Unique Transaction Identifier (UTI)
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      3. Unique Transaction Identifier (UTI)

      What format should be used to create UTIs?

      The Market Participant designated to generate the UTI shall generate and assign the UTI at, or As Soon As Technologically Practicable (ASATP) following, the time of execution of the swap, and prior to the reporting of required Swap Data. The unique transaction identifier shall consist of a single data element with a maximum length of 52 characters that contains two components: 

      1. The legal entity identifier of the Market Participant who generated the UTI; and

      2. An uppercase alphanumeric code generated and assigned to that swap by the automated systems of the SEF or DCM, which shall be unique with respect to all such codes generated and assigned by that SEF or DCM.

      References: CFTC Rule(s) §45.5(a)(1), §45.5(b)(1), §45.5(c)(1), §45.5(d)(1), §45.5(e), and 45.5(g).

      • New UTIs have a maximum of 52 characters but allow shorter UTIs
      • Constructed solely from the upper-case alphabetic characters A–Z or the digits 0–9, inclusive in both cases.
      • If generation of the UTI has been delegated, the generating entity for the purpose of determining the LEI to be embedded in the UTI should be the entity that actually generates the UTI and not the entity that delegated the generation.
      • No requirement to update a UTI solely because the LEI of the generating entity is no longer valid or applicable for some reason.