FRB Proposes Amendments to Capital Planning Requirements

The Federal Reserve Board ("FRB") proposed 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 tailoring framework (see previous coverage).

The amendments would 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 proposed amendments would also eliminate the capital plan rule requirement for Category IV firms to compute forward-looking capital projections under FRB-provided scenarios.

In addition, the FRB is proposing 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 FRB is also seeking feedback on existing capital planning guidance.

Comments on the proposal must be submitted by November 20, 2020.