MDO_Support_SOW_Amendment_1.pdf

Market Data Operations (MDO) Support

Amendment 1 – July 3, 2018

1.0 Background

Congress created the Commodity Futures Trading Commission (CFTC) in 1974 as an independent agency with the mandate to regulate commodity futures and option markets in the United States.

The Commodity Exchange Act was passed to serve the public interest by creating a system of self-regulation of trading facilities, clearing systems, market participants, and market professionals with oversight from the CFTC. The agency's mandate has been renewed and expanded several times since then, most recently by the Dodd-Frank Wall Street Reform and Consumer Protection Act.

The CFTC fosters markets that accurately reflect the forces of supply and demand and are free of disruptive activity by overseeing trade execution facilities, derivatives clearing organizations, swap dealers, data repositories, futures commission merchants, introducing brokers, commodity pool operators, commodity trading advisors and other market participants. The CFTC conducts surveillance, reviews new exchange applications, assures that market participants are in compliance with the Commodity Exchange Act and Commission regulations, including requirements imposed by the Dodd-Frank Wall Street Reform and Consumer Protection Act. All of these tasks and numerous others are achieved through vast quantities of data that is accumulated, verified, structured, analyzed, and reported.

Data is received daily from many market participants and usually loaded into the Commission’s Microsoft SQL Server databases. This data is received in a variety of different formats, but the agency is moving to XML data ingest standards (e.g. FIXML). Ad hoc files are often received in comma separated value (CSV) format, Microsoft Excel formats, or others. For the most part, this data ingest is handled by internal extract, transform, and load (ETL) processes.

The Data Management Branch (DMB) of the Office of Data and Technology (ODT) is responsible for the oversight, data architecture, and analytical support of electronic data received at the Commission. Working across all divisions, the DMB provides agency-wide data strategy, knowledge management, and query support. DMB data support includes building custom data visualization tools, prototyping conceptual data models, generating custom reports, and providing overall guidance on how to leverage the data available at the Commission.

The data analysis environment at the CFTC consists of SQL Server Management Studio (SSMS), SQL Server Reporting Services (SSRS), SAS, SAS JMP, MATLAB, Revolution Analytics “R”, Excel, PowerPivot, SharePoint, SAS Enterprise Business Intelligence Platform, Markit, Stata, SQL Services Analysis Services, and other third-party data analysis tools. Multiple fundamental factor models such as macroeconomic factor models, cross sectional fundamental factor models, and time-series fundamental factor models are often used when analyzing the CFTC data.

The intent of this statement of work (SOW) is to provide support for Market Data Operations (MDO) in processing Parts 16, 17, 20, 39, and 45 data. The work performed in this SOW will assist

MDO in carrying out its function of managing all data reported to the Commission in addition to handling all internal and external data requests.

2.0 Scope of Work

The contractor shall perform activities necessary to meet CFTC’s data management objectives as follows:

2.1 Large Trader Reporting of Daily Positions (Part 17): Ensure that data received from market participants is accurate and complete in the following ways:

2.1.1 Resolve Part 17 large trader errors identified in the Data Manager Application

(DMA)

2.1.2 Request missing position data from the reporting entities and ensure that the requested information is received. Missing data may should be submitted electronically.

2.1.3 Request and review submitted forms for unidentified accounts (Form 102A/S);

enter data into Integrated Surveillance System (ISS) and ensure that the account is associated with the correct trader. All forms are submitted electronically. Once the submitted information has been approved, the account needs to be associated with the correct trader.

2.1.4 Request Form 40s. Track, manage, and resolve Form 40 cases

2.1.5 Resolve large trader position, delivery notice, and exchange-traded fund (EFP) discrepancies as identified on the 00-01 report (this report compares positions reported by the firms to exchange-submitted clearing data

2.1.6 Resolve data issues related to the weekly publication of the Commitment of Traders (COT) report

2.1.7 Perform data reviews to ensure that submitted data is complete and matches source data at reporting firm.

2.1.8 Monitor the performance of market participants with regard to timeliness of submissions, the number of errors submitted on data files, discrepancies between what was reported and what was cleared.

2.2 Exchange Data Submissions (Part 16): Ensure that complete and accurate data is received from the exchanges in the following ways:

2.2.1 Review and resolve exchange data errors

2.2.2 Request the setup of new commodities when data is received for commodities not currently set up in ISS. Once the commodities have been entered, reprocess all exchange files containing data for those commodities.

2.3 Commodity Swaps Reporting (Part 20): Ensure that data received from market participants is accurate and complete in the following ways:

2.3.1 Review data submissions for completeness and accuracy

2.3.2 Process missing account identifications forms (Form 102S)

2.3.3 Request Form 40S; track, manage, and resolve 40S cases

2.3.4 Link 102S accounts to existing traders

2.3.5 Track the issues and performance of market participants

2.4 Ownership and Control Reporting (OCR): Ensure that data received from market participants is accurate and complete in the following ways:

2.4.1 Process volume threshold forms (Form 102B)

2.4.2 Process omnibus account identifications (Form 71)

2.4.3 Track the issues and performance of market participants

2.5 Swaps Data:

2.5.1 Review Part 45 data submissions

2.5.2 Review Swap Execution Facility (SEF) data submissions

2.5.3 Track the issues and performance of market participants

2.6 Miscellaneous Functions:

2.6.1 Review Part 39 submissions; track the issues and performance of market participants

2.6.2 Monitor internal and external requests for data and ensure that all data requests are addressed

2.6.3 Ingest and enter Form 204 and 304 data

3.0 Tasks

The contractor shall perform the following tasks:

3.1 Review and process submitted forms – Review data submitted on the Forms 102A, 102B, 102S, 40, 40S, 71 for accuracy and completeness

3.2 Analyze submitted data for accuracy, completeness, and consistency

3.3 Communicate with market participants – Contact the appropriate market participant regarding submitted, incomplete, and/or delinquent data

3.4 Reference applicable regulations – Become familiar with Parts 15, 16, 17, and 20 of the CFTC regulations and be able to reference them when needed

3.5 Ensure reference data accuracy, integrity, and quality

3.6 Maintain reference data – Ensure that relationships (account/trader, trader/trader, owner/trader, firm/trader, etc.) in the system are current and accurate; set up new commodities when needed; and ensure that all related information is accurate

Transition Support

The contractor shall perform phase-out activities to transition work to a successor contractor.

Specifically, the contractor shall cooperate with any successor contractor and perform all actions necessary to transfer operations to ensure full continuity of services. If requested by the Contracting Officer or the Contracting Officer’s Representative (COR), the contractor shall submit a transition plan, which addresses certain areas, including, but not limited to, specific phase-out milestones, actions that implement cooperation with the successor, and transfer of data to the successor. The contractor shall incorporate all comments received from the Contracting Officer and/or the COR into the transition plan.

4.0 Deliverables

All of the contractor’s written deliverables shall, at a minimum, be clear and concise, comprehensive with respect to all relevant aspects of the subject matter, and sufficiently detailed to provide a full understanding of the conclusions contained therein.

The contractor shall submit all written deliverables to the COR electronically unless otherwise requested to be submitted in hard copy. Electronic copies shall be submitted in a format agreeable to the COR (e.g., Word, Excel, PowerPoint, PDF, etc.). Additionally, the contractor shall provide an electronic copy of each deliverable to the Contracting Officer. All of the contractor’s documentation must be compliant with Section 508 of the Rehabilitation Act of 1973. All deliverables are considered “draft” until the contractor receives notification that they are accepted from either the COR or Contracting Officer.

If a deliverable due date falls on a Saturday, Sunday, or federal holiday, the due date for that deliverable shall be the next business day.

Reporting Activities Deadline

(business days)

Meeting/session minutes 3 days after each meeting/session

Status reports in accordance with the reporting requirements section of the BPA. The status report should include the metrics in section 4.1

Weekly

Financial reports in accordance with the reporting requirements section of the

BPA

Monthly

SOP Documents or Updated SOP As applicable

Operational reports which provide insight into transaction volume, the overall state of the market to include (not limited to) exposure, gross notional outstanding, risk analysis, and cross asset class reporting

As applicable

4.1 Metrics for weekly status report

The metrics that should be included on the weekly status report are:

The number of contacts made with industry participants and errors addressed

A detailed list of market participants contacted, the date of contact, the reason for contact, and the outcome if applicable

The number of 102, 40, 204 & 304 processed

5.0 Period of Performance

The period of performance is twelve (12) months after task order award, and includes four (4) additional years of performance, in one-year incremental options, exercisable at the Commission’s discretion. The period of performance shall begin upon the award of the task order. The contractor shall perform transition-in activities during the first 30 days of the period of performance, after which time the contractor will assume full responsibility for the SAS Administration task.

6.0 Travel

There is no travel requirement.

7.0 Acceptance of Deliverables

The COR will have at least ten (10) business days to complete its review of the deliverables. The contractor shall have five (5) business days to correct the rejected deliverable and return it to the

CFTC COR.

8.0 Level of Effort

CFTC estimates that the level of effort for successful completion of this task order is as follows:

Function Estimated Hours

Key: Senior Data Operations Specialist (x1 FTE) 1,920

Key: Data Operations Specialist (x3 FTEs, plus x2 FTE Optional Surge) 1,920

Resources are expected to have two or more years of data operations experience.

Note: Staffing levels may fluctuate over time as priorities and funding dictate.

9.0 Place of Performance

The primary work location for this support shall be at the CFTC Central Regional Offices at 525 West Monroe Street, Suite 1100, Chicago, IL 60661 and 140 Broadway, 19th Floor, New York, NY 10005. Upon prior written approval from the COR, the contractor may perform services at a CFTC Regional Office, Main Headquarters or remotely via a virtual private network (VPN) connection.

During the course of the performance of this task order, the CFTC may require resources to perform work in one of its regional offices if the stakeholders needing assistance are located in that location. All work must be performed within the continental United States.

10.0 Anticipated Start Date of Task Order

The anticipated start date of this task order is September 1, 2018.

Period Covered Not-To-Exceed Amount

Option Year I $

Option Year II $

Option Year III $

Option Year IV $

11.0 List of Attachments applicable to this task order:

Attachment A – Non-Disclosure/Confidentiality Statement

Commodity Futures Trading Commission Market Data Operations Senior Futures and Options Senior Data Operations Specialist

INTRODUCTION

The contractor serves as a Senior Data Operations Specialist in the Market Data Operations (MDO) section of the Commodity Futures Trading Commission (CFTC). MDO is responsible for managing data reported to the Commission as well as handling all data requests from within the Commission.

QUALIFICATIONS

Two years of data operations experience. Bachelor degree in business, finance, or a related field.

Knowledge of futures industry.

DUTIES AND RESPONSIBILITIES

The contractor’s primary assignments consist of the following:

• Serves in a lead role, responsible for overseeing the work of the Data Operations Specialists

• Review and analysis of firms’ position, ownership and control data

• Review and analysis of futures and options data, and market data for compliance, completeness, consistency and quality

• Review and analysis of data published on Commission reports

• Receives and/or enters data submitted on the Cash Grain form (Form 204) and Call Cotton form (Form 304)

• Quality analysis of transactional, position, ownership and control data

• Responding to data inquiries from other divisions within the Commission

The contractor analyzes a variety of futures and other derivatives data by monitoring reports filed by exchanges, futures commission merchants (FCMs), traders, and resolving reporting problems.

The contractor ensures that reporting entities submit position data accurately, ensuring appropriate corrective action is taken. He/she confirms position and transaction data and maintains a good rapport with reporting entities and market participants. The contractor examines account information submitted on various CFTC forms, initiates inquiry and resolves ambiguity upon receipt of questionable information. He/she analyses 00-01 report findings and consults with the appropriate party to resolve discrepancies. He/she updates the system to reflect changes and corrections.

The contractor monitors the receipt of daily exchange reporting which includes permanent record and clearing member data. He/she examines error reports, analyses all discrepancies, and communicates with exchange personnel to request incomplete data and assure the resolution of discrepancies.

GUIDELINES

The contractor uses the Commission’s general rules and guidelines in Parts 15, 17, 18, and 20 of the Commodity Exchange Act (CEA) when performing his/her various duties.

COMPLEXITY

The contractor is responsible for ensuring that the Commission’s rules and regulations are interpreted and applied consistently across all reporting firms, not only within the region but also across regions.

SCOPE AND EFFECT

The work includes analyzing futures and options data and communicating with FCMs and exchanges to ensure the accurate and timely submission of data.

The data analyzed by the contractor is widely used by all divisions within the Commission and is relied upon for its accuracy. The data is used for surveillance of the futures markets and swaps markets, Enforcement cases, and determining the financial stability of FCMs. The data is also used in reports published on the Commission website.

PERSONAL CONTACTS AND PURPOSE OF CONTACTS

The contractor is in contact with industry participants, the general public and other CFTC staff answering questions regarding reporting requirements and required forms.

PHYSICAL DEMANDS

The work is sedentary with no travel.

WORK ENVIRONMENT

The work is performed in an office setting.

Commodity Futures Trading Commission Market Data Operations Futures and Options Data Operations Specialist

INTRODUCTION

The contractor serves as a Data Operations Specialist in the Market Data Operations (MDO) section of the Commodity Futures Trading Commission (CFTC). MDO is responsible for managing data reported to the Commission as well as handling all data requests from within the Commission.

QUALIFICATIONS

One year of data operations experience. Bachelor degree in business, finance, or a related field.

Knowledge of futures industry.

DUTIES AND RESPONSIBILITIES

The contractor’s primary assignments consist of the following:

• Review and analysis of firms’ position, ownership and control data

• Review and analysis of futures and options data, and market data for compliance, completeness, consistency and quality

• Review and analysis of data published on Commission reports

• Receives and/or enters data submitted on the Cash Grain form (Form 204) and Call Cotton form (Form 304)

• Quality analysis of transactional, position, ownership and control data

• Responding to data inquiries from other divisions within the Commission

The contractor analyzes a variety of futures and other derivatives data by monitoring reports filed by exchanges, futures commission merchants (FCMs), traders, and resolving reporting problems.

The contractor ensures that reporting entities submit position data accurately, ensuring appropriate corrective action is taken. He/she confirms position and transaction data and maintains a good rapport with reporting entities and market participants. The contractor examines account information submitted on various CFTC forms, initiates inquiry and resolves ambiguity upon receipt of questionable information. He/she analyses 00-01 report findings and consults with the appropriate party to resolve discrepancies. He/she updates the system to reflect changes and corrections.

The contractor monitors the receipt of daily exchange reporting which includes permanent record and clearing member data. He/she examines error reports, analyses all discrepancies, and communicates with exchange personnel to request incomplete data and assure the resolution of discrepancies.

GUIDELINES

The contractor uses the Commission’s general rules and guidelines in Parts 15, 17, 18, and 20 of the Commodity Exchange Act (CEA) when performing his/her various duties.

COMPLEXITY

The contractor is responsible for ensuring that the Commission’s rules and regulations are interpreted and applied consistently across all reporting firms, not only within the region but also across regions.

SCOPE AND EFFECT

The work includes analyzing futures and options data and communicating with FCMs and exchanges to ensure the accurate and timely submission of data.

The data analyzed by the contractor is widely used by all divisions within the Commission and is relied upon for its accuracy. The data is used for surveillance of the futures markets and swaps markets, Enforcement cases, and determining the financial stability of FCMs. The data is also used in reports published on the Commission website.

PERSONAL CONTACTS AND PURPOSE OF CONTACTS

The contractor is in contact with industry participants, the general public and other CFTC staff answering questions regarding reporting requirements and required forms.

PHYSICAL DEMANDS

The work is sedentary with no travel.

WORK ENVIRONMENT

The work is performed in an office setting.