Bank Stress Tests: FDIC and OCC Propose Amendments to Their Stress Testing Rules

Sullivan & Cromwell LLP - December 27, 2018
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On December 18, the FDIC and the OCC issued proposed rules that would amend their respective stress testing rules consistent with the requirements imposed by Section 401 of the Economic Growth, Regulatory Relief and Consumer Protection Act.  The proposed rules would revise the minimum threshold for national banks, federal savings associations, and FDIC-supervised state nonmember banks and state savings associations to conduct stress tests from $10 billion to $250 billion, and would reduce the number of required stress testing scenarios from three to two by eliminating the supervisory “adverse” scenario.  The proposed rules would also revise the frequency by which certain national banks, federal savings associations, and FDIC-supervised state nonmember banks and state savings associations would be required to conduct stress tests, and make certain other conforming changes to the agencies’ respective stress testing rules.