1. How QFC Recordkeeping is like a Box of Chocolates
Compliance solutions for the new U.S. Treasury Department Rule:
Qualified Financial Contracts Recordkeeping related to Orderly Liquidation Authority

2. What is QFC Recordkeeping?
The Treasury Department’s new regulation aims to facilitate managing Qualified Financial Contracts (QFCs) in Orderly Liquidation Authority (OLA) FDIC Receivership.
The Regulation applies to large financial companies party to an open QFC including:
Securities;
Commodities;
Forwards;
Repos; and
Swaps.
The Regulation requires reporting of 128 data points for all open QFCs.
What is 8of9?
8of9 is a next generation RegTech company that translates complex financial regulation into simple solutions.
We strive to build a world where regulatory compliance is automated and easy to understand. 
Our tools capture, store, and monitor regulatory content so you can focus on doing what you do best.
We deliver regulations in code.

3. Why is QFC Recordkeeping like a Box of Chocolates?
QFC Recordkeeping requires you to store information relevant to your QFCs and provide it to the FDIC within 24 hours of a request.
Your data looks like this…
but regulators require this.
The industry stores financial contracts in .PDF and Word Documents, failing to keep track of required QFC data.
Qualified Financial Contracts
Regulators expect contracts to be linked to trading and credit systems to provide real-time data.
Qualified Financial Contract Data Points

4. Required Data For QFC Recordkeeping Compliance:
From Mud to Morsel…
You must collect 128 discrete data points from EACH Qualified Financial Contract and provide this information to the FDIC.
Only 5 of 128 Requirements per QFC
Required Data For QFC Recordkeeping Compliance:
Position Level - 31 Data Points
Corporate Organization - 12 Data Points
Counterparty Netting Set - 24 Data Points
Counterparty Data -12 Data Points
Legal Agreement - 20 Data Points
Booking Information - 7 Data Points
Collateral Detail - 15 Data Points
Safekeeping Agent - 7 Data Points

5. Why QFC Recordkeeping Will Create a Sticky Mess
There are five major obstacles in compliance with QFC Recordkeeping Requirements.
1. Data is not collected, unreliable or in an improper format.
2. Regulation overlaps with itself and other regulations, putting pressure on staff.
3. Regulations and requirements are complex and constantly changing.
4. Internal processes within financial institutions are also constantly changing.
5. There is insufficient information governance and granularity.
Bad Data
Regulatory Rat Nests
Changing Regulations
Growing Complexity
No Audit Trail

6. Don’t Worry, You’re Already Collecting The Data You Need!
Even though your organization may not be coordinating, some of the required data is the same as data you are already collecting!
QFC
FATCA
RRP
CP Domicile of Counterparty
C Percentage Ownership of Immediate Parent Entity in the Entity
A Is Collateral Re-Hypothecation Allowed?
A Third-Party Credit Enhancement Provider Identifier (for the benefit of the counterparty)
A Agreement Governing Law

7. How Solutions can help you with QFC recordkeeping.
Data Internal to the customer
Data External to the customer
Data that needs to be Created
Regulatory Answer!
8of9 believes that all regulation should be broken down into ones and zeros. All data falls into one of the following categories:
8of9 created Regulatory Rules
Other Service Providers
Data Cleanse
Fully auditable, controlled, accurate, up-to-date answer, transaction by transaction
Output of data cleanse prepared in appropriate rules engine formatting
Non Regulatory Data (e.g. Pricing Data)
Up-to-date regulatory status and rules
8of9’s Business Logic Engine

8. Our consultants are different:
How Services can help you with QFC recordkeeping.
Legal Knowledge
All 8of9ers have J.D.s + other advanced degrees (M.B.A.s, L.L.M.s, Ph.D.s,)
RegTech
Diverse Backgrounds in finance, tech, law, public sector & Extensive training in IT
Project Management
Executive Training in Emerging Regulations, Project Management and Excel from industry experts.
8of9 believes that the current approach to solving regulatory problems is cost-prohibitive, ineffective, and unsustainable.
Our consultants are different:
We excel at:
Understanding the spirit and purpose of regulatory requirements
Developing communication plans for regulators
Working with diverse stakeholders
Identifying gaps in business and technology processes
Building controls to remediate weaknesses

9. QFC Recordkeeping Timeline
Timeline for Implementation
The Treasury Department releases the final rule.
QFC Recordkeeping Final Rule
Large-Sized Company Compliance Date
Compliance is Required for Certain Financial Companies with ≥ $1 Trillion in assets.
Mid-Sized Company Compliance Date
Compliance is Required for Certain Financial Companies with ≥ $500 Billion and < $1 Trillion in assets.
Compliance is Required for Certain Financial Companies with ≥ $250 Billion and < $500 Billion in assets.
Small-Sized Company Compliance Date
October 31, 2016
June 23, 2018
December 30, 2018
December 30, 2019
The Trump Effect: Trump’s Transition team vowed to “dismantle” Dodd-Frank, and Republican lawmakers have sought to abolish the OLA. However, it is currently unclear exactly what changes Trump and Congress will make to these requirements.

10. More Sustainable QFC Information Packaging
8of9 provides a deep understanding of the QFC recordkeeping requirements and simple solutions to the most difficult regulatory problems!
Map Existing Data to QFC Requirements
Identify Gaps & Create Missing Data
Data Cleansing & Categorization
Connect Source Data to Rules Engine
Develop Reports
8of9’s legal knowledge and regulatory experience will ensure:
All aspects of complex data collection and submission are handled correctly
Compliance with the most recent version of the regulation

11. We look forward to working with you soon!
Contacts
CEO Mary Kopczynski, J.D./Ph.D.
COO Matthew Fand, J.D./M.B.A.
Address
8of9
1115 Broadway 11th Floor
New York, NY 10010
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