Capital Planning Construct
Although the FRB in its proposal indicated that this rulemaking would also begin consideration of the U.S. large-bank capital framework post-COVID, its final rule largely confines itself to aligning stress-test standards with the 2019 tailoring rule and stress capital buffer (SCB) for Category IV banking organizations. The most significant change from the proposal applies the new capital-planning and SCB standards to large savings-and-loan holding companies (SLHCs), eliminating one of the last remaining advantages enjoyed by these charters in comparison with bank holding companies.