A Look At The New Qualified Financial Contracts Rule

By Rashmi Seth, Eli Whitney Debevoise II, Rosa Evergreen, David Freeman Jr., Gregory Harrington, Henry Morriello, Skanthan Vivekananda, Arturo Caraballo, Michael Karol, Andrew Joseph Shipe and Anthony Raglani (October 13, 2017, 3:01 PM EDT) -- New regulations approved by the Board of Governors of the Federal Reserve System and the Federal Deposit Insurance Corp. will fundamentally change the playing field for end users or buy-side counterparties that engage in certain types of financial agreements with the world's largest financial institutions. The new rules have been adopted as part of the regulators' ongoing efforts to address the "too-big-to-fail" problem. They will require any U.S. top-tier bank holding company that is a global systemically important banking organization (GSIB), the subsidiaries of such a GSIB (including state member and nonmember banks and state savings associations and most of their...

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