Financial Regulatory Developments Focus - January 2015

In this issue:

- Bank Prudential Regulation & Regulatory Capital

- Bank Structural Reform

- Credit Ratings

- Derivatives

- Enforcement

- Financial Services

- Recovery & Resolution

- People

- Events

- Excerpt from Bank Prudential Regulation & Regulatory Capital:

Qualified Financial Contracts Recordkeeping Related to Orderly Liquidation Authority -

On January 7, 2015, the US Department of the Treasury (“US Treasury”), acting for the US Financial Stability Oversight Council (“FSOC”), issued a proposed rulemaking aimed to implement the Qualified Financial Contract (“QFC”) recordkeeping requirements of the Dodd-Frank Act. The proposed rules would apply to financial companies with $50 billion or more in consolidated assets, financial companies designated by the FSOC, as well as financial affiliates of these companies and would require recordkeeping of positions, counterparties, legal documentation and collateral. This information is needed to help the Federal Deposit Insurance Corporation (“FDIC”) as receiver to, among other things, decide whether to transfer QFCs, evaluate the consequences of decisions to transfer, disaffirm or permit the termination of QFCs with one or more counterparties, and conclude whether any financial systematic risks are posed by the transfer, disaffirmation or termination of such QFCs in the case of a distressed situation. The deadline for comments is April 7, 2015.

Please see full publication below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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