BPI Comments on Federal Reserve Implementation of Capital Assessments and Stress Testing Reports

To Whom it May Concern:

The Bank Policy Institute[1] appreciates the opportunity to comment on the proposal by the Board of Governors of the Federal Reserve System to extend for three years, with revision, the Capital Assessments and Stress Testing Reports (FR Y-14A/Q/M; OMB No. 7100-0341).[2] We support the stated goal of the revisions “to better identify risk as part of the stress test, to better facilitate data reconciliation, and to mitigate ambiguity within the instructions”[3] and the proposed revisions to the FR Y-14A. However, we have concerns with the proposed implementation timeline for the changes to the FR Y-14M and FR Y-14Q and suggest several adjustments that should be made to the proposed revisions before they are adopted. Additionally, there are several proposed revisions for which the burden of implementation far outweighs the utility of the data provided and therefore these proposed revisions should not be adopted. Appendix A to this letter includes additional technical recommendations and requests for clarification on the proposed changes.

To read the full comment letter, please click here.

[1] The Bank Policy Institute is a nonpartisan public policy, research, and advocacy group, representing the nation’s leading banks and their customers. Our members include universal banks, regional banks and the major foreign banks doing business in the United States. Collectively, they employ almost 2 million Americans, make nearly half of the nation’s small business loans and are an engine for financial innovation and economic growth.

[2] 87 Fed. Reg. 11432 (March 1, 2022).

[3] 3Id at 11434.