On September 23, BPI submitted a comment letter to the Federal Reserve on proposed changes to the Comprehensive Capital Analysis and Review (CCAR) stress test reports (FR Y-14A/Q/M). The letter emphasizes the potential for significant implementation challenges associated with the proposed effective date of the changes, which would be effective as of the same date as the close of the comment period. The letter also includes a number of requests for technical changes and clarifications.
BPI Comments on Fed’s Proposed Changes to CCAR Reporting Requirements
