October 18, 2016
The International Swaps and Derivatives Association, Inc. (“ISDA”) appreciates the opportunity to provide the Office of the Comptroller of the Currency (the “OCC”) with comments and recommendations regarding the notice of proposed rulemaking (the “OCC Proposed Rule”) promulgated by the OCC regarding mandatory contractual stay requirements for qualified financial contracts (“QFCs”) of federally chartered and licensed financial institutions that are members of systemically important U.S. banking organizations and the U.S. operations of systemically important foreign banking organizations (together, “Covered Banks”).
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