As required, the FRB is seeking views on the filings it plans to require from the nineteen largest U.S. bank holding companies, building on the 2009 stress test.1 The templates follow a proposed set of stress tests for a larger class of BHCs,2 but would not apparently extend beyond the banks in the 2009 exercise. However, the pending proposal, not to mention the Dodd-Frank requirement for stress tests for all BHCs over $50 billion3 suggests that filings could be required of many more than the nineteen BHCs specifically mentioned in the NPR. The Office of Management and Budget (OMB) must approve these paperwork requirements before the FRB may demand them, taking into account matters such as the burden of the requested information. The FRB’s own burden estimates indicate that the nineteen affected BHCs are expected to spend tens of thousands of hours on these filings, and the hundreds of pages actually required suggest that the burden would be at least as large as the FRB estimates.


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