ARTICLE
7 October 2020

FRB Proposes Amendments To Capital Planning Requirements

CW
Cadwalader, Wickersham & Taft LLP

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Cadwalader, established in 1792, serves a diverse client base, including many of the world's leading financial institutions, funds and corporations. With offices in the United States and Europe, Cadwalader offers legal representation in antitrust, banking, corporate finance, corporate governance, executive compensation, financial restructuring, intellectual property, litigation, mergers and acquisitions, private equity, private wealth, real estate, regulation, securitization, structured finance, tax and white collar defense.
The FRB is also seeking feedback on existing capital planning guidance.
United States Finance and Banking

The Federal Reserve Board ("FRB") proposed amendments to conform the capital planning, regulatory reporting and stress capital buffer requirements for "Category IV" firms to the requirements under the FRB's October 2019 tailoring framework (see previous coverage).

The amendments would apply to firms that are subject to the Category IV standards; i.e., firms that (i) have between $100 billion and $250 billion in total assets, and (ii) are not otherwise subject to Categories I-III in light of their particular activities. The proposed amendments would also eliminate the capital plan rule requirement for Category IV firms to compute forward-looking capital projections under FRB-provided scenarios.

In addition, the FRB is proposing changes to its (i) stress testing regulations, (ii) Stress Testing Policy Statement, and (iii) regulatory reporting requirements concerning business plan change assumptions and capital action assumptions, in order to make them consistent with the FRB's stress testing rule amendments (see previous coverage).

The FRB is also seeking feedback on existing capital planning guidance.

Comments on the proposal must be submitted by November 20, 2020.

Primary Sources

  1. FRB Press Release: Federal Reserve Board invites public comment on proposal that would update the Board's capital planning requirements to be consistent with other Board rules that were recently modified
  2. FRB Proposed Rule: Amendments to Capital Planning and Stress Testing Requirements for Large Bank Holding Companies, Intermediate Holding Companies and Savings and Loan Holding Companies

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