CFTC Advisory: Deadline for CICIs and Swap Data Reporting Approaches | Practical Law

CFTC Advisory: Deadline for CICIs and Swap Data Reporting Approaches | Practical Law

The CFTC has issued an advisory reminding market participants that the final default date for swap data reporting under all final CFTC swap data reporting rules is April 10, 2013, and that all parties to swaps for which data must be reported must obtain a CICI by that date.

CFTC Advisory: Deadline for CICIs and Swap Data Reporting Approaches

Practical Law Legal Update 7-525-2918 (Approx. 3 pages)

CFTC Advisory: Deadline for CICIs and Swap Data Reporting Approaches

by PLC Finance
Published on 21 Mar 2013 • USA (National/Federal)
The CFTC has issued an advisory reminding market participants that the final default date for swap data reporting under all final CFTC swap data reporting rules is April 10, 2013, and that all parties to swaps for which data must be reported must obtain a CICI by that date.
The April 10, 2013 deadline for compliance with all final Dodd-Frank swap data reporting rules is approaching (see Practice Note, US Derivatives Regulation: Practical Guide to Over-the-Counter (OTC) Swap Data Reporting). In connection with this deadline, the CFTC's Division of Market Oversight (DMO) and Office of Data and Technology (ODT) issued an advisory on March 15, 2013 reminding all swap counterparties that each counterparty must also obtain a CFTC Interim Compliant Identifier or CICI by April 10, 2013. CICIs are a temporary substitute for legal entity identifiers (LEIs), the global system for transaction counterparty identification, which is not yet operative. In addition, on March 8, 2013, the LEI Regulatory Oversight Committee released its first progress report on the Global LEI Initiative.
CICIs will transition into the global LEI system once one is established, at which time these identifiers will be referred to as LEIs.
In order to ensure compliance with the CICI deadline, the DMO and ODT suggest that:
  • Each swap counterparty should visit www.ciciutility.org to check its CICI status and either:
    • self-register for a CICI; or
    • self-certify its third-party-registered CICI.
  • Swap dealers should contact each of their swap counterparties regarding CICIs and remind them to obtain a CICI before the April 10 deadline if they have not already done so.
On March 8, 2013, the LEI Regulatory Oversight Committee, which is responsible for overseeing the global LEI system, released its first progress note on the Global LEI Initiative.
For more on the CICI registration requirement and the substitution of CICIs for LEIs until the global LEI system is in place, see Legal Update, CICIs to Substitute for Legal Entity Identifiers on Interim Basis.