Treasury Extends Compliance Dates For Certain QFC Recordkeeping Requirements

The Secretary of the U.S. Treasury Department ("Treasury"), as Chair of the Financial Stability Oversight Council and in consultation with the FDIC, adopted a final rule extending the compliance dates for regulations implementing qualified financial contract ("QFC") recordkeeping requirements for certain non-bank financial companies.

As previously covered, the Treasury established QFC recordkeeping rules for certain non-bank financial companies in order to facilitate the possible FDIC resolution of such companies under the Orderly Liquidation Authority. The rules require non-bank financial companies that meet specified systemic risk criteria ("records entities") to maintain records on "[QFC] positions, counterparties, legal documentation, and collateral." The rules were adopted with a staggered compliance schedule ranging from 18 months to 4 years based on the size of the records entity. Records entities are also permitted to make requests for exemption from