As large BHCs rush to complete their submissions to the FRB for the 2014 Comprehensive Capital Analysis and Review (CCAR) stress test, the Federal Reserve has revised two key aspects of it. It first updated the initial framework, by advising BHCs that expectations of asset reductions under stress are not warranted by experience and thus may not be included in capital-adequacy projections. The FRB has also implemented new standards limiting recognition of certain credit-risk transfer structures that apply not only to CCAR, but also to other capital-adequacy calculations for state member banks and BHCs with assets over $10 billion.
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