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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”)?
  20. What are the valid values for location fields (A3.7, A4.14, CO.10, CO.11, CP.5, CP.6)? Can the field length exceed the 50-characters limit?
  21. How is collateral excess or collateral deficiency calculated (applies to A2.13 & A2.14)?
  22. Are fields A2.9 (collateral posted by records entity) and A2.10 (collateral posted by counterparty) complements of one another? – if counterparty posted $100 (A2.10 is $100), then records entity received $100 (A2.9 is -$100).
  23. What validations are performed on the data files?

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.

3 QFCs netted under the same master agreementd

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.

6 QFCs under a master agreementd

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.

Difference between Counterparty Identifier and Netting Agreement Counterparty Identifier 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.

CP1, CP2, and CP3 are related entitiesd

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:

The guarantee(s) of a guaranteed QFC

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.

Entity (ABC4 Inc. – entity ID ABC4) with two immediate parents with corresponding CO Table entries

20. What are the valid values for location fields (A3.7, A4.14, CO.10, CO.11, CP.5, CP.6)? Can the field length exceed the 50-characters limit?

All location fields are validated against the UN/LOCODE Code List - https://www.unece.org/cefact/locode/service/location

The preferred format is “City, State, Country” or “State, Country” or “Country” as appropriate. Location field lengths are validated against a maximum field length of 150 characters.

Last updated: October 19, 2018

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21. How is collateral excess or collateral deficiency calculated (applies to A2.13 & A2.14)?

A2.13 and A2.14 show the value of collateral excess or collateral deficiency after application of all haircuts and relevant collateral posting requirements. This concept can be best explained by an example. Let’s say the market value of QFCs under a Netting Set is $100 (A2.6) and the CSA calls for posting $110 in collateral. Assume that the market value of the collateral posted is $120 (A2.9 or A2.10). If after application of all haircuts, the value of the collateral is $108, then the collateral deficiency is $108 -$110 = -$2. However, if the value of the collateral after application of all haircuts is $115, then the collateral excess is $115 - $110 = $5. The -$2 or the $5 is what goes in A2.13 or A2.14. Please note that collateral deficiency is negative and collateral excess is positive.

Last updated: October 19, 2018

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22. Are fields A2.9 (collateral posted by records entity) and A2.10 (collateral posted by counterparty) complements of one another? – if counterparty posted $100 (A2.10 is $100), then records entity received $100 (A2.9 is -$100).

A2.9 and A2.10 are not complements. Due to timing mismatch, it is possible that a records entity posts collateral with the counterparty on the same netting set on which the counterparty has posted collateral with the records entity. The collateral posted by the records entity is shown in A2.9 and the collateral posted by the counterparty is shown in A2.10. Note that A2.9 and A2.10 cannot be negative.

Last updated: October 19, 2018

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23. What validations are performed on the data files?

The following are some of the checks performed on the data files. Please note the list is not a complete list of all the validations performed on the data. In order to pass these validation checks all data must be accurate and in particular:

  1. There cannot be any nulls in any fields. If a particular field is not applicable then please enter the default value for the field – 0 for numeric fields, NA for character fields and 2099-12-31 for date fields.
  2. Fields must be of the correct data type and length.
  3. As of Date (A1.1, A2.1, A3.1, A4.1, CO.1, CP.1, BL.1, SA.1) must be within 3 days of the submission date. Note that the Rule requires records based on values and information that are no less current than previous end-of-day values and information.
  4. Records Entity Identifier in fields A1.2, A2.2, A3.2, A4.2 and BL.2 must have a corresponding entry in the CO table (CO.2).
  5. Counterparty Identifier (A1.4, A4.4), Agreement Counterparty Identifier (A3.6) and Netting Agreement Counterparty Identifier (A1.10, A2.3) must have corresponding entries in the CP table (CP.2).
  6. Agreement Identifier (A1.8) and Netting Agreement Identifier (A1.9, A2.4, A4.5) must have corresponding entries in A3 table (A3.3).
  7. A1.2 + A1.5 + A1.6 must have corresponding entries in BL - BL.2 + BL.3 + BL.4.
  8. Notional and Principal amounts in A1.19 and A1.20 must be 0 or a positive number.
  9. Type of QFC (A1.7) must be a valid type in the QFC data dictionary (this assumes the Records Entity has a data dictionary).
  10. Location/domicile/jurisdiction (A3.7, A4.14, CO.10, CO.11, CP.5, CP.6) must be a valid location in the UN/LOCODE dictionary and in the format “City, State, Country” or “State, Country” or “Country”, as appropriate.
  11. Type of QFC (A1.7.1) is required if A1.7 is a guarantee or other third party credit enhancement.
  12. If not ‘NA’, Underlying QFC obligor identifier (A1.7.2, A2.4.1 and A3.6.1) must be in CO.2 or CP.2.
  13. Underlying QFC obligor identifier (A1.7.2) is required if A1.7 is a guarantee or other third party credit enhancement. This field is validated against CO.2 (for affiliates) or CP.2 (for non-affiliates).
  14. Trade Date (A1.11) cannot be later than the submission date.
  15. Termination Date (A1.12) cannot be earlier than the submission date.
  16. Next call, put or cancellation date (A1.13) cannot be earlier than the submission date. If not applicable, please use the default date of 2099-12-31.
  17. Next payment date (A1.14) cannot be earlier than the submission date. If not applicable, please use the default date of 2099-12-31.
  18. Next margin payment date (A2.15) cannot be earlier than the submission date. If not applicable, please use the default date of 2099-12-31.
  19. Current market value of the position in local currency (A1.16) and Current market value of the position in US dollars (A1.17) must both be positive, negative or 0.
  20. Asset classification (A1.18, A4.11) must be 1 or 2 or 3.
  21. Covered by third-party credit enhancement agreement (for the benefit of the records entity) (A1.21, A2.5, A3.10) and Covered by third-party credit enhancement agreement (for the benefit of the counterparty) (A1.21.3, A2.5.3, A3.12.1) must be ‘Y’ or ‘N’.
  22. If A1.21 is ‘Y’, A1.21.1 is validated against CP.2 and A1.21.2 is validated against A3.3.
  23. If A1.21.3 is ‘Y’, A1.21.4 is validated against CP.2 or CO.2 and A1.21.5 is validated against A3.3.
  24. If A2.5 is ‘Y’, A2.5.1 is validated against CP.2 and A2.5.2 is validated against A3.3.
  25. If A2.5.3 is ‘Y’, A2.5.4 is validated against CP.2 or CO.2 and A2.5.5 is validated against A3.3.
  26. If A3.10 is ‘Y’, A3.11 is validated against CP.2 and A3.12 is validated against A3.3.
  27. If A3.12.1 is ‘Y’, A3.12.2 is validated against CP.2 or CO.2 and A3.12.3 is validated against A3.3.
  28. If A1.21 is ‘N’, A1.21.1 and A1.21.2 must be ‘NA’. If A1.21.3 is ‘N’, A1.21.4 and A1.21.5 must be ‘NA’. If A2.5 is ‘N’, A2.5.1 and A2.5.2 must be ‘NA’. If A2.5.3 is ‘N’, A.2.5.4 and A2.5.5 must be ‘NA’. If A3.10 is ‘N’, A3.11 and A3.12 must be ‘NA’. If A3.12.1 is ‘N’, A3.12.2 and A3.12.3 must be ‘NA’.
  29. Local Currency (A1.15, A4.8) must be a valid ISO currency code.
  30. If A1.24 is not NA, entry must have a corresponding entry in CO.2.
  31. Percentage ownership of immediate parent (CO.8) must be greater than 0.0 and less than or equal to 100.0.
  32. Immediate parent entity identifier (CO.5) must have a corresponding entry in CO.2, and the corresponding entity name (CO.7) must match CO.4.
  33. If not ‘NA’, Safekeeping agent identifier for records entity (A2.17) and Safekeeping agent identifier for counterparty (A2.18) must have corresponding entries in SA table in SA.2.
  34. Sum of QFC exposure (A1.17) by A1.2, A1.10 and A1.9 must match the sum of QFC exposure (A2.6) by A2.2, A2.3 and A2.4.
  35. Sum of all positive QFC exposure (A1.17) by A1.2, A1.10 and A1.9 must match the sum of positive QFC exposure (A2.7) by A2.2, A2.3 and A2.4.
  36. Sum of all negative QFC exposure (A1.17) by A1.2, A1.10 and A1.9 must match the sum of negative QFC exposure (A2.8) by A2.2, A2.3 and A2.4.
  37. Sum of all QFC exposure (A2.6) by A2.2, A2.3 and A2.4 must match the sum of all positive exposure in A2.7 and all negative exposure in A2.8.
  38. A2.11, A2.12, A2.13, A2.14, A4.7 and A4.9 must be greater than or equal to 0.
  39. A2.13 must be less than or equal to A2.9 by records entity, netting counterparty and netting agreement (A2.2, A2.3 and A2.4).
  40. A2.14 must be less than or equal to A2.10 by records entity, netting counterparty and netting agreement (A2.2, A2.3 and A2.4).
  41. Sum of collateral posted by records entity (A2.9) by A2.2, A2.3 and A2.4 must match the sum of collateral in A4.9 by A4.2, A4.4 and A4.5, where A4.3 is ‘P’.
  42. Sum of collateral received by records entity (A2.10) by A2.2, A2.3 and A2.4 must match the sum of collateral in A4.9 by A4.2, A4.4 and A4.5, where A4.3 is ‘R’.
  43. If A3.8 is “Y”, all entries in A3.9 must have a corresponding entry in CO table (CO.2) or CP table (CP.2).

Last updated: October 19, 2018

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