The Legal Entity Identifier (LEI) program is designed to create and apply a single, universal standard identifier to any organization or firm involved in a financial transaction internationally.

DTCC, SWIFT Launch CICI Utility and Web Portal

The Depository Trust & Clearing Corporation (DTCC) and SWIFT have launched a Web portal at http://www.ciciutility.org/ to begin assigning CFTC Interim Compliant Identifiers (CICIs) after being designated by the U.S. Commodity Futures Trading Commission (CFTC) to do so.

For more information, please see:

• CICI Guidance on Registration and Certification (New)
• Practical Guide for CICI Registration and Certification for Funds, Asset Managers and Fund Administrators (New)
• CUSIP Global Services Press Release on CICI Utility
• DTCC and SWIFT press release on CICI Utility
• CICI Practical Guide (Revised November 2012)
• Introduction to Bulk Registration

CFTC Designation and CICI Utility Portal Launch

On July 24, the CFTC released an Order designating DTCC and SWIFT as the providers of entity identifiers for CFTC swap data reporting. These identifiers are known as CFTC Interim Compliant Identifiers (CICIs) until the establishment of a global Legal Entity Identifier (LEI) solution, at which time they are expected to become LEIs.

As a result of this designation, DTCC and SWIFT are making certain CFTC-required changes to the CICI Utility Portal for launch. The CICI Utility Portal launched and was ready for use on August 21, 2012.

At launch, the portal already contained 24,000 validated entity records that have been assigned CICIs that align with the ISO 17442 standard. The portal allows entities to query and/or download the data and also allows entities to certify their records or register new records.

The CICI Utility Portal includes a user guide and a set of answers to frequently asked questions to assist individuals and organizations in using the portal. In addition, webinars will be planned to educate the industry and address open questions.

We will be continuing our dialogue with the CFTC and providing additional updates.

Please view the CFTC press release for more information.

 

Overview

The Legal Entity Identifier (LEI) program is designed to create and apply a single, universal standard identifier to any organization or firm involved in a financial transaction internationally. Such an identifier for each legal entity would allow regulators to conduct more accurate analysis of global, systemically important financial institutions and their transactions with all counterparties across markets, products and regions, allowing regulators to better identify concentrations and emerging risks. For risk managers in financial institutions, the LEI will increase the effectiveness of tools aggregating their exposures to counterparties.

Recommendations

After extensive dialogue and due diligence, a group of international trade associations have made recommendations to the global regulatory community on the requirements for an LEI solution as well as LEI solutions providers. They include:

• Standards Body: The International Organization for Standardization (ISO) has created a new draft standard, ISO 17442, as the new, authoritative legal entity identification standard.
• Registration Authority and Facilities Manager: The Depository Trust & Clearing Corporation (DTCC) and The Society for Worldwide Financial Interbank Telecommunication (SWIFT), along with DTCC’s wholly-owned subsidiary Avox Limited, were recommended as key partners to operate the core LEI utility as the central point for data collection, data maintenance, LEI assignment and quality assurance.
  • SWIFT, as the registration authority, will register and assist entities with self-registration.
  • DTCC, as facilities manager, will collect requests for new LEIs to be created, validate the information provided by leveraging Avox’s capabilities, maintain and store the reference data associated with each LEI, and maintain the public distribution of the LEI database.
• Federated Registration: The Association of National Numbering Agencies (ANNA) through its network of 82 national numbering agencies, will register, validate and maintain LEIs for issuers, obligors and other relevant parties in the 118 markets they serve.

The G-20 nations have endorsed the creation of the LEI and have called for the Financial Stability Board (FSB) to oversee the program and to make recommendations in several areas, including the governance framework, the funding and operational models, the scope of the reference data including access and confidentiality and implementation phasing. The FSB will be preparing recommendations in these areas by the end of April 2012 for consideration by the G-20 at their Summit in June.

The U.S. Commodity Futures Trading Commission (CFTC) became the first regulator to mandate the use of the LEI in regulatory reporting. CFTC Rule 17 CFR Part 45 -- Swap Data Recordkeeping and Reporting Requirements, beginning in mid-2012, will require dealers executing OTC derivatives transactions with their global counterparties to report those transactions subject to CFTC oversight to Trade Repositories, identifying themselves, their counterparties and the reference entities of the contracts with LEIs. The CFTC is also participating in the FSB Process.

The industry and the recommended solution providers, including DTCC, are working together to launch an initial Phase 1 Solution this spring to enable firms facing these new regulatory reporting requirements to meet them beginning in mid-2012. Further work on the LEI Utility beyond this initial phase will commence after the FSB process concludes and will be guided by their recommendations.

The LEI Project Scope and Preliminary Implementation Plan Summary

This document includes more information on all of the above, plus details about the Phase 1 implementation including:

• A list of targeted entity classes. The industry requirements call for any legal entity that enters into a financial transaction being eligible for an LEI.
• A list of the data that the Draft ISO 17442 LEI Standard calls for to be provided on each LEI record.
• A description of a new web portal being built to support registration and validation of legal entity data.
• Principles guiding the planned LEI infrastructure including that the LEI Database will be available free of charge to all users, including commercial data vendors, without licensing, and with no restrictions on usage.
• Phase 1 components and details including field classifications, process scenarios and record states.

On January 20, 2012 the GFMA posted on its web site a TEST File created by DTCC and SWIFT, of over 2,600 provisional legal entity identifiers, as well as a brief summary describing the provisional legal entity identifier attributes. This was made available so that financial market participants can begin to evaluate, understand and test the operational implications for their businesses of recently enacted and impending regulatory reporting requirements that include legal entity identification.

Statement on FSB Recommendations

DTCC fully supports the position of the GFMA in their media statement on the FSB recommendations, and worked with GFMA and SWIFT in the analysis of those recommendations. DTCC looks forward to continuing to work with our industry partners and the FSB to successfully implement the LEI.

Further updates will be made via this web page. Other valuable resources are available through the links provided on this page.

Links

GFMA provisional legal entity identifier Test File
GFMA LEI Resource Center

SIFMA
LEI Overview

Financial Stability Board (FSB) LEI Documents
Macroprudential Policy Tools and Framework
Call for members for LEI Industry Advisory Committee

G-20 Announcement

CFTC Rule

U.S. Office of Financial Research (OFR)
OFR Policy Directive
OFR Progress Press Release

@dtcc
The ABCs of LEI