The U.S. Commodity Futures Trading Commission (CFTC) requires major swap dealers and participants to report any trades with CICIs for themselves and for their counterparties, as well. It also requires all swap counterparties to obtain a CICI as part of the recordkeeping related to such transactions. Under these rules, many firms globally are required to have CICIs, and they will need to register or certify their information in the CICI Utility database.
The CICI will ultimately transition to the global legal entity identifier (LEI) program, which is being overseen by the Financial Stability Board (FSB) on behalf of the G20 nations. DTCC, SWIFT, ISO and industry representatives, led by the Global Financial Markets Association (GFMA), are playing active roles in the FSB’s process to design and implement a global LEI solution that meets the needs of both the industry and regulatory communities. The industry’s recommended solution, implemented to support the CICI, is designed to move to a “federated” solution for the global LEI, allowing registries in each country or jurisdiction to assign and validate LEIs. DTCC and SWIFT are partnering with the Association of National Numbering Agencies to evolve towards that end.