Treasury Proposes Extending Compliance Dates For Certain QFC Recordkeeping Requirements

The Secretary of the Treasury, as Chair of the Financial Stability Oversight Council ("FSOC"), proposed an amendment to extend the compliance date of regulations implementing qualified financial contract ("QFC") recordkeeping requirements for certain non-bank financial companies that may pose systemic risk.

In order to facilitate the FDIC resolution of failing banks under the FDIC's Orderly Liquidation Authority, Treasury had adopted final rules that require non-bank financial companies that meet specified systemic risk thresholds ("records entities") to maintain specified records concerning QFC positions, counterparties, legal documentation and collateral. The rules provided staggered compliance dates and granted the Treasury Secretary (in consultation with the FDIC) discretion to provide exemptions as well as extensions of the compliance dates.