Alert February 26, 2013

Reminder: Swap End-Users Must Obtain LEIs/CICIs by April 10, 2013

CFTC Swap Data Recordkeeping and Reporting Requirements require each counterparty to any swap that is subject to the jurisdiction of the CFTC to obtain a legal entity identifier, or “LEI,” which is a unique code used to identify a legal entity in all recordkeeping and swap data reporting.  The current version of the LEI is called the CFTC Interim Compliant Identifier, or “CICI.”

End-users—that is, swap counterparties that are neither swap dealers nor major swap participants—are required to obtain a CICI no later than April 10, 2013. The deadline has already passed for swap dealers and major swap participants to obtain a CICI.

CICIs may be obtained at the DTCC-SWIFT Registration Portal at https://www.ciciutility.org.  Those planning to apply for a CICI should first search for the registrants’ name on the portal, as certain entities were pre-assigned CICIs by the organizations maintaining the site.  For those that have not been pre-assigned CICIs, registration requires providing certain information about the registrant and paying a registration fee of $200.