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.