Financial Services Bulletin: Action At The Fed, FDIC, And OCC

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Agencies Propose Stress Test Guidance for Medium-sized Firms

On Tuesday, July 30, 2013, the Board of Governors of the Federal Reserve System (the “Fed”), the Federal Deposit Insurance Corporation (the “FDIC”), and the Office of the Comptroller of the Currency (the “OCC”) proposed guidance describing supervisory expectations for stress tests conducted by financial companies with total consolidated assets between $10 billion and $50 billion.  These medium-sized companies are required to conduct annual company-run stress tests beginning this fall under rules the agencies issued in October 2012 implementing Section 165(i)(2) of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”).  The stress test rules allow different approaches by different companies in the $10 billion to $50 billion asset range.  The proposed guidance addresses the supervisory expectations for Dodd-Frank Act stress tests and provides examples of practices that would be consistent with those expectations.

Read the Fed press release

Read the FDIC press release

Read the OCC press release

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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