CFTC Designates Provider of Legal Entity Identifiers

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[authors: Kevin M. Foley, Blake J. Brockway]

In general, Commodity Futures Trading Commission Rule 45.6 provides that each counterparty to a swap must be identified by a single legal entity identifier (LEI) for purposes of the CFTC’s swap recordkeeping and reporting rules. On July 23, the CFTC issued an order announcing that the Depository Trust & Clearing Corporation & SWIFT (DTCC-SWIFT) would be responsible for providing LEIs (which will be known as CFTC Compliant Interim Identifiers or CICIs) on an interim basis until the CFTC transitions to a global LEI system. The CFTC designated DTCC-SWIFT as the CICI provider for a limited term of two years.

CFTC registered entities and swap counterparties subject to the CFTC’s jurisdiction must use the CICIs provided by DTCC-SWIFT for purposes of the CFTC’s swap recordkeeping and reporting rules. CFTC registered entities and swap counterparties may contact DTCC-SWIFT at:

The Depository Trust & Clearing Corporation
55 Water Street
New York, NY 10041
212-855-1000

Click here to see the CFTC’s order.

 

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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