Key takeaways:

• 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.