This update is a reminder that the April 10, 2013 deadline is approaching for all swap counterparties (including hedge funds) to obtain a legal entity identifier (LEI), currently known as a CFTC Interim Compliant Identifier or “CICI.” Counterparties that have adhered to the ISDA Dodd-Frank Protocol will have already obtained a CICI as part of the adherence process.
In connection with the Commodity Futures Trading Commission’s (CFTC) recordkeeping and reporting regulations promulgated under the Dodd-Frank Act, all swap counterparties (not just swap dealers and major swap participants) must obtain and maintain a CICI by April 10, 2013. The CFTC has encouraged swap dealers to notify their counterparties of this requirement, however, regardless of
whether your counterparties have notified you of this obligation, all ounterparties are required to obtain a CICI by the deadline.
According to the CFTC, swap counterparties should log on to the CICI Utility web portal at http://www.ciciutility.org to check their CICI status. It is possible that a counterparty may already have a CICI, even if the counterparty did not itself register for it. If the CICI Utility database already contains a CICI for the counterparty, the counterparty should (a) check the accuracy of its CICI reference data and make any needed corrections, and (b) self-certify the CICI if it was issued through third-party registration. If the counterparty does not have a CICI, it can register for one through CICI Utility web portal.