Defense Security Service

Industrial Security Field Operations

FCL Orientation Handbook

February 18, 2015
Defense Security Service FCL Orientation Handbook

Page 2

Table of Contents

WELCOME MESSAGE FROM DSS DIRECTOR........................................................................................................... 3

1.0 FCL ROADMAP ................................................................................................................................................. 5

2.0 FCL PROCESS REQUIREMENTS WORKSHEET ..................................................................................................... 6

3.0 BUSINESS STRUCTURE AND EXCLUDEDTIER ENTITIES ...................................................................................... 8

3.1 BUSINESS STRUCTURE REQUIRED DOCUMENTS ...............................................................................................................8

3.2 REQUIRED FORMS...................................................................................................................................................10

3.2.1 Required e-FCL Forms Signatures per Business Structure ...........................................................................10

3.3 EXCLUDED TIER ENTITY PROCESS................................................................................................................................12

3.3.1 In-Process Excluded Tier Entity Requirements............................................................................................12

3.3.2 Highest Cleared Excluded Tier Entity ..........................................................................................................13

4.0 E-FCL PROCESS ............................................................................................................................................... 14

4.1 LOGGING INTO E-FCL ..............................................................................................................................................14

4.2 E-FCL IN 5 STEPS....................................................................................................................................................14

5.0 ACCOUNTS AND SYSTEMS.............................................................................................................................. 15

6.0 TELEPHONIC AND FCL INITIAL REVIEW PREPARATION.................................................................................... 17

6.1 TELEPHONIC SURVEY PREPARATION ............................................................................................................................17

6.2 FCL INITIAL REVIEW ................................................................................................................................................17

APPENDIX A: REQUIREMENTS.............................................................................................................................. 18

A.1 REQUIRED E-FCL FORMS AND DOCUMENTS.................................................................................................................18

A.2 REQUIRED KMP PCLS.............................................................................................................................................19

A.3DEFINING KMPAUTHORITIES OF POSITION.................................................................................................................19

A.4 TRAINING..............................................................................................................................................................21

APPENDIX B: E-FCL FAQS...................................................................................................................................... 22

APPENDIX C: EXCLUSIONRESOLUTIONS .............................................................................................................. 24

C.1HIGHEST CLEARED ENTITY NOTING EXCLUDED ENTITY’S EXCLUSION AND RESOLUTION TO EXCLUDE PARENT ORGAINIZATION ..........24

C.2 EXCLUSION RESOLUTIONOF CORPORATE ORGANIZATION ...............................................................................................25

C.3 EXCLUSION RESOLUTION FOR LLC MEMBER.................................................................................................................26

C.4 EXCLUSION RESOLUTION FOR CERTAIN DIRECTORS AND OFFICERS ....................................................................................27

APPENDIXD: GLOSSARY ...................................................................................................................................... 28

D.1 TERMS .................................................................................................................................................................28

D.2 BUSINESS STRUCTURE .............................................................................................................................................29
Defense Security Service FCL Orientation Handbook

Page 3

Welcome Message from DSS Director

On behalf of the Defense Security Service (DSS), welcome to the first step in the Facility Security 

Clearance (FCL) process. We recently received a request from a Government Contracting Activity 

(GCA) or cleared contractor to sponsor your Facility for a FCL under the National Industrial Security 

Program (NISP) for performance on a classified government contract.

DSS is delegated security administration responsibilities and is the Cognizant Security Office (CSO) 

on behalf of the Department of Defense (DoD). As the CSO, DSS will advise and assist your facility 

during the FCL process. Your facility will be required, at a minimum, to execute certain designated 

forms, such as the Department of Defense Security Agreement, DD Form 441 (or DD Form 441-1 for 

division/branch facilities); process Key Management Personnel (KMP) for personnel security 

clearances; and appoint a U.S. citizen employee as the Facility Security Officer (FSO).

FCL Roadmap

FCL Orientation Handbook

Day 1 – Day 5

DSS to provide FSOs an 

educational, user friendly, and 

informative guide to start the FCL 

process

Telephonic Survey

Day 5 – Day 10

ISRs to guide FSOs through FCL 

process, e-FCL system, explain 

Discontinuation Points, and help 

identify documents and forms 

required per company’s business 

structure

Complete e-FCL upload

Day 10 – Day 20

FSOs to upload all documents and 

forms per its company’s business 

structure into e-FCL

FCL Initial Review

Day 20 - 45

ISRs to review company’s e-FCL 

package and prepare for Initial FCL 

Orientation meeting. FSOs to

submit KMP e-QIPs and

fingerprints and prepare for 

meeting

Post FCL Outreach

First Year Under NISP

DSS personnel reaches out to 

facilities residing in NISP under a 

year to determine compliance with 

NISPOM, implementation of a 

facility security program, and

assess the facility’s potential risk to

National Security

FSO FCL Responsibilities and FCL Discontinuation Points

Over the course of the next 45 days it is your responsibility to identify your company’s business

structure and provide required documentation, and forms. To make this process transparent, the

FCL Orientation Handbook provides a roadmap, guiding you along the FCL process. In addition to

this FCL Orientation Handbook a DSS Industrial Security Representative (ISR) will contact you shortly 

to assist in obtaining your Facility’s FCL.

There are three discontinuation points during the FCL process:

1. Failure to upload the required Documentation and Forms in the Electronic-Facility Security

Clearance (e-FCL) system within 20 days after receipt of the FCL Orientation Handbook

2. Failure to submit KMP Electronic Questionnaire for Investigations Processing (e-QIPs) within 45 

days after the receipt of the FCL Orientation Handbook

3. Failure to submit KMP fingerprints within 14 days after submitting KMP e-QIPs

First Year Post FCL Responsibilities

Once the FCB issues your FCL, you are required to comply with the DoD 5220.22-M “National 

Industrial Security Program Operation Manual (NISPOM)” and implement a security program. An 

Industrial Security Representative will reach out to your facility 120 days after the FCL is issued to 

conduct a brief outreach assessment of your facility’s compliance with NISPOM requirements

and implementation of its facility security program.

Stanley “Stan” L. Sims

Director, Defense Security Service
Defense Security Service FCL Orientation Handbook

Page 4

Overview of the National Industrial Security Program (NISP)

The NISP was established by Executive Order 12829 in January of 1993 for the protection of 

classified information. The NISP applies to all executive branch departments and agencies, and to all 

cleared contractor facilities located within the United States, its Trust Territories and possessions. 

Participation is voluntary, but access to classified information will not be permitted otherwise.

When your facility receives its FCL, it will be subject to provisions of the NISPOM; the NISPOM may 

be downloaded from the DSS web site at http://www.dss.mil. This Handbook is not intended to 

replace the NISPOM, and your first order of business should be to review the NISPOM itself.

The classification levels in the NISP are CONFIDENTIAL, SECRET, and TOP SECRET. The FCL level your 

facility receives is based upon the classified contract you have been awarded and its requirements. 

Interim clearances, based upon lesser investigative requirements, may be issued at each of these 

levels. An Interim FCL may be granted under certain conditions if your facility qualifies. There may 

be conditions that exist that may preclude the issuance of an interim FCL.

Finally, your facility must not be under Foreign Ownership, Control or Influence (FOCI) to such a 

degree that the granting of an FCL would be inconsistent with the national interest.
Defense Security Service FCL Orientation Handbook

 Page 5

1.0 FCL Roadmap
Defense SecurityService FCLOrientation Handbook

Page 6

2.0 FCL Process Requirements Worksheet

The following table provides a list of the required documents, forms, action items, accountsto activate, training, and discontinuation pointsthroughoutthe FCL

process and first year under NISP.

Note: Contractor e-FCL Administrator may begin to upload Documents and Formsinto e-FCL once the FCL Orientation Handbook is received on Day 1. ISR will not 

visit Contractor’s Facility until all information is uploaded into e-FCL.

FCL Orientation Handbook & Complete e-FCL upload FCL Initial Review Post FCL Initiatives 

Telephonic Survey

Timeline Day 1 – 10 Day 10 – 20 Day 20 - 45 First Year under NISP

Documentation  Identify Business Structure

(see 3.1)

 Identify Key Management

Personnel(KMP) (see 3.1)

 Identify Tier Entities, if 

applicable (see 3.2)

 Submit all required e-FCL 

Documents(see 3.1)

 Review CDSE Self-Inspection

guide

Forms  Submit all Required e-FCL 

Forms(see 3.2)

Action Items  Review Center for

Development of Security

Excellence (CDSE) FSO Toolkit

 Review e-FCL

e-FCL User Guide

 Start uploading

documentation into e-FCL

 Verify KMP U.S. citizenship

 Review National Industrial

Security ProgramOperating

Manual (NISPOM)

 Submit KMP citizenship 

verification (U.S. passport and 

birth certificate)

 ISR visits Contractor’s Facility 

after e-FCL is approved and all 

required KMPssubmit e-QIPs

 Provide KMP citizenship

verification during ISR on-site 

visit

 Submit KMP Electronic 

Questionnairesfor 

Investigation Processing (eQIPs) to OPM within 45 days 

after receipt of the FCL

Orientation Handbook (see 5.0)

 Submit KMP fingerprints 

within 14 days after 

submitting KMP e- QIPs (see

5.0)

 Prepare to comply with

NISPOM requirements

 Prepare to implement a

 Comply with NISPOM

requirements

 Implement a facility security program 

aligned to NISPOM requirements

Security Program 
Defense SecurityService FCLOrientation Handbook

Page 7

Activate

Accounts

 Apply for a Commercial and

Government Entity (CAGE) 

Code (See 5.0)

 Log-Into e-FCL (See 4.0)

e-FCL User Guide

Apply for a Secure Web 

Fingerprint Transmission 

(SWFT) account

Apply for a JPAS Account

Training  Recommend to register and 

begin FSO training in CDSE

 Recommend to register and 

begin FSO training in CDSE

 Complete FSO training 

provided by CDSE

Discontinuation

Points

 DSS determines FCL

justification is not valid

 Failure to submit all Documents

and Formsinto the e-FCL within

20 days after receipt of FCL

Orientation Handbook

 Failure to submit KMP e-QIPs

within 45 days after receipt of 

the FCL Orientation Handbook

 Failure to submit KMP 

fingerprints within 14 days 

after submitting KMP e-QIPs

 Failure to comply with NISPOM

requirements or implement a 

facility security programmay 

resultin the invalidation of the 

facility’s FCL
Defense Security Service FCL Orientation Handbook

Page 8

3.0 Business Structure and Excluded Tier Entities

The following section detailsthe required Business Structure and Excluded Tier Entity Forms and Documentsto 

submit to the e-FCL.

Discontinuation Point: Failure to submit all Forms, Business StructureDocuments, and Excluded Tier Entity 

Documentsinto the e-FCL within 20 days after receipt of your FCL OrientationHandbook resultsin the 

discontinuation of your Facility’s FCL.

3.1 Business Structure Required Documents

The following table outlines Business Records and Personnel Security Clearances(PCLs) for KMPsrequired by

Business Structure.

Business Structure Business Records Required PCLsfor KMPs

Sole Proprietorship  Business License

 FictitiousName Certificate

 Recent changesto company 

structure

General Partnership  Business License

 FictitiousName Certificate

 PartnershipAgreement

 Legal Organization Chart

 Board/Company Meeting

Meetings*

 Recent changesto company 

structure

Limited Partnership  Business License

 FictitiousName Certificate

 PartnershipAgreement

 Certificate of Limited Partnership

 Legal Organization Chart

 Board/Company Meeting

Meetings*

 Recent changesto company

structure

Joint Venture (JV)  Business License

 FictitiousName Certificate

 JV Agreement

 Legal Organization Chart

 Board/Company Meeting

Meetings*

 Recent changesto company 

structure

 Owner of sole proprietorship

 Senior Management Official (SMO)

 FSO

 SMO

 FSO

 All General Partners, except:

Single Partner(must be cleared)

Management Committee (all 

committeemembersmust be cleared)

 SMO

 FSO

 All General Partners, except:

Single Partner(must be cleared) 

Management Committee (all 

committeemembersmust be cleared)

 Limited Partners need PCL if they work

on classified contracts or need accessto 

classified information

 SMO

 FSO

 JV Partners must be excluded or cleared 

if their duties require access to classified 

information

 Officials working on JV are cleared if their

dutiesrequire accessto classified 

information
Defense Security Service FCL Orientation Handbook

Page 9

Business Structure Business Records Required PCLsfor KMPs

PrivatelyHeld Corporation  Business License

 FictitiousName Certificate

 Articles of Incorporation

 By-Laws

 Stock Ledger

 Legal Organization Chart

 Board/Company Meeting

Meetings*

 Recent changesto company 

structure

PubliclyHeld Corporation  Business License

 FictitiousName Certificate

 Articles of Incorporation

 By-Laws

 Most recent SEC filings

 Legal Organization Chart

 Board/Company Meeting

Meetings*

 Recent changesto company 

structure

Limited Liability Company  Business License

 FictitiousName Certificate

 Certificate of Formation or Articles 

of Organization

 Legal Organization Chart

 Operating Agreement

 LLC Meeting Meetings*

 Recent changesto company

structure

College/University  Charter

 Board/University Meeting

Meetings*

 Legal Organization Chart

 Recent changesto university 

structure

 SMO

 FSO

 Chairman of the Board

 Vice Chair of Board, if provisionsfor

rotating or Pro Tem duties

 CorporateOfficials are cleared if their 

dutiesrequire accessto classified 

information

 SMO

 FSO

 Chairman of the Board

 Vice Chair of Board, if provisionsfor 

rotating or Pro Tem duties

 CorporateOfficials are cleared if their

dutiesrequire accessto classified 

information

 SMO

 FSO

 LLC Members are cleared if their duties 

require accessto classified information

 Managers

 SMO

 FSO

 President

 Regents/Trustees/Directors are cleared if

their dutiesrequire accessto classified 

information

*Include themostrecent Meeting Minutes and anyMeeting Minutesto reflect changesto a company’s address, name, 

KMPs, etc.

** If Business Structure is not identified, discuss with ISR during Telephonic Survey

Excluded KMPs: DSS will determine which Officers and Directors of the company not accessing classified 

information are considered excluded, and do not need a PCL. The company must submit exclusion resolutionsfor 

these Officers and Directors(see Appendix C).

If Key Management Personnel are cleared for contractual performance reasons and not in connection with the

FCL then this difference needsto be identified.
Defense Security Service FCL Orientation Handbook

Page 10

3.2 Required Forms

The following outlinesthe Formsrequired for upload into the e-FCL.

Forms To Include on Forms

SF-328; Certificate Pertaining 

to Foreign Interests

 Certificate pertaining to a company’sforeign interests

 Execute two original SF328 formsfor DSS and contractorretention

 SF328 must be signed by an employee or representative of the company who 

has actual authority to execute agreements with the U.S. Government on 

behalf of the company

 Upload signed SF328 into e-FCL

 Provide all supplementalresponsesto affirmative SF328 questions(See 

supplemental data sheetsin e-FCL)

SummaryData Sheet  List company website

 Include stock information

 List all previous business names

 List all Tiered Parents

 Match number of Directorsin Articles of Organization to Company Bylaws

 List all addresses dating back 10 years

 Current Chairman of the Board

Key Management Personnel

(KMP) Form

Tiered Parent List

If applicable

 Spell out entire KMP names

 Social Security Number not required for excluded KMPs

 Citizenship of all personnel listed as required to be cleared

 KMPs must match the Articles of Organization, by-laws or amendments

 List of all Parent Companies(see 3.3)

DD Form 441  Agreement between your organization and the United States Government that 

detailsthe security responsibilities of both the cleared organization and the 

United States Government

 Execute two original DD441 formsfor DSS and contractorretention.

 DD441 must be signed by an employeeor representative of the company who 

has actual authority to execute agreements with the U.S. Government on 

behalf of the company.

 Upload signed DD441 into e-FCL upon receipt of countersignaturesfrom DSS.

 DD Form 441

DD Form 441-1

If applicable

 Attachment to the DD Form 441 listing cleared divisions or branch officesthat 

are included in and covered by the provisions of the organization's Security 

Agreement and Certificate Pertaining to Foreign Interest.

 DD Form 441-1

3.2.1 Required e-FCL Forms Signatures per Business Structure

The following guidelines provide information to sign the DD441, DD441-1 and SF328 forms according to your 

company’s Business Structure.

Business Structure Business Structure

Sole Proprietorship 



General Partnership 



Sole proprietor will execute the DD 441/ SF328.

“Certification” section of DD 441/ SF328 will not be executed, but 

one witness must sign these forms

All general partners will executeDD 441/ SF328

One witnesssignature is required

Limited Partnership  One witnesssignature is required
Defense Security Service FCL Orientation Handbook

Page 11

Business Structure Business Structure

Joint Venture  DD 441/ SF328 forms must be executed by an authorized 

representative of one the contractor participants performing on 

the classified contract

PrivatelyHeld Corporation  Authorizedmanagement personnelmay execute the DD441/ SF328 

forms

 Witnessis not required

 Corporate seal must be applied, if applicable

PubliclyHeld Corporation  Authorizedmanagement personnelmay execute the DD441/ SF328 

forms

 Witnessis not required

 Corporate seal must be applied, if applicable

Limited Liability Company (LLC)  LLC member or authorizedmanagermay execute the DD 441/ 

SF328 forms

 Two witnessesmust sign the DD 441 and SF328

 Certification, at bottom, does not need to be completed

If only one officer exists within your organization then work with your assigned Industrial Security 

Representative to determine how the forms must be certified or whether an alternate process with witnesses 

should be utilized.
Defense Security Service FCL Orientation Handbook

Page 12

3.3 Excluded Tier Entity Process

The objective of this processis to clear the Sponsored Facility and identify Tiered Companiesto exclude from 

accessto classified information. A Tiered Company, also known as a Parent Company, is defined as a company 

owning at least a majority of another company’s voting securities. DSS determinesif Tiered Companies are 

required to obtain an FCL or can be excluded from accessto classified information.

3.3.1 Excluded Tier Entity Requirements

The processflow below outlinesthe required documentsthe Sponsored Facility must provide to DSS on behalf of 

any Intermediate Excluded Entities and the Ultimate Excluded Entity. In this process neitherthe Ultimate Excluded 

Entity nor any of the Intermediate Tiered Entities hold a FCL.

3.2.1.1 Process Flow

Excluded Entity: In-Process Facility

Sponsored Facility:

Company A

First Tier Excluded Entity:

Company B

Second Tier Excluded

Entity: Company C

Third Tier Excluded

Entity: Company D

Ultimate Excluded Entity: 

Company E

1) Provides company org 

chart, KMP lists and

business records to Ultimate

Excluded Parent

2) Provides company org 

chart, KMP lists and 

business records to Ultimate 

Excluded Parent

3) Provides company org 

chart, KMP lists and 

business records to Ultimate 

Excluded Parent

4) Compiles excluded entity 

companies org charts, KMP 

lists and business records

5) Consolidates a SF-328 for 

the excluded entities

Acknowledges exclusion of 

the Excluded Entities from 

access to classified 

information

Resolution for intermediate 

excluded entities

8) Submits excluded entities 

documentation into e-FCL; 

submits Subsidiary Exclusion 

Resolution into e-FCL

7) Provides documents to

Sponsored Facility

9) Submits all e-FCL 

documents and forms 

required per its 

Business Structure

3.3.1.2 Entity Roles and Responsibilities

Entity Responsibility

Intermediate

Parent/Owner Entity

 Submits Company’sOrganization Chart, KMP List, and Business Records 

to Ultimate Cleared Entity
Defense Security Service FCL Orientation Handbook

Page 13

Entity Responsibility

Ultimate Parent/Owner

Entity

Sponsored Facility

(Highest Cleared Facility)

 Provides all Entities Organization Charts, KMP Lists, and Business Records 

to Sponsored Facility

 Provides Sponsored Facility the requested Exclusion Resolution on behalf 

of its company and Intermediate parentsto be Excluded

 Submits Parent entitiesto be Excluded Organization Charts, KMP Lists, 

Business Records, and Exclusion Resolution for entities

 Submits Subsidiary Exclusion Resolution acknowledgement

 Submits all required e-FCL Forms and Documents per its Business

Structure

3.3.2 Highest Cleared Tier Entity

The processflow below documentsthe required documentsthe Sponsored Facility and Highest Cleared Entity must 

provide to DSS on behalf of any Intermediate Excluded Entities and the Ultimate Excluded Entity. In this process

the Highest Cleared Entity holds a FCL and provides DSS updates on behalf of the Ultimate Excluded Entity and 

Intermediate Tier Entities. Highest Cleared Entity previously submitted all required Documents and Formsfor 

Excluded Entities during its FCL process.

3.2.2.1 Process Flow

Excluded Entity: Highest Cleared Facility

Sponsored Facility:

Company A

Highest Cleared Entity:

Company B

First Tier Excluded Entity:

Company C

Second Tier Excluded

Entity: Company D

Ultimate Excluded Entity: 

Company E

Acknowledges exclusion of 

the parent company from 

access to classified 

information

Information for Excluded 

Entities previously submitted 

by Highest Cleared Entity 

during its FCL process

1) Submits company updates 

to Ultimate Excluded Entity

2) Submits company updates 

to Ultimate Excluded Entity

5) Submits Subsidiary 

Exclusion Resolution into eFCL

4) Submits Excluded Entities

information for

Sponsored Facility

3) Submits all Excluded 

Entity company updates to 

Highest Cleared Facility

6) Submits all e-FCL 

documents and forms 

required per its 

Business Structure

3.3.2.2 Entity Roles and Responsibilities

Entity Responsibility

Intermediate Entity  Submit changesto Ultimate Entity, if applicable

Ultimate Entity  ProvidesIntermediate Entity changesto Highest Cleared Entity, if 

applicable

Highest Cleared Entity  Provides Entity changesto DSS, if applicable

Sponsored Facility  Submits all required e-FCL Forms and Documents per its Business

Structure

 Submits Subsidiary Acknowledgement of Exclusion Resolution
Defense Security Service FCL Orientation Handbook

Page 14

4.0 e-FCL Process

The e-FCL web based systemto submit company data in an electronic format for facility clearance and FOCI 

mitigation e-FCL Submission Site URL: https://submission.dssfcl.anl.gov. Your account will have been registered by 

the Facility ClearanceBranch (FCB) upon receipt of your Sponsorship Package from the cleared contractor or GCA. 

The Company designates a representative, usually the FSO, as the e-FCL Administrator. Below outlinesthe e-FCL 

processsteps:

Facility Clearance Branch Company e-FCL Administrator

Receives

Sponsorship Package

Creates Company’s

e-FCL account

Receives “Welcome

Package”

Logs into e-FCL

account

Obtains and uploads 

e-FCL documents 

and forms

4.1 Logging into e-FCL

Prior to Logging-In: It is recommended that you download the e-FCL “ Su b mis sion Sit e Us er Gu id e” , to gain

a better understanding of the system, how to Log-In the first time, and the required documents and formsto upload 

into the system.

First Time Log-In: The Log-In requires a User ID and Password. The initial User ID is the e-mail address entered 

when the User wasregistered by DSS or by the company’s e-FCL Administrator. The temporary password was sent 

to the e-mail address entered when the User wasregistered by the DSS or by the company’s e-FCL Administrator. 

First time Log-In also requiresthe e-FCL Administrator to enter the Company’s Organization Type and

Organization’s EmployerIdentification (EIN) Tax ID or SSN. The e-FCL automatically generatesthe formsrequired 

by Organization Type as well as a list of required document uploads.

4.2 e-FCL in 5 Steps

The e-FCL Submission Site providesUsers with an easy five 

step processfor completing and

submitting e-FCL submission packages. The package 

consists of all of the forms and attachments

required for a facility clearance submission. The user can 

navigate between steps as needed and enter or exit the 

package as many times as needed before sending the final 

submission.

Below provides a list of the five steps and the required

forms and documentsto submit into the e-FCL. All

potential forms and documents are listed under A.1 this document.

Step # e-FCL Submission Step e-FCL SubmissionDescription

1 Complete Forms Electronic copies of all required forms are provided for completion 

based on the type of contractor organization

2 Upload Documents Uploads are requested of key business documents.

Also review required documents per your company’s business

structure

3 Requested Forms Formsrequested by DSS for FOCI Mitigation are stored here, this step 

will be empty the first time an Initial Package is submitted

4 Review Forms After reviewing all documents and uploads,the system checksto 

ensure that all forms and uploads have been completed and displays

those that still need to be completed

5 Send Final Submission Finalsubmission, once the package is submitted the contractor cannot 

edit the package unless DSS “unlocks” it
Defense Security Service FCL Orientation Handbook

Page 15

5.0 Accounts and Systems

The table below outlinesthe Accounts and Systemsthe FSO must activate or leverage to submit additional 

documentsfor its Facility to receive its FCL and to maintain a compliantsecurity programafter obtaining the FCL.

Discontinuation Point: Failure to submit all KMP e-QIPs within 45 days after receipt of the FCL Orientation 

Handbook resultsin the discontinuation of your Facility’s FCL. Failure to submit KMP fingerprintswithin 14 days 

aftersubmitting KMP e-QIPS resultsin the discontinuation of your Facility’s FCL.

Accounts Reason for Account Description Links

Commercial and 

Government Entity 

(CAGE) Code

Joint Personnel 

Adjudication 

System (JPAS)*

Electronic 

Questionnairesfor 

Investigations 

Processing (eQIP)*

Provides a standardized 

method to identify your 

specific facility

System to support 

adjudication process. 

(Account created after 

Facility is issued its FCL.)

Submit KMP information 

through this systemas part 

of the PCL process

The CAGE Code is a five-character ID number 

used extensively within the federal 

government, assigned by the Department of 

Defense’sDefense Logistics Agency (DLA). It 

tracks basic facility information. If your 

company does not already have a CAGE Code 

for the facility requiring clearance, one may be 

obtained by submitting a DD Form 2051 to 

Commander, Defense Logistics Services

Center, ATTN: DLSC-SBB, Federal Center, 74

North Washington, Battle Creek, MI 49017-

3084. Alternatively, you may visit Systemfor

Award Management (SAM) to obtain your

CAGE Code

JPAS standardizesthe adjudication process

within DoD, and provides a database and 

processeswithin the security managerrealm

of functions. It allows communication between

the central adjudication facility (CAF) and the 

security personnel in the field who actually 

give cleared individuals accessto classified 

information.

For JPAS access,submit DMDC’s new 

Personnel Security SystemAccess Request 

(PSSAR) form to the DMDC Contact Center for 

processing

A Public Key Infrastructure (PKI) is required for

JPAS. Please see link

e-QIP allowsthe user to electronically enter, 

update and transmittheir personal 

investigative data over a secure internet 

connection to a requesting agency

DD Form

SAM

JPAS

PKI

e-QIP

ISFD Provides FCL and 

safeguarding status

for prime and subcontractors

Web enabled database that maintains FCL

related information
Defense Security Service FCL Orientation Handbook

Page 16

Accounts Reason for Account Description Links

Secure Web 

Fingerprint 

Transmission 

(SWFT)*

Security Training, 

Education and 

Professionalization 

(STEPP)

Submit KMP fingerprints 

through SWFT or third party 

vendorto complete KMP’s 

PCL process

(Account created after

Facility is issued its FCL.)

Provides courses for 

Contractor’s security 

professionals

SWFT allowsthe submission of fingerprintsto 

be uploaded electronically through its system. 

(All fingerprintimagesthat are provided in 

support of background investigations must be 

captured and submitted electronically)

For SWFT access,submit DMDC’s new

Personnel Security System Access Request 

(PSSAR) form to the DMDC Contact Centerfor 

processing

Programmaintaining the list of courses DSS 

provides Contractor’ssecurity professionals. 

The courses are intended for use by 

Department of Defense and other U.S. 

Government personnel and contractors within 

the National Industrial Security Program.

SWFT

STEPP

* For support on e-QIP, JPAS, or SWFT please contact Defense ManpowerData Center (DMDC) at 1-800-467-5526 

or dmdc.contactcenter@mail.mil
Defense Security Service FCL Orientation Handbook

Page 17

6.0 Telephonic and FCL Initial Review Preparation

6.1 Telephonic Survey Preparation

In preparation for the upcoming Telephonic Survey please be prepared to discuss and ask questions on the 

following topics with the ISR:

 Company Business Structure and required Documents and Forms

 KMP List; KMPsrequiring PCLs and Excluded KMPs

 Tier Entity process and required documentation

 e-FCL submission process

 e-QIP submission process

 CAGE Code account

 SWFT account

 Review CDSE FSO Toolkit

6.2 FCL Orientation Meeting

In preparation for the FCL Initial Orientation Meeting please be prepared to discussthe following topics with the ISR

during their on-site visit:

 Company’s NISPOM requirements

 Facility’s Security Program

 Provide KMP U.S. citizenship verification (Passport or Birth Certificate)
Defense Security Service FCL Orientation Handbook

Page 18

Appendix A: Requirements

The following are the required Documents, Forms, Accounts, and Training an FSO will need to submit or complete 

prior to the Discontinuation Point for its Facility to receive a FCL.

A.1 Required e-FCL Forms and Documents

The table below lists the Documentsthat are always required in the e-FCL, those required for a particular business 

structure, and those required only if DSS uploads files into the e-FCL folder designated as “Shared Files”, which can 

be viewed by both the Company and DSS personnel. NO CLASSIFIED DOCUMENTS CAN BE UPLOADED INTO THE EFCL SYSTEM.

Document Always Required Business Structure Requirement Shared File Requirement

Articles of 

Organization/Incorporation

Operating Agreement/By-laws 

DD-254 

DD-441/DD-441-1 

Excluded Parent Documents 

Miscellaneous Documents 

Shared DSS Files 

Cover Letter 

Technology Control Plan 

Electronic Control Plan 

Articles of Incorporation 



Privately Held Corporation

Publicly Held Corporation

Business License 



Sole Proprietorship

General Partnership

 Limited Partnership

 Joint Venture

 Privately Held Corporation

 Publicly Held Corporation

 Limited Liability Company

Bylaws 



Privately Held Corporation

Publicly Held Corporation

FictitiousName Certificate 



Sole Proprietorship

General Partnership

 Limited Partnership

 Joint Venture

 Privately Held Corporation

 Publicly Held Corporation

 Limited Liability Company

PartnershipAgreement 



General Partnership

Limited Partnership

Joint Venture Agreement  Joint Venture
Defense Security Service FCL Orientation Handbook

Page 19

Document Always Required Business Structure Requirement Shared File Requirement

Stock Ledger  Privately Held Corporation

 Publicly Held Corporation

Organization chart  General Proprietorship

 Limited Partnership

 Joint Venture

 Privately Held Corporation

 Publicly Held Corporation

 Limited Liability Company

Charter  College/University

A.2 Required KMP PCLs

KMP Business Structure

SMO  All Business Structures

FSO  All Business Structures

General Partners 



General Partnership

Limited Partnership

Limited Partners  Limited Partnership

JV Partners  Joint Venture

Chairman of the Board 



CorporateOfficials 



Privately Held Corporation

Publicly Held Corporation

Privately Held Corporation

Publicly Held Corporation

 Joint Venture

Regents/Trustees/Directors  College/University, Company, Corporation

Chief ExecutiveOfficer (CEO)  College/University, Company, Corporation, 

Partnership, Sole Proprietorship

ManagingMember / Member  Limited Liability Corporation

A.3 Defining KMP Authorities of Position

Please note that the descriptions of the Authorities of the Position are general and do not include all 

characteristicsfor each position. Roles may differ per your company.

KMP Role Authorities of the Position

CEO  Highestranking executivemanagerin a corporation or organization’s

by-laws or organizational documents

 Responsible for the overallsuccess/management of the organization

 Ultimate authority to make final decisionsfor an organization

 Responsibility for creating, planning, implementing, and integrating the 

strategic direction/vision of an organization

 Reportsto a Board of Directors and serves at the discretion of the

Board of Directors
Defense Security Service FCL Orientation Handbook

Page 20

KMP Role Authorities of the Position

President  Creates, communicates, and implementsthe organization's vision, 

mission, and overall direction

 Leads, guides, directs, and evaluatesthe work of other executive 

leadersincluding senior vice presidents, vice presidents and directors

 Formulates and implementsthe strategic plan that guidesthe direction 

of the business

 Overseesthe organization in accordance with the direction established

in the strategic plans

Chairman of the Board  Trusted with the responsibility of chairing a board or organization

 Governsthe board according to the bylaws of the organization. The

chairmanmust attend the board meetings and committeesregularly.

 Committed to board duties and has vast knowledge of the organization

itself

 Evaluates annual performance of the organization

 Chairman rarely involvesthemselvesin the company's day-to-day 

operations, instead concentrating on the bigger picture and various 

strategiesto increase the company's bottomline

 Institutes company policies and guidelines, and make certain that they

are carried out via upper management

 Recruits, interviews, and hires the CEO

 Votes on key issuessurrounding the company; when board is at a

standstill on an issue, the chair makesthe final decision

Manager  For an LLC, only a manager or authorized officer can bind the LLC as 

specified in the Operating Agreement or when there is no operating 

agreement, State Law where LLC is formed

 Elected by the members

 Decision authority on key policies,transactions, and establishment of 

guidelinesfor how the LLC will operate

 Can appoint officersto serve at the pleasure of the manager

General Partner  Full management control and also acceptsfull personalresponsibility 

for partnership liabilities as specified by state law where the 

partnership wasformed and the partnership agreement

 Right to manage the business, conducttransactions on the behalf of the

business, and are liable for the business’ debts

 Commonly is active in the day-to-day operations of the business

 May be an individual or company

Shareholder  Makes a financial investmentin the corporation, which entitlesthose 

with voting sharesto elect the directors as specified in the 

Shareholders agreement and/orstate law

 Does not normally have any rightsto be involved directly in company

management

 Connection to companymanagement is typically via the Board of

Directors

 If shareholder is not satisfied with the performance of the directors,

they may remove the directors or refuse to re-elect them
Defense Security Service FCL Orientation Handbook

Page 21

KMP Role Authorities of the Position

Board of Director  Protectsshareholders’ assets and ensure they receive a decentreturn 

on investment

 Provides oversight and strategic direction on behalf of the shareholders 

as authorized in the by-laws or State law

 Monitors corporate governance within an organization

 Approvesfinancialstatements

 Selects and evaluates CEO; approves appropriate compensation for CEO

 Evaluates attractiveness of and pay dividends

 Overseesshare repurchase programs,recommend stock splits, etc.

 Recommends or discouragesmergers and acquisitions

Vice President  Second in command in an organization and has specific responsibilities 

depending on the needs of his or her organization as directed by the bylaws

 Assistsin formulating and implementing the strategic plan that guides

the direction of the business or their area of responsibility

 Leads, guides, directs, and evaluatesthe work of other executive leaders

including assistant vice presidents, directors, and managers

 Achievesthe organization's overallstrategic goals and profitability

requirements as determined by the strategic plans

 Assists creating, communicating, and implementing the organization’s

vision, mission, and overall direction

 In the President’s absence,the Vice President actsin the role

Chief OperatingOfficer (COO)  Responsible for the daily operations.

 Provides communication, leadership, and guides management as

necessary to ensure that company hasthe proper operational controls,

administrative and reporting proceduresin place to effectively grow the 

organization

 Ensures effective communication with the President/CEO by keeping

him/herinformed of daily operations

 Ensuresthat operating objectives and standardsof performance are

understood by management and employees

 Ensuresthat Company complies with all applicable legal and regulatory

requirements and, where appropriate, best practice to maximize the 

financial integrity of Company

 Ensures appropriate and satisfactory systems are in place for monitoring

Company performance against planned and budgeted expectations

Limited Partner  Generally does not have any kind of management responsibility.

 They are not material participants,strictly investors

 Share in profits and losses based on share of ownership

Member Similar to a stockholder in a corporation. Responsible for formation of 

the LLC and/or having owning interest in the LLC as designated in the 

Operating Agreement and/or State Law when there is no Operating 

Agreement

 Chooses a managerto manage the LLC

 Can also be the manager

A.4 Training

Training Classes Link

FSO Initial Training http://www.cdse.edu/resources/resources-fso.html
Defense Security Service FCL Orientation Handbook

Page 22

Appendix B: e-FCL FAQs

Question Answer

How do I set up an e-FCL

account?

Is the FSO the only person at 

the company who can have an 

account and password? If so, 

what happensif a change

takes place with the company 

when the FSO is on leave?

The DSS Facility ClearanceBranch registers all companiesin the process of 

obtaining a new facility clearance for an e-FCL account. The account is issued to 

the company's Facility SecurityOfficer (FSO).

Upon registration, the FSO is typically designated as the User Administrator and 

account holder. The FSO can create additional accounts under the Organization 

tab allowing others accessto their information. If an FSO unexpectedly leaves 

without providing accessto the account, please contact your assigned ISR.

Do I need to keep a copy of 

the SF 328 even though I 

uploaded an electronic copy 

into the e-FCL system?

How long will my account be 

valid for?

Because of the socialsecurity 

information on the KMP lists,

is information transmitted and 

stored in a secure manner?

I uploaded an incorrectfile in 

the system. Can I delete the 

file?

Can a HomeOffice of a Multifacility Organization see 

subsidiary e-FCL account 

information?

Do I need to upload DoD 

Contract Security

Classification Specification DD

Form 254sin e-FCL?

Is there a file size limit to 

attachmentsin the system?

Is there a way to make my 

filessmaller to meet the 5MB 

size upload limit?

Even though the signed and sealed copy of the SF 328 is uploaded in the system, 

you must keep the original documentfor viewing by the ISR upon request.

Your account is valid untilsuch time as you no longer hold a facility clearance. 

The e-FCL system meets governmentstandardsfor the protection of proprietary

and personal information.

Yes, you can delete and replace any uploaded file as long as the package is

"unlocked" by DSS. To complete this action, follow these steps:

 Right click on the uploaded document.

 Then performone of the following actions:

View (allowsthe user to view the document)

Replace (allowsthe user to replace whateverthe document is with a new 

one)

Delete (allowsthe user to delete the document)

Yes, if the subsidiary e-FCL user administrator establishes a secondary 'user 

account'for the home office user under their CAGE Code. To accomplish this, the 

subsidiary user administratormust go into the "Organization" tab on the left hand

of the page, then choose "Users",then "Add a New User." If the new user already

has an existing e-FCL account,the next time they log into e-FCL they will see the

multiple organizationslisted for viewing (as long as the same email addressis

used for all accounts).

DSS requeststhat you include copies of DD -254s under the DD -254 tab within 

the Upload Documentssection of the e-FCL system.

Yes, 5MB per individualfile.

Yes, if you have Adobe Acrobat Professional you can reduce the size of a file.
Defense Security Service FCL Orientation Handbook

Page 23

Question Answer

What if reducing the size of a 

file still doesn't make it less 

than 5MB in size?

Where do I register for an 

account?

As a currently cleared facility, 

do I need to complete a full 

package in order to just report 

a changed condition?

As an existing cleared 

company do I really need to 

complete a new SF-328 since 

my information has not 

changed?

My facility falls under a 

consolidated SF-328 from our 

home office. Doesthe system 

require that I complete the 

electronic SF-328 and upload a 

signed hard copy as well?

You will then have to split apart the document and upload it in sectionsthat are

5MB and under in size.

Companiesthat are currently cleared or which are a U.S. Excluded Parent who 

require an e-FCL account to report a changed condition should contacttheir ISR 

who can registerthem for an account. Companieswho are in-processfor a 

clearance will be contacted directly by the Facilities Clearance Branch who will 

registerthem for an account.

All companies, existing and in-processmust complete an "initial package."An 

initial package requiresthat an electronic version of the SF-328 and KMP lists be 

completed. Corporate documents must be uploaded as well. Once this initial 

package is completed, all your documentation is retained in the system and 

future changed conditions are quick and easy to report.

The e-FCL system requiresthat an electronic SF-328 form be completed, printed 

and a hard copy of it uploaded with signatures.However, if your SF328 

information has not changed, once you have completed the electronic copy, you 

can upload into the systema copy of your existing SF-328. The same principle 

appliesto the KMP list.

No, if you fall under a consolidated SF-328, within Step 1 of the system, you can 

check a box which statesthat you fall under a consolidated SF-328. Once that box 

is checked, you will not be required to complete the electronic copy, nor will you 

be asked to upload one in the system. .
Defense Security Service FCL Orientation Handbook

Page 24

Appendix C: Exclusion Resolutions

C.1 Highest Cleared Entity Noting Excluded Entity’s Exclusion and Resolution to

Exclude Parent Organization

I, (Insert Full Name),the duly elected Secretary of (Insert Name of Highest Cleared Entity), a corporation in the State 

of (Insert Name of State), do hereby certify that the following is a true and complete copy of a resolution passed at

a meeting of the Board of Directors of said Corporation, at which a quorum was present, duly called, and held

(Insert Month Day, Year).

BE IT RESOLVED that officials of (Insert Name of Highest Tier Excluded Entity and any Intermediate 

Entities),the ultimate tier entity organization, or any of the intermediate tier entities of (Insert Name and Address 

of Highest Cleared Entity),shall not require and shall not have accessto classified information in the custody of 

(Insert Name of Highest Cleared Entity), a subsidiary organization or any other facilitiesreporting to (Insert Name 

of Highest Cleared Entity) that require accessto classified information.

BE IT FURTHER RESOLVEDthat (Insert Name of Highest Cleared Entity) hereby acknowledgesthe 

execution of a resolution by (Insert Name and Address of Highest Excluded Entity) whereby the Corporation, its 

officers and directors, as such, and intermediate entities will not require and will not have accessto classified 

information in the custody of (Insert Name of Highest Cleared Entity), a subsidiary corporation, and furtherthat 

this action will not affect adversely the policies of said subsidiary involving the security and safeguarding of 

classified information or performance of classified contracts.

BE IT FURTHER RESOLVEDthat these actions of the Board of Directors of the (Insert Name of Highest 

Cleared Entity) are taken for the purpose of exempting the (Insert Name of Highest Tier Excluded Entity and 

Intermediate Tiers) from the necessity of being processed for a Facility Security Clearance equivalentto that held by 

the (Insert Name of Highest Cleared Entity) in conformity with the “National Industrial Security ProgramOperating 

Manual.”

IN WITNESS WHEREOF I have hereunto set my hand and affixed the seal of (Insert Name of Highest

Cleared Entity) this(Insert Date).

Signature

Note: Two copiesshall be furnished to the local DSS Industrial Security field office with an originalsignature and 

corporate seal on each. One copy shall be furnished to the subsidiary. Both the highesttiered excluded entity and 

the highest cleared subsidiary must execute a “Certificate Pertaining to Foreign Interest” (SF 328).

If the parent is to be excluded from a higher category of classified information, the next to last paragraph should 

read “... from the necessity of having to be processed for a Facility Security Clearance equivalentto that held by 

the (Name of Subsidiary).”
Defense Security Service FCL Orientation Handbook

Page 25

C.2 Exclusion Resolution of Corporate Organization

I, (Insert Full Name), the duly elected Secretary of (Insert Name of Highest Tier Excluded Entity), a corporation 

organized in the State of (Insert Name of State), located at (Insert Address of Highest Tier Excluded Entity) do 

hereby certify that the following is a true and complete copy of a resolution passed at a meeting of the Board of 

Directors of said Corporation, at which a quorum was present, duly called and held (Insert Month Day, Year).

BE IT RESOLVED that (Insert Name and Address of Highest Tier Excluded Entity and Intermediate Entities), 

its officers and directors, as such, will not require and will not have access to classified information in the custody of 

(Insert Name of Highest Cleared Entity), or any other facilities reporting to (Insert Name of Highest Cleared Entity) 

that require access to classified information, and further that (Insert Name of Highest Cleared Entity), has been 

delegated full authority to act completely independent of (Insert Name of Highest Tier Excluded Entity and 

intermediate tiers) in all matters that involve or relate to (Insert Highest Cleared Entity’s) responsibility to perform 

on classified contracts, to include safeguarding classified information.

BE IT FURTHER RESOLVED that this action is taken for the purpose of exempting (Insert Name of Highest 

Tier Excluded Entity and Intermediate Tiers) from the necessity of being processed for a Facility Security Clearance 

(FCL) in conformity with the “National Industrial Security Program Operating Manual (NISPOM).” In lieu of a 

Facility Security Clearance, (Insert Name of Highest Tier Excluded Entity) will report any changed conditions, as 

defined in NISPOM 2-102, within the complete organizational structure that may impact the FCL eligibility of 

(Insert Name of Highest Cleared Facility). Any changes that may impact FCL eligibility of (Insert Name of Highest 

Cleared Facility) will be disclosed to the Facility Security Officer at (Insert Name of Highest Cleared Facility) or in 

special circumstances, directly to the Defense Security Service.

IN WITNESSWHEREOF I have hereunto set my hand and affixed the seal of (Insert Name of Company) this

(Insert Date).

Signature
Defense Security Service FCL Orientation Handbook

Page 26

C.3 Exclusion Resolution for LLC Member (Organization)

I, (Insert Full Name), the duly elected (Management Official Title) of (Insert Name of LLC Member), a (Type 

of Organization) organized in the State of (Insert Name of State), located at (Insert Address of LLC Member) do 

hereby certify that the following is a true and complete copy of a resolution passed at a meeting of the (Type of 

Management Board) of (Management Officials) of said (Type of Organization), at which a quorum was present, 

duly called and held (Insert Month Day, Year).

BE IT RESOLVED that (Insert Name and Address of LLC Member), its management officials, as such, will not 

require, shall not have, and can be effectively and formally excluded from access to classified information disclosed 

to (Insert Name of subject LLC), a Limited Liability Company, and further that (Insert Name of subject LLC), has been 

delegated full authority to act completely independent of (Insert Name of LLC Member) in all matters that involve 

or relate to (Insert Name of subject LLC)’sresponsibility to safeguard information.

BE IT FURTHER RESOLVED that (Insert Name and Address of LLC Member), is taken for the purpose of 

exempting the (Insert Name of LLC Member) from the necessity of being processed for a Facility Security Clearance 

in conformity with the “National Industrial Security ProgramOperating Manual.”

Signature

Date

(Senior Management Official of LLC Member)
Defense Security Service FCL Orientation Handbook

Page 27

C.4 Exclusion Resolution for Certain Directors, Officers, and LLC Member (if

Person)

I, (Insert Full Name), do hereby certify that I am (Identify eligible KMP officer/position title) of (Insert 

Name of Corporation), a (Insert Corporation, Company) organized and existing under the laws of the State of (Insert 

Name of State), and that the following is a true and correct copy of a resolution adopted by the Board of Directors, 

management board, or a similar type of executive body of the said (Insert Corporation, Company) at a meeting 

held at (Insert Location) on (Insert Month, Day, Year) at which time a quorum was present.

WHEREAS, current Department of Defense Regulations contain a provision making it mandatory that the 

Chairman of the Board, Senior Management Official and Facility Security Officer meet the requirements for 

eligibility for accessto classified information established for a contractorfacility security clearance; and

WHEREAS, said Department of Defense Regulations permit the exclusion from the personnel of the 

requirements for access to classified information of certain members of the Board of Directors and other officers, 

provided that this action is recorded in the corporateminutes.

NOW THEREFORE BE IT DECLARED that the Chairman of the Board, Senior Management Official and 

Facility Security Officer at the present time do possess, or will be processed for, the required eligibility for access to 

classified information; and

BE IT RESOLVED that in the future, when any individual enters upon any duties as Chairman of the Board, 

Senior Management Official and Facility Security Officer, such individual shall immediately make application for the 

required eligibility for accessto classified information; and

BE IT RESOLVED AND DIRECTED that the following members of the Board of Directors and other officers 

or members shall not require, shall not have, and can be effectively and formally excluded from access to all 

CLASSIFIED information disclosed to the corporation/company and shall not affect adversely corporate/company 

policies or practices in the performance of classified contracts for the Department of Defense or the Government 

contracting activities (User Agencies) of the National Industrial Security Program.

NAME TITLE

IN WITNESS WHEREOF I have hereunto set my hand and affixed the seal of (Insert Name of Company)this

(Insert Day/Month of Year).

Signature

Note: Two copies shall be furnished to the local DSS Industrial Security field office with an original 

signature and corporate seal on each. One copy shall be furnished to the subsidiary. Both the highest 

excluded entity parent and highest cleared subsidiary must execute a “Certificate Pertaining to Foreign 

Interest” (SF 328).
Defense Security Service FCL Orientation Handbook

Page 28

Appendix D: Glossary

D.1 Terms

Roles Responsibilities

Center for Development of

Security Excellence (CDSE)

Commercial and Government

Entity (CAGE) Code

 Providesthe DoD with a security center of excellence for the 

professionalization of the security community and be the premier 

provider of security education and training for the DoD and industry 

under the National Industrial Security Program(NISP)

 Five-characterID number used extensively within the federal 

government, assigned by the Department of Defense’sDefense 

Logistics Agency (DLA). It tracks basic facility information

Contractor  Provides cleared governmentsupport to a Prime Contractor and/or a

GCA

Defense Security Service

(DSS)

 Providessecurity oversight of the 14,000 facilities performing on 

classified contract work for US federal agencies within the NISP

Discontinuation Point  Facility failure to meet submission deadlinesresultsin the 

terminationof continuing with the facility’s FCL process

Electronic Facility Clearance

System (e-FCL)

Electronic Questionnaires for 

Investigations Processing (eQIP)

Facility Clearance Branch

(FCB)

Facility Security Clearance

(FCL)

 Online systemutilized by Contractor’s Facility administrator to 

upload Documents and Formsfor the FCL process

 System managed by the US Office of Personnel Management (OPM) 

that automatesthe common security questionnaires used to process 

federal background investigations

 Administers and overseesthe approval or rejection process of a

Sponsored Facility’s FCL

 Issued by DSS, allowing a company to performcleared government 

contract work on behalf of a GCA or another contractor

Facility SecurityOfficer (FSO)  Provides operational oversight of a cleared Facility’s compliance with 

the requirements of the National Industrial Security Program(NISP)

 Acts as Facility’sseniorsecurity officer

Industrial Security

Representative (ISR)

Joint Personnel Adjudication

System (JPAS)

Key Management Personnel

(KMP)

 Focuses efforts on assisting Contractorto identify and mitigate 

processes, people, or systems posing the greatestrisk to a 

Contractor’sfacility

 Assiststhe Contractorto receive its FCL

 Performs Pre-Assessmentresearch and conductsthe Annual

Assessment

 Reviews Security Violation Final Reportssubmitted by FSOs and 

conducts Administrative Inquiries

 Assiststhe FSO and/or FCB in the Invalidation, Revocation,

Revalidation, and Termination processes

 Standardizesthe adjudication process within DoD, and provides a 

database and processes within the security managerrealm of 

functions

 Individualsrequired to be cleared or excluded as determined by the 

Cognizant Security Agency or when delegated, its CSO, as part of 

issuing a Facility Security Clearance. This may include Owners, 

Officers Directors, Executive Personnel, Partners, LLC Members, 

Managers, Trustees, Regents, Proxy Holders,NISP Facility Security 

Officer, Insider Threat Program Manager, etc.
Defense Security Service FCL Orientation Handbook

Page 29

Roles Responsibilities

National Industrial Security 

Program Operation Manual 

(NISPOM)

National Industrial Security

Program (NISP)

 Provides baseline standardsfor the protection of classified 

information released or disclosed to industry in connection with 

classified contractsunder the NISP

 Program outlining criteria for cleared facilitiesto safeguard classified 

information while performing work on contracts, programs, bids, or 

research and development efforts

Prime Contractor  Providessponsorship for a Contractorto obtain a FCL

 Responsible for ensuring that sub-contractors have a valid FCL

 Responsible for reporting information that may affect their FCL and

theirsubcontractors FCL to DSS.

Senior Management Official

(SMO)

Secure Web Fingerprint

Transmission (SWFT)

Security Training, Education 

and Professionalization 

(STEPP)

 Contractor’ssenior most official at the facility

 System used to submit fingerprintsfor e-QIPs

 Programmaintaining the list of courses DSS provides Contractor’s

security professionals

Telephonic Survey  Robust informalsurvey conducted by ISR with FSO to walk through 

the requirements of the FCL process; occurs 5 – 10 days after receipt 

of FCL OrientationHandbook

D.2 Business Structure

Roles Responsibilities

General Partnership  Refersto an association of persons or an unincorporated company 

with the followingmajor features: created by agreement, proof of 

existence and estoppel, formed by two or more persons, and the 

owners are all personally liable for any legal actions and debtsthe 

companymay face

Highest Cleared Facility  Parent company that has previously received its FCL and provides 

updates on Intermediate Tiered company’s while its subsidiary is 

going through its FCL process

Intermediate Excluded

Company

 Subsidiary of the Ultimate Excluded Entity and a parent of the facility 

undergoing the FCL process. It is also excluded from reviewing 

classified information its subsidiary is contracted to perform by a 

Prime Contractor or GCA

Joint Venture  Business agreementin which the parties agree to develop, for a finite 

time, a new entity and new assets by contributing equity. They 

exercise control over the enterprise and consequently share 

revenues, expenses and assets

Limited Partnership  Partnership in which only one partneris required to be a general 

partner

Limited Liability Company  Flexible form of enterprise that blends elements of partnership and 

corporate structures.An LLC is not a corporation; it is a legal form of 

company that provideslimited liability to its ownersin the vast 

majority of United Statesjurisdictions
Defense Security Service FCL Orientation Handbook

Page 30

Roles Responsibilities

PrivatelyHeld Corporation  Owned either by non-governmental organizations or by a relatively 

small number of shareholders or company memberswhich does not 

offer or trade its company stock (shares)to the general public on the 

stock market exchanges, but rather the company'sstock is offered, 

owned and traded or exchanged privately

PubliclyHeld Corporation  Offersits securities(stock/shares, bonds/loans, etc.) for sale to the 

general public, typically through a stock exchange, or through market 

makers operating in over the counter markets

Sponsored Facility  Facility sponsored by a Prime Contractor or GCA to receive a FCL to 

performclassified government work

Sole Proprietorship  Refersto a type of business entity that is owned and run by one 

individual and in which there is no legal distinction between the 

owner and the business.

Tiered Company (Parent

Company)

 Defined as a company owning at least a majority of another 

company’s voting securities

Ultimate Excluded Entity  Highest parent company facility that is excluded from reviewing 

classified information its subsidiary is contracted to perform by a 

Prime Contractor or GCA