Alert November 12, 2013

CFTC Announces Mutual Acceptance of Approved Legal Entity Identifiers

The CFTC announced that registered entities and swap counterparties subject to the CFTC’s jurisdiction may now comply with the CFTC’s swap data recordkeeping and reporting requirements with respect to Legal Entity Identifiers (“LEIs”) by using LEIs provided by any pre-Local Operating Unit (“pre-LOU”) approved by the Regulatory Oversight Committee (“ROC”) of the global LEI system and approved by the ROC as issuing globally acceptable LEIs.  In other words, registered entities and swap counterparties subject to CFTC jurisdiction may now use any LEI endorsed by the ROC as globally acceptable; they do not need to use a CFTC Interim Compliant Identifier (“CICI”).