Agencies Issue Final Stress Test Guidance for Medium-Sized Firms

The Federal Reserve Board and two other federal bank regulatory agencies have issued final rules on how companies with total consolidated assets between $10 billion and $50 billion should conduct stress tests.

The final guidance from the Fed, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency clarifies aspects of the agencies' proposed guidance released last year. Those clarifications are in response to comments received.

Measures specified for firms' varying sizes
The guidance confirms that companies with assets between $10 billion and $50 billion are not subject to the Fed's capital plan rule, the Fed's annual Comprehensive Capital Analysis and Review, Dodd-Frank Act supervisory stress tests, or related data collections. Those measures apply only to bank holding companies with assets of $50 billion or more.

Medium-sized companies are required to conduct annual stress tests under rules issued by the agencies in October 2012 to implement a provision in the Dodd-Frank Wall Street Reform and Consumer Protection Act. These companies—with assets between $10 billion and $50 billion—must perform their first stress tests under the Dodd-Frank Act by March 31, 2014.

Rules' flexibility accommodates various factors
The agencies' stress test rules are flexible to accommodate different risk profiles, sizes, business mixes, market footprints, and complexity. Consistent with this flexibility, the final guidance describes general supervisory expectations for these companies' Dodd-Frank Act stress tests and offers examples of practices that would be consistent with those expectations.

March 13, 2014