FDIC Proposes Modifications to QFC Recordkeeping Rules for IDIs in a Troubled Condition

On December 13, 2016, the FDIC proposed amendments to its recordkeeping requirements for qualified financial contracts for insured depository institutions in a “troubled condition”.

The FDIC’s proposed rule is principally designed to more closely align its existing recordkeeping rules with the Dodd-Frank Act recordkeeping requirements adopted by the Secretary of the Treasury.   While the FDIC’s proposed rule aligns in most ways with the Dodd-Frank Act recordkeeping requirements, in certain key respects the FDIC’s proposed rule departs from the Treasury’s recordkeeping rule.  Comments on the FDIC’s proposed rule are due on February 27, 2017.