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.
You Might Also Be Interested In...
AML, Bank Secrecy Act and Sanctions BPI Submits Comment Letter to FinCEN Regarding AML Program Effectiveness
Bank Governance BPI Offers Recommendations to NY Financial Services Regulator on a Re-Proposed Regulation on Disclosure of Confidential Supervisory Information
Cybersecurity BPI Files Comment Letter with U.K. Banking Authorities in Response to Operational Resilience Proposals
Regulatory Reporting and Accounting BPI Submits Comment Letter to Banking Agencies on Revisions to Call Report
Resolution & Recovery Planning Putting “Too Big to Fail” to Rest: Evidence from Market Behavior in the COVID-19 Pandemic
Consumer Affairs BPI Joins Joint Coalition Comment Letter Responding to CFPB NPR on General Qualified Mortgage Definition
More Posts by This Author
FinTech & Innovation FinTech and Big Tech Companies Want the Benefits of Banking Without the Responsibilities. Regulatory Loopholes Could Let Them Succeed.
AML, Bank Secrecy Act and Sanctions BPI Endorses Legislative Compromise to Reform Anti-Money Laundering Framework and End Anonymous Shell Companies
Bank Activities and Structure BPI Asks OCC to Furnish Data Used to Support Rushed Fair Access Proposal in FOIA Request