FRB – Provided responses to CCAR resubmission questions

November 11, 2020

Stress Capital Buffer

Firms are no longer required to request prior approval to make distributions, including one-time or quarterly dividend increases, in excess of those included in its capital plan, provided the distribution is consistent with limitations included in the SCB final rule.

Stress Test Results

Firm-specific results from banks’ performance under both scenarios will be released by year-end with completed reviews of resubmitted capital plans occurring in early 2021. At year-end, the FRB intends to provide results in a format similar to past DFAST results.

COVID Specific Responses

To determine VaR- and stressed VaR-based capital requirements for Market Risk RWA, exceptions from March 6 – March 27, 2020 may be excluded in the firm’s multiplier calculation until they would naturally roll out of the backtesting window on March 27, 2021.

Firms subject to Category IV standards are not required to estimate in resubmitted capital plans projected revenues, losses, reserves, and pro forma capital levels, including regulatory capital ratios, under supervisory scenarios issued September 17, 2020. FRB will reflect the federal loan guarantee for PPP loans in its stress test.

Client Impact:

FRB updated FR Y-14 Q & A (last updated September 2020)

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