Sullivan & Cromwell Discusses Banking Organization Capital Plans and Stress Tests By Kathryn E. Collard, Sarah C. Flowers and Benjamin H. Weiner February 14, 2017 by Kathryn E. Collard On January 30, 2017, the Federal Reserve published a final rule,[1] initially proposed on September 26, 2016,[2] that will modify the CCAR capital plan and stress testing rules applicable to bank holding companies (“BHCs”) with $50 …