New Fed Reserve Rules Require US Bank Holding Companies to Conduct Stress Tests, Early Remediation

  • By: Staff Editor
  • Date: December 29, 2011
Webinar All Access Pass Subscription


The Federal Reserve has recently issued new rules that would strengthen regulation and supervision of large US bank holding companies and systemically important nonbank financial firms.
These new rules address the following issues:
  • Capital
  • Liquidity
  • Credit exposure
  • Stress testing
  • Risk management
  • Early remediation requirements
The rules would cover those requirements mandated by the Dodd Frank Act.
The proposed rules generally apply to:
  • All U.S. bank holding companies with consolidated assets of $50 billion or more and
  • Any nonbank financial firms that may be designated by the Financial Stability Oversight Council as systemically important companies
Savings and loan holding companies (SLHCs) would not be subject to the requirements included in these proposed rules, except for certain stress test requirements.
The Federal Reserve plans to issue rules covering foreign banking organizations and SLHCs later.
Proposed Rule Requirements
Risk-based capital requirements and leverage limits
The proposed risk-based capital requirements and leverage limits will be implemented in two phases, with the first phase already effective from November 2011 when the Fed issued the capital plan rule. This rule expects companies to:
  • Develop annual capital plans
  • Conduct stress tests, and
  • Maintain adequate capital, including a tier one common risk-based capital ratio greater than 5 percent, under both expected and stressed conditions.
The second phase would include a Federal Reserve rule to implement a risk-based capital surcharge based on the framework and methodology developed by the Basel Committee on Banking Supervision.
Liquidity Requirements
The Federal Reserve expects to implement these requirements in two phases as well:
Phase 1
  • Institutions would be subject to qualitative liquidity risk-management standards generally based on the interagency liquidity risk-management guidance issued in March 2010.
  • Companies will have to:
    • Conduct internal liquidity stress tests and
    • Set internal quantitative limits to manage liquidity risk
Phase 2
  • The Federal Reserve would issue one or more proposals to implement quantitative liquidity requirements based on the Basel III liquidity rules.
Stress Tests
  • According to the proposed rules, the Federal Reserve would conduct annual stress tests of companies using three economic and financial market scenarios.
  • These results would be made public and include company-specific information.
  • The companies themselves would have to conduct one or more company-run stress tests each year and to make a summary of their results public.
Single Counter-Party Credit Limits
  • The proposed Federal Reserve rules would limit credit exposure of a covered financial firm to a single counterparty as a percentage of the firm's regulatory capital.
  • Credit exposure between the largest financial companies would be subject to a tighter limit.
Early Remediation Requirements
Remediation requirements would be applied to all those companies and institutions covered by the proposed rules. These requirements would ensure that all financial weaknesses are addressed at an early stage.
According to the proposed rules, the triggers for remediation, such as capital levels, stress test results, and risk management weaknesses, will have to be calibrated to be forward-looking in some cases.
Required remediation actions would depend on the severity of the trigger, but could include:
  • Restrictions on growth
  • Capital distributions
  • Executive compensation
  • Capital raising
  • Asset sales
Additional resources
Read the proposed Federal Reserve rules, Enhanced Prudential Standards and Early Remediation Requirements for Covered Companies¸ in full.


Best Sellers
You Recently Viewed