Title II of the Dodd-Frank Act gives the Secretary of the Treasury in his capacity as chair of the Financial Stability Oversight Council unique rulemaking authority in one area:  mandating record-keeping requirements for qualified-financial contracts (QFCs) if primary federal regulators fail to act by specified deadlines.  Since they in fact did fail to act, Secretary Lew has now laid out a comprehensive record-keeping regime that would apply to a wide array of financial-services firms, not just the biggest banks and those so far regulated as non-bank systemically-important financial institutions (SIFIs).   

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