Financial Regulatory Developments Focus - October 2016

Bank Prudential Regulation & Regulatory Capital -

US Board of Governors of the Federal Reserve System Releases Proposed Rule to Modify Capital Plan and Stress Testing Rules -

On September 26, 2016, the US Board of Governors of the Federal Reserve System issued a proposed rule modifying the capital plan and stress testing rules for the 2017 test cycle. The proposed changes include the elimination of the qualitative portion of the Comprehensive Capital Analysis and Review for certain large and noncomplex firms (generally, firms with less than $250 billion in total consolidated assets), along with a reduction in the amount of data that such firms would be required to submit on the FR Y-14 regulatory reports. Such institutions however, would remain subject to the quantitative CCAR requirements and to normal supervision by the Federal Reserve Board regarding their capital planning. The proposed rule would be effective for the 2017 CCAR. Comments on the proposal are due by November 25, 2016.

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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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