The Clearing House Association (TCH) submitted a comment letter to the Bank of England (BOE) in response to its October 2013 discussion paper outlining a proposed stress testing framework for the UK banking system. The letter highlights the value and importance of capital adequacy stress testing in supporting and preserving a safe and effective global banking system and expresses support for the BOE’s efforts to develop and implement a regular stress testing regime for the UK banking system.
TCH also applauded the BOE for its stated commitment to coordinate with other national regulators in finalizing and implementing its own stress testing framework. Drawing on prior experience evaluating and informing the development of the U.S. stress testing framework, TCH provides several recommendations and observations regarding the BOE proposal, including (i) measures intended to ensure results that are credible and meaningful for regulators and market participants and (ii) a clear delineation of real and certain consequences for any failure to meet such applicable requirements (rather than an array of possible consequences). In addition, the letter encourages BOE to continue to coordinate with U.S. regulators to ensure that their respective stress-testing frameworks are as aligned as possible.