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William Byrnes

They will also discuss how conduct risk is being considered by the Japanese authorities and their expectations of regulated firms. A brief primer on the evolution and drivers of conduct risk. Global and local regulatory approaches and important recent developments. Commenters asked that the agencies eliminate duplicative requirementsand use an interagency forum, like the Federal Financial InstitutionsExamination Council, to develop common forms, policies, procedures,assumptions, methodologies, and application of results.

P a g e 16with having multiple entities within one organizational structure subjectto stress testing requirements. The Board anticipates that it will continue to consult with the FDIC andOCC in the implementation of the final rule, and in particular, in thedevelopment of stress scenarios.

The Board plans to develop scenarios each year in close consultation withthe FDIC and the OCC, so that, to the greatest extent possible, a commonset of scenarios can be used for the supervisory stress tests and the annualcompany-run stress tests across various banking entities within the sameorganizational structure. Commenters recommended that, in order to reduce burden, the Boarddevelop and require the use of a single set of scenarios for a bank holdingcompany and any depository institution subsidiary of the bank holdingcompany, if the Board imposed separate stress testing requirements onboth the bank holding company and bank.

In order to reduce burden on banking organizations, the final ruleprovides that a subsidiary depository institution generally will disclose itsstress testing results as part of the results disclosed by its bank holdingcompany parent. Disclosure by the bank holding company of its stress test results andthose of any subsidiary state member bank generally will satisfy anydisclosure requirements applicable to the state member bank subsidiary. For example, under those circumstances, the bank holding company andstate member bank may use the same data collection processes andmethods and models for projecting and calculating potential losses,pre-provision net revenues, provision for loan and lease losses, and proforma capital positions over the stress testing planning horizon.

ISO 31000:2009

In either case, average total consolidated assets are measured on the as-ofdate of the relevant regulatory report. Such a company will be required to comply with this final rule until it isrequired to conduct stress tests under subpart G. The final rule does not apply to foreign banking organizations. The Board expects to issue a separate rulemaking on the application ofenhanced prudential standards to foreign banking organizations.

Effective DateUnder the proposal, the company-run stress testing requirementsapplicable to bank holding companies and state member banks wouldhave become effective upon adoption of the final rule.

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First Stress Test for Bank Holding Companies and State MemberBanks that Meet the Asset Threshold on or before December 31, Commenters indicated that smaller and mid-sized banking organizationsneed more time to develop the systems and procedures to conductcompany-run stress tests and to collect the information requested by theBoard in connection with these tests.

In response to these comments, the Board is delaying the date thatexisting, smaller companies are required to conduct their first stress test,as described below. Bank Holding CompaniesUnder the final rule, a bank holding company that meets the assetthreshold on or before December 31, , must conduct its first stress testbeginning in the fall of , unless that time is extended by the Board inwriting.

Such a bank holding company is not required to publicly disclose theresults of its stress test until June State Member BanksUnder the final rule, a state member bank that meets the asset thresholdon or before November 15, , and is a subsidiary of a bank holdingcompany that participated in the SCAP, or successor to such bankholding company, must comply with the requirements of this subpartbeginning in the fall of , unless that time is extended by the Board inwriting.

Any other state member bank that meets the asset threshold on or beforeDecember 31, , must comply with the requirements of this subpartbeginning in the fall of , unless that time is extended by the Board inwriting. In addition, the Federal Advisory Council recommended that the Boardphase in disclosure requirements to minimize risk, build precedent, andallow banks and supervisors to gain experience, expertise, and mutualunderstanding of stress testing models.

P a g e 21Under the final rule, these companies will be required to conduct theirfirst stress tests beginning in the fall of the calendar year after they meetthe asset threshold, unless that time is extended by the Board in writing. First Stress Test for Savings and Loan Holding CompaniesUnder the final rule, a savings and loan holding company will not berequired to conduct its first stress test until after it is subject to minimumcapital requirements.

A savings and loan holding company that meets the asset threshold whenit becomes subject to minimum capital requirements will be required toconduct this first stress test in the fall of the calendar year after it firstbecomes subject to capital requirements, unless the Board accelerates orextends the time in writing. A savings and loan holding company that meets the asset threshold afterit becomes subject to capital requirements will be required to conduct itsfirst stress test beginning in the fall of the calendar year after it meets theasset threshold, unless that time is extended by the Board in writing.

The Board would have required an as-of date of September 30 ofinformation to be submitted to the Board. By no later than mid-November of each calendar year, the Board wouldprovide bank holding companies, state member banks, and savings andloan holding companies with scenarios for annual stress tests.

By January 5 of the following calendar year, these companies would berequired to submit regulatory reports to the Board on their stress tests.

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P a g e 22By early April of that calendar year, companies would be required to makepublic disclosure of results. Several commenters provided suggestions on the proposed timeline. Those comments focused on the as-of date for data to be submitted bybank holding companies, state member banks, and savings and loanholding companies, the date for submitting results to the Board, and thedates when public disclosures of stress test results are to be made.

For instance, some commenters suggested that the Board should use datacollected at as-of dates other than September 30, such as June 30 orDecember 31, and make corresponding changes to the timing of publicdisclosure in order to reduce burden on companies during the year-endperiod.


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One commenter suggested having a floating submission date, allowingorganizations to submit their results at the point in the year when it ismost convenient. Some commenters also requested that the Board release the scenariosearlier to provide banking organizations more time to prepare therequired reports for the stress tests. The final rule maintains the as-of date for data for the purposes of theannual company-run stress tests so that the same set of scenarios can beused to conduct annual company-run stress tests for large bank holdingcompanies and their subsidiary state-member banks.

The Board believes, and several commenters noted, that such alignmentis beneficial. Furthermore, using the same scenarios for all firms subject to stresstesting requirements will decrease market confusion, minimize burdenon institutions, and provide for comparability across institutions. P a g e 23requirements for large bank holding companies in order to align thestress testing requirements with the capital planning requirementsapplicable to these institutions under section Commenters requested that the Board release the scenarios earlier in theannual stress test cycle to provide banking organizations more time toprepare the reports for company-run stress tests.

Under the final rule, the Board will provide descriptions of the baseline,adverse, and severely adverse scenarios generally applicable to companiesno later than November 15 of each year, and provide any additionalcomponents or scenarios by December 1. The Board believes that providing scenarios earlier than November couldresult in the scenarios being stale, particularly in a rapidly changingeconomic environment, and that it is important to incorporate economicor financial market data that are as current as possible while providingsufficient time for companies to incorporate the scenarios in their annualcompany-run stress tests.

Commenters suggested that smaller banking organizations be allowedadditional time to conduct their company-run stress tests in light ofresource constraints faced by these institutions. In response to these comments, the Board has delayed the timing ofreport submission to the Board for most banking organizations. P a g e 24All other bank holding companies, savings and loan holding companies,and state member banks are required to conduct their stress tests andsubmit the results to the Board by March These quiet periods are designed to limit communications that coulddisseminate proprietary company information prior to earningsannouncements.

All other banking organizations will be required to disclose their resultsbetween June 15 and June ScenariosThe proposal provided that the Board would publish a minimum of threedifferent sets of economic and financial conditions, including baseline,adverse, and severely adverse scenarios, under which the Board wouldconduct its annual analyses and companies would conduct their annualcompany-run stress tests.

Commenters pointed out that consistency in annual scenariodevelopment will make comparability of stress test results betweeninstitutions and across time periods more accurate, increase marketconfidence in the results of stress tests, and make for more dependablecapital planning by banking organizations.

Commenters also requested the opportunity to provide input on thescenarios. The Board believes that it is important to have a consistent andtransparent framework to support scenario design. The baseline scenario is defined as a set of conditions that affect the U. P a g e 26The adverse scenario is defined as a set of conditions that affect the U.

The severely adverse scenario is defined as a set of conditions that affectthe U. In general, the baseline scenario will reflect the consensus views of themacroeconomic outlook expressed by professional forecasters,government agencies, and other public-sector organizations as of thebeginning of the annual stress-test cycle.

The Board expects that the severely adverse scenario will, at a minimum,include the paths of economic variables that are generally consistent withthe paths observed during severe post-war U. Each year, the Board expects to take into account of salient risks thataffect the U. The Board expects that the adverse scenario will, at a minimum, includethe paths of economic variables that are generally consistent with mild tomoderate recessions. The Board may vary the approach it uses for the adverse scenario eachyear so that the results of the scenario provide the most value tosupervisors, given the current conditions of the economy and the bankingindustry.

Enterprise Risk Management

P a g e 27specifically capturing, in the adverse scenario, risks that the Boardbelieves should be understood better or should be monitored. The scenarios will consist of a set of conditions that affect the U. These conditions will include projections for a range of macroeconomicand financial indicators, such as real Gross Domestic Product GDP , theunemployment rate, equity and property prices, and various other keyfinancial variables, and will be updated each year to reflect changes in theoutlook for economic and financial conditions.

The paths of these economic variables could reflect risks to the economicand financial outlook that are especially salient but were not prevalent inrecessions of the past. Depending on the systemic footprint and scope of operations andactivities of a company, the Board may require that company to includeadditional components in its adverse or severely adverse scenarios or touse additional scenarios or more complex scenarios that are designed tocapture salient risks to specific lines of business.

The Board is making this modification to allow for coordination of thetrading shock between a bank holding company and any state memberbank subsidiary that is subject to the market risk rule. The process by which the Board may require a company to includeadditional components or use additional scenarios is described undersection D. Some commenters suggested that the Board adopt a tailored approach toscenarios to better capture idiosyncratic characteristics of each company.

For example, commenters representing the insurance industry suggestedthat any stress testing regime applicable to insurance companiesincorporate shocks relating to the exogenous factors that actually impacta particular company, such as a shock to the insurance companysinsurance policy portfolio arising from a natural disaster, andde-emphasize shocks arising from traditional banking activities. In addition, the Board expects banking organizations to consider otherscenarios that are more idiosyncratic to their operations and associatedrisks, as part of their ongoing internal analyses of capital adequacy.

The Board is adopting this final rule to implement the stress testrequirements for covered companies established in section i 1 and 2 of the Dodd-Frank Act. Furthermore, implementation of the stress testing requirements for bankholding companies that did not participate in the Supervisory CapitalAssessment Program is delayed until September P a g e 30BackgroundThe Board has long held the view that a banking organization, such as abank holding company or insured depository institution, should operatewith capital levels well above its minimum regulatory capital ratios andcommensurate with its risk profile.

P a g e 31the financial condition of the participating bank holding companiesunder a scenario that was more adverse than that which was anticipatedto occur at the time, and had an overall stabilizing effect. On November 22, , the Board issued an amendment capital planrule to its Regulation Y to require all U.

In the wake of the financial crisis, Congress enacted the Dodd-Frank Act,which requires the Board to implement enhanced prudential supervisorystandards, including requirements for stress tests, for covered companiesto mitigate the threat to financial stability posed by these institutions.

P a g e 32absorb losses as a result of adverse economic conditions supervisorystress tests. The Act requires that the supervisory stress test provide for at least threedifferent sets of conditions—baseline, adverse, and severely adverseconditions—under which the Board would conduct its evaluation. The Act also requires the Board to publish a summary of the supervisorystress test results. On January 5, , the Board invited public comment on a notice ofproposed rulemaking proposal or NPR that would implement theenhanced prudential standards required to be established under section of the Dodd-Frank Act and the early remediation requirementsestablished under Section of the Act, including proposed rulesregarding supervisory and company-run stress tests.

P a g e 33Under the proposed rules, the Board would conduct an annualsupervisory stress test of covered companies under three sets of scenarios,using data as of September 30 of each year as reported by coveredcompanies, and publish a summary of the results of the supervisory stresstests in early April of the following year. September 26, Service providers have emphasized on enhancing their supply chain activities to address the growing demand for shopping.

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