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ARTICLE · 27 MARCH 2013

Party To A Swap Contract? CFTC Registration Rules Apply

Venable LLP
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Please note the April 10, 2013, deadline to register and obtain a Legal Entity Identifier (LEI), described in the advisory recently released by the Commodity Futures Trading Commission.

United StatesFinance and Banking
Daniel Danello
Daniel Danello
Mitchell Kolkin
Mitchell Kolkin

Please note the April 10, 2013, deadline to register and obtain a Legal Entity Identifier (LEI), described in the advisory recently released by the Commodity Futures Trading Commission (CFTC).

LEI registration is required by CFTC reporting and recordkeeping rules adopted under the Dodd-Frank Act.

For swap contracts in effect on or after April 25, 2011, each party to the contract (not just swap dealers and major swap participants) must register and obtain an LEI.

Also please note two other upcoming CFTC compliance dates.  

Beginning May 1, 2013, a commercial entity entering a swap contract with a swap dealer must agree to the ISDA August 2012 Dodd-Frank Protocol or similar contractual terms. 

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