On January 23, BPI submitted an unsolicited supplemental comment letter to the Fed regarding its recently finalized changes to the Comprehensive Capital Analysis and Review (CCAR) stress test reports (FR Y-14A/Q/M). The letter requests that CCAR 2020 instructions be released as early as possible and invites further discussion with the Fed if the industry interpretation of certain of the final FR Y-14A reporting changes (i.e., firms are now permitted to reflect global market shock adjustments to capital deduction calculations, balance sheet, leverage and risk-weighted asset calculations) does not comport with the intent of the Fed in including these Y-14A changes in the final notice. The letter also encourages the Fed to add optional data fields for securitization exposures, allowing the agency to more accurately calculate stress losses on these items for electing firms.
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