March 31, 2021

Mr. Joseph J. Barry

Senior Vice President and Global Head of

 Regulatory, Industry and Government Affairs

State Street Corporation

State Street Financial Center

One Lincoln Street

Boston, Massachusetts 02111-2900

Dear Mr. Barry:

This responds to the correspondence dated March 23, 2021, submitted on behalf

of State Street Corporation (“State Street”), Boston, Massachusetts, addressed to the Board of 

Governors of the Federal Reserve System (“Board”) regarding the request for an extension of 

time to conform certain contracts to the requirements of the Board’s qualified financial contract 

stay rule (“QFC Stay Rule”).

1

 Specifically, State Street has requested an extension of time to 

conform any covered QFC2 that is a custody services agreement and did not qualify for the 

exemption granted by the Board on October 1, 2020 (“Extension Request QFCs”), to the 

requirements of the QFC Stay Rule.

3

 

In acting on State Street’s previous exemption request, the Board granted State 

Street until April 1, 2021, to conform those QFCs for which relief was denied to the requirements 

of the QFC Stay Rule. State Street represents that it has engaged in significant efforts to 

conform the Extension Request QFCs, but that its conformance efforts have been complicated by 

1

 12 CFR part 252, subpart I.

2

 “Covered QFC” has the same meaning as in the QFC Stay Rule. 12 CFR 252.82(c). 

3

 On October 1, 2020, the Board granted an exemption from the requirements of the QFC Stay 

Rule for certain custody services agreements that did not involve U.S. counterparties and were 

not otherwise linked to U.S. firms (non-U.S., non-linked contracts). See Letter to Rebecca J. 

Simmons, Sullivan & Cromwell LLP, from Margaret McCloskey Shanks, Deputy Secretary, Bd.

of Governors of the Fed. Rsrv. Sys. (Oct. 1, 2020).
2

continued challenges around the work environment related to the COVID-19 pandemic, 

particularly for foreign clients. In light of the challenges presented by the COVID-19 pandemic 

and because a temporary extension of time is unlikely to pose significant risk to State Street and 

the U.S. financial system, a temporary extension of time would be reasonable. Accordingly, 

acting pursuant to authority delegated by the Board and having considered all relevant facts, 

I grant State Street an extension of time until October 1, 2021, to conform the Extension Request 

QFCs to the requirements of the QFC Stay Rule.

Throughout the course of this extension of time, State Street must provide

Board staff with monthly updates on State Street’s progress in conforming the Extension 

Request QFCs. 

This action may be revised or revoked based on changes to applicable regulations 

or other relevant factors. This action is based on all the facts of record, including the information 

discussed above, and the representations in your submissions and supplemental information. 

Any material change in those facts or representations could affect this approval and should be 

communicated promptly to Board staff.

Please contact Lucy Chang at (202) 475-6331 or Evan Hechtman at (202) 263-

4810, both of the Board’s Legal Division, or Lesley Chao of the Board’s Division of Supervision 

and Regulation at (202) 974-7063 if you have any questions.

Very truly yours,

 (Signed) Ann E. Misback

Ann E. Misback

Secretary of the Board