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Tuesday, February 19, 2013

ABA Comments on Fed’s Scenario Design Framework for Stress Testing

ABA and The Financial Services Roundtable submitted a comment letter on the scenario development policy statement issued by the Board of Governors of the Federal Reserve. The Dodd-Frank Act mandates banking regulatory agencies to provide at least three different sets of stressed scenarios.

The associations have concerns about several components of the policy statement and requested the Agencies:
  • Coordinate to provide identical stress test scenarios to depository institutions and bank holding companies; 
  • Provide scenarios to institutions earlier to enhance institutions’ internal governance of the results; 
  • Adopt an approach for developing supervisory stress scenarios that leads to predictable, complete, and reasonable scenarios; 
  • Provide a more detailed written description of the adverse and severely adverse scenarios; and 
  • Provide clarity on how the Agencies developed the international assumptions and provide additional country specific variables.
Read the full letter.

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