Financial Associations Seek Extension of Comment Period on Stress-Testing Proposal

Five banking trade associations urged the Federal Reserve Board ("Fed") to extend the comment period for its Notice of Proposed Rulemaking on enhanced transparency and public accountability in supervisory stress testing. Comments are currently due on or before January 22, 2026.

In their letter to the Fed, the Bank Policy Institute, American Bankers Association, Financial Services Forum, SIFMA and ISDA explained that they are undertaking a detailed review of the proposal, which includes nearly 1,500 pages of technical model documentation and significant proposed changes to the stress-testing framework, capital-planning rules, and related reporting requirements. They argued that an additional 30 days is necessary to allow sufficient time to analyze the extensive materials, incorporate yet-to-be-released information, and develop meaningful feedback.

The associations noted that the proposal is more detailed and technical than other recent regulatory initiatives, pointing out that the Fed granted a substantial comment-period extension in 2023 for the Basel III Endgame proposal. They argued that extending the deadline would ensure the development of well-supported comments on the proposal’s complex modeling, transparency, and prudential-oversight considerations. They stated that additional time would also support a more robust public record and ultimately help the Fed refine a stress-testing framework that advances transparency, accountability, and effective supervisory oversight.