Bank Stressed Capital Requirements: Federal Reserve Board Governor Tarullo Indicates an Increase in Large Bank Holding Companies’ Post-Stress Minimum Capital Ratios Is Likely

Sullivan & Cromwell - November 27, 2015

In a November 23, 2015 interview on Bloomberg TV, Federal Reserve Board Governor Daniel Tarullo stated there is a “pretty good chance” that the Federal Reserve will increase the post-stress minimum capital ratios that large bank holding companies are required to demonstrate they meet in their annual stressed capital plans filed with the Federal Reserve. Any material change in the minimum is likely to be of particular significance because many banks have indicated that the stressed capital requirements are the most constraining of all the capital requirements.