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.