TCH Comments on the Proposed QFC Recordkeeping Rules Compliance Dates

The Clearing House (TCH) commented on the Treasury Department’s proposed rule to extend the compliance dates for firms to comply with Treasury’s QFC recordkeeping rule under the Dodd-Frank Title II Orderly Liquidation Authority.  The extension is designed to allow Treasury more time to rule on various pending exemption requests under the rule. TCH letter stresses the importance of Treasury ruling on those requests as soon as possible.  TCH recommends that Treasury extend the compliance dates by 9 months, rather the 6 months provided for in the proposal.  We also recommend that Treasury and FDIC coordinate to align the compliance dates between the Treasury’s QFC recordkeeping rule and a substantially similar parallel rule that the FDIC has for QFC recordkeeping by insured banks.