SIFMA’s Asset Management Group (SIFMA AMG) provided comments on the
proposed rulemaking promulgated by the Federal Deposit Insurance Corporation
(FDIC) regarding a proposed rule that would restrict the contractual provisions
of qualified financial contracts (QFCs) entered into by certain FDIC-supervised
institutions (Covered FSIs) that are subsidiaries of certain U.S. and non-U.S.
systemically important banking organizations.  These restrictions extend
to QFCs entered into by Covered FSIs with counterparties that are not Covered
FSIs, which would include, among others, asset managers’ clients.