Many fund managers have already received notices from their swap dealer counterparties regarding the implementation of “contractual stay rules” adopted by the U.S. federal banking authorities (QFC Rules). Swap dealers are now urging their counterparties to adhere to the ISDA 2018 U.S. Resolution Stay Protocol (Protocol). Fund managers that do not adhere to the Protocol or take other steps to bring their trading documentation into compliance may not be able to trade certain qualifying financial contracts with their counterparties after January 1, 2019. In this guest article, Michele Navazio, partner at Seward & Kissel, provides an overview of the Protocol and related QFC Rules, with an emphasis on issues that fund managers need to consider in assessing whether to adhere to the Protocol or opt for bilateral amendments to their trading documentation. The relative merits of the two approaches strongly suggest that fund managers should, in almost all cases, choose to adhere to the Protocol. For more on the QFC Rules and Protocol, see “Steps Fund Managers Should Take Now to Ensure Their Trading of Swap, Repo and Securities Lending Transactions Continues Uninterrupted After January 1, 2019” (Oct. 18, 2018). For additional commentary from Navazio, see “Private Funds Conference Addresses Recent Developments Relating to Fund Structuring and Terms; SEC Examinations and Enforcement Initiatives; Seeding Arrangements; Fund Mergers and Acquisitions; CPO Regulation; JOBS Act Implementation and Compliance; and Derivatives Reforms (Part Three of Three)” (Nov. 14, 2013).