The Division of Market Oversight, or DMO, and Office of Data and Technology, or ODT of the CFTC have issued an advisory reminding all swap counterparties of the imminent April 10, 2013, deadline for each counterparty to obtain a legal entity identifier, or LEI, currently known as a CFTC Interim Compliant Identifier or CICI.

In the advisory, DMO and ODT suggest two immediate steps to ensure compliance with CICI requirements. One, each swap counterparty should visit, check its CICI status, and self-register for a CICI or self-certify its third-party-registered CICI if that is needed. Two, swap dealers should contact each of their counterparties regarding CICIs, and remind them to obtain a CICI before the April 10 deadline if they have not already done so.

According to the advisory this means that all swap counterparties, even those that are not swap dealers or major swap participants, and even those not required to report swap data, must obtain a CICI before April 10, 2013. In addition, each entity must maintain its own CICI after it is issued, keeping its reference data current and accurate, and re-certifying the record at appropriate intervals.