April 10 Deadline for Swap End User Legal Entity Identifier Requirement

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Every swap end user (i.e., any party to an outstanding derivative contract who is not a swap dealer or major swap participant) should be aware that April 10, 2013 is the deadline for obtaining a “CFTC Interim Compliant Identifier” number (or CICI) in connection with its swap activities. The requirement arises under Commodity Futures Trading Commission Rule 45.6(f), which specifies that every “swap counterparty” must use a legal entity identifier (LEI) in all recordkeeping. The global regime for LEIs is not yet in place, so the CFTC arranged for the issuance of CICIs as an interim measure until definitive LEIs are available. The rule is already applicable to registered swap dealers and major swap participants, and the compliance date for end users is April 10, 2013. The CICI requirement applies only to entities, not to individuals.

A detailed explanation of the requirement can be found here.

A CICI can be obtained for $200 from the CICI Utility website run by DTCC.

If a third party previously obtained a CICI for an end user, the end user must still go to the CICI website by April 10 to “certify” the CICI. In every case, an end user is responsible for maintaining its own CICI after it is issued, including by re-certifying it at required intervals. A CFTC press release on this point can be found here.

 

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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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