In this report, FedFin continues the in-depth analysis of the FRB’s systemic regulations, building on a prior report that assessed the NPR’s overall framework and analyzed its capital, liquidity and credit-exposure provisions.1 Here, we turn to the risk-management, stress-test, debt-to-equity limit and early-remediation proposals; these also pose significant strategic and operational challenges for BHCs with assets over $50 billion and, when designated, systemic nonbank financial companies.2 However, provisions in the NPR related to board risk committees and stress tests analyzed here also reach BHCs and banks with assets above $10 billion, expanding the scope of these rules to regional institutions otherwise outside the systemic safeguards.

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