Agencies take next step to combine stress-test reports into one

Following no comments received last fall, the three federal banking agencies are moving forward on their proposal to combine three separate, yet identical, stress test reports into a single new Federal Financial Institutions Examination Council (FFIEC) report, according to “joint notice” filings Thursday with the Federal Register.

The Federal Reserve, Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corp. (FDIC) have submitted the combined form (FFIEC 016) to the Office of Management and Budget (OMB) for review and final approval. Assuming OMB approves, the form would take effect for the stress test report due July 31, 2018. The final form will be subject to a 30-day comment period before final approval.

In October, the three agencies issued the combined form for a 60-day comment period (ending Dec. 5) – and received no comments. The new form reflected the company-run stress testing requirements promulgated by the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank), as reflected in the agencies’ current information collections. The form is filed by depository institutions and holding companies with $10 billion to $50 billion in total consolidated assets.

When proposing the form, the three agencies said they were implementing a “limited number of revisions” that would align the new report with recent actions taken to reduce regulatory burden in forms FFIEC 031 and FFIEC 041 Consolidated Reports of Condition and Income and the Fed Board’s FR Y-9C Consolidated Financial Statements for Holding Companies.

In addition, the banking agencies said they were proposing to have institutions provide their Legal Entity Identifier (LEI) on the report form, if they already have one.

The proposed new form, once approved, replaces:

  • For the Federal Reserve: FR Y-16 (Annual Company-Run Stress Test Report For State Member Banks, Bank Holding Companies, and Savings and Loan Holding Companies with Total Consolidated Assets Greater Than $10 Billion and Less Than $50 Billion);
  • For the OCC: DFAST 10-50B (Annual Company-Run Stress Test Reporting Template and Documentation for Covered Institutions with Total Consolidated Assets of $10 Billion to $50 Billion under the Dodd-Frank Act);
  • For the FDIC: DFAST 10-50 (Company-Run Annual Stress Test Reporting Template and Documentation for Covered Institutions with Total Consolidated Assets of $10 Billion to $50 Billion under the Dodd-Frank Act).

Agency Information Collection Activities: Submission for OMB Review; Joint Comment Request