THIS ARTICLE PROVIDES SYSTEM USER GENERAL GUIDANCE ONLY AND DOES NOT CONSTITUTE LEGAL ADVICE OR DEFINITIVE ADVICE OF ANY NATURE.
The Beneficial Owner CFTC 19-17 Contact is designed to address the requirement of CFTC Letter 19-17 (the “Letter”)( https://www.cftc.gov/node/217076 ) which mandates that US FCMs that support separate account margining obtain and maintain current contact information for an authorized representative of the beneficial owner of each separately margined clearing account at the US FCM. CFTC oral guidance is that designation of a representative at the asset manager is not permissible, and that the designated Beneficial Owner CFTC 19-17 Contact should be a natural person at or within the structure of the Beneficial Owner, with sufficient authority to receive and address an FCM’s notice that an account of the Beneficial Owner has failed to pay timely margin.
FIA Tech is enhancing its OCR data service to include the ability for user firms to create profiles representing the Beneficial Owner CFTC 19-17 Contact and to associate them with the Beneficial Owner profile. This new profile association feature is expected to be available in the system in August 2020.
Adding Natural Person Contacts
To get started on creating Natural Person profiles representing the Beneficial Owner CFTC 19-17 Contact it is recommended to first view what profiles you already manage in the system. Go to myapps.fia-tech.com to login, then go to OCR, Reports, Profile Extract. (A blank template can also be downloaded by going to Profiles, Upload, Excel Template.)
Make sure the drop down reads "Managed by Me", then click "Download Report".
This report will display all the profiles you currently manage in the system.
To create new Natural Person profiles in the system click on the Natural Person tab and enter the persons details.
Save the file locally, then go to Profiles, Upload, Select File.
This will create the new Natural Person profile in the system.
Associating 19-17 Contacts
Natural Person profiles can be associated to Owner profiles in one of two ways:
1. Associate via the UI
Go to the relevant Owner profile and click Edit:
Then under "Beneficial Owner CFTC 19-17 Contact" click "Choose Existing" or "Create New".
After choosing to associate an existing Natural Person profile as the 19-17 contact or creating a new Natural Person profile click save.
2. Associate via the upload spreadsheet
To associate a Natural Person profile via the upload spreadsheet simply enter the info into the 19-17 contact section on the Legal Entities tab:
Enter the Natural Person info exactly as it appears on the Natural Persons tab. To associate a new profile leave the "Ocr Profile Id" column blank and to associate a profile that already exists in the system enter the Natural Person profile's ID in the "Ocr Profile Id" column. Then upload the spreadsheet and check the Dashboard for error messages:
If you receive any dashboard errors upon upload or have any questions please feel free to contact FIA Tech at 1-202-772-3088 or email@example.com .