Orrick, Herrington & SutcliffeยทBANKING / FINANCE

Fed Finalizes Stress Test Transparency and Capital Volatility Rules

The Federal Reserve finalized two rules on September 30 governing stress-test disclosure and year-over-year volatility in stress-test-related capital requirements, and separately proposed a revised noninterest income model.

The Federal Reserve finalized two rules on September 30: one on the transparency and public accountability of the supervisory stress test, and another aimed at reducing year-over-year volatility in stress test-related capital requirements. Alongside them, the Fed proposed a revised model for noninterest income.

These touch the core mechanics of the Comprehensive Capital Analysis and Assessment (CCAR) exercise for large bank holding companies. Disclosure rules determine what information about stress-test methodology and outcomes reaches counterparties, investors, and counterpart banks, while a volatility-reduction rule could reshape how stress-test-derived capital adjustments evolve from one cycle to the next. Both feed into capital planning, stress capital buffers, and shareholder-return decisions.

Bank and capital-markets counsel should care for three reasons: scope and timing questions for current-cycle submissions and stress capital buffer calculations; the interaction between the volatility rule and each institution's internal capital model; and the proposed noninterest income model, on which comment is open.

Watch the effective dates and transition periods in the final rules and the comment deadline on the proposal. Evidence here is a single trade-press summary, so rule text and effective dates should be confirmed against the Fed's releases.

federal-reservestress-testingccarcapital-requirementsbank-supervisionnoninterest-income

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