CICI Sidesteps the Storm
by Theresa Pagliocca
When DTCC began executing business continuity plans throughout the organization, the CICI Utility staff had the luxury of operating business as usual.
“The CICI team did not have to deploy its continuity plan for one simple reason – the Utility’s operational and technical teams and platforms aren’t located in New York,” said William Hodash, DTCC Managing Director, Business Development.
The CICI Utility, a partnership between DTCC and SWIFT, is a global business with a globally dispersed operating model. CICI, short for CFTC (Commodity Futures Trading Commission) Interim Compliant Identifier, is the identifier that enables the industry to satisfy entity identifier requirements for CFTC over-the-counter (OTC) derivatives reporting and recordkeeping rules. These identifiers are an important tool to assist regulators and the financial industry in managing systemic risk.
How the data flows
DTCC provides the facilities manage-ment, including reference data validation, for the CICI Utility while SWIFT provides the ISO 17422 numbers assigned to each entity.
The CICI Utility teams are located in Iowa, Wales and Belgium, as well as New York. “As a result of this globally dispersed model, the hurricane never hindered the CICI Utility’s ability to assign identifiers or validate reference data,” said Ronald Jordan, DTCC Chief Data Officer. “Throughout the storm, customers were able to access the CICI web portal and submit registrations, and the public was able to download the database.”
When a registration request comes in from a customer, it is processed on the web portal where credit card payment is also supported. The web portal platform is located in Iowa and operated by Kingland Systems Corporation. The registration request is then sent to the SWIFT team in Belgium where a 20-character CICI number is assigned in a matter of seconds.
The CICI is then returned to the web portal, added to the CICI database, and placed in an operational queue to be validated by the Wales-based CICI operations team the next day. That team validates the information using publicly available authoritative sources from over 230 jurisdictions around the world using expertise and intellectual property developed over the past decade by Avox, a separate subsidiary of DTCC.
Plans are in place
While the CICI Utility did not have to implement its continuity plan during the recent hurricane, the business has built robust safeguards to ensure continued operations in case of other events.
“DTCC, SWIFT and Kingland Software each have multiple data centers and detailed business continuity plans,” said Hodash. “We have put redundancies into place to ensure the CICI Utility can continue to serve its customers regardless of outside or unforeseen forces.”
More on CICI
The CFTC began mandating the use of CICIs to identify trading parties in transaction reporting to swap data repositories for OTC credit and interest rate derivatives effective October 12, 2012. The rules will extend to other OTC derivatives asset classes starting in mid-January 2013.
Insurance & Retirement Services: A U.S. Business
by Robin Shapiro
Another example of DTCC’s dispersed workforce model is the Insurance & Retirement Services (I&RS) team. This U.S.-based business has been decentralized since 2002, with staff members located in six states.
“Our initial intent was to expand our hiring options by tapping into the national market for experienced and knowledgeable professionals regardless of their location,” said Adam Bryan, General Manager of I&RS. “That concept evolved into a team that is practiced at working together remotely, which has served DTCC and our clients well in terms of business continuity over the years.”
Connected throughout Sandy
In the days leading up to and following Hurricane Sandy, the I&RS team held daily touch-base calls to keep up to date. “We wanted everyone on the same page, with the latest information,” said Bryan. This coordinated team approach also facilitated seamless client contact.
“We maintained open lines of communication with clients throughout the storm and its aftermath, keeping them up to date on the situation and DTCC’s functionality,” said Bryan. “We also made sure clients with questions, concerns or problems knew how to contact the I&RS staff that had full connectivity.”
By now, working remotely and across state boundaries is business as usual for IR&S. “Each team member is set up with the technology and resources to work from home, so when people on the East Coast lost power during the storm, staff in other parts of the country were immediately able to step in and support our work,” said Jeanann Smith, DTCC Director, I&RS.@