The CFTC Division of Market Oversight (DMO) and Office of Data and Technology (ODT) issued an Advisory reminding swap counterparties of the imminent April 10, 2013 deadline for all swap counterparties to obtain a legal entity identifier (LEI), currently known as a CFTC Interim Compliant Identifier or "CICI."
The Advisory stresses the fact that the CICI requirement applies to all swap counterparties, even those that are not registered with the CFTC and even those that are not required to report swap data. The Advisory also suggests that swap dealers should take active steps to inform each of their swap counterparties of the need to obtain CICIs and that swap counterparties previously issued CICIs through third-party registration, must self-certify the CICI data record before April 10.
Part 45 of the CFTC regulations ("Swap Data Recordkeeping and Reporting Requirements") requires the use of CICIs in all swap recordkeeping and swap data reporting. The source for obtaining a CICI is the CICI Utility designated by the CFTC, available at www.ciciutility.org.