Sullivan & Cromwell discusses Bank Capital Plans and Stress Tests
On July 17, the Board of Governors of the Federal Reserve System (the “FRB”) released a notice of proposed rulemaking (the “NPR” and the rules set forth therein, the “Proposed Rule”) that would modify certain aspects of the FRB’s capital plan rule (the “Capital Plan Rule”)[1] and Dodd-Frank Act stress test rules (the “DFAST Stress Test Rules”)[2] applicable to large bank holding companies (“BHCs”)[3] and certain banking organizations with total consolidated assets of more than $10 billion. The NPR would also affect elements of the … Read more