Mandatory Contractual Stay Requirements for Qualified Financial Contracts of certain FDIC-Supervised Institutions

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.