Online Registration System: NFA implements enhancements and offers some helpful tips
In June 2002, NFA launched its new Online Registration System (ORS), providing the futures industry with an efficient, cost-effective method of fulfilling an essential regulatory obligation. In the five months that ORS has been in operation, almost 2,600 firms have established security managers and have made over 20,000 filings.
NFA has received many helpful suggestions from Members about improving ORS. We have been able to implement some of these already-for example, adding filters to the Notice page to make it easier to use. In addition, firms are now able to amend Employment, Education and Residential History information.
While users of ORS have reaped the many benefits of the new system, such as instant issuing of Temporary Licenses and less paperwork, we know that some features of ORS are causing Members difficulties. Because of good feedback from the users of ORS, over time, the system will include more and more of your ideas to make it easier to use. In the meantime, the following are tips to help Members deal with some common problems.
1. Applications are being automatically withdrawn.
Firms and their APs, principals and branch office managers have 90 days after the firm files any application to complete it. By "complete," we mean provide all items NFA needs to act on the application, such as fingerprint cards, fees, test results and verifications by the individuals. For firm applications, these items could include such things as financial statements, applications for individuals who are principals and fees. If these items are not provided, ORS will automatically withdraw the application. The firm can track its applications by using the Internal Processing pages.
- The Application Withdrawal Date page shows the date that each application will be withdrawn if not completed.
- The Outstanding Requirements page lists all of the information that the firm or individual must provide to complete the application.
2. Other things are automatically happening, like temporary licenses being withdrawn, without explanation.
Besides the Application Withdrawal Date and Outstanding Requirements pages, the Internal Processing section contains other pages that provide the information a firm needs to track its applications. Firms can always determine the progress of their applications by reviewing the Internal Processing pages frequently (we suggest daily).
- After an application is filed, a TL is granted, registration is granted, or an application is withdrawn, ORS places a notice in the firm's Notices page. They are listed in chronological order from newest to oldest but can be re-sorted and filtered for easy reference.
- The TLs Due to Withdraw page tells the firm when an AP's TL will be withdrawn unless NFA receives the applicant's fingerprint card, test results and application fee and the applicant verifies the application. This date is always 20 days after the TL is issued. Any of these items that NFA has not received appears on the Outstanding Requirements page.
- If the firm has begun but not filed an application or withdrawal notice, it will show up on the Processing Not Complete page. Please note that we expect to begin withdrawing applications that have been on this page for a long period of time. We are currently deciding how long is too long and will let Members know before actually beginning this automatic withdrawal process.
3. Users can't open an application that has been started but not finished.
Users need to exit applications in a certain way to avoid this. ORS permits only one user at a time to have an application open. ORS considers any application to be "open" unless the user has "exited gracefully." This means clicking on the "Exit This Application" link appearing at the top of the left-hand navigation column on ORS pages. If a user exits any other way (e.g., just closing the browser), ORS will think the application is open and no one else will be able to open it.
When users encounter this problem, they can "close" the application from the Processes Not Complete page by finding the application and changing the "Y" to "N" in the "In Use" column. Users must be cautious when doing this, however. Just because an application appears on this page with a "Y" does not necessarily mean someone left it "open" by not "exiting gracefully." Another user may actually be entering information into the application. Changing the "Y" to "N" when someone is entering data will cause any data entered on a page that is not filed to be lost. The ID of the person who has the application "open" appears on this page and it would be prudent to check with that person before closing the application.
4. Verifications not filed.
After the firm files an AP, principal or branch office manager application, the individual needs to verify it. This is the electronic equivalent of the individual's handwritten signature on the hardcopy applications that he/she used to file. When firms start an individual application, a page appears that contains a temporary password and UserID, which must be given to the individual in order to verify the application. The password will never be displayed again, so firms should print the page to keep a record of it. Also, the firm's security manager (not NFA) can generate a new temporary password for the individual if that becomes necessary.
5. Security managers forgetting their passwords.
Security managers can't reset their own passwords if they forget it or are locked out after entering an incorrect password too many times. The best way for firms to deal with this is to have the original security manager (this is the security manager who the firm designated in the enrollment process) set up an additional security manager for the firm. If either one forgets his/her password, the other can reset it. This is also good practice in case the security manager is unavailable to help other users, such as when the security manager is on vacation.
6. Others names.
The Other Names field in the ID Assignment process is only for entering additional names by which the individual to whom the firm is assigning the ID was or is known. The most common example of this is the person who has changed names because of marriage or divorce. This field is not used for the names of additional persons to whom the firm wants to assign IDs.
7. Entity Principals.
The Entity Principal page is used to enter the names of business organizations, such as corporations that are principals of the firm applying for registration. These are almost always firms that own 10% or more of the applicant or registrant and are commonly called "Holding Companies." Firms should not enter the names of individuals who are principals of the firm on the Entity Principal page. Instead, firms file individual applications to identify them as principals of the firm.
8. Education/Employment/Residential History.
As mentioned above, ORS will soon include a page where corrections to Education/Employment/Residential History can be made. However, there are some limitations on how to make corrections both in the new pages and the pages that currently appear in the application. Users may add or delete entire items and can modify the dates for any item. However, the best way for a user to change the name of an employer or a residential address is to delete the entire entry and add a new one with the correct information.
9. Paper filings.
Since the introduction of ORS, NFA has stopped accepting hardcopy versions of any filings that can be made in ORS. With certain unusual exceptions, NFA will only accept Notice Form 7-R, Form 8-W and certain supporting documents such as court records in hardcopy format. Otherwise, the user must file in ORS. We continue to receive hardcopy forms, letters and faxes, mainly to change existing information such as addresses. Sending these to NFA only delays whatever the sender is trying to accomplish because NFA will send them back and instruct the sender to file the change electronically. NFA will accept test results, but the individual should wait at least two business days after taking the test and then check ORS before sending them. By that time, the NASD almost always will have reported the test results electronically to NFA and thus sending the hardcopy is not necessary.
We appreciate all of the comments and suggestions from Members and encourage additional feedback to aid us as we modify ORS to make it as easy and user-friendly as possible. E-mail all comments or questions to firstname.lastname@example.org or call our Information Center at 800-621-3570 or 312-781-1410.