OCC Proposes to Revise Regulatory Reporting Requirements for Banks

In May 2018, the Economic Growth, Regulatory Relief, and Consumer Protection (EGRRCP) Act amended provisions in the Dodd-Frank Act and provided that, eighteen months after the Act's enactment, financial companies with total consolidated assets of less than USD 250 billion that are not bank holding companies will no longer be subject to the company-run stress testing requirements in section 165(i)(2) of the Dodd-Frank Act. In contrast, on the date of enactment, bank holding companies under USD 100 billion in total consolidated assets were no longer subject to section 165(i)(2). To avoid unnecessary burden for depository institutions and to maintain consistency between bank holding companies and depository institutions, OCC, FED, and FDIC extended the deadlines for all regulatory requirements related to company-run stress testing for depository institutions with average total consolidated assets of less than USD 100 billion until November 25, 2019 (at which time both statutory exemptions will be in effect). The OCC, in coordination with the FED and FDIC, is in the process of revising its stress testing regulation to incorporate the amendments of the EGRRCP Act.

OCC intends to use the data collected to assess the reasonableness of the stress test results of covered institutions and to provide forward-looking information to the OCC regarding a covered institution's capital adequacy. OCC also may use the results of the stress tests to determine whether additional analytical techniques and exercises could be appropriate to identify, measure, and monitor risks at the covered institution. The stress test results are expected to support ongoing improvement in a covered institution's stress testing practices with respect to its internal assessments of capital adequacy and overall capital planning.

OCC recognizes that many covered institutions with total consolidated assets of USD 100 billion or more are required to submit reports using Comprehensive Capital Analysis and Review (CCAR) reporting form FR Y-14A. OCC also recognizes FED has proposed to modify the FR Y-14A and, to the extent practical, OCC will keep its reporting requirements consistent with FR Y-14A  of FED to minimize burden on covered institutions. Therefore, OCC is proposing to revise its reporting requirements to mirror the proposed FR Y-14A by FED, for covered institutions with total consolidated assets of USD 100 billion or more. The proposed changes include changes to accommodate the revised asset threshold necessitated by EGRRCP Act. The proposed changes also include the removal of the Retail Repurchase worksheet and various clarifications in the instructions. In addition to the changes that parallel the FED's proposed changes to FR Y-14A, OCC is also proposing to remove or modify certain items on the OCC supplemental schedule, which collects additional information not included in FR Y-14A.

Related Links 

• Federal Register Notice
• Proposed Reporting Templates: Form DFAST-14A (ZIP)
• Proposed Reporting Instructions: Form DFAST-14A (PDF)
• Dodd-Frank Act Stress Test (Company-Run)
  

Comment Due Date: December 31, 2018

Keywords: Americas, US, Banking, Stress Testing, Dodd Frank Act, Reporting, FR Y-14A, CCAR, DFAST, EGRRCP Act, OCC, FED