Bank Capital Plans and Stress Tests: Federal Reserve Issues Instructions and Guidance for the 2016 Comprehensive Capital Analysis and Review Program

Sullivan & Cromwell LLP - February 3, 2016
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On January 28, 2016, the Federal Reserve issued its annual summary instructions (the “CCAR 2016 Instructions”) for its supervisory Comprehensive Capital Analysis and Review program for 2016 (“CCAR 2016”) applicable to bank holding companies with $50 billion or more of total consolidated assets (“Covered BHCs”).  Thirty-three institutions will participate in CCAR 2016, including 30 of the 31 Covered BHCs that participated in CCAR in 2014 and three institutions that are new to the program.  Covered BHCs must submit their capital plans for CCAR 2016 to the Federal Reserve on or before April 5, 2016.  The Federal Reserve will release the CCAR 2016 results and its objection or non-objection to Covered BHCs’ capital plans, including the reasons for any objections, no later than June 30, 2016. In general, the CCAR 2016 Instructions are substantively similar to the instructions provided in prior CCAR cycles.  However, they include several changes, updates and other notable provisions.