Bank Capital Plans and Stress Tests: Federal Reserve Seeks to Enhance Transparency of Its Stress Testing Program Through Amendments to Its Scenario Design Framework, a New Stress Testing Policy Statement, and Enhancements to Supervisory Stress Test Disclosure

Sullivan & Cromwell LLP - February 22, 2019
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On February 5, the Federal Reserve finalized changes to its stress testing program intended to enhance the transparency of the program, which includes the stress tests applied to U.S. bank holding companies with total consolidated assets of $100 billion or more and U.S. intermediate holding companies of foreign banking organizations in connection with CCAR and DFAST. The changes are largely consistent with those proposed in December 2017, described in detail in our December 2017 Memorandum to Clients. Notable clarifications, commentary, and revisions to the December 2017 proposals are described in this memorandum.