OCC Consults on Annual Stress Test Reporting Requirement for Banks
OCC is proposing to revise a regulatory reporting requirement, as part of the reporting form FR Y-14A, for national banks and federal savings associations. The related information collection is for the company-run annual stress test reporting template and documentation for covered institutions with total consolidated assets of USD 250 billion or more, under the Dodd-Frank Act. OCC is proposing to revise its reporting requirements to mirror the proposed FR Y-14A of FED for covered institutions with total consolidated assets of USD 250 billion or more. The comment period on this proposal ends on December 02, 2019.
The proposed changes include updates to various schedules to reflect the current expected credit loss (CECL) accounting methodology. These changes would accommodate covered institutions that have adopted CECL by the reporting date and those that have not yet adopted CECL by the reporting date. The proposed changes also include a collection of supplemental CECL information. The proposed changes also include items not related to CECL adoption. The purpose of these changes is to keep the reporting forms in line with changes in the Consolidated Reports of Condition and Income (Call Report) as well as to provide further clarity or alignment of the instructions with the XML reporting files. There are also changes that would require information to be reported at a different level of granularity. OCC believes that the systems covered institutions use to prepare the FR Y-14 reporting templates to submit to FED will also be used to prepare the reporting templates described in the notice.
Section 165(i)(2) of the Dodd-Frank Act requires certain financial companies, including national banks and federal savings associations, to conduct annual stress tests and requires the primary financial regulatory agency of those financial companies to issue regulations implementing the stress test requirements. Under section 165(i)(2), a covered institution is required to submit to FED and to its primary financial regulatory agency a report at such time, in such form, and containing such information as the primary financial regulatory agency may require.
Related Link: Federal Register Notice
Comment Due Date: December 02, 2019
Keywords: Americas, US, Banking, EGRRCP Act, Stress Testing, Dodd Frank Act, FR Y-14, CECL, Reporting, CCAR, FED, OCC
Advises U.S. and Canadian financial institutions on risk and finance integration, CCAR/DFAST stress testing, IFRS9 and CECL credit loss reserving, and credit risk practices.
Credit analytics expert helping clients understand, develop, and implement credit models for origination, monitoring, and regulatory reporting.
Scott is a Director in the Regulatory and Accounting Solutions team responsible for providing accounting expertise across solutions, products, and services offered by Moody’s Analytics in the US. He has over 15 years of experience leading auditing, consulting and accounting policy initiatives for financial institutions.
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