Financial Services Report -- Spring 2012


In this issue

Beltway Report; Bureau Report; Mortgage Report; Operations Report; Privacy Report; Plastics Report; and Preemption Report.

Excerpt from Beltway Report

Bend Over, Cough On

January 23, 2012, the Federal Deposit Insurance Corporation (“FDIC”) published a notice of proposed rulemaking that would require certain large insured depository institutions to conduct annual capital adequacy stress tests. The proposal, implementing section 165(i)(2) of the Dodd- Frank Act, would apply to FDIC-insured state nonmember banks and FDIC-insured state-chartered savings associations with total consolidated assets of more than $10 billion. The FDIC regulated 23 state nonmember banks with total assets of more than $10 billion as of Sept. 30, 2011. The stress tests would provide forward-looking information that would assist the FDIC in assessing the capital adequacy of the banks covered by the rule. The banks that would be required to conduct the stress tests also are expected to benefit from improved internal assessments of capital adequacy and overall capital planning.

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