Under the final rules for swap data reporting requirements for historical swaps and future swaps1, all market participants are required to obtain a legal entity identifier that will be reported to the relevant swap data repositories or the Commodity Futures Trading Commission (the “CFTC”) and used to identify each counterparty to a swap transaction.

Last week, the CFTC announced the designation of DTCC-SWIFT as the provider of an interim legal entity identifier called “CFTC Interim Compliant Identifier” or “CICI.” CICIs are to be used until a global legal entity identifier system is fully operational, at which time the CFTC anticipates the transition of CICIs into that global system of legal entity identifiers.

Swap counterparties who are neither swap dealers nor major swap participants may not be subject to swap data reporting requirements, but they are still required to obtain a CICI or have their reporting counterparties obtain a CICI for them.

All market participants who wish to apply for a CICI for themselves or for their counterparties can do so at the following website, which is owned, managed and operated by DTCC-SWIFT. https://www.ciciutility.org/index.jsp

While access to the website is free and open to the public, DTCC-SWIFT charges a $200 CICI assignment fee.