Docs (EGUS) Resources
This page provides training and documentation materials for users of the new Docs platform (formerly EGUS). As FIA Tech continues to develop and add enhancements in the Docs platform we will provide additional training and troubleshooting resources for our users
Please review the following guides, reference data information and project documentation:
- Docs Quick Start Guide: This short 13 page guide provides all of the information a user needs to begin using Docs to initiate, update, approve and execute give-up agreements.
- Docs Admin Guide: This guide outlines how administrators can manage and create users and update party information in the Admin section of the Docs application.
- Docs Guide to Electronic Rate Schedules: This guide provides information on representing rate schedules in the electronic format available in the Docs platform. Electronic rate schedules are mandatory in the Docs system, and offer a standard way for firms to express and share their rates.
Understanding Docs Reference Data:
- Docs Product Report: A complete list of products currently available in Docs. Docs product codes have been normalized to be the same as the exchange product clearing code. It’s suggested that users review both the product name as well as the underlying product code when creating electronic rate schedules to ensure that you’re adding the correct product.
- Docs Product Abbreviation and Acronym Guide: The purpose of this document is to provide information regarding Docs product terminology, including abbreviations, acronyms, and the underlying structure of the product groups.
- DOCS Exchange Code to MIC Mapping: This spreadsheet contains a list of all DOCS exchange codes mapped to their corresponding MIC, Operating MIC and exchange name. We are providing this document so that firms can easily identify exchanges on their DOCS rate schedules.
- Docs to Atlantis Exchange Mapping: Complete list of Docs exchanges and corresponding Atlantis exchanges.
FIA Tech Project Documentation:
- Docs Product Normalization Project Documentation: FIA Tech has undertaken a project to normalize its product data that is used on electronic rates schedules in Docs. This webpage contains information about this project, and documentation of the updates that FIA Tech is making.
- PDF Rate Schedule Digitization Initiative: The purpose of the digitization initiative is to help firms create a centralized rate schedule repository in Docs in order to improve and strengthen downstream brokerage settlement systems. This page includes information about the project and contact information.
To obtain a User ID and password to access the API on UAT or Production please contact firstname.lastname@example.org.
Integration with Downstream Systems
- Adherence Agreement
- Send completed hard copy of agreement to:
Docs Documentation FIA Technology Services Inc. 2001 Pennsylvania Ave NW Suite 600 Washington DC 20006-1823 USA
- FIA Tech will contact the Docs administrator upon receipt of the adherence agreement and provide log in credentials and training
Training and Webinars
Recorded Webinars: Introduction to the Docs Workflow: This session gives firms an overview of the system Dashboard, and how to take an agreement from Initiation to Executed.
- Introduction to the Docs Workflow (30 minutes)
Amending Agreements in Docs: This brief video provides users of the Docs platform information on what edits can be made to Executed agreements, including how to create amendments.
- Amending Agreement in Docs (15 minutes)
Coming Soon: Administrating Parties and User in Docs: This session introduces administrators to party and user management in the Docs platform
FIA Tech and FIA’s Law & Compliance Division Joint Webinar on the 2017 Give-Up Agreement Templates: In this joint webinar, FIA Tech and FIA’s L&C Division present the 2017 versions of the Uniform Give-Up Agreement
Definitions for Give-Up Parties
Customer: The party to whose account the positions ultimately will be given up for clearing. Notwithstanding that the Customer (sometimes referred to as the “client”) may authorize another party to place orders on its behalf, the Customer is always a party to the give-up agreement (the “Agreement”). Although it may authorize a Trader to sign on its behalf (and may be identified by account number in the Trader version), it is ultimately responsible for obligations relating to the positions, such as margin, delivery, etc.
Trader: The party to whom the Customer has given authority to place orders on its behalf with Executing Brokers for give-up to the Customer’s account maintained by the Clearing Broker. In most instances, the Customer also has given authorization to the Trader to enter into and sign the Agreement on its behalf. In the United States, Traders usually are required to be licensed as Commodity Trading Advisors, unless they qualify for an exemption.
Clearing Broker: The party that maintains a futures clearing account for the Customer and to which the positions resulting from orders executed by an Executing Broker pursuant to the Agreement ultimately are given up. The Clearing Broker must be licensed as a futures intermediary in its home jurisdiction, but is not required to be a member of any exchange. Section 3 of the Agreement provides that, in instances where a Clearing Broker is not a member of the exchange on which the trades are executed, it may use the services of a clearing member to clear the positions on the exchange on its behalf. However, these agents are often affiliates of the Clearing Broker in another jurisdiction (see “Use of Agents” below for clarification of when entities should be named parties to a Give-Up Agreement). Nonetheless, the Clearing Broker must remain responsible to the Customer for its obligations under the Agreement. Usually the clearing member, when acting as agent for the Clearing Broker is not a party to the Agreement; however at least one exchange, the London Metal Exchange (“LME”) does require it.
Executing Administrative Clearer This term is used to define the Category 1 (Ring Dealing) or Category 2 (Associated Broker Clearing) Member of the LME that is responsible for entering into the LME Matching System (LMEMS) trades executed by a Category 4 (Associated Broker) Member that is acting as the Executing Broker.
Clearing Administrative Clearer This term is used to define the Category 1 (Ring Dealing) or Category 2 (Associated Broker Clearing) Member of the LME that is responsible for entering into the LME Matching System (LMEMS) trades that are being given up to a Category 4 (Associated Broker) Member that is acting as the Customer’s Clearing Broker.
Executing Broker (See also “Order Passing Broker”): The party that executes trades on a futures exchange pursuant to orders received from the Customer, Trader or another authorized agent of the Customer. The positions ultimately are given up to the Customer’s account maintained by the Clearing Broker. The Executing Broker must be licensed as a futures intermediary in its home jurisdiction, but is not required to be a member of the exchange on which the trades are executed. Section 3 of the Agreement provides that in instances where the Executing Broker is not a member, it may use the services of a member of the relevant exchange to execute the trades on its behalf. These agents are often affiliates of the Executing Broker who are members of the relevant exchange and are involved in the operational trade flow of the give-up, not independent order passing parties (see also “Order Passing Broker”). The Executing Broker remains responsible to the Customer for its obligations under the Agreement. Often the executing member, when acting as agent for the Executing Broker, is not a party to the Agreement; however, at least one exchange, the LME, does require it*.
Carrying Broker: This term is used to define the Customer’s Clearing Broker in instances where such broker is not a member of the exchange where the trades are executed, and the exchange requires clearing member that maintains the Clearing Broker’s omnibus account on such exchange to be a party to the Agreement (e.g., LME).
Order Passing Broker: This term is used for a party that has been authorized, usually by the Trader, to pass Trader’s orders for the Customer’s account to the Executing Broker. It usually maintains a relationship with the Executing Broker. In some instances it is merely referenced in the Agreement, but not a party to it. This party is sometimes referred to as the Agent Executing Broker when it is not affiliated with the Executing Broker.
LME Clearing Member: This term is used to define the member of the LME that clears the Customer’s LME positions in the omnibus account it maintains for the Customer’s non-LME Clearing Broker. The non-LME Clearing Broker is then defined in the Agreement as the Carrying Broker.
LME Executing Member: This term is used to define the member of the LME that executes the Customer’s LME trades pursuant to orders received from an Executing Broker that is not a member of the LME. *LME rules require that (i) all give-up transactions must be documented by a give-up agreement; (ii) all parties to a give-up transaction must be parties to the give-up agreement and (iii) both the executing and clearing members must be parties to the Agreement even when acting as agents for non-member brokers. When the Executing Broker and Clearing Broker each have the direct relationship with the Customer (and Trader, if applicable) and are both LME members, the standard Customer or Trader versions of the Agreement should be used.
Other items to note regarding Give-Up Agreements:
Use of Agents: In general, Give-Up Agreements were designed to detail the obligations under a give-up arrangement and clearly delineate the parties to the execution and clearing relationship. The key to the successful and accurate Give-Up Agreement is that the parties to the Agreement readily match the operational trade flow, making it easier for both the Clearing Broker and Executing Broker to resolve any out-trades or other operational matters. Thus, the additional definitions above were developed over the years to address those parties which may be involved in the handling of a futures order, but not necessarily in the operational trade flow. If one of the parties to a Give-Up Agreement intends to use an agent that is neither an affiliate of that party nor a member of the relevant exchange or clearinghouse, best practice would be to clearly identify the agent and its role (for example, an order passing broker) in the Give-Up Agreement.
Bilateral vs. Give Ups: Some futures trades such as blocks and EFRPs are executed bilaterally and entered into and exchange system for settlement (e.g., Clearport or ICE-Block). These are not give-up transactions necessarily. The customer’s clearing firm enters limits directly into Clearport or ICE-Block and can permission, at the customer’s request, another firm which the customer has engaged (either as broker or counterparty) to enter the trade into the account. If the trade exceeds the limits set by the clearing firm, it will be rejected. Thus, this type of transaction is a bi-lateral transaction submitted for clearing as set forth in CFTC Rule 1.73(a)(2)(iii) and not a give-up transaction as discussed in Rule 1.73(a)(2)(iv). The clearing firm pre-sets limits in Clearport or ICE-Block and transactions exceeding such limits will be rejected. If an executing firm or counterparty does not have access to Clearport or ICE-Block and chooses to execute the futures block or EFRP as a give-up, the executing firm will have a screening requirement under Rule 1.73(a)(2)(iv).
Q: What is Docs?
A: Docs is the FIA Tech Accelerate electronic give-up agreement and documentation system. It is a web-based application designed to allow Executing and Clearing Brokers, Traders and Customers to execute the FIA International Uniform Give-Up Agreement and the Cleared Derivatives Execution Agreement electronically.
Q: Do you have to be a member of FIA to participate?
A: No. Docs is open to all parties to execute Give-Up Agreements regardless of membership in FIA.
Q: How does my firm get access to the system?
A: Each legal entity wishing to execute Give-Up Agreements in Docs must sign the Adherence to the FIA Tech System User Agreement. The Adherence Agreement requires the institution to specify a System Administrator and a Billing Contact. New institutions cannot be introduced to the system before a hard copy of the original Adherence Agreement is received by FIA Tech’s DC office. Once the Adherence Agreement is received, FIA Tech will contact firm’s System Administrator directly with further log in information and training.
Q: We are a global firm with many affiliates involved in the give-up process. Which entity/affiliate should be named as the institution?
A: The system is organized by institutions and parties. Institutions can be a short, generic name such as Best Securities, which encompass all of the affiliates (parties). Institution names have no legal standing and will not show up on agreements; it is just a way of organizing affiliates under an umbrella name. Party names should represent legal entities i.e. Best Securities, Inc., Best Securities, LLC, Best Securities Pty. All documents underneath an institution are visible to all parties. If a firm does not want an affiliate to have access to another affiliate’s documents, then the affiliate needs to be under a separate institution.
Q: What if I have an affiliate that is a customer or trader and another affiliate that is a broker?
A: The customer or trader affiliate should be listed as a separate party but it can be located under the same institution. If the same party means to act in both customer and trader roles, as well as in the broker role, they would need to be represented in the system as two different parties.
Q: Why haven’t you provided a 3-or 4-party LME Agreement?
A: There is no need to create a special Customer or Trader LME Version if both the Executing and Clearing Brokers are LME member firms (and there are no other executing or clearing brokers involved). Firms can simply use the standard Customer and Trader Versions of the Give-Up Agreement. As noted above, if either or both the direct Executing or Clearing Broker is “not” an LME member firm, then FIA’s Law and Compliance Committee has created special LME versions to be used for these situations.
How the System Works
Q: Who can initiate an agreement?
A: Any party with storage can initiate an agreement in Docs. If a party is a preferred initiation, there is a feature in Docs that allows firms to indicate this preference.
Q: Please describe how changes can be made to the text of the Give-Up Agreements?
A: Docs presents each paragraph of the Give-Up Agreement in two columns. The original text is contained in the left column. The right column gives the system user the opportunity to make changes in the language. Any change in the language appears in boldface type or strikethrough on the final version of the agreement, so all parties to the agreement can immediately see changes. Any party on the agreement can make changes before the agreement is executed.
Q: Can we set up users with read-only access?
A: Yes. Each user can be given a separate set of permissions in Docs. They can be set up with read-only access, access to review agreements, approve agreements or rates schedules. These settings are maintained internally by the Docs System Administrator at the firm.
Q: If we elect to use only one institution and create different parties within that institution, can we establish an administrator for each party rather than for the institution?
A: No. Firms can have multiple administrators for the institution, but they cannot have an administrator for each party. All administrators will have access to change information/permissions for all users and parties under the institution.
Q: When a new account is added, is the Clearing Broker only required to make this change or must all of the parties to that Give-Up Agreement approve this new account change?
A: When a new account is added, all parties to the agreement are notified. New accounts can be added to standard agreements at any point in time. In the case of LME Agreements, all parties to the agreement must approve the addition of a new account just like they do a new agreement.
Q: Can we use the Uniform Give-Up Agreements for non-U.S. equity options transactions?
Q: Please describe how commission rate schedules will be displayed on Docs.
A: Docs makes it possible to download information contained in the Give-Up agreement into internal and vendor systems. System users may upload rate schedules in PDF format, or create rate schedules electronically within Docs using a standard rate table.
Q: Will Docs information be available to downstream systems like GPS, Fees, ION and Sungard?
A: There is currently a common feed that is suitable for Fees, GPS and other proprietary systems.
Q: Does the Docs System operate on a 24/7 basis or is there any down time for the System?
A: The system is available 24/7. When necessary, we conduct maintenance on weekends—close of business U.S. (Friday evening U.S.) to opening of business in Asia (Sunday evening U.S.).
Uploading Legacy Agreements
Q: Please describe what is meant by a “Legacy Agreement.” How can Legacy Agreements be added to the Docs System for use by all parties?
A: Firms may choose to store legacy agreements—agreements executed outside Docs—on the system. These agreements must be converted to PDF documents for uploading. Docs has a page where legacy documents must be uploaded—it prompts the user to add the names of the parties and the effective dates of the agreement.
Q: Can I upload legacy agreements without notifying the other parties to the agreement?
A: FIA Tech does not provide legal advice; however, it does not require permission from the counterparties in order to upload a legacy agreement. Only the counterparties to the agreement can see this agreement.
Q: What Fees are associated with Docs?
A. Docs users must pay a per agreement fee for every executed agreement, and a storage fee based on the number of documents a firm has stored in the system. To review our fees, please read the Docs Pricing System.
Q: Who pays the per agreement fee?
A: Only the conformed brokers will be charged the Per-Agreement Fee, if there is no conformed executing broker then the conformed clearing broker will pay the Per-Agreement Fee.
Q: Does the number of documents executed and stored include those executed by all of my affiliates?
A: Yes. An institution is responsible for the charges of all its affiliates.
Q: Is a fee charged for uploading legacy agreements?
A: The Per Agreement Fee will be charged to the Institution that uploaded the Legacy Agreement, regardless of its role on the agreement.
Q: Do customers/traders pay any fees?
A: Customer/trader parties have the option of maintaining Storage of Docs agreements. Customers/traders that choose not to store documents in Docs will have execution only access at absolutely no cost, and will have seven days after execution to print or email the agreement.
Q: Can executing and clearing brokers elect to not pay the storage fee?
A: No. All executing and clearing brokers are subject to the storage fee. Consequently, brokers cannot join the system as no charge institutions.
Q: How often will system users be billed?
A: FIA Tech will bill system users quarterly.
Transition from EGUS to Docs
Q: Will I be able to access my agreements/schedules/firm info/etc. in the previous EGUS once the system is launched?
A: With the introduction of the new platform, data will be migrated to the new system for access. The previously site will be decommissioned and agreements and data will no longer be available either through the web interface or the API.
Q: Will my existing agreements be modified to follow the new agreement templates?
A: No, previously existing agreements that are migrated to the Docs platform will not be modified to the new agreement template language.
Q: Where can I get more information on new system functionality?
Q: Where can I get more information on ongoing system developments/releases?
Q: Will all the features in the current system be replicated in the new EGUS?
A: Many system features in the current EGUS will be represented in the new system, albeit in modified forms. To note, however, is that the MVP of the new system does not include a rate schedule building module. Instead we are relying on the eModule as the primary rate schedule building tool after initial system launch.
Q: Will our firm be able to use our current API configuration with the new platform?
A: While the API is designed to be backwards compatible for simplicity in testing and integration, API users will need to point to new URLs for both testing and production sites. Additionally, for enhanced security purposes, API passwords will expire every six months, at which point new passwords are required.
Q: Will the new platform be able to integrate with my current external systems?
A: All current integrations via API will remain supported within the new Docs application.
Q: Is there any change to the fee structure for using the new platform?
A: No, the Docs platform follows the same fee structure existing under EGUS, which may be found in the page.
Q: How will migration to the new system occur?
A: FIA Tech will be doing a weekend switchover from the current system to Docs. This will occur during Q4 of 2017. FIA Tech will announce a migration date as the time grows nearer. There will be no overlap between the current system and Docs. All users will be migrated to the Docs over the same weekend after which EGUS will be decommissioned.
Q: How can my firm provide feedback on features in the new system?
A: If you have specific features that you would like to see in the system, or would like to provide feedback throughout the modernization process, please reach out to email@example.com to engage with the team responsible for this project.
Q: If the Executing Broker is inactive in Docs, will another party to the agreement be assessed this fee?
A: No. Only executing brokers who actively use Docs will be assessed this fee.
Q: Will this fee be assessed to legacy agreements?
A: If a legacy agreement was uploaded and a PDF rate schedule was attached to the agreement, then the legacy agreement will be included in the assessment. However, if the legacy agreement has no rate schedule attached in the rate schedule section, it will be exempt.
Q: My agreement has both a PDF and eRate attached, will this agreement be part of the assessment?
A: No. Only agreements that contain only a PDF rate schedule will be assessed this fee. Agreements that have both PDF rates and eRates attached will be exempt from the assessment fee.
Q: We have a large number of inactive agreements, will the fee be assessed to these agreements?
A: The fee is only assessed to Executed agreements. Terminated agreements in Docs will NOT be included in the assessment. Firms that are concerned that a number of their executed agreements are no longer active should review their agreements in order to determine if some of them should be Terminated.
Q: There are a large number of non-conformed parties under my institution, will I be charged an assessment fee for agreements set up under these parties?
A: No. You will only be charged an assessment fee for agreements where a conformed party under your institution is the Executing Broker.
Q: We have rates on many of our agreements that cannot be electronically reflected, how do we deal with these?
A: If you have a rate schedule that combines rates that can be entered into the eRate format, and rates that cannot, you can choose to partially digitize the agreement. Agreements in Docs can have both a PDF and an eRate attached. However, the decision to partially digitize an agreement is up to each firm and may be appropriate under some circumstances, but not others. Additionally, if 90% or more of an Docs institution’s agreements have electronic rate schedules on them, this institution is exempt from the assessment fee. This percentage was set to allow for rate schedules that can’t yet be put into the eRate format.
System User Agreement Data Protection Addendum
Q. What does this DPA do?
The GDPR classifies users of data as either data controllers or data processors. Data controllers and data processors have different responsibilities with respect to personal data, which generally is any data that can be used to identify an individual person. The DPA makes clear FIA Tech’s role as a data processor and the System User’s role as the data controller and identifies the obligations of each with respect to processing and protecting personal data.
Specifically, the DPA defines the responsibilities of FIA Tech and its System Users in the event of:
• a complaint from an individual, or a request to exercise their rights under the GDPR;
• an investigation by a regulator;
• a data breach that would give rise to significant risk to individuals.
Q. How does this DPA Change the System User Agreement?
The DPA does not change the underlying terms of our Main Agreement. The DPA provides terms that are additional to the Main Agreement in order to more fully protect personal data that FIA Tech receives in connection with the provision of its services.
Q. Does the DPA address the transfer of data from the EU to the U.S.?
Yes. The GDPR states that personal data about European residents can only be lawfully transferred to jurisdictions outside the EU that have in place data protection laws deemed adequate by the European Commission. The DPA states that FIA has certified to the EU-U.S. Privacy Shield, a transfer mechanism agreed upon by the U.S. Department of Commerce and the European Commission, to support the legal transfer of data from the EU to the U.S., and that data will be transferred on the basis of that mechanism.
Q. What happens if FIA Tech uses a vendor to help process data?
In some cases, FIA Tech may use the services of a third-party vendor to process personal data. The GDPR refers to such parties as “sub-processors.” The DPA specifies that FIA may use sub-processors to process personal data, and that in those cases, FIA will obligate the sub-processor to contract terms that are no less protective than those set forth in the DPA.
Q. Why is this DPA necessary?
Article 29 of the GDPR provides that the data processor, or anyone acting on its behalf, may only process data in accordance with the instructions it has received from the data controller. This DPA, together with the Main Agreement that the DPA supplements, provides those instructions and obligates FIA Tech to follow them.
In addition, Article 24 requires the data controller to take steps to ensure, and be able to show, that processing of personal data is performed in accordance with the terms of the GDPR. This DPA provides for FIA Tech and our System Users’ data processing and transfer in compliance with the GDPR and provides the necessary documentation of our agreement to meet those obligations.