The Board of Governors of the Federal Reserve System (Board),
the Office of the Comptroller of the Currency (OCC), and the
Federal Deposit Insurance Corporation (FDIC) adopted rules
(together, the QFC Stay Rules) in 2017 requiring amendments to
certain qualified financial contracts (QFCs). The compliance dates
for these rules depend on the type of QFC counterparty facing a
"covered entity" (as defined below), and are being phased
in beginning on January 1, 2019 and ending on January 1, 2020.1
Notwithstanding this compliance phase-in, dealers subject to the
QFC Stay Rules have been requesting that all of their
counterparties, including end users, take action to facilitate
compliance as though the initial compliance date, January 1, 2019,
applied to all types of QFC counterparties. This article is
intended to help buy-side participants navigate the compliance
process, with emphasis on describing (i) the various types of
contracts that constitute "covered" QFCs subject to
