constructed to provide for notifications of issues related to Profiles that may require attention or of the need to update Profiles as required on an annual basis.

NOTE: At this time, the notification feature for firms acting as Third Party Controllers has not been implemented. This USER GUIDE will be updated to provide more information about notices relevant to firms acting as Third Party Controllers in a future release.


http://fia-tech.com/OCR/


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Figure 83

For firms acting as Third Party Controllers, the default icon on the Dashboard screen is Profiles, as shown in Figure 83, which is used to access Search and Create functions.


GUIDE:




5.3 Create a Legal Entity Profile for Your Firm

To create a Legal Entity Profile for your firm, you will need to access the Create a new Profile screen.

To access the Create a new Profile screen, click on Create within the Profiles menu or the Profiles icon, as shown in Figure 84.



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Figure 84

On the Create a New Profile screen, click on the Legal Entity button to access the format used to create Profiles for Legal Entities. See Figure 85.

NOTE: After you click on the Legal Entity button, specific fields to be completed will appear in the remaining parts of the form. See Figure 86.

Figure 85



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Figure 86



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5.3.1 Enter Your Firm’s Legal Entity Information

Information about your firm must be entered in the fields listed below and as shown in the upper box in Figure 86. The fields are as follows:

Legal Entity Name


Legal Entity ID (LEI) – 20 character alphanumeric ending in two digits


Website

NFA ID (if known)

Email


Street

Suite

City

State or Province

Postal Code

Country

3rd Party Controller – checkbox (check mark is required)

An example is shown in Figure 87, where Samantha Foster entered the required information for her firm, Ocean Bay Commodity Advisors, and placed a check mark in the 3rd Party Controller checkbox.

Figure 87

NOTE: If you choose to supply your firm’s Legal Entity Identifier (LEI) in the Legal Entity ID field and put a check in the Supplied by LEI checkbox, certain information from the LEI record will be accessed and incorporated into your firm’s Legal Entity Information. Because



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information is accessed from the LEI record, the following fields within the Profile do not need to be completed if the Supplied by LEI checkbox is checked: Street, City, State or Province, Postal Code, and Country.

NOTE: When you place a check mark in the 3rd Party Controller checkbox, you will immediately see a pop-up 3rd Party Controller warning box alerting you that your check mark will cause the Profile for your firm to be visible to other users. See warning message in Figure 88.

Figure 88

When the 3rd Party Controller warning box appears, click Yes, Continue. Because your firm is acting as a Third Party Controller for Owners whose Profiles were created by other firms, certain information within your firm’s Profile must be visible to those firms, who are Client users of the system.

NOTE: The portion of your Profile that will be available to all Client users of the system is specifically the Legal Entity Information shown in Figure 87. Information that you will maintain in other parts of the Profile will be available only to specific Reporting Firms that you designate. See below at Section 5.4.

5.3.2 Enter Your Firm’s Main Contact Information

After the Legal Entity Information for your firm has been entered, the Main Contact Information section of the form should be completed. The information in this section is stored by the system in a separate Profile that will be visible only to the Reporting Firms permitted by you to view and use your Main Contact information. Main Contact information for your firm is required.

To enter information about your Main Contact, click on the Create New button in the Main Contact Information box shown as the lower marked box in Figure 86.

After you click on the Create New button, a form will open showing the fields in which your information should be entered. See Figure 89.

The following fields are included:

First Name

Middle Name

Last Name

Name Suffix



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Website

NFA ID (if known)

Email


Street

Suite

City

State or Province

Postal Code

Country

Employed by this Legal Entity - checkbox

Relationship to the Legal Entity

Title or Position at Legal Entity

Figure 89

NOTE: By default, the Main Contact is identified as an employee of the Legal Entity. This employee status can be changed if needed by unchecking the Employed by this Legal




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Entity checkbox and removing the word Employee from the Relationship to Legal Entity box. See Figure 89.

Enter the information about your Main Contact as required.

Depending on how you entered the Legal Entity Information for your firm, certain variations may affect your entry of Main Contact information. These variations are discussed below in Section 5.3.2.1 and Section 5.3.2.2.

5.3.2.1 Review and Edit Auto Filled Fields, if Needed

In the Main Contact Information section, certain fields may be auto filled based on the Legal Entity information already entered. See Figure 90.

If any auto filled information is incorrect or inapplicable to the Main Contact, correct the auto filled fields as needed.



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Figure 90

Enter the remaining information required in the Main Contact Information section shown in Figure 89 using the formats and drop-down selections provided.


5.3.2.2 Include Your Firm’s LEI and Mark the “Supplied by LEI” Checkbox

If you identified your firm’s LEI in the Legal Entity Information section of the Profile and you checked the Supplied by LEI checkbox, address information is not auto filled in the Main Contact Information when the Main Contact is entered.



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Instead, when the Profile for the Main Contact is created, the same LEI that was entered in the Profile of the Legal Entity may also be entered within the Main Contact Information and the Supplied by LEI box may be checked again. See Figure 91.

NOTE: If the Supplied by LEI box is checked in the Main Contact Information section, the following fields for the Main Contact may be left blank: Street, City, State or Province, Postal Code, and Country.

To have address fields in the Profile of the Main Contact pulled from the Legal Entity’s LEI, enter or copy and paste the LEI number that was entered in the Legal Entity Information section into the Legal Entity ID (LEI) field of the Main Contact Information.

Figure 91 shows an example of a Profile for Fox Creek Gas and Electric Utility, Inc. that was created with the Supplied by LEI box checked for both the Legal Entity and the Main Contact.

NOTE: Even when the Supplied by LEI box is checked, the Phone and Email fields must be filled in for the Legal Entity and the Main Contact. See Figure 91.



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Figure 91

5.4 Assign Permissions to Your Firm’s Profile

Having placed a check mark in the 3rd Party Controller checkbox as described in Section 5.3.1, you have made your firm’s Legal Entity Information in its Profile available to Client users of the OCR Data Service. Client users establish Profiles of Owners and designate Controllers who are the individuals or organizations that direct the trading for each Owner. To the extent that your firm serves as a Controller with respect to any of their Owners, Client users will add your firm’s Profile to the Profile of the Owner to indicate that your firm’s Controller role.

Reporting Firms, in contrast, must report specific controller information to the CFTC in accordance with the Final Rule and therefore require access to additional specific information about your firm, including identification of individuals such as your firm’s Main Contact. By assigning Permission to a specific Reporting Firm that executes your trades, you authorize the Reporting Firm to view and use your Profile, in its entirety, to the purpose of performing the reporting required.



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Those Reporting Firms that you have designated as permitted to see and use your firm’s Profile are able to view their own permitted status but do not see the permitted status of any other firm. All of the Reporting Firms that execute trades directed by your firm should be permitted to see your Profile.

Permission to view and use your firm’s Profile for reporting purposes is granted to Reporting Firms in the lower part of the Create a New Profile screen shown in Figure 86.

In the example of entered permissions shown in Figure 92, four Reporting Firm firms have been permitted to use the Profile for their ownership and control report.

Check the appropriate checkboxes to assign Permission to Reporting Firms listed to use your firm’s Profile for their ownership and control reporting.

If needed, click on Uncheck All button to clear all check marks from the Profile Permissions section of the form. See Figure 92.

Figure 92

When you add Permissions to your Profile, the same Permissions will automatically inherit to your firm’s Main Contact. See Appendix B for further information about Automatic Permission Inheritance.

5.5 Save Your Firm’s Profile

Save your firm’s Profile by following the steps described at Section 4.5, resolving any warning flags or error flags as needed.

After you click on the Create Profile button to save your firm’s Profile, a pop-up box shown in Figure 93 will appear.



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Figure 93

In the pop-up box, click No.

You will be directed to a new screen showing your firm’s information, confirming that the Profile was created successfully, and including a new Account Controllers section. See Figure 94.

Figure 94



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The next section provides details on how to use the Account Controller box (See Figure 94) to maintain information needed for reporting about the personnel in your firm who direct trading on behalf of your firm’s clients.

5.6 Enter Information about Your Firm’s Personnel Who Direct Trading

Personnel in your firm who direct trading on behalf of your firm’s clients should be included in your firm’s Profile within the Account Controllers box. See Figure 94.

Each person is added one by one using the Add button. See Figure 94.

Click on the Add button to identify any one of your personnel as an Account Controller.

After you click on the Add button, two options will appear, Select Profile and Create new Profile. See Figure 95.

Click on the Create new Profile button to create a Profile for each individual that will be included within the firm’s Profile. See Figure 96.

Figure 95

After you click on the Create new Profile button, you will be directed to the Create a new Profile screen shown in Figure 85.

Click on the Natural Person button to access the format that you will use to enter information about an individual. See Figure 96.

NOTE: Profiles of individuals are created in the format called Natural Person. Profiles of organizations, corporations, and other legal entities are created using the Legal Entity format.

Within the Natural Person format, information is organized in two sections, Natural Person Information and Employer Information, as shown in Figure 96. Each section is addressed below in turn.



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Figure 96



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5.6.1 Enter Natural Person Information

Information about individuals who acts as Account Controllers within your firm is entered as shown in the Natural Person Information box shown above in Figure 96.

The fields are as follows:

First Name

Middle Name

Last Name

Name Suffix

Profile Name (auto generates)



Website

NFA ID (if known)

Email


Street

Suite

City

State or Province

Postal Code

Country

Enter the information indicated in the Natural Person Information section in Figure 96 using the formats and drop-down selections provided.


5.6.2 Enter Employer Information

Within the Employer Information section of the Natural Person Profile format, employer information can be entered or accessed from an existing Legal Entity Profile. See the Employer Information section marked by the lower box in Figure 96, which contains four buttons:

None

Self Employed

Choose Existing

Create New

To the extent that you have already created a Legal Entity Profile for your firm and the individuals who will be identified as Controllers are its employees, you may use the Choose Existing button to reference your firm’s Profile to as employer of each Controller. To do so, perform the following steps:

Click on the Choose Existing button.




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After you click on the Choose Existing button, a Search Profiles screen will appear.

If your firm’s Profile is displayed among the default search results on the Search Profiles screen, click on the line containing the Profile to highlight the line.

If you do not see your firm’s Profile displayed among the default search results on the Search Profiles screen, enter your firm’s name in the search box.

o Click on Search button.

o When your firm’s Profile appears in the search results, click on the line containing the Profile to highlight the line.

Click on the Select button to select your firm’s Profile and cause it to appear in the Employer Information box. See Figure 97, where Ocean Bay Commodity Advisors was selected to identify the Controller’s employer.

Enter the Relationship to Employer and the Title or Position at the Employer. See Figure 97.

Figure 97

5.6.3 Review Permissions

In the lower part of the Create Profile screen for each of your firm’s employees who act as Controllers, Permissions are supplied by default based on your firm’s Permissions. These supplied Permissions ensure that Reporting Firms that can view your firm’s Profile will also have access to the Profiles of the individuals who direct trading. For their reporting, the Reporting Firms require certain information the controller Profiles together with the information they obtain from your firm’s Profile.

Verify the Permissions that were supplied by default for each individual who directs trading on behalf of one or more of your firm’s clients. Each Permission that the individual’s Profile, as an Account Controller, will inherit from the firm’s Profile is labeled Please review!. See Figure 98.

Remove any check marks for Reporting Firms marked Please review! in the Profile Permissions box if the specific Account Controller does not actually work with the Reporting Firm.

NOTE: Removing a check mark from a selection labeled Please review! does not impact your firm’s Permissions. The Profile of your firm will remain visible based on the Permissions that you assigned to it.



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Figure 98

In the event that you need to add additional Permissions to a Controller Profile, place a check mark in the checkbox next to the name of each additional Reporting Firm that will be added.

NOTE: If you add Permissions to any of your Controllers, your firm’s Profile will automatically inherit the new Permissions. However, the Main Contact for your firm will not inherit the new Permissions. The Profile of the Main Contact will also need to be updated to reflect the additional permissioning. See Section 5.7.5.

Use the Create Profile button shown in Figure 98 to save the Profile for each individual who direct trading by following the steps described at Section 4.5, resolving any warning flags or error flags as needed.

An example of a completed Profile for an individual (“Natural Person”) serving as an Account Controller for a Third Party Controller firm is shown in Figure 99. Rodney Hudaker is represented as an employee acting as a Financial Advisor to clients of Ocean Bay Commodity Advisors; his Profile is available to International Bank Ltd and Norwelton Securities for reporting purposes.



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Figure 99

The completed Profile for the Third Party Controller firm Ocean Bay Commodity Advisors, Rodney Hudaker’s employer, is shown in Figure 99. Rodney Hudaker is identified as one of the firm’s Account Controllers, along with Merylin Carasa and Reina Salas.

The Permissions for Ocean Bay Commodity Advisors are the same as those that were set for Rodney Hudaker. See Figure 99.



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Figure 100

5.7 Maintain Your Firm’s Profile Information

Information in Profiles that you created is used with your permission by specific Reporting Firms and incorporated into their reporting to the CFTC. Accuracy of the regulatory reporting relies on the correctness of information in your Profiles as initially entered and maintained.

In the event that information in your Profiles was incorrectly entered or has recently changed, you should update the Profile as needed to ensure its correctness.

In addition, if you added Permissions to a Controller that were not previously established for the firm, the Profile for you firm’s Main Contact also needs to be updated to include the additional Permissions. See Section 5.6.3.




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In general, you should review your firm’s Profile at least once each year, as well as the Profiles of your firm’s Main Contact and Account Controllers, to ensure that their information is always up to date.

To update information in your Profiles, you will need to access the Profile Details screen for each Profile. Within the Profile Details screen, the following specific information can be edited:

Legal Entity Information and Main Contact Information (in your firm’s Profile)

Natural Person Information and or Employer Information (in Profiles that you created for individuals serving as Account Controllers)

Account Controllers (add or remove)

Permissions (add or remove)

NOTE: The Profile Managers within a Profile cannot be edited. You as the individual who created a Profile are the Profile Manager and the only person who can edit the Profile.

Steps required to perform these updates are discussed in this section.

5.7.1 Locate the Profile or Profiles to Review and Update

To locate a Profile that requires updating, from your Dashboard screen, click on Search in the drop-down menu or Profiles icon. See Figure 101.

Figure 101

After you click on Search, a Search Profiles screen will appear, as shown in See Figure 102.

To limit your search results to include only your firm’s Profiles that you created, select owned by me from the Show Profiles drop-down list. See Figure 102.

NOTE: If you wish, you may also view Legal Entity Profiles created by other firms acting as Third Party Controllers by choosing visible to me. Legal Entity Profiles created by Third Party Controllers, including your firm’s Profile, are always visible to all users.



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Enter your firm’s name or the last name of the employee whose Profile you need to edit. See Figure 102, where the Profile of an Account Controller, Rodney Hudaker will be recovered using a search for “Hudaker.”

Figure 102

Click Search.

After you click Search, your search results will be displayed as shown in Figure 103.

Figure 103

Click on the OCR Profile ID hyperlink in the row containing the Profile to access the Profile Details screen, from which you can edit the details in the Profile.

5.7.2 Edit Your Firm’s Profile Information

In the event that Legal Entity or Main Contact information for your firm has changed or requires updating, access your firm’s Profile as described in Section 5.7.1.

Click on your firm’s OCR Profile ID number to access the firms Profile as shown in Figure 103.

Update your firm’s Legal Entity and Main Contact information by following the steps described in Section 4.7.2.

5.7.3 Edit Information in Your Firm’s Main Contact and Account Controller Profiles

In the event that Natural Person information of your firm’s employees has changed or requires updating, access the relevant Profiles to be updated as described in Section 5.7.1.

Click on the OCR Profile ID number of the Profile to be reviewed and edited as shown in Figure 103.

Update the Natural Person Information as needed following the steps described in Section 4.7.3.

5.7.4 Remove and Replace an Account Controller

In the event that an individual serving as an Account Controller for your firm leaves the firm and is replaced, the Account Controller who left should be removed from your firm’s Profile and his or her



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Natural Person Profile should be deleted from the system. In addition, your firm’s Profile should be updated to reflect any new individuals serving in the Account Controller role.

These tasks are performed as follows:

To update the controller information in your firm’s Profile, access the Profile as described in Section 5.7.1.

When your firm’s Profile Details screen appears, refer to the Account Controllers box shown in Figure 94.

To remove the previous Account Controller, click on the X at the right of the line containing the name of the Controller that will be removed. See Figure 104.

Figure 104

You will be prompted to confirm whether you wish to remove the Account Controller. See Figure 105.

Click on the Yes, Remove button.

Figure 105

You will be shown a confirmation message stating that the Account Controller was deleted successfully. See Figure 106.



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Figure 106

NOTE: After removing the Account Controller from the firm’s Profile, be sure to review the firm’s Permissions and the Permissions of its Main Contact. You should remove any Permissions that are no longer required and may have been assigned only in relation to the Controller who was removed. See Section 5.7.5 for more information about updating Permissions.

To add a new Account Controller, refer to the Profile Details screen shown in Figure 106 and follow the steps described in Section 5.6 for adding a Controller within the Account Controllers box.



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5.7.5 Edit Permissions within in a Profile

Permissions assigned to a Profile are changed from the Profiles Permissions section of the Profile Details screen shown in Figure 106.

To do so, the following steps should be performed:

Click on the Edit button within the Profiles Permissions section. See Figure 107.

Figure 107

When you click on the Edit button, the Edit Profile Permissions pop-up screen shown in Figure 108 will appear showing the current Permissions.

Place check marks in additional checkboxes to add permissions for additional Reporting Firms to access and use the Profile.

Remove any current check marks for permissions that are being removed.

If needed, click on Uncheck All button to clear all check marks from the Profile Permissions section of the form.



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Figure 108

After all changes have been made, click on the Save button at the bottom of the Edit Profile Permissions pop-up screen to save your changes to the permissions.

After you click on the Save button, any Permissions that you added to a Profile are saved automatically not only for that Profile but for any Profile that is Secondary to it. See Appendix C , Automatic Permission Inheritance. Therefore, if the Profile that you are updating is your firm's Profile, any new Permissions will be applied automatically to your firm's Main Contact. Your firm's Main Contact does not need to be updated separately.

In contrast, if your change removed Permissions from your firm's Profile, clicking on the Save button revokes the Permissions only from that Profile. You must also remove the Permission from your firm's Main Contact.

If you have removed one or more Permissions from a Profile, be sure to also update any other Profiles related to it that should also have the Permission or Permissions removed.

NOTE: If you have updated your firm’s Legal Entity Profile with Permission changes, regardless of whether the changes are addition of new Permissions or removal of Permissions, be sure to also update the Permissions for your firm's personnel who function as Account Controllers, if needed. New permissioning and revocation of Permissions do not cascade from Third Party Controllers to their employees who are listed in the Account Controllers box. See Appendix C .



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5.7.6 Delete a Profile

To delete a Profile that is no longer needed, refer to Section 4.9 and follow the indicated steps.



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Chapter 6 OCR Data Service for Reporting Firm Users Reporting Firm Users create Accounts within the OCR Data Service system that are used for reporting of ownership and control information to the CFTC and contain specific information required for Form 102A, Form 102B, and Form 102S reports. Profiles identifying Owners and Controllers are associated to the Accounts and convey the specific owner and controller information that is reported.

Actions performed by Reporting Firm Users to carry out these functions within the OCR Portal are described in this section. Topics are as follows:

Acceptance of Terms & Conditions

Establishment of Market Roles

Entering of Accounts

Linking of Accounts to Profiles

Searching Profiles

Creation of Profiles by Reporting Firms if needed

6.1 Accept Terms & Conditions as Required

Reporting Firm Users logging in to the FIA Tech OCR Portal for the first time may be prompted to review and accept Terms & Conditions for use of the Service prior to accessing the system.

Accept the Terms & Conditions for use of the system if you are prompted to do so.


NOTE: If at any time the Terms & Conditions are revised, you may be asked to review and agree to the new Terms & Conditions at your next login.

NOTE: In the event that a Master Services Agreement between the Participant organization and FIA Tech has superseded the Terms & Conditions for user access to the FIA Tech OCR Data Service, your initial logon to the Service may bypass the Terms & Conditions.

After accepting the Terms & Conditions as required, you will be directed to the OCR Dashboard with a message welcoming you to the Ownership and Control Reporting as shown below in Figure 109.

The Dashboard screen will be the screen that appears in the future each time you access the system.

6.2 OCR Dashboard for Reporting Firm Users

The OCR Dashboard provides access to functions performed by Reporting Entity Users involving creation and maintenance of Accounts, review of Profiles and Association of Profiles to Accounts, and Management of Market Roles for the Reporting Entity. Access to these functions is as follows and as shown in Figure 109:

The Profiles icon and toolbar button are used to search Profiles created by Clients or, in some cases, by you or your Reporting Firm. It is also used to create a Profile if a Profile was not been created by your Client.

The Accounts icon and toolbar button are used to add Accounts to the system and to search Accounts as needed. After an account is created, Profiles are associated with the Accounts, which allows information from the Profiles to be used for ownership and control reporting by the system.

The Reporting Firms icon and toolbar button are used to identify the markets in which the Reporting Firm trades, which can be modified by each Reporting Firm User.



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Figure 109

Use of the FIA Tech OCR Data Service by Reporting Firm Users to perform these functions is described in the following sections.

In addition, the Dashboard has been constructed to provide for notification to Reporting Firm Users of issues related to their data and their reporting of trades. These notifications are located in the Notifications section of the Dashboard as shown in Figure 109 and are described in detail in Chapter 9.


GUIDE:

o OCR PORTAL QUICK START GUIDE FOR CLIENTS






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NOTE: If you have asked your Clients to enter Profiles in the OCR Data Service, you may wish to provide them a copy of our OCR PORTAL QUICK START GUIDE FOR CLIENTS as they get started.

6.3 Manage Reporting Firm Market Roles

Market Roles established for the Reporting Firm must be entered and maintained by Reporting Firm Users to ensure that the activity of the firm on each market in which it performs trades is correctly reflected.

The actions required to manage Reporting Firm Market Roles are described in this section.

6.3.1 Access Market Roles

To access Reporting Firm Market Roles, click on the Reporting Firms icon in the Dashboard as shown in Figure 109, or click on the Search button just below the Reporting Firms icon.

You will be directed to the Search Reporting Firm screen shown in Figure 110.

Figure 110

Click on the Search button to see a listing of the Reporting Firms whose Market Roles you may enter. See Figure 111.

In the example shown in Figure 111, Reporting Firm User Goh Hui Ling can set Market Roles for two Reporting Firms, International Bank Ltd and Industrial Bank of Greece.

Double click on the name of the Reporting Firm that you intend to edit from the list shown.

Figure 111





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You will be directed to the Reporting Firm Details screen where two sections represent the designations of Market Roles. The first section, Global Roles Applicable to all Markets, indicates the roles that the firm has in all markets in which it operates. The second section, below the first section, is named Specific Roles Applicable to Individual Markets and indicates Market Roles of the firm that are specific to a single market. See Figure 112, where the Market Roles of International Bank Ltd will be edited.

Figure 112

NOTE: You may notice that International Bank Ltd has an OCR Profile ID, as shown in Figure 112. The Reporting Firm’s data contained in its Profile is reported to the CFTC in ownership and control reporting for the firm’s trades and may be edited from this screen by clicking on the firm’s OCR Profile ID. Editing of the Reporting Firm’s Profile is outside the scope of this USER GUIDE and should be discussed with your Reporting Firm Administrator.

Click on the Edit button to review and update Market Roles. See Figure 112.

You will be taken to the Edit Reporting Firm screen, where you can access and make additions and changes to the firm’s Market Roles.



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Figure 113

6.3.2 Establish Global Roles Applicable to All Markets

Global Market Roles shown in the box called Global Roles Applicable to All Markets in Figure 113 designate the firm’s roles that apply to be all markets. When a checkbox is checked in the Global Roles Applicable to All Markets, it indicates that the firm operates in that role in markets. A role checked in Global Roles Applicable to All Markets does not need to be designated individually for specific markets. In the example shown in Figure 113, International Bank Ltd has established FCM as a global role that applies to all markets in which it trades.

NOTE: The Foreign Broker checkbox should be used to designate non-U.S. firms that trade in the U.S. market through their relationship with a Domestic FCM.

To add additional Global Market Roles, place check marks in the boxes provided.

If it is necessary to remove any Global Market Roles, remove check marks that do not properly reflect the firm’s activity in all markets.

NOTE: If you remove all Global Market Roles, be sure to create Market Roles for each individual market in which the Reporting Firm trades as described in Section 6.3.3.

6.3.3 Identify Roles Specific to an Individual Market

In addition to the firm’s Global Market Roles that apply to all markets, Market Roles may also be identified that are specific to an individual market. This is done in the Specific Roles Applicable to Individual Markets box.

To identify roles that apply to a single market, click on the Search Market drop-down list to choose the market for which you will specify roles. See Figure 114.

In the example shown in Figure 114 and Figure 115, a Swap Dealer role will be added for ICE Swap Trade LLC.



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Figure 114

After the market, in this case, ICAP SEF (US) LLC, has been selected, you will be provided an opportunity to designate the role or roles to be added for the market. In Figure 115, the check mark in the Swap Dealer checkbox shows that the International Bank Ltd also operates as a Swap Dealer within ICAP SEF (US) LLC.

NOTE: The Foreign Broker checkbox should be used to designate non-U.S. firms that trade in the U.S. market through their relationship with a Domestic FCM.

NOTE: Any roles for the market that have already been designated as Global Market Roles do not need to be marked with check marks for individual Market Roles. Check marks should be placed in boxes for roles that are specific to the market and are not Global Market Roles.

Place a check mark in the appropriate boxes for Market Roles for the market.

If a market was incorrectly selected or needs to be removed because the firm is no longer trading in the market, use the Remove button shown in Figure 115 to remove the market.



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Figure 115

6.3.4 Save Market Roles

To save your global Market Role designations and any assignments of additional Market Roles that you have made to individual markets, click on the Save button on the Edit Reporting Firm screen. See Figure 115.

Your changes will be saved and you will see a confirmation messages stating that the Reporting Firm updated successfully. See Figure 116.



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Figure 116

6.4 Review the Owner, Controller Profiles that You Will Use for Reporting

The completeness and accuracy of your Reporting Firm's compliance reporting of ownership and control information relies on, among other things, the completeness and accuracy of information contained in the Profiles that you will associate to each of your Accounts. Profiles identify Owners and Controllers and provide specific required information, including information about Main Contacts and Employers, that will be included in your reporting.

Prior to creating Accounts within the system, it is advisable that you review your owner and controller Profiles, including any Profiles that you or others in your firm have created, to ensure their completeness and accuracy. Your review should address the following:

For each account that you will need to report, verify that a Profile for the Owner has been created.

For each Profile that you recognize as an Owner, verify that Profiles for any Controllers have also been created.

Determine whether any Third Party Controllers are directing trading for an Owner.

Review all of your Profiles for completeness:

- Profiles of Legal Entities should include a Main Contact.

- Profiles for Natural Person Controllers should have an Employer.

You may review your Profiles via FIABatch files provided in the Notifications section of the Dashboard or by accessing your Profiles individually within the OCR Portal.

To review Profile information within your FIABatch files, click on the most recent FIABatch export listed in your Dashboard and refer to Section 9.2.3. See also Figure 117. Within the FIABatch file, you will be able to identify Profiles of Owners and the Profiles of the Controllers who direct the trading for those Owners’ accounts.




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To review your Profiles within the OCR Portal, click on the Profiles tab within your Dashboard screen shown in Figure 109 to obtain a drop-down list of clickable options.

Click Search within the drop-down list. See Figure 117.

Figure 117

You will be directed to a Search screen shown in Figure 118.

Click Search to view all of your Profiles.

NOTE: To limit the Profiles you will see to those created by you or others in your firm, use the Show Profiles drop-down list to select owned by me. The default selection, visible to me, returns all Profiles, including those created by your Clients.

Figure 118

To view groups of your Profiles that were created together, you may search using the Profile Manager’s User Name. For example, to search for all Profiles created by Russell Warren, you may search using rwarren as a search term. See Figure 119.



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Figure 119

Finally, to review your Profiles one by one, enter any part of the Owner’s name in your records to identify the Profile that was created by your Client.

For example, in the search shown in Figure 120, the search term "Fund" recovered Health Fund, Inc in the search results. Likewise, the firm Great Lakes National Insurance Trust would be found if a search was done for "Insurance," "Great," "Lakes," "National," or "Trust."

Figure 120

When your search results appear, click on the OCR Profile ID number in the first column to access the Profile Details screen of the Owner’s Profile. See Figure 120.

When the Profile Details screen appears, verify that the Owner Profile:

o Includes Account Controllers. For example, the Profile Details screen for Health Fund, Inc, accessed from Figure 120, lists two Account Controllers, Great Lakes National Insurance Trust and Russell Warren, Inc. See Figure 122.

o Includes a Main Contact, if the Owner is a Legal Entity. For example, in the Profile Details screen for Health Fund, Inc, Marshall Hastings has been designated as the Main Contact. See Figure 122.

If you are unable to locate a Profile for an Owner or if a Controllers and a Main Contract were not properly designated within the Owner’s Profile, contact the Profile Manager using the information at the bottom of the Profile Details screen and request that Profiles be added or updated as needed. See Figure 122.



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Figure 121

In addition to verification of the Owner Profile, certain information in the Controller Profile or Profiles should also be verified, including the Profiles of Third Party Controllers.

To verify controller information, click on the OCR Profile ID number to the left of the Controller’s name. See Figure 122.

After you click on the Controller’s OCR Profile ID number, the Profile Details screen for the Controller will appear. See Figure 122.

If the Controller is a Legal Entity, verify that a Main Contact is identified in the Controller’s Profile. See the Profile Details for Great Lakes National Insurance Trust in Figure 122.



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Figure 122

In addition, if the Controller is a Third Party Controller, verify that individual Account Controllers are listed in the Account Controllers box. See Figure 123.



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Figure 123

If the Controller is a Natural Person, verify that the Controller’s Employer information is included in the Profile. See the Profile Details for Russell Warren’s Profile shown in Figure 124.



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Figure 124

If Main Contact and Employer information is incomplete in the controller Profiles that you will be reporting, or if individual Account Controllers are absent within a Third Party Controller Profile, contact the Profile Managers using the information at the bottom of the Profile Details screens and request that the Profiles be updated. See Figure 122 and Figure 124.



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6.5 Enter Accounts

To ensure that your accounts will be reported via the FIA Tech OCR Data Service and the requirements of the OCR Final Rule will be met, all accounts should be entered in the system following the procedure described below.

NOTE: Once all accounts have been entered, only new accounts will need to be added and existing accounts updated as needed to keep the information current.

Entry of accounts into the OCR Data Service system is performed by Reporting Firm Users.

To create an Account and enter your account information, perform the following steps:

On the Dashboard screen, click on the Add text button within the Accounts toolbar drop-down list or Accounts icon. See Figure 125.

Figure 125



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You will be directed to a Create a new account screen shown in Figure 126 requiring entry of the following fields:

Reporting Firm (the Reporting Firm that will be reporting the information)

Category (Special (102A), Trading, Consolidated (102S))

Account Number

Account Name

Is Omnibus5 (Yes, No)

Class (None, House, Customer) (Omnibus only)

Origin Reason (Special (102A) Accounts only)

Enter the information indicated in the Account Information section of the screen, using the drop-down selections provided. See Figure 126.

NOTE: The Reporting Firms listed in the Reporting Firm drop-down list will be entities within the Participant firm or firms for which you have been established as a Reporting Firm User. When information is reported to the CFTC, the Reporting Firm is identified, not the Participant, based on your selection in the Reporting Firm field.

Click on the Create Account button to create the Account. See Figure 126.

Figure 126

5 Although the drop-down list includes None as a selectable option for the Is Omnibus field, None should not be selected. Insofar as None was a permitted option at one time when certain Accounts were uploaded into the system within FIABatch files, None should be removed manually from such Accounts and Yes or No should be specified. See Section 6.11.1 for details about editing Account information.



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You will be directed to an Account Details screen confirming that the new Account was created. See Figure 127, which shows an Account Details screen for a Trading Account with information required for reporting on Form 102B.

The Account Details screen provides separate sections for use in making associations specific to each Account Category.

For Trading Accounts (102B), the associations are as follows.

Profile Associations to relate owner, controller, and omnibus originator Profiles

Special Account Associations to relate the other accounts controlled by the same Controller

Market Associations indicating the markets on which the account trades

For Special (102A) Accounts, the following associations are required:

Profile Associations to relate owner, controller, and omnibus originator profiles, as well as Profiles of Domestic FCMs

Trading Account Associations to relate the other accounts controlled by the same Controller

For Consolidated (102S) Accounts, these associations are used:

Profile Associations to relate owner, controller, and omnibus originator Profiles

Paired Swaps / Swaptions Details to provide details related to swaps

These associations are addressed in the following sections in turn.



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Figure 127

6.6 Add Profile Associations to Accounts (102A, 102B, and 102S)

Profile Associations are added to the Accounts you have created to ensure that Owners and Controllers are accurately reported to the CFTC the in accordance with the OCR Final Rule. Analogous relationships for Omnibus Accounts are also maintained as Profile Associations.

NOTE: Profiles of Owners and Controllers are created and maintained primarily by Clients, who establish your permission to view the Profiles for accounts that you trade. In addition, certain Profiles are also created by Third Party Controllers, which are Legal Entities with personnel who direct trading on behalf of Client users. Reporting Firm Users may also create Profiles as needed, as described in Section 6.6.4. When Profiles are updated with new information, Accounts to which the Profiles have been associated will automatically reflect the updated information.



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Specific requirements for the association of Profiles related to each Account Category are as follows:

Trading Accounts, which are reported on Form 102B, unless they are omnibus accounts, must include at least one owner Profile and at least one controller Profile. The Controller must be a Natural Person. Trading Accounts may have more than one Controller and may also have Third Party Controllers who is a Natural Person.

Special Accounts, which are reported on Form 102A, that have Controller as their Origin Reason may have one and only one associated Profile as the Controller, which may be the Profile of a Third Party Controller that is a Legal Entity.

Special Accounts that have Owner as their Origin Reason may have one and only one associated Profile as the Owner.

Special Accounts that have Owner & Controller as their Origin Reason may have one and only one associated Profile as the Owner & Controller.

Consolidate Accounts, which are reported on Form 102S, unless they are omnibus accounts, must include at least one owner Profile and at least one controller Profile.

Omnibus Trading Accounts must have one Omnibus Originator Profile.

Special Accounts that have Omnibus Originator as their Origin Reason must have one associated Profile as the Omnibus Originator.

Omnibus Consolidated Accounts must have one associated Omnibus Originator Profile.

Special Accounts of Foreign Brokers, regardless of their Origin Reason, must have at least one associated Profile in the Role of Domestic FCM.

The procedure for adding Profiles of Owners and Controllers to Accounts is described below. Trading Accounts, Special Accounts, and Consolidated Accounts are addressed in turn. The requirements listed above are illustrated in the examples used for each Account Category addressed.

6.6.1 Associate Profiles within Trading Accounts

Guidelines for the Association of Profiles associated with Trading Accounts are shown in warning messages within the Profile Associations box once the Account has been created:

Non-omnibus Trading Accounts should have at least one owner and controller Profile. See Figure 128.

Omnibus Trading Accounts should have one Omnibus Originator Profile. See Figure 129.

Figure 128



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Figure 129

To comply with the warnings and cause them to disappear, click on the Add button. See Figure 128 and Figure 129.

If the Trading Account is not omnibus, from the options Owner, Controller, or Owner & Controller roles within the Role field, begin by selecting Owner. See Figure 130.

NOTE: When making Profile Associations to Trading Accounts, it is preferable to add the Association of the Owner First, as is illustrated here. Association of the Controller’s Profile should be done after the Profile of the Owner has been made. See Section 6.6.1.1 for more information about Association of a controller Profile within a Trading Account.

If the Trading Account is omnibus, select Omnibus Originator, which is the only option within the Role field. See Figure 131.

Figure 130

Figure 131

Click on the Select Profile button to choose the Profile of the Owner or Omnibus Originator for the Trading Account.

A list of available Profiles that are available to your Participant organization will appear, reflecting any applicable limitations applicable to the role. See Figure 132.

Highlight the line containing the Profile to be selected.

NOTE: If the Profile for the Owner or Omnibus Originator that you wish to associate does not appear in the list, you may search for the Profile using the search function described in



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Section 4.3.1.1. If a Profile for the person or entity has not yet been created, you may create a Profile following the procedure described below in Section 6.6.4.

Click on the Select button to associate the Profile with your Trading Account. In Figure 132, Health Fund, Inc is being selected as the Owner’s Profile for a non-omnibus Trading Account.

Figure 132

After you click on the Select button, if the Profile that you selected is a Legal Entity and a Main Contact was not included in the Profile, you will see a pop-up box alerting you that the Profile needs to be updated with Main Contact information. See Figure 133.

Figure 133

If you are associating a Legal Entity Profile that does not include a Main Contact, inform the Profile Manager of the incomplete Profile and request that the required Main Contact information be added.

Click the OK button to associate the incomplete Legal Entity Profile.

After you click on the OK button, or, if the Profile was already complete, you will be returned to the Account Details screen, where the Profile Associations box will display the OCR Profile ID of the Profile that you selected. See Figure 134, where the Health Fund, Inc selection as the Owner of a non-omnibus Trading Account is shown.



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Figure 134

NOTE: When the Profile of the Owner is associated, the Relationship to Owner field remains empty. The Owner does not have a “relationship to Owner.”

Click on the Change Profile button to select a different Profile, if needed.

Click the Save button to save your selection, which will save the Profile that you chose as the Omnibus Originator or Owner of the Trading Account.

6.6.1.1 Associate Controller Profile to Trading Account

Non-omnibus Trading Accounts require association of a Profile in the role of Controller in addition to that of the Owner. To the extent that the Profile of the Owner already designates within it a Natural Person Controller, that Profile is pulled into the Trading Account automatically and is incorporated as the Default Controller.

An example is shown in Figure 135, where Russell V. Warren was the Controller identified in the Profile of the Owner, Health Fund, Inc. Therefore, the Profile of Russell V. Warren has been brought in automatically as the Default Controller for the Trading Account.

NOTE: If the Profile of the Owner designated within it more than one Controller, the Trading Account will reflect multiple Default Controllers.

NOTE: The Default Controller (or Default Controllers) cannot be removed. However, if another Controller is designated, the Default Controllers are overridden and drop out of the Trading Account.

Figure 135

If you wish to accept a Default Controller, no further action is needed. The Default Controller will be reported as the Controller for the Trading Account in reporting to the CFTC.

If you wish to override a Default Controller, or to identify a Controller in the event that a Default Controller was not associated, click on the Add button.

Select a different Profile to associate with the role of Controller for the Trading Account. See Figure 136, where Phyllis Wimberlie is being identified as the Controller instead of the Default Controller, Russell V. Warren.




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NOTE: If the Default Controller does not properly identify the actual Controller for the Trading Account and a Profile for the actual Controller was not found, you will need to create the Profile in order to associate it or ask the Client to do so. Refer to Section 6.6.4 as needed for further information about creation of Profiles.

NOTE: If, in addition to any Default Controller, a Third Party Controller also directs trading for the account, it is necessary to also associate the individual Natural Person Account Controllers listed in the Third Party Controller's Profile. See Appendix C . Third Party Controllers do not auto populate.

Supply the Relationship to Owner information. See Figure 136.

Figure 136

Click the Save button to save your new selection. See Figure 136.

Once you have saved your new Profile Association for the Controller role, the Profile that you added will appear in the listed associations and you will see a message stating that the Profile Association was added successfully. See Figure 137. In this case, Phyllis Wimberlie is now shown as the Controller, replacing Russell V. Warren, whose Profile was previously associated by default. See Figure 136.

Figure 137

Click on the Edit button to edit the Relationship to Owner field if needed.

If you wish to remove the Profile Association, click on the X. See Figure 138.

NOTE: If the Controller who was added to override the Default Controller is removed, the Default Controller will be restored based on the information in the Owner’s Profile.




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Figure 138

Click on the Add button again to associate Controllers with the Trading Account, if needed.

6.6.2 Associate Profiles within Special Accounts

Guidelines for the Association of Profiles associated with Special Accounts are shown in warning messages within the Profile Associations box once the Account has been created:

Non-omnibus Special Accounts should have one and only one owner and controller Profile. o If the Origin Reason was Controller, the Role must be Controller. See Figure 139. o If the Origin Reason was Owner, the Role must be Owner. See Figure 140. o If the Origin Reason was Owner & Controller, the Role must be Owner &

Controller. See Figure 141.

Omnibus Special Accounts should have one Omnibus Originator Profile. See Figure 142.

Special Accounts entered by a Reporting Firm that is operating as a Foreign (non-U.S.) Broker within the U.S. market must include the Profile in the role of Domestic FCM.

Figure 139

Figure 140



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Figure 141

Figure 142

To comply with the warnings and cause them to disappear, and to add a Domestic FCM if needed, click on the Add button. See Figure 139, Figure 140, Figure 141, and Figure 142.

6.6.2.1 Add Owner Profile to a Special Account

If the Origin Reason for the Special Account was Owner, chose the only available Role, which is Owner.

Click on the Select Profile button.

Figure 143

A list of available Profiles will appear similar to the list shown above in Figure 132.


NOTE: If the Profile for the Owner that you wish to associate does not appear in the list, you may search for the Profile using the search function described in Section 4.3.1.1. If a Profile for the person or entity has not yet been created, you may create a Profile following the procedure described below in Section 6.6.4.

Click on the Select button to associate the Profile with your Special Account.



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If you are associating a Legal Entity Profile that does not include a Main Contact, a pop-up box will alert you that the Profile is incomplete. See Figure 133.

If the Legal Entity is incomplete pop-up box appears, inform the Profile Manager that Main Contact information needs to be added to the Profile.

Click OK to continue.

You will then be returned to the Profile Associations box, where the selected Profile will be displayed. See Figure 144, where the Profile of Lesley D. McAleese was selected as the Owner of the Special Account.

Figure 144

Click Save to associate the selected Profile in the role of Owner. See Figure 145.

Figure 145

Once you have saved your new Profile Association for the Owner role, the Profile that you added will appear in the listed associations and you will see a message stating that the Profile Association was added successfully. See Figure 145.

6.6.2.2 Add Controller Profile to a Special Account

If the Origin Reason for the Special Account was Controller, chose the only available Role, which is Controller. See Figure 146.

Click on the Select Profile button. See Figure 146.




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Figure 146


Highlight the line containing the Profile to be selected, which may be that of a Third Party Controller.

NOTE: If the Profile for the Controller that you wish to associate does not appear in the list, you may search for the Profile using the search function described in Section 4.3.1.1. If a Profile for the person or entity has not yet been created, you may create a Profile following the procedure described below in Section 6.6.4.





You will then be returned to the Profile Associations box and the selected Profile will be displayed. See Figure 147, where the Strategic Capital Investment Trust, LLC was selected.

Figure 147

Click Save to associate the selected Profile in the role of Controller. See Figure 147.

Once you have saved your new Profile Association for the Controller role, the Profile that you added will appear in the listed associations and you will see a message stating that the Profile Association was added successfully. See Figure 148.



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Figure 148

6.6.2.3 Add Owner & Controller Profile to a Special Account

If the Origin Reason for the Special Account was Owner & Controller, either of two approaches may be taken to associate the Owner & Controller Profile, as described below.

Using the drop-down list shown in Figure 149, you may choose Owner, Controller, or Owner & Controller for the Role field.

Select Owner & Controller from the list and associate the Profile in one line. See Section 6.6.2.3.1.

Or identify the Profile twice, first as the Owner and again as the Controller. Both approaches are described. See Section 6.6.2.3.2.

6.6.2.3.1 Associate the Owner & Controller Profile in One Line

To enter the Owner & Controller Profile in one line, click on the Select Profile button. See Figure 149.

Figure 149

Within the Role field, select Owner & Controller. See Figure 149.




NOTE: If the Profile for the Owner and Controller that you wish to associate does not appear in the list, you may search for the Profile using the search function described in Section 4.3.1.1. If a Profile for the person or entity has not yet been created, you may create a Profile following the procedure described below in Section 6.6.4.






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You will then be returned to the Profile Associations box, where the selected Profile will be displayed. See Figure 150, where the Profile of Fox Creek Gas and Electric Utility, Inc. was selected as the Owner & Controller of the Special Account.

Figure 150

Click Save to associate the selected Profile in the role of Owner & Controller. See Figure 151.

Figure 151

Once you have saved your new Profile Association for the Owner & Controller role, the Profile that you added will appear in the listed associations and you will see a message stating that the Profile Association was added successfully. See Figure 151.

6.6.2.3.2 Associate the Owner & Controller Profile in Two Lines

To enter the Owner & Controller Profile in two separate lines, click on the Select Profile button. See Figure 151.

Figure 152

Within the Role field, select Owner. See Figure 152.




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NOTE: If the Profile for the Owner that you wish to associate does not appear in the list, you may search for the Profile using the search function described in Section 4.3.1.1. If a Profile for the person or entity has not yet been created, you may create a Profile following the procedure described below in Section 6.6.4.

Click on the Select button to associate the Profile of the Owner with your Special Account.




You will then be returned to the Profile Associations box and the selected Profile will be displayed. See Figure 153, where Fox Creek Gas and Electric Utility, Inc. was selected.

Figure 153


Once you have saved your new Profile Association for the Owner role, the Profile that you added will appear in the listed associations. See Figure 154.

Figure 154

Repeat the process described in this section to add a second line with the Controller selected in the Role field. See Figure 155.



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Figure 155


You will see a message stating that the Profile Association was added successfully. The same Profile will be associated as the Owner and as the Controller in two separate lines. See Figure 156.

Figure 156

6.6.2.4 Add Omnibus Originator Profile to a Special Account

If the Origin Reason for the Special Account was Omnibus Originator, choose the Role of Omnibus Originator. See Figure 157.


Figure 157



NOTE: If the Profile for the Omnibus Originator that you wish to associate does not appear in the list, you may search for the Profile using the search function described in Section 4.3.1.1. If a Profile for the person or entity has not yet been created, you may create a Profile following the procedure described below in Section 6.6.4.




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You will then be returned to the Profile Associations box and the selected Profile will be displayed. See Figure 158, where the International Bank Ltd was selected.

Figure 158

Click Save to associate the selected Profile in the role of Omnibus Originator. See Figure 158.

Once you have saved your new Profile Association for the Omnibus Originator role, the Profile that you added will appear in the listed associations and you will see a message stating that the Profile Association was added successfully. See Figure 159.

Figure 159

6.6.2.5 Associate Profile of a Domestic FCM to a Special Account

If the Reporting Firm is operating as a Foreign Broker in the U.S. market, designation of a Domestic FCM is required within the Profile Associations box. The requirement to associate the Profile of a Domestic FCM applies regardless of the Origin Reason for the Special Account.

To associate a Domestic FCM, perform the following steps:

Choose the role of Domestic FCM. See Figure 160.




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Figure 160


Highlight the line containing the Profile of the Domestic FCM to be selected.





You will then be returned to the Profile Associations box and the selected Profile will be displayed. See Figure 161, where the International Bank of Greece was selected.

Figure 161

Click Save to associate the selected Profile in the role of Domestic FCM. See Figure 161.

Once you have saved your new Profile Association for the Domestic FCM role, the Profile that you added will appear in the listed associations and you will see a message stating that the Profile Association was added successfully. See Figure 162.



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Figure 162

An example of a Special Account established by a Foreign Broker is shown in Figure 163, where the Reporting Firm Industrial Bank of Greece has established a Special 102A Account to report on trades executed for it by International Bank, Ltd, its Domestic FCM.

In Figure 163, the Origin Reason for the Special Account is Controller; therefore the Profile of the Controller, Nicholas Zolatas, has also been associated. The process for associating a Controller is described in Section 6.6.2.2.



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Figure 163

6.6.3 Associate Profiles within Consolidated Accounts

Guidelines for the Association of Profiles associated with Consolidated Accounts are shown in warning messages within the Profile Associations box once the Account has been created:

Non-omnibus Consolidated Accounts should have at least one owner and controller Profile. See Figure 164.

Omnibus Consolidated Accounts should have one Omnibus Originator profile. See Figure 165.




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Figure 164

Figure 165

To comply with the warnings and cause them to disappear, click on the Add button. See Figure 164 and Figure 165.

If the Consolidated Account is not omnibus, add Profiles for the Owner and Controller as described below in Section 6.6.3.1.

If the Consolidated Account is not omnibus, add the Profile of the Omnibus Originator as described below in Section 6.6.3.2.

6.6.3.1 Associate Profiles of the Owner and Controller to Non-omnibus Consolidated Account

If the Consolidated Account is not omnibus, from the options Owner, Controller, or Owner & Controller roles within the Role field, select Owner. See Figure 166.

Figure 166

To select the Profile of the Owner, click on the Select Profile button. See Figure 166.



NOTE: If the Profile for the Owner that you wish to associate does not appear in the list, you may search for the Profile using the search function described in Section 4.3.1.1. If a Profile



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for the person or entity has not yet been created, you may create a Profile following the procedure described below in Section 6.6.4.

Click on the Select button to associate the Profile of the Owner with your Consolidated Account.




You will then be returned to the Profile Associations box and the selected Profile will be displayed. See Figure 167, where Jeffrey Walker was selected as the Owner.

Figure 167


Once you have saved your new Profile Association for the Owner role, the Profile that you added will appear in the listed associations. See Figure 168.

Figure 168

Repeat the process described in this section to add a second line with the Controller selected in the Role field. See Figure 169, which shows that Russell V. Warren was selected to be associated as the Controller.



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Figure 169


You will see a message stating that the Profile Association was added successfully. See Figure 170.

Figure 170

NOTE: If the Owner and Controller for the Consolidated Account are the same, they may be entered one line with the Owner & Controller selected as the Role.

6.6.3.2 Associate Omnibus Originator to Omnibus Consolidated Account

If the Consolidated Account is an Omnibus Account, chose the only available Role that can be selected for the Profile, which is Omnibus Originator. See Figure 171.

Figure 171

To select the Profile of the Omnibus Originator, click on the Select Profile button. See Figure 171.



NOTE: If the Profile for the Omnibus Originator that you wish to associate does not appear in the list, you may search for the Profile using the search function described in Section 4.3.1.1.




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If a Profile for the person or entity has not yet been created, you may create a Profile following the procedure described below in Section 6.6.4.

Click on the Select button to associate the Profile of the Omnibus Originator with your Consolidated Account.




You will then be returned to the Profile Associations box and the selected Profile will be displayed. See Figure 172, where International Bank Ltd was selected as the Omnibus Originator.

Figure 172

Click Save to associate the selected Profile in the role of Omnibus Originator. See Figure 172.

Once you have saved your new Profile Association for the Omnibus Originator role, the Profile that you added will appear in the listed associations. See Figure 173.

You will see a message stating that the Profile Association was added successfully. See Figure 173.

Figure 173

6.6.4 Create Profiles as Needed for Association to Accounts

In the event that a Profile has not been created for an Account that you are required to enter, you may create a Profile using the same procedure followed by Clients in Section 4.3.

Your ability to create Profiles makes it possible for your organization to report its owner and controller information to the CFTC in a timely manner when the accounts are reportable based on the best information available.

To create a Profile, follow the steps described in Section 4.3 for Clients.




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NOTE: As a Reporting Firm User, when you create a Profile you do not need to permission your Participant organization to see and use the Profile. Therefore the steps enumerated in Section 4.4 do not apply to Reporting Firm Users.

Associate your Profile to the Account as you would have done had a Client created the Profile. See Section 6.6.

NOTE: After creating a Profile, you may wish to inform your Client that a permanent Profile is needed.

NOTE: Clients do not have access to Profiles that you create. Clients cannot edit or update a Profile that you entered. Even though you created a Profile, your Client would need to create a new Profile in the system to provide their own owner and controller information.

Later, if your Client creates its own Profile for the same entity, you will be informed of the new Profile and will be able to remove your Profile from the Account and associate the new Profile that was created instead. See Section 6.11. Once you have done so, your Reporting Firm Administrator will inform FIA Tech that the account has been updated and the Profile that you created can be removed.

6.7 Add Special Account Associations to a Trading Account (102B)

For Trading Accounts that trade within one or more Special Accounts, the Special Account Associations box must be completed to associate each Special (102A) Account. This Special Account Associations box is the middle box on the Account Details screen for the Trading Account. See Figure 127.

To add a Special Account Association, click on the Add button within the box. See Figure 174.

Figure 174

A drop-down list of available Special Accounts will appear in a Search Accounts screen.

NOTE: Because only Special (102A) Accounts can be associated with a Trading Account, only Special (102A) Accounts are shown in the drop-down list shown. In Figure 175, only one Special Account is shown as available because the Reporting Firm International Bank Ltd has created only one Special Account.

From the list of available Special (102A) Accounts that have been entered in the system, highlight the correct account to select it and click on the Select button. See Figure 175.



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Figure 175

After you click on the Select button, the selected Special (102A) Account will be displayed as an associated account in the Account Details screen.

You have the option to save your selection or change it by returning to the drop-down list, as shown in Figure 176.

To return to the list and make a different selection, click on the Change Account button.

To save your selection, click on the Save button.

Figure 176

Once saved, a message is displayed showing that the Account association was added as shown in Figure 177.

NOTE: To view the Account Details screen for Special (102A) Account that was added, you may click on the number in the Account Number column as shown in Figure 177, which will take you to the Special Account for Strategic Capital.

Figure 177



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6.7.1 Search Accounts

If the Account that you wish to associate was not visible in the display of available Accounts (see Figure 175), you may search within the results displayed and filter the results to limit the number of Accounts shown. See Figure 179. For illustration, searches of all Account Categories are addressed below.

On the Dashboard screen, click on the Search text button within the Accounts toolbar drop-down list or Accounts icon to access the Search Accounts screen. See Figure 178.

Figure 178

To search for a specific account, enter the Account Number or Account Name in the Search by accounts field of the Search Accounts screen.

Click on the Search button to execute your search.

Filter your search as needed by clicking on the Filter icon for any column that you wish to filter and entering your Filter Criteria.

CAUTION: If you filter your search results, be sure to clear the filter prior to performing any subsequent searches.



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Figure 179

If you are still unable to locate the Account and there is any possibility that the account could have been made inactive, put a check in the Show Inactive box to display inactive accounts within your search results. See Figure 179.

Once you have located the Account, double click on the Account Number if you need to review or edit information in the Account Details screen, or, if you are performing an Account Association, highlight the account click on the Select button to associate the Account. See Figure 175.

6.8 Add Trading Account Associations to a Special Account (102A)

For Special Accounts comprising multiple Trading Accounts that are traded as a group, the Trading Account Associations box in the Special (102A) Account must contain a complete list of the Trading Accounts.

NOTE: When a Special Account Association is added to a Trading Account following the procedure described in Section 6.7, the relationship established between the two Accounts is reciprocal. This means that the Trading Account automatically appears as an association in the Special (102A) Account. For this reason, the association between a Trading Account and a Special (102A) Account is only entered in the system once, either within the Trading Account or within the Special (102A) Account.

If you wish to enter the association of a Trading Account within a Special Account, perform the following steps:

Locate the Trading Account Associations box on the Account Details screen for the Special Account. See example in Figure 180.



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Figure 180

Click on the Add button shown in Figure 180 to access the list of Trading Accounts that may be added. See Figure 181.

Locate the Trading Account that you intend to associate with your Special (102A) Account.

o If you are unable to locate the account among the accounts displayed, perform a search using the Account Name or Account Number and filter your results as needed as described in Section 6.7.1.

Highlight the Trading Account that you intend to associate. See Figure 181.

Click on the Select button. See Figure 181.



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Figure 181

Once you have clicked on the Select button, you will be returned to the previous Account Details screen, where the account that you chose will appear in the Trading Account Associations box. See Figure 182.

Click on the Change Account button if you wish to change your selection.

Otherwise, click on the Save button to save the association. See Figure 182.

Figure 182

When you click on the Save button to save your final choice, you will see a confirmation message stating that the Account association was added successfully. See Figure 183.



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Figure 183

If the Trading Account that you wish to associate was not visible in the display of available Trading Accounts (see Figure 181), you may search within the results displayed and filter the results to limit the number of Accounts shown. Refer to Section 6.7.1 for detailed search steps.

6.9 Add Market Associations to a Trading Account (102B)

Market Associations and related Short Codes are added to Trading Accounts using the lower box shown on the Account Details screen in Figure 127.

NOTE: Market Associations are required if your firm intends to file ownership and control reports from within the OCR Portal. See Section 8.3. Otherwise Market Associations may be entered but are not required.

To add Market Associations, locate the Market Associations box within the Trading Account as shown in Figure 184.





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Figure 184

Click on the Add button to obtain a format for entering the required information shown in Figure 185.

Figure 185

Use the drop-down list of Market Names to select the market. See Figure 186.

Key in the related Short Code as shown.

To add the Short Code, click on the plus sign next to the box where the Short Code was typed. See Figure 186.

Figure 186

Your selected Market Name and the Short Codes that you entered are displayed for review. See Figure 187.



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If changes are required, select a different market from the Market Name drop-down list or remove the Short Code by clicking on the x symbol to its left and add a different Short Code.

Otherwise, if the information is correct, click on the Save button to add your Market Association.

Figure 187

When you click on the Save button, you will see a confirmation that your Market association was added successfully. See Figure 188.

Figure 188

6.10 Add Paired Swaps/Swaptions Details to a Consolidated (102S) Account

Reportable details related to swap counterparty and customer consolidated accounts are associated to Consolidated (102S) Accounts within the Paired Swaps / Swaptions Details box.

The Paired Swaps / Swaptions Details box is found on the Account Details screen for Consolidated (102S) Accounts as shown in Figure 189.



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Figure 189

To add information within the Paired Swaps / Swaptions Details box, click on the Add button to access the required format. See Figure 190.

Figure 190

Use the drop-down list to indicate None, Yes, or No for the Swap field. See Figure 191.

Use the drop-down list to indicate None, Yes, or No for the Swaption field.

Provide an activity description for the transaction in the Activity Description box.

Click on the Save button to save your information.



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Figure 191

You will receive a confirmation message that the Swaps association was added successfully. See Figure 192.

Figure 192

6.11 Edit Accounts

All Accounts may be edited from the Account Details screen for the Account.

To access the Account Details screen, search for the Account to be edited following the search steps described in Section 6.7.1.

Select the Account to be edited from all Accounts displayed, or search as follows and as shown in Figure 193:

o Search for a specific Account by entering the Account Name or Account Number in the Search by accounts … search field.

o Search for a specific Account by entering the Profile Name or OCR Profile ID of any Profile associated to the Account in the Search by … profiles field.

NOTE: Searching by Profile may be useful if you wish to search for all Accounts for a specific customer.

NOTE: Within your search results, the Owners, Controllers, and Other Contacts columns relate to Profiles associated with each Account. The Owners column shows the Profile associated in the role of Owner, the Controllers column shows the Profile associated in the role of Controller, and the Other Contacts shows Profiles associated in the role of Omnibus Originator or Domestic FCM.



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Figure 193

6.11.1 Edit Account Information in Accounts (102A, 102B, and 102S)

The following account information fields are editable for all categories of Accounts:

Account Name

Is Omnibus

Class

Active

For Special (102A) Accounts, the following account information can also be edited:

Origin Reason

To edit these fields, click on the Edit button on the Account Details screen as shown in Figure 194.



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Figure 194

An Edit Trading Information screen, Edit Special (102A) Information screen, or Edit Consolidated (102B) Information window will appear, depending on the Account Category. See Figure 195, Figure 196, and Figure 197.

Change the Account Name and edit the other fields as needed to update the record.





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Figure 195

Figure 196

Figure 197

After your changes have been made, save them by clicking on the Save button. See example in Figure 197.

After clicking on the Save button, you will be returned to the Account Details screen, where a confirmation message stating Account updated successfully will be displayed. See Figure 198.



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Figure 198

6.11.2 Remove Associations from Accounts (102A, 102B, and 102S)

If needed, associations may be deleted from Accounts when information changes or to make corrections using the Account Details screen. See Figure 194.

Profile Associations may be removed from all Accounts regardless of the Account category.

Special Account Associations and Market Associations may be removed from Trading Accounts.

Trading Account Associations may be removed from Special (102A) Accounts.

Paired Swaps / Swaptions Details may be removed from Consolidated (102S) Account.

NOTE: Removal of a Profile Association is needed if a Profile that you created is being replaced by a new Profile created by the Client containing updated owner and controller information for the Account. When you add the new Profile that the Client created, your original Profile should be removed. Likewise, if a Client for some reason wishes to deactivate a Profile, you may be asked to remove the Association from your Account so that the Profile can be deactivated.



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To remove an association from an Account, click on the red X to the left in the row where the association appears. See Figure 194 and the example showing how to remove a Special Account Association in Figure 199.

Figure 199

After you click on the red X, you will be asked to confirm your deletion, after which a message will be displayed confirming that the deletion was performed. In the example shown in Figure 200, the confirmations states Account association deleted successfully.

Figure 200

If you removed a temporary Profile and replaced it with a new Profile created by a Client, inform your Reporting Firm Administrator of that the account record has been updated so your Profile that is no longer being used can be removed.

6.11.3 Edit Certain Fields in Trading Accounts (102B)

The following additional changes can be made to information in Trading Accounts:

Relationship to Owner information describing associated Profiles

Short Codes related to Market Associations

These actions are performed using the Account Details screen for the Trading Account as shown in Figure 194. Each will be discussed in turn.

6.11.3.1 Edit Relationship to Owner Information

To edit Relationship to Owner information in a Trading Account, click on Edit icon to the left in the row where the association appears. See Figure 201.



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Figure 201

When the Relationship to Owner field becomes editable, make the change required and save your change using the Save button. See Figure 202.

Figure 202

After you click on the Save button, you will exit the Edit mode and see a confirmation that your change was saved. See Figure 203.

Figure 203

6.11.3.2 Edit Short Codes

To add or remove Short Codes information within the Market Associations box in a Trading Account, click on Edit icon to the left in the row where the short code appears. See Figure 204.





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Figure 204

When the Short Codes field becomes editable, type in the new Short Code to be added and click on the plus sign next to the field. See Figure 205.

Figure 205

The new Short Code that was added will appear together with the Short Code that was already associated to the record.

NOTE: Either Short Code may be removed by clicking on the x symbol appearing next to it. See Figure 206.

Click on the Save button to save your changes. See Figure 206.

Figure 206

After you click on the Save button, you will exit the Edit mode and see a confirmation message stating Market association updated successfully. See Figure 207.



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Figure 207

6.11.4 Edit Paired Swaps / Swaptions Details in Consolidated (102S) Accounts

Swap and swaption details may be updated within Consolidated (102S) Accounts if the information changes.

These changes are entered on the Account Details screen for the Consolidated (102S) Account record in the Paired Swaps / Swaptions Details box. See Figure 208.

To access the Account Details screen, search for the account record to be edited following the search steps described in Section 6.7.1 and select the record from among the search results.

On the Account Details screen, edit the swap and swaption information, click on Edit icon to the left in the row in the Paired Swaps / Swaptions Details box where the short code appears. See Figure 208.



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Figure 208

When the edit options appear, you may edit the Swap field, the Swaption field, and the Activity Description field. See Figure 209.

NOTE: The Swap field and the Swaption field are completed using drop-down lists.

Figure 209

Click on the Save button to save your changes.

After you click on the Save button, you will exit the Edit mode and see a confirmation message stating Swaps association updated successfully. See Figure 210.




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Figure 210

6.12 Deactivate and Reactivate an Account

Accounts that are no longer needed may not be deleted; however, they may be made inactive. Once they have been made inactive, Accounts can also be reactivated. The process for deactivating ad reactivating an Account is described in this section.

6.12.1 Deactivate an Account

To make an Account inactive, follow the steps described in Section 6.7.1 to search for the Account.

On the Account Details screen, click on No to make the Account no longer active, as shown in Figure 211.



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Figure 211

After you click on No in the Active field, you will be prompted to confirm your intention to make the Account inactive. See Figure 212.

Figure 212

Click the Yes, Deactivate button to perform the deactivation.

You will see a confirmation message of your update and the Active status will be shown as No in red. See Figure 213.



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Figure 213

6.12.2 Reactivate an Account

If your firm determines that a user who was deactivated needs to be reactivated, access the user’s deactivated record using the process described in Section 6.7.1.

Place a check mark in the Show Inactive checkbox in the lower left corner of the Search Accounts box to include inactive within the search results. See Figure 214.



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Figure 214

In the search results, click on the Account Number of inactive Account that will be reactivated to access the Account Details for the Account as shown in Figure 214.

On the User Details screen, click on Yes in the Active field to reactivate the user, as shown in Figure 215.



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Figure 215

After you click on Yes in the Active field, you will be prompted to confirm your intention to reacvitate the Account. See Figure 216.

Figure 216

Click the Yes, Activate button to reactivate the Account.

You will see a confirmation message of your update and the Active status will be shown as Yes in green. See Figure 217.



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Figure 217

6.13 Return to the FIA Tech User Hub

The My Apps drop-down menu in the top right of every FIA Tech OCR Portal screen provides an option to return to the FIA Tech User Hub. See example in Figure 218.

To return to the FIA Tech User Hub, click UserHub from within the drop-down list.



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Figure 218

After clicking on UserHub, you will be directed to the Welcome screen shown in Figure 1.



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Chapter 7 Reporting Firm Administrator Functions Access to the FIA Tech OCR Data Service system is established by FIA Tech for Participant firms, which include one or more Reporting Firms within the meaning of the OCR Final Rule. FIA Tech provides administrator access to the system for one or more individuals identified by each Participant firm to serve as a Reporting Firm Administrator. If a Participant has structured within its organization one or more additional Participants, an Administrator could also have responsibility for multiple Participants.

Reporting Firm Administrators are responsible for the establishment of Reporting Firm User access to the FIA Tech OCR Data Service Portal for their personnel who will enter and maintain account information. Reporting Firm Administrators can also act as Reporting Firm Users and perform all functions that Reporting Firm Users perform. In addition, Reporting Firm Administrators can establish certain users as additional Administrators.

NOTE: Reporting Firm Administrator functions are performed within the FIA Tech User Hub. See Chapter 3 to review access and navigation within the User Hub.

NOTE: Reporting Firm Users cannot register to access the FIA Tech OCR Data Services via the User Hub as described in Section 3.1. Reporting Firm Users must be registered by Administrator of their participating firm.

Any Reporting Firm Administrator may establish additional Reporting Firm Administrators for the Participant based on the needs of the Participant organization.

These and certain additional Reporting Firm Administrator functions are addressed in this chapter as follows:

Accessing Administrator Functions within the User Hub

Searching of Reporting Firm User and Administrator Accounts

Creation of Reporting Firm User and Administrator Accounts

Assignment to Participant Organization

Establishment of User and Administrator Roles

Deactivation of Reporting Firm User and Administrator Accounts

For access to annotations to the screenshots used in this Chapter, see ANNOTATIONS FOR CHAPTER

7.

7.1 Access Administrator Functions

The FIA Tech User Hub is the locus of administrator functions. Within the User Hub, the Administration button is used by Administrators to access all related to creation and management of OCR Data Service access. See Figure 219.

NOTE: Only Reporting Firm Administrators may perform administrator functions. The Administration button appears on the Welcome to FIA Tech User Hub only for users to whom Administrator roles have been assigned.

NOTE: The toolbar also provides a link to Administration. See Figure 219.

Click on the Administration button or link within the FIA Tech User Hub to access administration functions.



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Figure 219

After clicking on Administration, you will be directed to a Search Users screen within the Administration tab that supports both searching of user records and the addition of new users. See Figure 220.

Figure 220

7.2 Search Reporting Firm Records of Users and Administrators for Review

User records that have been established may be accessed for review, including records for both Reporting Firm Users and Reporting Firm Administrators, as follows:

To review all user records, click on the Search button within the Administration tab.

A display of all records will appear, within which you may search further or narrow your results to obtain a specific record. Both user and administrator records are included in the search results. See Figure 221.

NOTE: If you filter your results, be sure to clear the filter before performing subsequent searches.

o To search within the search results, type the User Account Name, First Name, Last Name, or Email Address of the user. See Figure 221.

Click on the Search button.

o To filter your search results, click on the filter icon in any column and enter your filter criteria. See Figure 221.



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Figure 221

To search for one specific record without reviewing other records, enter your search criteria for the record in Search Users field shown in Figure 221 and click on the Search button.

The record for the specific user that you searched for should appear in your search results. See Figure 222.

Click on the user’s User Account Name to open the User Details screen for the user as shown in Figure 222.

Figure 222

Details within the user record can be reviewed within the User Details screen. See Figure 223.



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Figure 223

Click on the Return to Admin button shown in Figure 223 to return to the Search Users screen. See Figure 220.

7.3 Create Reporting Firm Users and Administrators

When additional Reporting Firm Users and Administrators are needed by your Participant firm, you may create access for new users by using the Add User function and verify whether a new user has completed the registration process.

7.3.1 Add a New User to the System

To add a new user, click on the Add User button shown in Figure 220.

NOTE: The Add User button is also available within your search result displays. See Figure 221 and Figure 222.

After clicking on the Add User button, you will be directed to the Add a new user form shown in Figure 224. The form asks for information about the new user in the following fields:

o First Name

o Last Name

o Email Address

o User Account Name

o Password

o Confirm Password

o Company

o Location

o CAPTCHA text

Complete the form by entering the information requested.



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Click on the Add User button at the bottom of the Add a new user form to add your new user to the system. See Figure 224.

Figure 224

After you click on the Add User button, an email message will be sent to the new user with additional instructions for completing the user access. You will also see confirmation stating that the New user was created. See Figure 225.

NOTE: The link in the email verification message that the new user will receive after you have registered them becomes invalid after 48 hours. The new user should click on the link to complete the registration process within 48 hours once the message is received.

NOTE: The orange triangle with an exclamation point in Figure 225 indicates that the email address of the new user has not been verified. An email message was sent to the new user but the new user has not yet responded.



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Figure 225

7.3.2 Verify User Status and Resend Verification Email Message

Later, to verify whether the new user has responded to the system’s email message, search for the new user using the process described in Section 7.2.

In the search results, click on the new user’s User Account Name to access the User Details screen for the user as shown in Figure 226.

Figure 226

Within the User Details screen, verify whether the new user has responded to the verification email as shown on the User Details screen. See Figure 225.

If the orange triangle with an exclamation point in Figure 225 remains, showing that the new user has still not responded to the email message that was sent by the system, click on the resend the verification email link to send a follow-up message. See Figure 225.



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NOTE: Once the new user’s email address has been verified, the new user may log in to the system and update their user data in the record as described in Section 3.4. In addition, the password set by you as Administrator may be changed by the new user as described in Section 3.5.

When the new user’s email address has been verified, the orange triangle and Resend the verification email link will be removed from the User Details screen within the Administration tab. You will also see a last login date showing when the user has logged in in the Last Login On field. See Figure 227.

Figure 227

NOTE: The date in the Last Login On field provides an indication of whether users are actively managing their data and reviewing notifications from the OCR Data Service that are delivered to their Dashboard as described in Chapter 9.

7.4 Assign New Users to Participant Organization

All users, including both Reporting Firm Users and Reporting Firm Administrators, must be assigned to the Participant organization or organizations in which they will carry out OCR functions.

In many organizations, users can be assigned to only one Participant because the entire organization was established within the system as one Participant firm.

In other organizations, however, multiple Participants may have been created representing different divisions, departments, or subsidiary entities. Users in such organizations may need access to Profiles and Accounts for one or more of the Participants but not for others.

To assign a new user to the appropriate Participant or Participants, search for the user using the process described in Section 7.2.

In the search results, click on the new user’s User Account Name to access the User Details screen for the user as shown in Figure 228.

On the User Details screen, click on the Edit button in the User Participants box, as shown in Figure 228.



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Figure 228

The User Details screen will display User Participant options to which the user can be assigned.

Click the checkbox next to the name of each Participant within which the user will require access to Profiles and Accounts. See Figure 229.

Figure 229

NOTE: In the example shown, Miyeoung Park can only be assigned to one Participant.

CAUTION: When assigning a user to Participants, ensure that your user is assigned to Participants within the Participants that you manage. If the user’s Participants do not include any Participants for which you are an Administrator, you will no longer have administrative access to the user. In the example shown, if Rebecca Peters removes the check mark from International Bank LTD (INTL), she will no longer be able to access Miyeoung Park’s user information because Miyeoung Park will no longer be a user for International Bank LTD (INTL).

Click the Save button to save any changes you have made.

7.5 Establish User and Administrator Roles

Roles assigned to users differentiate their status as Reporting Firm Users or Reporting Firm Administrators. These roles are associated with specific functions: Reporting Firm Users perform the functions described in Chapter 5; Reporting Firm Administrators may perform the same functions described in Chapter 5 and also perform the administration functions described in this chapter.



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NOTE: The system does not assign default roles to new users. See Figure 228, where the default User Roles shown are None. Therefore, roles must be assigned in order for a new user to access the firm’s Profiles, create Accounts, and perform various Account Associations required by the firm to comply with its reporting requirements.

Assignment of roles is performed as follows:

To assign user roles to a new user, search for the record using the process described in Section 7.2.

In the search results, click on the new user’s User Account Name to access the User Details screen shown in Figure 228.

On the User Details screen, click on the Edit button in the User Roles box, as shown in Figure 228.

The User Details screen will display User Roles to which the user can be assigned.

Click the checkbox next to each role that the user will perform. See Figure 230.

7.5.1 Establish Reporter Entity Administrator roles

Assign to Reporting Firm Administrator the roles of:

OCR – Participant firm OCR administrator

UserHub - Participant firm OCR administrator (see Figure 230)

Figure 230

7.5.2 Establish Reporter Entity User roles

Assign to Reporting Firm Users the role of:

OCR – Participant firm OCR user (see Figure 231)

Figure 231

Click the Save button to save the assigned roles.



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7.6 Edit User Information

User information for both Reporting Firm Users and Reporting Firm Administrators should be managed and kept up to date, with roles and Participant assignments updated as needed and as duties change. When the status of the user or other information changes, details related to the change may be edited from the User Details screen of the user record. In addition, certain contact information that was not required to register the user may be added by editing the user information as described in this section.

To access a user record for review and editing, search for the user using the process described in Section 7.2.

In the search results, click on the new user’s User Account Name to access the User Details screen for the user record as shown in Figure 228.

Within the User Details screen, click on the to the User Details screen button as shown in Figure 232 to access editable fields.

Figure 232

Update the information in the editable fields as needed. See Figure 233, where the phone numbers and job title have been added to Miyeoung Park’s information.

Fields that can be edited include:

o First Name

o Last Name

o Email Address

o Title

o Business #

o Mobile #



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o Fax#

o Location

o Active

Figure 233

Click the Save button to your changes to the user record as shown in Figure 233.

You will see a confirmation message stating that your changes were saved. See Figure 234.

Figure 234



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NOTE: At a user’s request, you may also reset the user’s password using the Change Password link shown in Figure 234. The steps for changing a password are described in Section 3.5.

7.7 Deactivate and Reactivate User Access

User access to the OCR Data Service may be deactivated and reactivated as needed using the processes described in this section.

7.7.1 Deactivate a User

When a Participating firm no longer requires a user to have access to the OCR Portal, the Reporting Firm Administrator may terminate the user’s access as described in this section.

Termination of access is accomplished when the Reporting Firm Administrator deactivates the user record within the User Details screen by changing the Active status from Yes to No, as follows:

To access a record to be deactivated, search for the record using the process described in Section 7.2.

In the search results, click on the User Account Name of the user who will be deactivated to access the User Details screen for the user record as shown in Figure 222.

On the User Details screen, click on No to make the user no longer active, as shown in Figure 235.

Figure 235

After you click on No in the Active field, you will be prompted to confirm your intention to make the user inactive. See Figure 236.



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Figure 236

Click the Yes, Deactivate button to perform the deactivation.

You will see a confirmation message of your update and the Active status will be shown as No in red. See Figure 237.

Figure 237

7.7.2 Reactivate a User

If your firm determines that a user who was deactivated needs to be reactivated, access the user’s deactivated record using the process described in Section 7.2.

Place a check mark in the Show Inactive checkbox in the lower left corner of the Search Users box to include inactive users within the search results. See Figure 238.



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Figure 238

In the search results, click on the User Account Name of inactive user who will be reactivated to access the user’s User Details as shown in Figure 238.

On the User Details screen, click on Yes in the Active field to reactivate the user, as shown in Figure 239.

Figure 239

After you click on Yes in the Active field, you will be prompted to confirm your intention to reacvitate the user. See Figure 240.

Figure 240



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Click the Yes, Activate button to reactivate the user.

You will see a confirmation message of your update and the Active status will be shown as Yes in green. See Figure 241.

Figure 241



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Chapter 8 Reporting of Data on Volume of Trades The substantive owner and controller data submitted by the OCR Data System to the CFTC in ownership and control reports is contained in Accounts created ty Reporting Firms and Profiles created by primarily by Clients and in some cases also by Reporting Firms. The Profiles contain specific owner and controller information related to the Accounts and ensure that the level of detail required by the CFTC for reporting under the OCR Final Rule is met.

Filing of Form 102B reports takes place when trading volume of an account reaches a threshold specified by the CFTC. Form 102A and Form 102S are filed when an account has a reportable position based on criteria established by the CFTC. Any subsequent Form 102A, Form 102B, or Form 102S filing during the same year is required only if there was a change in the Account information, including information in Profiles associated to an Account.

The OCR Data System issues reports to the CFTC when it receives information from a Reporting Form that a specific Account should be reported based on its trading activity for that day. This information that “triggers” the reporting is delivered electronically to FIA Tech and is matched to Account and Profile information stored in the system to generate the required reports. Each triggered report is checked against the last reported date for the Account and, if the time since the last report is less than one year and no changes in the information are noted, the new reporting is suppressed “due to no change.”

This section describes these processes used by Reporting Firms to identify accounts that require reporting to FIA Tech and “trigger” the required Form 102A, Form 102B, and Form 102S reports.

8.1 Third Party Transmission of Daily Trading Data

Reporting Firms may contract with a third party vendor for transmission of daily data files to FIA Tech containing identification of the Reporting Firm’s reportable accounts for each trading day. Formatting for the files, which are referred to as “CftcBatch files,” must conform to the XML structure specified by FIA Tech.

8.2 Reporting Firm Uploading of Daily Trading Data

Reporting Firms may develop their own internal capability to produce daily CftcBatch files in the XML format specified by FIA Tech identifying their accounts that require reporting to the CFTC. Each Reporting Firm delivers its CftcBatch files directly to FIA Tech via upload to a designated folder on the FIA Tech SFTP server for its files.

8.3 Reporting Firm Manual Generation of Ownership and Control Reports

Reporting Firms anticipating a relatively small number of accounts that will require ownership and control reporting may monitor their trading internally and trigger the reporting manually within the FIA Tech OCR Portal. This process, which should be done on a daily basis to ensure timely reporting of reportable accounts, is performed as described in this section.

NOTE: For reporting on Trading Accounts filed within the OCR Portal, Market Associations must be made before reports can be filed. See Section 6.9.

8.3.1 Initiate Reporting of an Account

Locate the Account to be reported using the search process described in Section 6.7.1.

From the Account Details screen, click on the File Report button in the Form 102 Reports section of the screen. See Figure 242.



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Figure 242

After you click on the File Report button, you will see a File Report pop-up box with a warning message alerting you that you are about to report that an account has met the threshold criteria for ownership and control reporting on the date shown. See example of the warning message in Figure 243.

Figure 243

Note: If a Trading Account is being reported and Market Associations have not been established, you will not be able to proceed with the reporting. Instead, the error message shown in Figure 244 will be displayed in the File Report pop-up box.

Figure 244



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Add Market Associations to any Trading Accounts that you will be reporting, either individually or within a Special Account, prior to performing the reporting. See Section 6.9.

8.3.2 Select the Destination for the Report

Within the File Report pop-up box, select the appropriate destination for the report using the drop-down list in the Destination field. See Figure 248.

Figure 245

NOTE: The default Destination for reporting is CFTC.

8.3.3 Identify the Markets to be Reported, if Required

After you have selected the Destination for the report, if you are reporting a Trading Account or Special Account, indicate the market in which the trading that triggered the reporting took place.

NOTE: For Consolidated Accounts, a market is not designated.

Specification of the markets is described below for Trading Accounts and Special Accounts respectively.

8.3.3.1 Identify the Market for a Trading Account

Within the File Report pop-up box, you will need to indicate the market or markets for your reporting of a Trading Account.

Use the drop-down list to select the Markets in which the threshold for reporting was met and place a check mark in the appropriate checkboxes. See Figure 246.

NOTE: The drop-down list reflects the Market Associations that were made to the Trading Account.



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Figure 246

8.3.3.2 Identify the Market for a Special Account

Within the File Report pop-up box, you will need to indicate the market or markets for your reporting of a Special Account.

Use the drop-down list to select the Markets in which the threshold for reporting was met for each Trading Account within the Special Account. See Figure 247.

NOTE: The drop-down list reflects the Trading Account Associations that were made to the Special Account, as well as the Market Associations within each Trading Account. See Section 6.8 and Section 6.9.

Figure 247

8.3.4 File the Report

Click on the File Report button within the File Report warning message to file the report. See Figure 248.



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Figure 248

After you have filed the report, you will see a message stating that the report was filed successfully. See Figure 249.

Within the Form 102 Reports box details related to the filing will appear, together will certain historical data for reports filed to other Destinations.

NOTE: Columns used to display data within the Form 102 Reports box can be sorted and filtered as needed. See Figure 249.



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Figure 249

NOTE: Details related to the Form 102 filing will be shown within the Form 102 Reports box and will remain there until a subsequent report to the same Destination is filed. See Figure 250.




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Figure 250

Further details related to Notifications in the Dashboard related to reporting may be found in Section 9.2.1.



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Chapter 9 System Functions and Notifications

9.1 FIA Tech OCR Data Service Reporting to the CFTC

The FIA Tech OCR Data Service stores data in Accounts and associated Profiles entered via the OCR User Portal web interface as described in this document or uploaded and maintained via FIABatch files submitted by Reporting Firms. This data is amalgamated with data provided by the Reporting Firms on a daily basis that identify, for each trading day, accounts that engaged in reportable trading. The means by which Reporting Firms provide this trading data is described in Chapter 8.

Using the data provided directly by the Reporting Firms or by their third party contractors that indicate, on a daily basis, the Accounts to be reported and their respective Account Categories, the system generates and electronically submits Form 102A, Form 102B, and Form102S files to the CFTC and Central Counterparty Clearing Houses (CCP). In addition, if an Account was reported within the last year and reference data stored within the system has changed, an additional report is filed to update the changed information.

9.2 Automated System Notifications to Users

To ensure that Participant firms have the ability to monitor their ownership and control reporting and maintain records of their reporting as needed in accordance with their record retention policies, the FIA Tech OCR Data Service provides notification of the reporting and copies of reports filed with the CFTC to each Reporting Firm. The Service also monitors data quality and notifies users of potential erroneous, incomplete, or redundant data in Profiles and Accounts as reflected in the reports. Finally, the FIA Tech OCR Data Service also provides notifications related to system upgrades and availability of system resources. All Notifications to users remain in the Dashboard for up to one month.

These notices are described in this section.

9.2.1 Notifications of Ownership and Control Reports Filed with the CFTC

The OCR Data Service notifies Reporting Firms when ownership and control reports were filed with the CFTC and provides copies of the reporting in the Dashboard. If a report was successfully filed and required information was complete in the Accounts reported and in any associated Profiles, the status of the report will be Success. If there were errors in the report due to incompleteness of the reported information, the status of the report will be Warning. See Figure 251.

Click on the arrow at the left of each row to view of the details of the Notification. See Figure 251.

Click on the filename to download and review the reported information. See Figure 251.



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Figure 251

FIA Tech provides a copy to Reporting Firms of reports filed with the CFTC and other destinations, which serves as the notification of the reporting, in an .xml file named “OCRFORM_102_...” followed by the Reporting Firm’s three-letter identifier assigned by the CFTC and the date when the report was filed. See Figure 251. Within the file, which may be downloaded and opened in Excel or using any other XML-aware tool, the data that was reported can be reviewed, including information about the Account that was reported together with related data from any associated Accounts and Profiles.

In the event that certain Accounts were reportable on a given trading day based on position or volume of trades but the Accounts were recently reported and no information in the report has changed, Reporting Firm Users are provided an Info notification of the specific number of Form 102A, Form 102B, or Form 102S reports were suppressed “due to no change.”

9.2.2 File Load Notifications Related to Importing of FIABatch Files

The OCR Data Service supports uploading of large volumes of account data to a FIA Tech SFTP server in a standardized FIABatch .xml format. The FIABatch format contains designated fields that map directly to the fields used in the OCR Portal for entry and maintenance of Accounts. FIABatch files also contain the OCR Profile ID of associated Profiles and specify the status of each Profile as



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that of an Owner or Controller. Because of the complexity of the internal FIABatch file structure, Participants and their Reporting Firms that submit FIABatch files to FIA Tech normally do so with the assistance of their IT departments.

Participants that have uploaded FIABatch fields to the FIA Tech SFTP server receive confirmation notifications in the Dashboard that their uploaded files were successfully imported into the system. These notifications have Info status and inform the Reporting Firm of the “File loaded.” They also identify the imported file by its .xml file name “FIABATCH …” followed by the firm’s Participant Code, the date of the import, 0and a system-generated alphanumeric string.

Participant’s wishing to do so can verify their uploaded Account data by searching their Accounts in the OCR Portal and locating new data that was loaded into the system via the FIABatch file referenced.

If a FIABatch file that was uploaded could not be imported into the system because of structural defects in the data, an Error notification is provided in the Dashboard stating that “[f]ile has structural error(s) and failed to load,” followed by the firm’s Participant Code, the date of the attempted import, and a system-generated alphanumeric string. Within the Error notification, details of the validation error are shown.

Notification of imported FIABatch files that contain nonfatal errors is provided in a Warning message in the Dashboard informing Reporting Firm Users that a “[f]ile [was] loaded with validation errors,” followed by the firm’s Participant Code, the date of the import, and a system-generated alphanumeric string. Within the Warning notification, details of the validation error are shown. These errors may be corrected manually by accessing the relevant accounts in the OCR Portal or by updating the erroneous information via uploading of a subsequent FIABatch file.

9.2.3 Notification of a FIABatch File Export

The OCR Data Service provides Reporting Firm Users daily FIABatch file exports containing complete reference data for their Participant organization, including both Accounts and Profiles, and providing a means of reviewing and correcting information that the firm has entered into the system. Notifications of a FIABatch export generated by the system are provided in the Dashboard with a Success message stating “FiaBatch exported” and showing a link to the exported .xml file that can be downloaded for review. These exported FIABatch files have the file name “FIABATCH …” followed by the firm’s Participant Code and the date of the export.

The number of Accounts and Profiles contained in the FIABatch file export is displayed in the line where the notification is shown. See Figure 252.



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Figure 252

If the Reporting Entity User determines that corrections to the exported data are required, these corrections may be entered directly into the downloaded FIABatch file and uploaded back into the system via the FIA Tech SFTP server.

NOTE: FIABatch files contain data from Profiles that are managed by, or visible to, your firm. You may upload corrections to Profile information only for the Profiles that your firm manages. Profiles that were made visible to your firm for reporting purposes cannot be updated by your firm. Any required updating to the latter Profiles must be done by the Profile Managers for those Profiles.

To facilitate the proper entry and uploading of changes, FIA Tech suggests that Reporting Entity Users should work with their IT departments to view and edit exported FIABatch files using the department’s XML editing software.

9.3 Additional Notifications

The FIA Tech OCR Data Service will provide additional notifications to users via the Dashboard and other means to ensure the accuracy, currency, and consistency of data maintained in the system. In addition, users will also be informed of system status changes and of upgrades and enhancements introduced in new versioning via specific notifications.

Users should expect the following kinds of future notifications that will be described in greater detail in future revisions of this USER GUIDE:

o Notification to Reporting Firm of new Profile created by Client



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o Notification to Profile Manager of request to perform annual update of Profile data

o Notification to Reporting Firm that Client has updated a Profile

o Notifications of system status changes, system revisions, revisions of this USER GUIDE, and other information of interest to users



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Chapter 10 Troubleshooting

10.1 OCR User Portal Browser Functionality

The OCR User Portal is optimized for Internet Explorer 9 and higher, Chrome 20 and higher, Firefox 25 and higher, and Safari 7 and higher. If your browser version is older than any of the browser versions indicated, you may not have full access to the features of the system. The notification shown below will alert you to the incompatibility of your browser. See Figure 253.

Figure 253

10.2 OCR User Portal Logs You Out

You may be required to log back in to the OCR Data Service if, after logging in, there is no activity during the session for at least 27 minutes. Prior to being logging you out, the system will display a Need more time? warning with a countdown that reads as follows:

Your session is about to expire in 02:59 minutes. To continue your session, click 'Stay Logged In' below.

If you are logged off, any changes will be lost.

When you see the warning message, be sure to resume your work by clicking the Stay Logged In button if you intend to do so in order to suspend the automatic log out.

10.3 Email Registration Instructions Not Received by Client

If you are a Client and you registered to use the FIA Tech OCR Data Service but did not receive an email message providing further instructions to complete your registration, check your spam box to ensure that the message was not treated as spam by your email client.

If the registration message was not routed to spam, you may have entered an incorrect email address during the registration process. Contact FIA Tech for assistance using the contact information provided in Chapter 11.

10.4 Email Registration Instructions Not Received by New Reporting Firm User

If you are an Administrator you registered to new user to access the FIA Tech OCR Data Service but the new user did not receive an email message providing further instructions to complete the registration, ask the new user check his or her spam box to ensure that the message was not treated as spam by the new user’s email client.

If the registration message was not routed to spam, the email address that you entered during the registration process may have been incorrect. Contact FIA Tech for assistance using the contact information provided in Chapter 11.



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10.5 Log In Issues

If you are not successful when attempting to log in to the system using your User Name, you may wish to try logging in using your email address instead. You should be able to log in using your email address or user name together with your password.

Once you have logged in using your email address, view the My Details screen in My User Account to verify your User Name. See Figure 12.

10.6 Lock Out After Multiple Failed Login Attempts

If you are unable to log in to the FIA Tech User Hub and see a message on your screen saying, “Failure Policy Exceeded,” you have been locked out of the system as a result of repeated unsuccessful login attempts. The FIA Tech User permits four unsuccessful login attempts and locks out user who make a fifth unsuccessful attempt. If you are locked out of the User Hub, contact FIA Tech for assistance with resetting your password. Reporting Firm Users may also turn to their Administrators for assistance with password resets.

10.7 Access to Profiles

If you are a Reporting Firm User and you are unable to view Profiles to which you believe you should have access, check with your Reporting Firm Administrator to ensure that your user roles have been correctly established.

Once your user roles have been verified, if you are still unable to view your Participant’s Profiles, contact FIA Tech for assistance using the contact information provided in Chapter 11.

10.8 Foreign Broker Unable to Associate Profile of Domestic FCM

If you are a Foreign Broker associating the Profile of a U.S. Reporting Firm as your Domestic FCM and your organization is not a Reporting Firm within the Participant organization of the Domestic FCM, you may be unable to locate the Profile of your Domestic FCM when you search for it. Contact your Domestic FCM for assistance. Your Domestic FCM should be able to set a Permission within their Profile that will give you the access you need to perform the Association within your Special Accounts. Moreover, to the extent that your Domestic FCM may file ownership and control reports for your trades within an Omnibus Account, you may wish to coordinate with them regarding any other Profile Associations used.



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Chapter 11 Obtain Additional OCR Data Service Support In the event that issues or questions arise in relation to the FIA Tech OCR Data Service or the OCR Portal that are not addressed in this USER GUIDE, use the information in this chapter to contact FIA-Tech and obtain additional support.

NOTE: Prior to contacting us, you may wish to verify that you are using the most current version of this USER GUIDE by checking the Dashboard for current version information. If your issues are related to new versioning, the most recent version of the USER GUIDE should address any changes and may be responsive to your concerns.

To contact FIA Tech with any issues or concerns, use the information provided below:

11.1 Immediate Support

For an issue requiring an immediate response, check the FIA Tech website at fia-tech.com/contacts for phone contact information and hours of operation for our offices in Washington, DC and Singapore.

11.2 General Inquiries

Send email messages related to the FIA Tech OCR Data Service to [email protected]. You will receive a response to your message within two business days.


http://www.fia-tech.com/contacts

mailto:[email protected]


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Appendix A – Annotations to Selected Screenshots This USER GUIDE includes images of screens in the FIA Tech User Hub and OCR Data Service featuring fictitious examples of Legal Entities and Natural Persons in Client, Reporting Firm, Owner, Controller, and other roles and relationships for the purpose of illustrating certain OCR Portal functions.

These examples have no relationship to any existing person or entity and any resemblance to any existing person or entity is unintentional.

The following information is provided to aid in understanding of examples used. Click on the link to navigate to the figure or section where the information is used.


This screenshot shows My Details for Russell Warren’s User Account. Russell Warren is a Client user of the system.

The following information is reflected in the screenshot:

Russell V. Warren

User: Russell V. Warren

Employer: Great Lakes National Insurance Trust

Address: 5572 Olson Parkway, Cleveland OH 44106

Phone: 614-555-1234

Legal Entity ID: NA

NFA ID: NA

Website: NA

Email: [email protected]

Return to Figure 12.


This screenshot shows My Details for William Gustafson’s User Account. William Gustafson is a Reporting Firm user of the system.


William Gustafson

User: William Gustafson

Employer: International Bank Ltd

Address: 150 Howard Avenue, Houston, TX 77098

Phone: 281-222-3333

Legal Entity ID: NA

NFA ID: NA

Website: NA




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This screenshot shows the Profile Details for the Profile of Jeffrey Walker, which was located in search results. Jeffrey Walker is a Natural Person and the Owner of Jeffrey Walker Enterprises, a real estate development company. Russell Warren is the Trader for Jeffrey Walker’s account and acts as the Controller.


Jeffrey Walker

Name of Owner: Jeffrey Walker

Address: 5227 Oaklyn Ave, Cincinnati, OH 45203

Phone: 614-555-1234

Legal Entity ID: NA

NFA ID: NA

Website: NA


Jeffrey Walker Enterprises

Employer: Jeffrey Walker Enterprises

Address: 22 Main Street, Tenth Floor, Cincinnati, OH 45204

Phone: 614-555-6789

Legal Entity ID: NA

NFA ID: NA

Website: NA


Russell V. Warren

Name of Controller: Russell V. Warren



Phone: 614-555-1234

Legal Entity ID: NA

NFA ID: NA

Website: NA








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This screenshot shows the completion of a Legal Entity Profile for an Owner, Fox Creek Gas and Electric Utility, Inc., which has a Legal Entity ID (LEI). Information from the LEI is being used to provide address information for the Profile.


Fox Creek Gas and Electric Utility, Inc.

Name of Owner: Fox Creek Gas and Electric Utility, Inc.

Address: 202 S. Merton St., Appleton, WI 54911

Phone: 920-555-1234

Legal Entity ID: 278700F1LGTOH9J3H622

NFA ID: NA

Website: www.fcge.com




This screenshot shows the completion of a Legal Entity Profile for an Owner, Fox Creek Gas and Electric Utility, Inc., which has a Legal Entity ID (LEI). Information from the LEI is being used to provide address information for the Profile. Sarah Gustafson is an employee and serves as the Main Contact for the firm.





Phone: 920-555-1234


NFA ID: NA



Sarah Gustafson

Name of Main Contact: Sarah Gustafson

Title Chief Financial Officer


Phone: 920-555-1234


NFA ID: NA



http://www.fcge.com/






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This screenshot shows the completion of a Legal Entity Profile for an Owner, Strategic Capital Growth Fund. Marcia K. Finley is an employee and serves as the Main Contact for the firm. Her title is Strategic Investment Advisor.


Strategic Capital High Growth Fund

Name of Owner: Strategic Capital High Growth Fund

Address: 5572 57th Street, Kansas City, MO 64108

Phone: 816-555-1234

Legal Entity ID: 558700F1GYTVH9J5H331

NFA ID: 10000001

Website: www.stratcapinvestment.com


Marcia K. Finley

Name of Main Contact: Marcia K. Finley

Title of Main Contact: Strategic Investment Advisor

Employer: Strategic Capital Investment Trust, LLC


Phone: 816-555-1234

Legal Entity ID: 558700F1GYTVH9J5H331

NFA ID: 10000001

Website: www.stratcapinvestment.com




This screenshot shows two Account Controllers that were added to an owner Profile. Russell Warren is one Controller and his employer, Great Lakes National Insurance Trust, has been added to the Profile as an additional Controller.


Russell V. Warren





http://www.stratcapinvestment.com/


http://www.stratcapinvestment.com/



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Phone: 614-555-1234

Legal Entity ID: NA

NFA ID: NA

Website: NA


Great Lakes National Insurance Trust

Name of Controller: Great Lakes National Insurance Trust


Phone: 614-555-1234

Legal Entity ID: 558700F1HHCLH9J5H741

NFA ID: 2222222

Website: www.glnit.com




This screenshot shows that Profiles for Account Controllers added to an owner Profile include the owner Profile as a Controlled Account. Because Great Lakes National Insurance Trust was identified as Controllers for Health Fund, Inc, Health Fund, Inc. is one of the Controlled Accounts in the Profile of Great Lakes National Insurance Trust. Health Fund, Inc. is another account that that Great Lakes National Insurance Trust controls.


Great Lakes National Insurance Trust

Name of Controller: Great Lakes National Insurance Trust


Phone: 614-555-1234


NFA ID: 2222222



Jeffrey Walker



Phone: 614-555-1234

Legal Entity ID: NA

NFA ID: NA

Website: NA



http://www.glnit.com/




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Health Fund, Inc.

Name of Owner: Health Fund, Inc.

Address: 520 Main Street, Suite 100, Columbus, OH 43518

Phone: 614-555-5678

Legal Entity ID: 549300TSTPJCEQYZ1Z65

NFA ID: NA

Website: www.healthfundinc.com




This screenshot shows the Profile for the Ocean Bay Commodity Advisors, a firm that acts as a Third Party Controller and includes three personnel who act as individual Controllers.

Ocean Bay Commodity Advisors is not an Owner. Ocean Bay Commodities Advisors directs trading for Owners who are clients of other firms.

Ocean Bay Commodity Advisors

Name of Firm: Ocean Bay Commodity Advisors

Address: 520 Prater Way, Reno, NV 89431

Phone: 775-555-1234


NFA ID: 1120001

Website: www.obca.com


Samantha G. Foster

Name of Main Contact: Samantha G. Foster

Title of Main Contact: CEO

Employer: Ocean Bay Commodity Advisors


Phone: 775-555-1001


NFA ID: 1120001



Merylin Carasa

Name of Controller: Merylin Carasa

Title: Sr. FX Trader



http://www.healthfundinc.com/


http://www.obca.com/





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Phone: 775-555-1256

NFA ID: 1124311



Rodney Hudaker

Name of Controller: Rodney Hudaker

Title Commodities Associate



Phone: 775-555-1278

NFA ID: 1124312



Reina Salas

Name of Controller: Reina Salas

Title: Senior Investment Strategist



Phone: 775-555-1290

NFA ID: 1124313





This screenshot shows that two Reporting Firms, International Bank Ltd and Industrial Bank of Greece, have been organized under one Participant Code, INTL. Market roles are managed separately for each Reporting Firm.


International Bank Ltd

Name of Reporting Firm: International Bank Ltd


Phone: 281-111-1111

Legal Entity ID: AQDC2L0IWKO41Q0QJL52









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NFA ID: 6666666

Website: www.internationalbank.com


Industrial Bank of Greece

Name of Reporting Firm: Industrial Bank of Greece

Address: 150 El. Venizelou, 106 72 Athens, Greece

Phone: 30 210 4466-446

Legal Entity ID: NA

NFA ID: NA

Website: www.ibg.com




This screenshot shows that the Reporting Firm International Bank Ltd has identified that its role of FCM is applicable to all markets within which it trades, and that, additionally, it trades as a Swap Dealer within the ICAP SEF (US) LLC.





Phone: 281-111-1111


NFA ID: 6666666





This screenshot shows that when the Profile of Health Fund, Inc was associated to a Trading Account as the Owner, a Profile was automatically associated for the Default Controller, Russell V. Warren, based on information in the Owner’s Profile.


Health Fund, Inc.




http://www.internationalbank.com/


http://www.ibg.com/





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Phone: 614-555-5678


NFA ID: NA



Russell V. Warren

Name of Default Controller: Russell V. Warren



Phone: 614-555-1234

Legal Entity ID: NA

NFA ID: NA

Website: NA




This screenshot shows that the Default Controller for Health Fund, Inc was overridden by the addition of a Controller, Phyllis Wimberlie. When Phyllis Wimberlie’s Profile was associated in the role of Controller, the Default Controller Profile of Russell V. Warren was automatically removed.


Health Fund, Inc.



Phone: 614-555-5678


NFA ID: NA



Russell V. Warren

Name of Controller: Phyllis Wimberlie



Phone: 614-555-4321

Legal Entity ID: NA

NFA ID: NA

Website: NA








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This screenshot shows that the Profile of Lesley D. McAleese was associated to a Special Account for which the Origin Reason was Owner. Lesley D. McAleese has been identified as the Owner of the Special Account.


Lesley D. McAleese

Name of Owner: Lesley D. McAleese

Address: 2205 North Bend Drive, Blue Springs, MO 64015

Phone: 816-555-3456

Legal Entity ID: NA

NFA ID: NA

Website: www.mcaleesedodd.com




This screenshot shows that the Profile of Strategic Capital Investment Trust, LLC was associated to a Special Account for which the Origin Reason was Controller. Strategic Capital Investment Trust, LLC has been identified as the Controller of the Special Account.


Strategic Capital Investment Trust, LLC

Name of Controller: Strategic Capital Investment Trust, LLC


Phone: 614-555-1234


NFA ID: 2222222









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This screenshot shows that the Profile of Fox Creek Gas and Electric Utility, Inc. was associated to a Special Account for which the Origin Reason was Owner & Controller. Fox Creek Gas and Electric Utility, Inc. has been identified as the Owner & Controller of the Special Account.



Name of Owner & Controller: Fox Creek Gas and Electric Utility, Inc.


Phone: 920-555-1234


NFA ID: NA





This screenshot shows that the Profile of Fox Creek Gas and Electric Utility, Inc. was associated to a Special Account for which the Origin Reason was Owner & Controller. Fox Creek Gas and Electric Utility, Inc. has been identified as the Owner of the Special Account on the first line and the Controller of the Special Account on the second line. The OCR Profile ID is OCR2630 for both the Owner and Controller, demonstrating that the same Profile was associated twice.





Phone: 920-555-1234


NFA ID: NA




Name of Controller: Fox Creek Gas and Electric Utility, Inc.


Phone: 920-555-1234


NFA ID: NA









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This screenshot shows that the Reporting Firm International Bank Ltd has identified that its role of Domestic FCM for a Special Account that is being reported by the Industrial Bank of Greece. The Controller of the Special Account is Nicholas Zolotas, whose title is Vice President, International Department at the Industrial Bank of Greece.


Industrial Bank of Greece

Name of Reporting Firm: Industrial Bank of Greece


Phone: 30 210 4466-446

Legal Entity ID: NA

NFA ID: NA

Website: www.ibg.com





Phone: 281-111-1111


NFA ID: 6666666



Nicholas Zolotas

Name of Controller: Nicholas Zolotas

Employer: Vice President, International Department


Phone: 30 210 4466-446

Legal Entity ID: NA

NFA ID: NA

Website: NA





http://www.ibg.com/






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This screenshot shows Profiles for the Owner and Controller were associated to a Consolidated Account. Jeffrey Walker is the Owner and Russell Warren is the Controller. When the Consolidated Account is reported, information in the report is obtained from the two associated Profiles.


Jeffrey Walker



Phone: 614-555-1234

Legal Entity ID: NA

NFA ID: NA

Website: NA


Russell V. Warren




Phone: 614-555-1234

Legal Entity ID: NA

NFA ID: NA

Website: NA




This screenshot shows that the Reporting Firm International Bank Ltd has been identified as the Omnibus Originator for a Consolidated Account.





Phone: 281-111-1111


NFA ID: 6666666








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This screenshot shows that two Trading Accounts were associated with a Special Account. Note that Accounts were associated, not Profiles!


Lesley D. McAleese

Name of Account: Lesley D. McAleese

Account Number: 6027851T

Owner of Account: Lesley D. McAleese

Controller of Account: Marcia K. Finley


Phone: 816-555-3456

Is Omnibus: No

Class: Customer

Associated Special Account: Strategic Capital, 9999351


Name of Account: Strategic Capital High Growth Fund


Owner of Account: Strategic Capital Investment Trust, LLC



Phone: 816-555-1234

Is Omnibus: No

Class: Customer




This screenshot shows that two Trading Accounts were associated with a Special Account. Note that Accounts were associated, not Profiles!


Lesley D. McAleese

Name of Account: Lesley D. McAleese


Owner of Account: Lesley D. McAleese




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Phone: 816-555-3456

Is Omnibus: No

Class: Customer



Name of Account: Strategic Capital High Growth Fund


Owner of Account: Strategic Capital Investment Trust, LLC



Phone: 816-555-1234

Is Omnibus: No

Class: House




This screenshot shows that within the Trading Account established for Fox Creek Gas and Electric Utility Pension Fund, the Controller whose Profile was added to the Account was initially identified as an Employee. The Relationship to Owner field has been corrected to Officer.


Fox Creek Gas and Electric Utility Pension Fund

Name of Trading Account: Fox Creek Gas and Electric Utility Pension Fund


Owner of Account: Fox Creek Gas and Electric Utility, Inc.



Phone: 816-555-1234

Is Omnibus: No

Class: Customer





Phone: 920-555-1234


NFA ID: NA



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Jacob J. Hamilton

Name of Controller: Jacob J. Hamilton

Employer: Fox Creek Gas and Electric Utility, Inc.


Phone: 920-555-1234




This screenshot shows that information about Swaps and Swaptions was added the Consolidated Account established for Jeffrey Walker.


Jeffrey Walker



Phone: 614-555-1234

Legal Entity ID: NA

NFA ID: NA

Website: NA


Russell V. Warren




Phone: 614-555-1234



ANNOTATIONS FOR CHAPTER 7, REPORTING FIRM ADMINISTRATOR FUNCTIONS

This section uses examples to illustrate creation and management of User Accounts by Reporting Firm Administrators. These examples are based on the following information:

International Bank Ltd is a Participant comprising two Reporting Firms, International Bank Ltd and Industrial Bank of Greece.







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Two Reporting Firm Administrators were created for the International Bank, Ltd at the Participant level:

o Rebecca Peters was established as the Reporting Firm Administrator for International Bank Ltd.

o Rebecca Peters created an additional Reporting Firm Administrator for International Bank Ltd, Miyeoung Park.

Three Reporting Firm Users were created for International Bank, Ltd by the two Reporting Firm Administrators:

o Rebecca Peters created one Reporting Firm User, William Gustafson.

o Miyeoung Park created two Reporting Firm Users, Maria Hernandez and Goh Hui Ling.

Return to CHAPTER 7.


This screenshot shows Last Sent On dates for Form 102 reports filed by the Fox Creek Gas and Electric Utility Pension Fund to the CFTC and CME.


Fox Creek Gas and Electric Utility Pension Fund

Name of Trading Account: Fox Creek Gas and Electric Utility Pension Fund


Owner of Account: Fox Creek Gas and Electric Utility, Inc.



Phone: 816-555-1234

Is Omnibus: No

Class: Customer





Phone: 920-555-1234


NFA ID: NA



Jacob J. Hamilton

Name of Controller: Jacob J. Hamilton

Employer: Fox Creek Gas and Electric Utility, Inc.






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Phone: 920-555-1234






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Appendix B – Third Party Controller Integration

Third Party Controller Integration

The OCR Final Rule requires reporting of owner and controller information to the CFTC by Reporting Firms. Reporting Firms base their reporting of owner and controller information on data provided by their Clients, who establish owner and controller Profiles within the OCR Data Service and enable specific Reporting Firms to access and use them. In most cases, the Clients of the Reporting Firms are Controllers, i.e., Legal Entity Controllers, of accounts owned by their clients. The Clients’ employees act as Controllers, i.e., Natural Person Controllers, for the Owners, and their information must be included with reporting of the Owner’s trades.

These various relationships are represented in Figure B-1.

Owner

Natural Person

Controller

Legal Entity

Controller

Trading Account

Owner

Natural Person

Controller

Client user establishes ProfilesReporting Firm associates Profiles with its Accounts.

Figure B-1

An unusual situation arises when the Clients of the Reporting Firms engage the services of other firms to direct certain trading. When this occurs, the other firm, typically a Commodity Trading Advisor, is considered a Third Party Controller.

An example of an Owner’s Profile that will include a Third Party Controller directing some of the trading is shown in Figure B-2:

Owner

Natural Person

Controller

Client user engages Third Party Controller

Legal Entity

Controller

Legal Entity

Controller+

Figure B-2



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To ensure that data about Third Party Controllers is available to the Reporting Firms that are required to report it, firms that function as Third Party Controllers must enter their information into Profiles in the OCR Data System. The integration of their Third Party Controller information with other controller information that is reported is described below.

Third Party Controller Profiles are visible to all Client Users and specific Report Firms as established by permissioning.

When Third Party Controllers create their Profiles, they include in their firm’s Profile the employees of the firm who function as Account Controllers. See Figure B-3.

Third Party Controllers do not create Profiles of Owners.

Legal Entity

Controller

Natural Person

Controller

Natural Person

Controller

Natural Person

Controller

Permissioned to Reporting Firms

Third Party Controller Profiles include the Profiles of their Account Controllers

Visible to all Client users

Figure B-3

Client users identify Third Parties that they work with as Legal Entity Controllers for an Owner.

When a Client user is working with a Third Party Controller who directs trading for an Owner, the Third Party Controller firm is added to the Owner’s Profile. See Figure B-4.

Owner

Natural Person

Controller

Legal Entity

Controller

Client user identifies Third Party Controller as a Controller for an Owner

Legal Entity

Controller

Figure B-4

Reporting Firms report the individual Account Controllers who work for Third Party Controllers by associating their Profiles to the firm’s Trading Accounts.



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Reporting Firms access the Natural Person Controllers employed by the Third Party Controller and include them in the reporting of their Accounts. See example in Figure B-5.

Trading Account

Owner

Natural Person

Controller

Natural Person

Controller

Natural Person

Controller

Natural Person

Controller

Reporting Firm reports the Natural Person Controllers of the Third Party Controller with the Account

Figure B-5

In the event that multiple Trading Accounts are organized in a Special Account under the Third Party Controller, the Third Party Controller’s Legal Entity Profile is associated to the Special Account.

When a Special Account is formed with the designated Origin Reason “Controller” based on a Third Party Controller, the Reporting Firm associates the Third Party Controller’s Legal Entity Profile with the Special Account. See example in Figure B-6.

Trading Account

Owner

Natural Person

Controller

Natural Person

Controller

Natural Person

Controller

Natural Person

Controller

Trading Account

Owner

Natural Person

Controller

Natural Person

Controller

Natural Person

Controller

Special Account

Legal Entity

Controller

Special Accounts include the Legal Entity Profile of the Third Party Controller

Figure B-6



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Appendix C – Automatic Permission Inheritance

Automatic Permission Inheritance

The OCR Final Rule requires that reporting of information for Owners that are Legal Entities include a Main Contact for the entity. For Owners who are individuals, or "Natural Persons," information about the Owner's Employer is not required by the CFTC but may be included in the Owner’s Profile if the Owner has an Employer and the information is known.

Reporting of controller information requires the same designations. For Controllers that are Legal Entities, a Main Contact is required. For Controllers who are individuals, or "Natural Persons," the Owner's Employer must be reported.

Automatic Permission Inheritance ensures that, when you create a Profile for a Legal Entity (regardless of whether Owner, Controller, or Employer), the Legal Entity's Permissions inherit automatically to any Main Contact. Likewise, if you create a Profile for a Natural Person (regardless of whether Owner, Controller, or Main Contact), the Natural Person's Permissions inherit to the Employer, if you have designated an Employer.

Introduction

This document describes how Permissions granted to a Profile affect the Permissions of its related Profiles. The following rules apply:

Rule 1 Permissions are automatically inherited or revoked only if there is a Primary-Secondary Profile Relationship between two Profiles.

Rule 2 Automatic Permission Inheritance applies from a Primary Profile to a Secondary Profile.

These rules are discussed in turn.

Rule 1 - Permissions are automatically inherited or revoked only if there is a Primary-Secondary Profile Relationship between two Profiles.

A Primary-Secondary Relationship is established between two Profiles when one Profile, the Primary Profile, includes data from another Profile, the Secondary Profile. In the example shown in Figure C-1, the Primary Profile is for a Natural Person Owner and includes data from the Secondary Profile that was created for the Owner’s Employer. See Figure C-1.



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Figure C-1

As Error! Reference source not found. shows, OCR2597, the Profile of Jeffrey Walker, ncludes data from OCR2596, the Profile of Jeffrey Walker Enterprises. Russell Warren, who created the two Profiles, has identified Jeffrey Walker Enterprises as Jeffrey Walker’s employer. The two Profiles are in a Primary-Secondary Relationship.

In the example shown in Error! Reference source not found., the Primary Profile is for a egal Entity Controller and the Secondary Profile is for the Legal Entity’s Main Contact. See Figure C-2.

Primary Profile

Secondary Profile

Owner

Employer



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Figure C-2

In Figure C-2, OCR2599 is the Primary Profile and OCR2598 is the Secondary Profile. The Profiles are in a Primary-Secondary Relationship because OCR2599, the Profile for Great Lakes National Insurance Trust, contains data from OCR2598, the Profile of its Main Contact.

In the examples shown in Figure C-1 and Figure C-2, the Primary Profiles are Profiles of an Owner or Controller. In fact, all Profiles of Owners and Controllers are Primary with respect to their Main Contacts and Employers. These Primary-Secondary Relationships are shown in the diagram in Figure C-3.

Primary Profile

Secondary Profile

Controller

Main Contact



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Owner

Employer

Controller

Main Contact

Owner Controller

EmployerMain

Contact

Figure C-3

In some cases a Primary-Secondary relationship can be reciprocal. Reciprocity is established when the Natural Person who was designated as a Main Contact is also an employee of the same Legal Entity and the Employed by the Legal Entity checkbox was checked when the Main Contact was added. See the location of the Employed by the Legal Entity checkbox in Figure C-4.

Figure C-4

In the example shown in Figure C-5, Phyllis Wimberlie is an employee of Great Lakes National Insurance Trust and the Employed by the Legal Entity checkbox was checked when she was designated as its Main Contact. The Profile Details screen in Figure C-5 for Phyllis Wimberlie’s Profile shows that her Profile is Primary in relation to the Profile of Great Lakes National Insurance Trust, which is Secondary.

Based on reciprocity, Phyllis Wimberlie’s Profile and her employer’s Profile are both Primary and Secondary in relation to each other.

Main Contact



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Figure C-5

Other situations may also arise in which Primary Profiles may be a Main Contact or Employer. Profiles of Main Contacts can be Primary with respect to a third party Employer, in the event that a Main Contact for a Legal Entity has a a different employer. Finally, an Employer and a Main Contact can be in a Primary-Secondary Relationship if a Natural Person has an Employer whose Main Contact is another Natural Person. These Primary-Secondary Relationships involving Main Contacts and Employers are represented in Figure C-6.

Main Contact Employer

EmployerMain

Contact

Figure C-6

Finally, it should be noted that the relationship between Owners and Controllers is not Primary-Secondary. Therefore, Automatic Permission Inheritance and Revocation does not apply between Owners and Controllers. Account Controllers are listed in Owner Profiles within the Account Controllers section. See Figure C-2. Likewise, the Controlled Accounts section in controller Profiles lists the Owners for which the Controller directs trading. See Figure C-1. Although Owners and Controllers are both reported to the CFTC, controller Permission’s are established independently within the Controller’s Profile, after the Owner’s Permissions have been reviewed.

Based on the identification of Primary and Secondary Profiles set forth within Rule 1 and excluding Owner-Controller relationships, which are not Primary-Secondary, Rule 2 accounts for the behavior of Automatic Permission Inheritance when Permissions are added to ensure that reporting requirements are met.

Main Contact

Employer

Primary Profile

Secondary Profile



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Rule 2 - Automatic Permission Inheritance applies from a Primary Profile to a Secondary Profile.

Automatic Permission Inheritance ensures that any Permissions added to a Primary Profile are also added to the Secondary Profile. In the example shown in Figure C-1Error! Reference source ot found., Permissions that are added to Jeffrey Walker’s Profile (Primary Profile) inherit automatically to Jeffrey Walker Enterprises, his employer in the Secondary Profile. Likewise, Phyllis Wimberlie (Secondary Profile), the Main Contact for Great Lakes National Insurance Trust (Primary Profile), automatically inherits Permissions from the latter. See Figure C-2. Because of their reciprocal relationship, Great Lakes National Insurance Trust (Secondary Profile) inherits Permissions assigned to Phyllis Wimberlie (Primary Profile) as well. See Figure C-5.

Summary

Automatic Permission Inheritance applies only within Primary-Secondary Profile Relationships as described in Rule 1. Rule 1 excludes application of Automatic Permission Inheritance to Owner-Controller relationships, which are not Primary-Secondary.

Under Rule 2, Automatic Inheritance applies from Primary Profiles to Secondary Profiles. Therefore, when a Permission is added to a Primary Profile, it is added automatically to the Secondary Profile.



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Appendix D – Change History

Revision Date Summary of Changes

v.1 December 12, 2014 Initial publication conforming to OcrWeb 1-1.0.20.17

v.2 December 23, 2014 Update to align with OcrWeb v-1.0.21.7

v.3 January 12, 2015 Update to align with OcrWeb v-1.0.22.16 with substantial expansion of Section 5.5 and additions to Appendix A.

v.4 January 23, 2015 Update to align to OcrWeb v-1.0.23.8, add verification of figure callouts, and additions to Appendix A.

v.5 February 6, 2015 Update to align to OcrWeb v-1.0.25.2, restructure Appendix A with hyperlinks to and from selected figures, minor textual revisions throughout for clarification.

v.6 February 27, 2015 Update to align to OcrWeb v-1.0.25.7, add new Section 4.8 on management of Profile Permissions within grid structure, add new Section 5.4 on review of Profiles by Reporting Firms, and update procedure for filing reports.

v.7 March 19, 2015 Update to align to OcrWeb v-1.0.27.9, add new Appendix B on Automatic Permission Inheritance, substantially revise Section 5.4 to clarify workflow for review of Profiles, update screenshots, and introduce textual edits to improve style and clarify processes.

v.8 May 20, 2015 Add content related to Third Party Controllers, including a new Appendix B. Rename Appendix B to Appendix C and Appendix C to Appendix D.


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