DTCC-SWIFT stays on as legal identity identifier for American swap reporting

In order to further the smooth transition to a global system of legal entity identification, the U.S. Commodity Futures Trading Commission (Commission) issued an Amended and Restated Order on July 22, 2014, extending the designation of the utility operated by DTCC-SWIFT, DTCC representing the combination of the Depository Trust Company and the National Securities Clearing Corporation. as the provider of legal entity identifiers, or LEIs, pursuant to the Commission’s swap data recordkeeping and reporting rules.

DTCC-SWIFT’s initial designation was made by a Commission order on July 23, 2012. The designation was made for a two-year term. At the time the order was issued, the Commission was already participating in an international process to establish a global LEI system, into which the legal entity identifier to be used to comply with Commission requirements was expected to transition. The Amended and Restated Order extends DTCC-SWIFT’s designation for an additional one year, while the global LEI system becomes fully operational.

Consistent with the terms of the Commission’s order of July 23, 2012, as previously amended on June 7, 2013, the Amended and Restated Order continues to permit registered entities and swap counterparties subject to the Commission’s jurisdiction to comply with the Commission’s swap data recordkeeping and reporting rules by using legal entity identifiers issued by DTCC-SWIFT, or any other pre-Local Operating Unit (pre-LOU) that has been endorsed by the Regulatory Oversight Committee (ROC) of the global LEI system as being globally acceptable.

The Amended and Restated Order also clarifies that legal entity identifiers issued by such ROC-endorsed pre-LOUs – including legal entity identifiers issued by DTCC-SWIFT – are now known as LEIs, rather than pre-LEIs or CICIs. This means that, going forward, previously issued pre-LEIs – including CICIs issued by DTCC-SWIFT – will be known as LEIs, but they will not need to be reissued.

The DTCC-SWIFT utility – which had initially been referred to, on the utility’s website and in educational and other materials, as the CICI utility – is now known to the public as the Global Markets Entity Identifier (GMEI) utility. The utility may be accessed at www.gmeiutility.org. A full list of the pre-LOUs that have been endorsed by the ROC as globally acceptable, including the website via which each of these pre-LOUs may be accessed, is available at www.leiroc.org/publications/gls/lou_20131003_2.pdf.

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DTCC-SWIFT stays on as legal identity identifier for American swap reporting


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