The FRB, in concert with the FDIC and OCC, is proposing to revise both the process and substance of current stress tests.  Responding to industry concerns, the NPR would change the start date of the capital plan and stress test cycles from October 1 to January 1 of the following calendar year.  The NPR would also limit the ability of BHCs to make capital distributions to the extent that actual capital issuances are less than the amount indicated in the capital plan under baseline conditions. The FRB here also places large BHCs on notice that capital issuances must in fact occur as planned or sanctions may be imposed, with the FRB also warning that repeated failures to make planned issuances or engaging in distribution timing may result in reversal of prior FRB agreement to a filed plan.  The proposed rule would clarify application of the capital-plan and stress-test rules to subsidiaries of a U.S. intermediate holding company (IHC) of a foreign banking organization (FBO) and tighten the stressed scenarios included in large-BHC company-run stress tests. 
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