Final Rule Revising the Capital Plan and Stress Test Rules

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On January 31, 2017, the Federal Reserve Board (the “Board“) adopted a final rule that revises the capital plan and stress test rules for (i) bank holding companies with $50 billion or more in total consolidated assets and (ii) U.S. intermediate holding companies of foreign banking organizations. Under the final rule, large and noncomplex firms are no longer subject to the qualitative assessment of the Board’s Comprehensive Capital Analysis and Review (“CCAR“). However, large and noncomplex firms will remain subject to their capital requirements as part of CCAR’s quantitative assessment and will still be subject to regular supervisory assessments examining their capital planning processes. Press Release. Final Rule.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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