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    FED Proposes to Amend Capital Planning and Stress Testing Requirements

    September 30, 2020

    FED published a proposal to update the capital planning requirements to reflect the new framework from last year that sorts large banks into different categories based on their risks, with rules that are tailored to the risks of each category. Firms in the lowest risk category are on a two-year stress test cycle and not subject to company-run stress test requirements and this proposal reflects those changes. The proposal would make conforming changes to the capital planning, regulatory reporting, and stress capital buffer requirements for firms subject to Category IV standards to be consistent with the tailoring framework. FED also proposes to revise capital assessments and stress testing reports (FR Y-14 report), and reporting, recordkeeping, and disclosure requirements associated with Regulation YY (FR YY) to reflect the changes in the proposed rule. Comments must be received by November 20, 2020.

    For firms subject to Category IV standards, to align the capital plan rule requirements with the tailoring rule changes, this proposal would

    • remove the capital plan rule requirement to calculate forward-looking projections of capital under scenarios provided by FED.
    • update the frequency, to every other year, of calculating the portion of the stress capital buffer that is calculated as the decline in the common equity tier (CET) 1 ratio; these firms would be required to submit a capital plan to FED annually but would generally no longer be required to calculate the estimates of projected revenues, losses, reserves, and pro forma capital levels (effectively a form of stress testing) using scenarios provided by FED.
    • no longer require firms to submit to FED the forward-looking projections in granular form prescribed by the regulatory report FR Y-14A, Schedule A—Summary.

    To be consistent with the recent changes to the stress testing rules of FED, the proposal would make other changes to the stress testing rules, Stress Testing Policy Statement, and regulatory reporting requirements for business plan change assumptions, capital action assumptions, and the publication of company-run stress test results for savings and loan holding companies. The proposal would update the FR Y-14 reporting requirements for firms subject to Category I to IV standards to conform with changes made to the stress test rules. The notice also solicits comment on the guidance on capital planning for all firms supervised by FED, in light of the recent changes to relevant regulations and as part of FED’s ongoing practice of reviewing its policies to ensure that they are having their intended effect.

    Due to the continued economic uncertainty from COVID-19 response, FED announced that it will extend, for an additional quarter, several measures to ensure that large banks maintain a high level of capital resilience. Thus, for the fourth quarter of this year also, large banks—those with more than USD 100 billion in total assets—will be prohibited from making share repurchases. Additionally, dividend payments will be capped and tied to a formula based on the recent income. Later this year, FED will conduct a second stress test to further test the resilience of large banks and will release the results of this test by the end of the year.


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    Comment Due Date: November 20, 2020

     Keywords: Americas, US, Banking, COVID-19, Stress Testing, Capital Plan Rule, FR Y-14, Reporting, Regulation YY, Basel, FED

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