Frequently Asked Questions About Legal Entity Identifiers

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The Office of Financial Research (OFR) of the US Treasury Department (which was created by the Dodd-Frank Wall Street Reform and Consumer Protection Act) has been participating in a global effort to improve the infrastructure of the financial markets by creating a process for assigning every participant in financial transactions a Legal Entity Identifier (LEI), which is a unique identification number that facilitates transactional recordkeeping and reporting for financial transactions and can also be used for risk management purposes. On February 20, the OFR published a set of Frequently Asked Questions to educate the markets about the LEI project as it moves from the design phase toward implementation.

The regulations adopted by the Commodity Futures Trading Commission under the auspices of Title VII of the Dodd-Frank Act already require that every party entering into derivative transactions on or after July 12, 2013 have an LEI; however, since the global LEI framework is not yet in place, the CFTC has commissioned DTCC and SWIFT to issue an interim form of identifier (CFTC Interim Compliant Identifier or CICI) that will meet the requirements of its swap rules.

The full set of Frequently Asked Questions can be found here.

The CICI portal is available here.

 


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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