As the Commission prepares to receive OCR reporting in accordance with the dates outlined in No-Action Letter 15-03 dated February 10, 2015 (the 2015 Letter), the Commission’s Office of Data and Technology (ODT) will continue testing the submission of New Form 102 A/B/S through the CFTC Portal and the Secure FTP Process. The OCR Testing Regimen during the new no-action relief period will be broken out into three phases. This is a testing opportunity for the reporting parties and the Commission to validate complete Form 102 submissions. While the Commission’s Office of Data and Technology describes the data that should be received by the end of each testing phase, reporting parties should feel free to report as much of the OCR data as they can prior to the end of an applicable testing phase. In addition, all reporting parties should closely review the 2015 Letter for further information and conditions regarding the no-action relief.
Phase 1:
Start Date: Feb 24, 2015
End Date: April 28, 2015
By the end of Phase 1, each reporting party should have sent their complete set of production-grade New Form 102A data that has successfully passed both schema and rule validations. However, data regarding the trading accounts that comprise special accounts, including their owners and controllers, will be optional in Phase 1 and rule validation errors related to trading account data will not be returned for submissions that do not include this data. Trading account data for New Form 102A will be required by the end of Phase 3.
Phase 2:
Start Date: April 29, 2015
End Date: July 2, 2015
By the end of Phase 2, each reporting party should have sent their complete set of production-grade New Form 102S data that has successfully passed both schema and rule validations. This data should include information regarding consolidated account owners and consolidated account controllers, if applicable. As discussed in the 2015 Letter, parties submitting New Form 102S during the testing period are expected to provide, in addition to the data fields required on New Form 102S, the name, address, and contact information of the reportable counterparty.
Phase 3:
Start Date: July 3, 2015
End Date: September 4, 2015
By the end of Phase 3, each reporting party should have sent their complete set of production-grade New Form 102A, 102B and 102S data, including all fields required on the forms. Reporting parties should report DCM volume threshold accounts on New Form 102B during Phase 3, but not SEF volume threshold accounts (as such terms are defined in the 2015 Letter). The fields that should be submitted on New Form 102A, 102B and 102S include all owners, all controllers, and all trade level accounts and their owners and controllers. All submissions must have successfully passed both schema and rule validations by the end of Phase 3.
Definitions for terms above
Production-grade: The Commission expects to receive data that (a) in the context of New Form 102A testing, data that, to the extent it overlaps, is identical to data submitted pursuant to Part 17 of the Commission’s regulations (Large Trader data and Trader Capture Report data); (b) in the context of New Form 102S testing, data that, to the extent it overlaps, is identical to data submitted pursuant to Part 20 of the Commission’s regulations (Commodity Swaps data); and (c) in the context of New Form 102B testing, data that is equivalent to the data (with respect to DCM volume threshold accounts) that the Commission will receive following the implementation of electronic reporting on New Form 102B. Production Grade data will be used by the Commission only for testing purposes.
Complete Set: The Commission expects to receive the complete set of data from the reporting party for the forms identified, unless otherwise stated. This data would be the equivalent of a full refresh of the data sent to the Commission annually.
Questions about the OCR Testing Regimen should be sent to [email protected]
Reporting parties should periodically revisit this testing page for any updates to the OCR Testing Regimen.