The Clearing House (TCH) and SIFMA filed a comment letter responding to an FDIC NPR that seeks to harmonize Part 371 (which requires troubled IDIs to maintain records related to their QFCs) with a similar QFC recordkeeping rule for large financial groups recently adopted by the Treasury Secretary. The letter expresses support for harmonizing the two sets of requirements, but identifies specific areas where the FDIC’s rules would continue to diverge from the Treasury’s Final Rule. These areas include: (i) the absence of an exemption process in the FDIC’s rule; (ii) the significantly more limited de minimis exception in the FDIC rule; and (iii) the FDIC rule’s reliance on a single $50 billion asset threshold to define “full scope entities.”