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Each depositor insured to at least $250,000 per insured bank

Recordkeeping Requirements for Qualified Financial Contracts (QFCs) - Technical Points

The following frequently asked questions and answers are intended to help records entities interpret the Part 371 data requirements. They were prepared by, and represent the views of, the staff of the Federal Deposit Insurance Corporation (the “FDIC”). They are not rules, regulations, or statements of the FDIC, and do not have the approval or disapproval of the Board of Directors of the FDIC. They are not legally binding on records entities or the FDIC. The staff may update these questions and answers periodically based on the experience gained in the implementation of Part 371 by various records entities.

Technical Points Questions

  1. Where do I get answers for questions not provided below that are related to data requirements under Part 371?
  2. How do I send the data files to the FDIC?
  3. I forgot my password. How do I retrieve it?
  4. What is the file format?
  5. What is the file naming structure?
  6. Should there be a header row in the data files?
  7. Should there be an end-of-file indicator at the bottom of each file?
  8. What values should be used for fields that are not applicable for a given class of QFCs or product type?
  9. Is YYYY/MM/DD a valid date format?
  10. For the top-level entity, what should be in the Immediate Parent Entity Identifier?
  11. I have inter-affiliate trades. My counterparty on the trade is in the CO table (Corporate Organization Master). Should it also be in the CP table (Counterparty Master)?
  12. What can I enter in the field A1.7 – Type of QFC? Is it Interest Rate Swaps or IRS or Int Rt Swp?
  13. I am short a position. Do I report A1.19 (for Full Scope entities and A1.18 for Limited Scope entities) – Notional or principal amount of the position in local currency and A1.20 – Notional or principal amount of the position in U.S. dollars, as negative?
  14. How do I use the field A1.22 – Related position of records entity?
  15. What is the difference between field A1.8 (Agreement Identifier) and field A1.9 (Netting Agreement Identifier)? Are they required fields? Can they be “NA”?
  16. What is the difference between field A1.4 (Counterparty Identifier) and field A1.10 (Netting Agreement Counterparty Identifier)? Are they the same? If not, when will they be different?
  17. My QFC has more than one local currency. How do I show multiple currencies in fields A1.15, A1.16 and A1.19?
  18. How is(are) the guarantee(s) of a guaranteed QFC shown in fields A1.21 through A1.21.5 of table A1?
  19. How are entities with multiple immediate parents reported in the Corporate Organization Master Table (“CO Table”) and the Counterparty Master Table (“CP Table”)?

1. Where do I get answers for questions not provided below that are related to data requirements under Part 371?

Please email part371qfc@fdic.gov

Last updated: Dec. 12, 2017

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2. How do I send the data files to the FDIC?

FDIC uses GlobalScape Secure File Transfer to transfer files. You will provide the FDIC with a Point Of Contact for the file transfer process. The POC will receive an email with a User ID for the file transfer session. The password for the session will be provided over the phone – for security reasons this password cannot be emailed. The session stays open for 7 days. You will upload the data files and email FDIC once the files are available for download. FDIC will email back once the files have been downloaded. Once downloaded, the files are deleted from the portal.

Last updated: Dec. 12, 2017

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3. I forgot my password. How do I retrieve it?

We cannot retrieve passwords. We have to create a new file transfer session.

Last updated: Dec. 12, 2017

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4. What is the file format?

The files should be flat file with columns separated by “~” (tilde-delimited flat file)

Last updated: Dec. 12, 2017

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5. What is the file naming structure?

For Part 371 (Full Scope entities)

If the Part 371 entity (XYZ Bank) is part of a Part 148 family (HoldCo):


If the Full Scope Part 371 entity (XYZ Bank) is not a part of a Part 148 family -


For Part 371 (Limited Scope entities)

Last updated: Dec. 12, 2017

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6. Should there be a header row in the data files?

Yes. The field names should be used for the first row (or the header row). For example for A1 file, the first row should be as follows –
A1.1~A1.2~A1.3~A1.4~ … and so on

Last updated: Dec. 12, 2017

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7. Should there be an end-of-file indicator at the bottom of each file?

No. The last row should be the last data row.

Last updated: Dec. 12, 2017

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8. What values should be used for fields that are not applicable for a given class of QFCs or product type?

All fields should have value. All “null” or empty fields are flagged as error. Please use the following values for fields that are not applicable –
Text fields or AlphaNum fields – NA
Numeric – 0
Date – 2099-12-31

Last updated: Dec. 12, 2017

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9. Is YYYY/MM/DD a valid date format?

No. YYYY-MM-DD is the only acceptable date format.

Last updated: Dec. 12, 2017

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10. For the top-level entity, what should be in the Immediate Parent Entity Identifier?

These fields are used for establishing affiliate relations. Please use “NA” if the entity is the top level entity.

Last updated: Dec. 12, 2017

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11. I have inter-affiliate trades. My counterparty on the trade is in the CO table (Corporate Organization Master). Should it also be in the CP table (Counterparty Master)?

Yes. All counterparties – third parties and affiliates - should be in the CP table

Last updated: Dec. 12, 2017

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12. What can I enter in the field A1.7 – Type of QFC? Is it Interest Rate Swaps or IRS or Int Rt Swp?

A1.7 is a free form field. Interest Rate Swaps, IRS and Int Rt Swp are all valid values. However, you will have to pick one and use it consistently across all submissions. Also, if your product type is unique or the value is difficult to understand, you will be asked to provide a data dictionary with QFC Type definitions.

Last updated: Dec. 12, 2017

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13. I am short a position. Do I report A1.19 (for Full Scope entities and A1.18 for Limited Scope entities) – Notional or principal amount of the position in local currency and A1.20 – Notional or principal amount of the position in U.S. dollars, as negative?

No, notional amount should always be reported as positive

Last updated: Dec. 12, 2017

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14. How do I use the field A1.22 – Related position of records entity?

Let’s say you have five QFCs that are somehow tied together for some business reason or risk management reason, etc. You would tag these QFCs with the same value in the field A1.22. The actual value itself is not important – you could start with a sequential counter - grouping from 1, the next group of related QFCs would be tagged “2” in field A1.22, and so on.

Last updated: Dec. 12, 2017

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15. What is the difference between field A1.8 (Agreement Identifier) and field A1.9 (Netting Agreement Identifier)? Are they required fields? Can they be “NA”?

Field A1.8 is the primary governing agreement for the QFC, e.g., an ISDA Master, a Master Repurchase Agreement, a Guarantee Agreement, etc. Field A1.9 is used to identify the netting set that includes that QFC. If the netting set for a QFC is all the QFCs under the same master agreement, then the netting set is the master agreement and field A1.9 will show the same value as field A1.8. In the schematic below, there are 3 QFCs netted under the same master agreement.

A1.8 Schematicd

However, if there are multiple netting sets under a master agreement, then each netting set must be assigned its own unique identifier. If there is a QFC under that master agreement that is not part of any netting set under that master agreement then the QFC’s QFC-confirmation should be used as the netting agreement identifier. In the schematic below, there are 6 QFCs under a master agreement - 2 netting sets with 2 QFCs each, and the other 2 QFCs that are standalone, not netted and unsecured.

A1.8 Schematicd

It should be noted that on Table A2 the fields for Records Entity Identifier, Netting Agreement Counterparty Identifier, and Netting Agreement Identifier should all be filled in. These are required fields and cannot be “NA.”

Last updated: May 21, 2018

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16. What is the difference between field A1.4 (Counterparty Identifier) and field A1.10 (Netting Agreement Counterparty Identifier)? Are they the same? If not, when will they be different?

Fields A1.4 and A1.10 will be the same if the counterparty to the QFC is also the only party to the netting agreement (i.e. the netting agreement counterparty) and provides the collateral support to the netting agreement (if required). This is likely to be the case in the majority of situations, and is shown in the schematic below.

A1.4 Schematic d

In some cases, however, the party to the netting agreement (and the provider of collateral under the netting agreement) is not the QFC counterparty itself. In these cases, the QFC counterparty’s identifier is used to populate field A1.4 and the Netting Agreement Counterparty Identifier is used to populate field A1.10

In the schematic below, CP1, CP2, and CP3 are related entities and all have QFCs with RE. All CP1, CP2, and CP3 QFCs are netted under the terms of the relevant Netting Agreement. In addition, CP1 provides the collateral for all of its QFCs and its family’s QFC exposure with RE.

A1.4 Schematicd

Although this example is intended to enable a records entity to reflect the existence of such cross-party netting arrangements, if any, this should not be construed as any endorsement or approval of — or any opinion regarding the enforceability of — any such arrangements by the FDIC acting in any capacity.

Last updated: May 21, 2018

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17. My QFC has more than one local currency. How do I show multiple currencies in fields A1.15, A1.16 and A1.19?

Report multiple local currency fields delimited by colon (“:”) – e.g., field A1.15 could look like EUR:CHF. Note that the field definition would now apply to individual sub-field, i.e., for the A1.15 example, each subfield (EUR and CHF) has to be 3 characters and has to be an ISO currency code. For fields A1.16 and A1.19, each sub-field has to be of the format Num(25,5) separated by “:”.

Last updated: May 21, 2018

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18. How is(are) the guarantee(s) of a guaranteed QFC shown in fields A1.21 through A1.21.5 of table A1?

Certain Information about the guarantee(s) relating to a guaranteed QFC is captured in fields A1.21, A1.21.1, A1.21.2, A1.21.3, A1.21.4 and A1.21.5 (please see field descriptions for additional details). Note that the guarantees of QFCs are themselves QFCs and should be shown as separate QFCs on Table A1.

In the schematic below, an Interest Rate Swap (transacted under a Master ISDA) between RE and CP is guaranteed by CP-P (agreement ID GTY1) for the benefit of RE. In addition, RE-P has guaranteed the Interest Rate Swap (agreement ID GTY2) for the benefit of CP. In this example, the Interest Rate Swap and the related guarantees would be reported as follows:

A1.21 Schematic

Last updated: May 21, 2018

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19. How are entities with multiple immediate parents reported in the Corporate Organization Master Table (“CO Table”) and the Counterparty Master Table (“CP Table”)?

Entities with multiple immediate parent entities should be reported in two (or more) separate rows – each row will capture one immediate parent entity. The schematic below shows an entity (ABC4 Inc. – entity ID ABC4) with two immediate parents and the corresponding CO Table entries.

CO Table

Last updated: May 22, 2018

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