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ARTICLE · 23 APRIL 2013

Dodd-Frank Swaps Update: Compliance Dates Approaching

Dentons
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A number of Dodd-Frank compliance deadlines are quickly approaching for all users of swap contracts.

United StatesCorporate/Commercial Law
Jeffrey Koppele
Jeffrey Koppele
Stephen Kudenholdt
Stephen Kudenholdt
Jerome Walker
Jerome Walker
Priscilla Bunke
Priscilla Bunke
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A number of Dodd-Frank compliance deadlines are quickly approaching for all users of swap contracts.  By April 10, 2013, all swap counterparties must obtain a "legal entity identifier," currently known as the "CFTC Interim Compliant Identifier" or "CICI." Commodity Futures Trading Commission (CFTC) regulations require that the CICI be used for swap data recordkeeping as well as swap data reporting.

Each counterparty entering into or modifying a swap with a swap dealer or major swap participant ("MSP") on or after May 1, 2013, must adhere to the ISDA August 2012 Dodd-Frank Protocol or enter into similar contractual terms. Each counterparty must also enter into a second Dodd-Frank protocol, known as DF Protocol 2.0, by July 1, 2013.

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