DTCC-SWIFT to Provide Legal Entity Identifiers for Swap Transactions

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The Commodity Futures Trading Commission, or CFTC, has issued an order designating DTCC-SWIFT as the provider of the legal entity identifiers, or LEI, which will be used by registered entities and swap counterparties in complying with the CFTC’s swap data reporting regulations. LEIs, to be known as CFTC Interim Compliant Identifiers or CICIs until establishment of a global LEI system, are, according to the CFTC, essential tools for aggregation of derivatives data. The CFTC believes they will be crucial to the ability of CFTC and other financial regulators to use swap data to fulfill the systemic risk monitoring and mitigation, market transparency, and market abuse prevention purposes of the Dodd-Frank Wall Street Reform and Consumer Protection Act.

The CFTC is also participating in an international process, coordinated by the Financial Stability Board, or FSB, to establish governance principles and reference data requirements and implement a global LEI system. Once the global LEI system is implemented and operational, the CFTC anticipates that the interim identifier will transition into the global LEI.

Check dodd-frank.com frequently for updated information on the JOBS Act, the Dodd-Frank Act and other important securities law matters.

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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