How do I report Natural Person Identifiers?

If a counterparty is not eligible to receive a legal entity identifier as determined by the Global Legal Entity Identifier System, such counterparty shall be identified in all recordkeeping and all Data reporting with an alternate identifier as prescribed by the Commission. It is the duty of the Reporting Counterparty to always submit a unique and consistent Natural Person Identifier. In order to consistently submit a unique value, the LEI of the Reporting Counterparty followed by a unique identifier for the natural person shall be used for the identifier.

Anytime a Natural Person Identifier is used the related "Source" field should be submitted with the value "NPID".

If a company does not have an LEI can I report using a NPID?

No.