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This section provides helpful Frequently Asked Questions (FAQs) about DTCC's legal entity identifier (LEI) solution.

Questions and Answers

Important Developments(5)

Why is a Pre-LEI required?

All swap counterparties subject to CFTC jurisdiction are required to have a Pre-LEI for recordkeeping as well as reporting.

Reporting firms must identify themselves and counterparties with Pre-LEIs on transactions submitted to registered swap data repositories.

How do I register for a new Pre-LEI or certify an existing Pre-LEI record?

Self-Registration via Portal – Registrations for your entities can be completed via the GMEI Utility Portal at www.gmeiutility.org. All self-registered records are initially certified upon registration and the entity is required to maintain/certify the record annually. Payment can be made via credit card. As of April 1, 2013, a wire payment mechanism for registrations processed on the GMEI Utility Portal will be available.

Assisted Registration via Portal – A third-party can register another entity for a Pre-LEI via the GMEI Utility Portal if they have the entity’s explicit permission to do so. All Assisted Registration records are certified upon registration and the entity is required to maintain/certify the record annually. As of April 1, 2013, a wire payment mechanism for registrations processed on the GMEI Utility Portal will be available.

Bulk Registration – Self or Assisted Registration can be completed via a bulk file submission. For bulk registrations, payment can be made via wire transfer. Bulk registration files should contain at least 50 registrations, although files of fewer than 50 registrations may be considered. Please send an email to bulksubmission@gmeiutility.org if you are interested.

Certification via Portal – An entity receiving a Pre-LEI as part of the initial database population or via Third-party Registration (functionality that was discontinued and replaced by Assisted Registration on November 16, 2012) is required to certify their Pre-LEI as soon as possible following registration and annually thereafter. Certification can be done via the web portal. Payment can be made via credit card. As of April 1, 2013, wire payments for Certifications done on the GMEI Utility Portal will be available.

Bulk Certification – Beginning March 4, 2013, a Bulk Certification function was implemented to allow users to submit a bulk file certifying the reference data for their Pre-LEI records. This process allows for payment via wire transfer. Please send an email to bulksubmission@gmeiutility.org if you are interested.

How do I keep my records up-to-date between annual certification dates?

Individuals should be encouraged to submit the latest information for their entity records between annual certifications. To facilitate this type of submission, the Challenge process was created on the GMEI Utility Portal. This will allow users to submit any new information without being charged. As a result of the user’s submission, the GMEI Utility Validation Team will review the request, and update the record according to publicly available information. If additional information needs to be supplied to confirm the change, the user can submit information to the GMEI Utility Customer Service Team at customerservice@gmeiutility.org.

Who must perform the registration or certification?

Each swap counterparty subject to CFTC jurisdiction is expected to:

  • Self-register for a Pre-LEI or give explicit permission to another party to register it via Assisted Registration to certify its Pre-LEI record if it was registered during the initial load of the database or via Third-party Registration prior to November 16, 2012.
  • Maintain its own record via the annual Certification process

Subsequent to initial registration, all entities that have Self-registered or Assisted Registered for Pre-LEIs must certify the data associated with their Pre-LEI on an annual basis, even if there is no change to the information.

Entities who obtained a Pre-LEI via the initial load of the database prior to implementation, or via Third-party Registration prior to November 16, 2012, should Certify their Pre-LEIs as soon as possible, but no later than April 10, 2013 and then annually on an on-going basis.

When are Pre-LEIs required?

  • SDs for credit and interest rate swaps: December 31, 2012; annually thereafter
  • SDs for equity, FX, and commodity swaps: February 28, 2013; annually thereafter
  • MSPs, for all asset classes: February 28, 2013; annually thereafter
  • Non-SD/MSP counterparties, for all asset classes: April 10, 2013; annually thereafter


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