Key takeaways:

• On June 12, 2012, the CFTC published the final rules on swap data recordkeeping and reporting requirements for swaps entered into before the compliance date of the new swap data recordkeeping and reporting rules mandated by the Dodd-Frank Act.
• Under the final rules, parties who entered into swaps prior to the enactment date of the Dodd-Frank Act and prior to the effective date of the swap data recordkeeping and reporting rules will have certain recordkeeping and reporting obligations with respect to those historical swaps.
• All parties who entered into historical swaps and whose swap data will be subject to recordkeeping and reporting requirements will need to obtain a "Legal Entity Identifier" from the CFTC or an entity to be designated by the CFTC.