Swap Market Participants May Now Register for CICIs (Interim LEIs) Required for Swap Data Reporting

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Today, the CFTC announced the launch of a website for swap market participants to register for CFTC Interim Compliant Identifiers (CICIs), which are interim versions of the legal entity identifiers (LEIs) required for all swap data reporting. Since all swaps are required to be reported under Dodd-Frank, all entities engaging in swaps, whether they are the reporting counterparties or not, must obtain LEIs (for now, CICIs). Registration for a CICI requires a 200 USD fee. As described in a prior dodd-frank.com post, the CICIs will be provided by DTCC-SWIFT.

The CFTC is participating in an international process to implement a global LEI system and anticipates that, once the global LEI system is implemented and operational, the CICI will transition into the global LEI system.

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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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