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Home Archive for category "Dodd-Frank" (Page 3)
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Visuals of Federal Reserve’s 2014 Stress Test Results (Updated to Reflect CCAR Results)

We have prepared visuals (available here) of the Federal Reserve’s 2014 supervisory Dodd-Frank Act stress test (“DFAST“) results.   Update: We have updated these visuals to reflect the company-run DFAST results and the Federal Reserve’s 2014 Comprehensive Capital Analysis and Review (“CCAR“) results. 

Background:  On March 20, 2014, the Federal Reserve published results of the 2014 supervisory DFAST for 30 U.S. bank holding companies with $50 billion or more in total consolidated assets (“Large BHCs“). …  Read More

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Davis Polk Blackline of Federal Reserve’s Corrections to Dodd-Frank Stress Test Capital Ratio Projections

Today, the Federal Reserve published corrections to its 2014 supervisory Dodd-Frank Act stress test (“DFAST“) results.  We have prepared a blackline (available here) showing the Federal  Reserve’s revised capital ratio projections for 30 large U.S. bank holding companies under the supervisory severely adverse stress scenario.  According to the Federal Reserve, it adjusted the supervisory DFAST results to “address inconsistencies in the treatment of the fourth quarter 2013 actual capital actions and assumptions about preferred and employee compensation-related issuance over the course of the planning horizon.”

View Blackline of Federal Reserve’s Corrections to 2014 Supervisory DFAST Capital Ratio Projections

 

Materials: 

Federal Reserve, Dodd-Frank Act Stress Test 2014: Supervisory Stress Test Methodology and Results (originally published on Mar.…  Read More

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Dodd-Frank Enhanced Prudential Standards for Foreign Banks with Limited U.S. Footprints: Visual Memorandum

The Federal Reserve’s Dodd-Frank enhanced prudential standards (EPS) final rule adopts a tiered approach for applying EPS to foreign banks. Under the tiered approach, the most burdensome requirements will only apply to foreign banks with large U.S. operations, whereas fewer requirements will apply to foreign banks with limited U.S. footprints. We have prepared a visual memorandum focusing on the requirements that will apply to foreign banks with limited U.S. footprints, including the U.S. risk committee, internal liquidity stress testing, home country capital certification and home country capital stress testing requirements.…  Read More

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Comparison of Dodd-Frank Stress Tests for Large and Mid-Size Banking Organizations

The following chart provides a high-level comparison of the Federal Reserve’s Dodd-Frank stress testing requirements, related reporting requirements and supervisory expectations for  (1) large banking organizations (≥$50 billion in total consolidated assets) and (2) mid-size banking organizations (>$10 billion and < $50 billion in total consolidated assets).  The comparison chart is based on information contained in a recent Federal Reserve Supervision and Regulation (SR) letter.  Our blackline of the U.S. banking agencies’ final vs. proposed Dodd-Frank stress test supervisory guidance for mid-size banking organizations is available here.…  Read More

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Davis Polk Blackline of Dodd-Frank Stress Test Guidance for Mid-sized Banking Organizations

We have prepared a blackline that compares (1) the U.S. banking agencies’ final supervisory guidance regarding annual Dodd-Frank company-run stress tests for banking organizations with $10 billion to $50 billion in total consolidated assets (mid-sized banking organizations) against (2) the July 2013 proposed supervisory guidance.

View Blackline Comparing Final and Proposed Supervisory Guidance on Dodd-Frank Company-Run Stress Tests for Mid-sized Banking Organizations (PDF) Read More

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Foreign Banks: U.S. Liquidity Buffer Requirement – Visual Memorandum and Interactive Calculator

The Federal Reserve’s Dodd-Frank enhanced prudential standards final rule requires a foreign banking organization with $50 billion or more in U.S. assets to maintain separate U.S. liquidity buffers for its U.S. branches/agencies and U.S. intermediate holding company.  We have prepared a visual memorandum that uses diagrams, flowcharts, examples and an interactive calculator to illustrate the U.S. liquidity buffer requirement and related calculations.  The interactive calculator allows you to enter various internal and external cash flow amounts to assess the potential impact of the final rule’s prescribed method for calculating net stressed cash flow need.…  Read More

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