Final round of review set for OCC company-run stress test template changes

Comments on a template for stress testing by the largest banking institutions will be accepted until March 4 – during the second and final comment period planned prior to finalizing changes – by the Office of the Comptroller of the Currency (OCC).

The OCC, in a notice published in the Federal Register Thursday, says it is accepting comments on proposed revisions to its “Company-Run Annual Stress Test Reporting Template and Documentation for Covered Institutions under the Dodd-Frank Wall Street Reform and Consumer Protection Act” (Dodd-Frank). The changes includes modifications to company-run stress testing requirements made by the 2018 Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA, S. 2155).

Reports of the stress test must be provided to the Federal Reserve Board and the reporting institution’s primary regulator. OCC, in its notice, points out that the law exempts bank holding companies under $100 billion in total consolidated assets from the Dodd-Frank company-run stress testing requirements; firms that are not bank holding companies and which have less than $250 billion in total consolidated assets are exempt 18 months after enactment. The Fed, OCC and Federal Deposit Insurance Corp. (FDIC) have extended the deadlines for company-run stress test requirements to Nov. 25, 2019, for depository institutions under $100 billion – when both exemptions take effect.

The OCC notice indicates the regulator anticipates just eight (8) institutions submitting this form (edited down from the 23 noted in the October notice).

The OCC says it has made modifications consistent with changes made by the Fed Board to its FR Y-14A report; these include changes to accommodate the revised asset threshold set by EGRRCPA. The changes also remove the Retail Repurchase worksheet and various clarifications in the instructions; and remove or modify certain items on the OCC Supplemental Schedule, which collects additional information not included in the FR Y-14A.

The OCC said it received one comment on the proposed revisions that sought clarification about an item on the OCC Supplemental Schedule. “The information referenced by the commenter will not be collected in the revised Supplemental Schedule,” it said in its notice.

The OCC, in coordination with the Fed Board and Federal Deposit Insurance Corp. (FDIC), is also in the process of revising its stress testing regulation to incorporate EGRRPCA’s amendments, the agency said.

Company-Run Annual Stress Test Reporting Template and Documentation for Covered Institutions