Large and Noncomplex Bank Holding Companies

On September 30, 2020, the Federal Reserve released a proposal to update its capital planning requirements in a number of respects, including to integrate the capital plan rule with the Federal Reserve’s October 2019 final rules tailoring its enhanced prudential standards.  The proposal would make the following notable changes:

  • Replacement of Company-Run Stress Testing for

On March 6, 2019, the Federal Reserve issued a final rule to exempt from the qualitative component of the Comprehensive Capital Analysis and Review (“CCAR”) exercise large firms that have participated in CCAR for four consecutive years and have passed the final year’s qualitative component without objection.  The final rule serves to provide an immediate exemption for all domestic bank holding companies currently subject to CCAR, and to phase out the qualitative objection for U.S. intermediate holding companies of foreign banks (“IHCs”).

Continue Reading Federal Reserve Eliminates CCAR’s Qualitative Objection for Most Firms

On January 30, 2017, the Board of Governors of the Federal Reserve System (the “Federal Reserve Board”) released a final rule amending its capital plan and Comprehensive Capital Analysis and Review (“CCAR”) stress testing rules.

The final rule addresses the following key issues, among others:

  • Qualitative Assessments.  Under the final rule, “large and noncomplex bank holding companies” are no longer subject to the qualitative component of the annual CCAR assessment.  A large and noncomplex bank holding company is defined as any bank holding company (1) with average total consolidated assets between $50 billion and $250 billion; (2) with average total nonbank assets of less than $75 billion; and (3) that is not a global systemically important bank holding company (“G-SIB”).[1]  The Federal Reserve Board will no longer object to a large and noncomplex bank holding company’s capital plan in the annual CCAR assessment based on qualitative deficiencies; rather, the Federal Reserve Board will assess the strength of such a company’s capital planning process through the regular supervision process and targeted, horizontal assessments of capital planning.


Continue Reading The Federal Reserve Board Issues Final Rule Amending Capital Plan and CCAR Stress Test Rules