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CFTC Rule and Forms

The CFTC recently adopted new requirements for reporting of trading data that significantly expanded existing reporting requirements by establishing new volume thresholds for reporting and identifying additional triggering events. These requirements were 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 published on November 18, 2013.


The OCR Final Rule establishes that Reporting Firms must file:

  • Form 102A when an account becomes reportable.
  • Form 102B when an account reaches a “Reportable Trading Volume Level” of 50 or more contracts on a DCM or SEF with the same product identifier during a single trading day.
  • Form 102S for a swap counterparty or customer consolidated account with a reportable position.

In addition, the OCR Final Rule established that:

  • Form 40s must be filed by owners and controllers upon special call by the CFTC.
  • Form 71s must be filed by originators of an omnibus volume threshold account or an omnibus reportable sub-account.

FIA Tech developed the OCR Data Service in response to the new Final Rule to provide a single technology platform for delivery of ownership and control data in a standardized format to regulators and exchanges. Support for the initiative was provided by a number of Reporting Firms seeking a secure, efficient, and reliable means to ensure their compliance. FIA Tech worked in partnership with the Reporting Firms and with the CFTC to develop and test the system prior to implementation, ensuring its robustness and validating its benefits to Reporting Firms as a cost-effective and reliable compliance solution.





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