In conjunction with broader revisions to its stress-test standards outlined in a speech by Gov. Tarullo, the FRB is proposing to revise the Comprehensive Capital Analysis & Review (CCAR) stress test for BHCs and intermediate holding companies (IHCs) of foreign banks with less than $250 billion in assets that do not trigger other size or complexity thresholds.  These firms would no longer need to meet qualitative capital-planning standards,  with resiliency judged instead through the supervisory process.  CCAR’s quantitative requirements, modified in some respects and simplified in others, would remain applicable as Gov. Tarullo’s plan is finalized.  This NPR deals only with near-term changes to CCAR intended for the 2017 round; the full scope of the stress-capital buffer and its relationship to other large-BHC requirements will take shape in a future formal proposal from the FRB aimed at getting the changes in place by 2018.

The full report is available to retainer clients. To find out how you can sign up for the service, click here.