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Tuesday, May 1, 2012

Overlapping Stress Test Rule Making

ABA with four other trade associations wrote to the FDIC and OCC regarding their respective proposed rule makings implementing stress testing requirements of Section 165 of the Dodd-Frank Act. The Associations expressed their deep concern over the multiple stress test requirements from a variety of agencies.
The Associations are deeply concerned that these multiple overlapping stress test requirements, if not properly implemented and coordinated among the relevant agencies, will lead to a great degree of burdensome duplication and will add little marginal utility from a policy and supervisory perspective.

[T]he Associations strongly believe that well coordinated and holistic actions by the Federal banking agencies are required in order to avoid burdensome duplication with respect to the application of the Proposed FDIC Stress Test Rules, the Proposed OCC Stress Test Rules and the Proposed Federal Reserve Stress Test Rules.
In the letter the trade associations stated their strong support for stress testing requirements which would correspond with an institutions size, complexity, and familiarity with stress testing.

Read the full letter

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