Today the Federal Reserve Board (the “Board”) issued instructions and guidelines for two 2013 stress testing and capital planning programs, each of which builds on similar programs from last year. The Comprehensive Capital Analysis and Review 2013 (“CCAR”) describes the testing process and resulting capital plans that are required for the 19 bank holding companies (“BHCs”) that participated in the CCAR for 2011 and 2012. The Capital Plan Review 2013 (“CapPR”) sets forth the testing and capital planning requirements for the 11 BHCs with $50 billion or more in consolidated assets that undertook a similar exercise last year. The instructions and guidelines for both programs implement the capital plan rule, 12 C.F.R. § 225.8, and reflect the supervisory concerns underlying the earlier testing and planning programs.
The CCARs in 2011 and 2012 and the CapPR in 2012, as well as section 225.8, should be familiar to many. Nevertheless, a few observations specific to today’s releases are in order...
Please see full alert below for more information.
Firefox recommends the PDF Plugin for Mac OS X for viewing PDF documents in your browser.
We can also show you Legal Updates using the Google Viewer; however, you will need to be logged into Google Docs to view them.
Please choose one of the above to proceed!
LOADING PDF: If there are any problems, click here to download the file.
Administrative Law Updates, Finance & Banking Updates
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.
© Morrison & Foerster LLP | Attorney Advertising