Late yesterday, the FRB released its scenarios for 2020 supervisory stress-testing exercises, making clear that – for all its efforts – a revised stress capital buffer (SCB) standard (see FSM Report STRESS29) is unlikely to be finalized by the April 6 submission date.  The Fed may release an SCB interim final rule or other action to give filers context ahead of time, but it will need to move very quickly for this to have meaningful impact on filings; however, Fed action on the SCB at any point prior to final CCAR judgments in early spring could guide the Fed’s determination of individual BHC performance.

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