ABA filed a comment letter on changes to stress tests and capital planning exercises for large and mid-sized banks. The Federal Reserve proposed the changes to the Comprehensive Capital Assessment and Review and Dodd-Frank Act stress tests in July.
ABA welcomed the proposal to eliminate the Basel I Tier 1 common ratio requirement, the delay of advanced approaches for determining risk weighted assets and the delay of incorporating the supplementary leverage ratio into the exercises. The association added that CCAR and DFAST have seen “significant process improvements” since the exercises first began.
However, ABA expressed concern about the proposal’s inclusion of Volcker Rule deductions and its treatment of fixed dividend assumptions in DFAST. ABA also urged the Fed to revisit the interaction of capital buffers with bank holding company baseline capital actions, the standards for and transparency of the CCAR qualitative review and the uniform tax rate assumption for CCAR and DFAST.
Read the letter.