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Recent Developments Regarding CICI Requirements and Looming Deadlines for Compliance by End-Users of Swaps
22 March 2013
We would like to remind all swap end-users that all swap parties must obtain the "legal entity identifier" known as the "CFTC Interim Compliant Identifier" or CICI by April 10, 2013.
Commencing on May 1, 2013, external business conduct rules applicable to swap dealers impose an obligation on them to obtain certain information about their swap customers. Therefore, all swap end-users must either adhere to the ISDA D-F Protocol or amend their existing documents with each swap dealer to provide the necessary information by that date.
Mandatory clearing of certain interest rate and index credit default swaps will start on June 10, 2013 for Category 2 Entities. Therefore, all affected Category 2 Entities will need to establish clearing arrangements with one or more futures commission merchants before June 10 in anticipation of the effectiveness of mandatory clearing.
Emilie T. Hsu
Victoria G. J. Brown
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