Title

Final QFC Stay Rules Visual Memorandum
Client Memorandum

Created date

12/21/2017

The U.S. banking agencies recently issued final rules that will require U.S. G-SIBs and certain foreign G-SIBs to amend their swap contracts, repurchase agreements and other qualified financial contracts to include certain provisions meant to limit the ability of counterparties to close out these contracts in the case of a resolution of the G-SIB. 

The rules are part of the package of reforms implemented by the industry, Congress and the U.S. banking agencies since the financial crisis in an attempt to ensure that the largest financial institutions can be resolved in an orderly manner.  While the rules will be phased-in over the next 2 years, compliance will entail a significant effort by the G-SIBs and their counterparties.