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SISS Betsy Bruinsma Elizabeth.bruinsma@dss.mil Work phone # (210) 824-1546 ext 224. E-FCL. History When to Submit Initial Submission Common Issues Updates to e-FCL Conclusion. E-FCL Outline. DSS first started using e-FOCI – Dept. of Energy (DOE) program
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SISS Betsy Bruinsma Elizabeth.bruinsma@dss.mil Work phone # (210) 824-1546 ext 224 E-FCL
History When to Submit Initial Submission Common Issues Updates to e-FCL Conclusion E-FCL Outline
DSS first started using e-FOCI – Dept. of Energy (DOE) program Effective January 19, 2010, DSS modeled their own program using e-FOCI If a facility completed an initial submission through e-FOCI, data was migrated to e-FCL Electronic - Facility Clearance (e-FCL) – purpose is to improve efficiency, paperless and a repository for facility information E-FCL History
New facility being processed for a Facility Security Clearance (FCL) Facility has a change on the SF 328 – Certificate Pertaining to Foreign Interest Key Management Personnel changes Ownership change Facility address change Facility name change General rule – before submitting first confirm with your Industrial Security Representative (ISR) When to Submit
Defined as never submitting a complete e-FOCI or e-FCL submission before. First you will need a user name and password. New facility being processed for a FCL will automatically be registered by the Facility Clearance Branch. Facility with a current FCL will be registered by your ISR. Once registered, an e-mail will be sent to your facility point of contact. This person will then create their own user name and password. Initial Submission
Recommend downloading the DSS User Submission Site User Guide at: http://www.dss.mil/diss/documents/eFCLSubmissionSiteUserGuideV607Sept2010.pdf Before starting, review guide. Facility can access the e-FCL program from the DSS website or going directly to the e-FCL website: https://submission.dssfcl.anl.gov Only one user can be assigned for your facility through DSS, but the facility can assign another user internally. What does this mean to you??? Initial Submission (cont.)
Program only takes pdf files. Single file can be no larger than 5 MBs. Forms completed within e-FCL like the KMP list and SF 328, must be printed, signed, converted to a pdf file then uploaded into your submission. All forms requiring a signature need to be signed. Key when first starting your submission is annotating your correct organizational structure – why??? Initial Submission (cont.)
Once all of the information has been uploaded, you will submit your e-FCL package for review. At this time, you will not be able to make any changes to your e-FCL submission. ISR will review your submission and if additional items are needed, you will get an e-mail through e-FCL to tell you what information is required and that your e-FCL package has been unlocked. Initial Submission (cont.)
Not selecting the correct type of organization (LLC, General Partnership, Sole Proprietorship, Corporation, Branch/Division). Missing and incomplete information on the Summary Data Sheet. No website listed (if you have one) Stock information not listed Missing previous business names Missing tier parents Number of directors not matching articles of organization or bylaws Previous addresses going back 10 yrs not listed Common Issues
Incomplete information being provided for a “yes” answer on the SF 328. The program explains what information must be provided for a “yes” response. The SF 328 not completed correctly on the backside of form. Corporation – complete the “CERTIFICATION” section, but not the witnesses section. Complete also the “CERTIFICATE” section and apply corporate seal. Not a Corporation – complete only the “CERTIFICATION” section, two witnesses sign and print their names. Common Issues (cont.)
Who goes on the KMP list – discuss vs guide??? KMP list missing information Names are not completely spelled out KMP list not signed – FSO signature is fine Date for excluded KMPs is the date exclusion resolution signed Social security number not required for excluded KMPs KMPs do not match the articles of organization, bylaws or amendments Common Issues (cont.)
Corporate documents not loaded Examples – articles of organization, bylaws, amendments and meeting minutes changing corporate documents Shareholder Agreements If company has stocks, listing of stocks issued to persons or companies owning 5% or more Not loading documents under the correct headings – files Common Issues (cont.)
Select Change Condition Significant changes – discuss??? ISL_2009_03_December_09 Change of KMPs Change of address Change of ownership Change from a “yes” to “no” or opposite Updates to e-FCL
Before submitting an e-FCL submission, talk with your ISR to confirm the submission is required. Be exact, read your articles of organization and bylaws. If having issues, either call your ISR, e-FCL help desk as noted in the help guide or read common e-FCL Q&As - http://www.dss.mil//diss/efcl_faqs.html Conclusion