The first of three compliance deadlines for US regulations requiring resolution-related amendments to qualified financial contracts is January 1, 2019, and delaying compliance until the subsequent deadlines creates additional risk. Compliance programs may not be able to eliminate this risk due to the scope of contracts to be remediated and the staggered compliance period that looks back to the first compliance date.
USA, Banking, Capital Markets, Derivatives, Insolvency & Restructuring, Insurance, White & Case, Office of the Comptroller of the Currency (USA), Federal Deposit Insurance Corporation (USA), Dodd-Frank Wall Street Reform and Consumer Protection Act 2010 (USA)
This article was published in a slightly different form in the November 2016 issue of Futures & Derivatives Law by The Journal on the Law of Investment & Risk Management Products.
Introduction
USA, Derivatives, Insolvency & Restructuring, Litigation, White & Case, United States bankruptcy court