US Treasury Extends Compliance Dates for QFC Recordkeeping Requirement
The U.S. Department of the Treasury is adopting a final rule that extends the compliance dates of the regulation implementing the qualified financial contract (QFC) recordkeeping requirements related to Orderly Liquidation Authority under the Dodd-Frank Act. The final rule is effective from May 23, 2018.
The regulation currently provides for staggered compliance dates for the bulk of the recordkeeping requirements as follows. The regulation generally provides that:
- Records entities with USD 1 trillion or more in total consolidated assets have 540 days (approximately 18 months) after the effective date to comply with the regulation
- Records entities with total assets equal to or greater than USD 500 billion (but less than USD 1 trillion) have two years from the effective date to comply with the regulation
- Records entities with total assets equal to or greater than USD 250 billion (but less than USD 500 billion) have three years from the effective date to comply with the regulation
- All other records entities have four years from the effective date to comply with the regulation
Given that the effective date is December 30, 2016, the first of these compliance dates is currently June 23, 2018. This final rule amends the regulations to extend the compliance date by approximately nine months for records entities in the first compliance tier. Based on the substantive comment received in response to the proposed rule, it is believed that this extension will allow sufficient time for such records entities to comply with the rule after determinations have been made with respect to the exemption requests. Additionally, it has determined to extend the compliance dates for all other records entities by six months, as was proposed.
Related Link: Final Rule
Effective Date: May 23, 2018
Keywords: Americas, US, Banking, Securities, QFC, Recordkeeping, Dodd Frank Act, OLA, US Treasury
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