What if I don't have an LEI for Counterparty 2 and can't get one?

Question:

Where a counterparty 2 (CP2) does not obtain an LEI and the reporting party (RCP) provides the identity and contact information for CP2 to CFTC per 45.6: When the RCP does execute a trade with that CP2 and reports to the SDR, it will receive NACKs due to the lack of an LEI. Does the RCP still need to send a 45.14 Error Notification Form to CFTC staff?

The CFTC has already received notice from the RCP that CP2 does not have an LEI. The correction of this error is out of the control of the RCP until CP2 obtains its LEI, so these additional notifications may not be needed

CFTC Feedback:

After RCP provides the identity and contact details for CP2 to CFTC per 45.6, there is no need to send a 45.14 Error Notification Form.