The Federal Reserve should report mid-sized banks’ stress test results in the aggregate, limiting disclosures of individual banks’ results, ABA said. Differing regions and business models of banks in the $10-50 billion asset range could mean that banks perform dramatically differently depending on the Fed’s stress scenarios. “The different stress assumptions applied by one bank could make it look, inaccurately, to be in better or worse condition than its peers,” ABA said.
Instead, the Fed should report an aggregate summary of results for all mid-sized banks, ABA said — which would meet the Dodd-Frank Act’s requirement for disclosure of “a summary of results.” ABA also asked the Fed to provide a floating submission date to allow banks flexibility in when they allocate internal resources to the stress tests.
Read the letter.