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FRB Amends Capital Planning Requirements

The Federal Reserve Board ("FRB") adopted amendments to conform the capital planning, regulatory reporting and stress capital buffer requirements for "Category IV" firms to the requirements under the FRB's October 2019 prudential standards framework (see previous coverage).

The amendments apply to firms that are subject to the Category IV standards; i.e., firms that (i) have between $100 billion and $250 billion in total assets, and (ii) are not otherwise subject to Categories I-III in light of their particular activities. The FRB amended the final rule from its proposed form by also applying the capital planning requirements to large savings and loan holding companies subject to the Category II, Category III or Category IV standards under the tailoring framework.

In addition, the FRB adopted changes to its (i) stress testing regulations, (ii) Stress Testing Policy Statement and (iii) regulatory reporting requirements, concerning business plan change assumptions and capital action assumptions, in order to make them consistent with the FRB's stress testing rule amendments (see previous coverage).

The final rule will go into effect 60 days after its publication in the Federal Register.

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