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Federal Banking Agencies Issue Final Dodd-Frank Act Stress Test Guidance for MidSized Banking Organizations



by Stephen F. Donahoe
Kilpatrick Townsend & Stockton LLP - Washington Office

Erich M. Hellmold
Kilpatrick Townsend & Stockton LLP - Washington Office

Aaron M. Kaslow
Kilpatrick Townsend & Stockton LLP - Washington Office

Michael A. Mancusi
Kilpatrick Townsend & Stockton LLP - Washington Office

Kevin M. Toomey
Kilpatrick Townsend & Stockton LLP - Washington Office

March 21, 2014

Previously published on March 19, 2014

On March 5, 2014, the Federal Reserve Board (the “FRB”), the Federal Deposit Insurance Corporation (the “FDIC”) and the Office of the Comptroller of the Currency (the “OCC”) issued final supervisory guidance implementing the provisions of section 165(i) (2) of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”) regarding annual company-run stress tests for mid-sized banking organizations. The final supervisory guidance applies to all bank and savings and loan holding companies, national banks, state member banks, state non-member banks, federal savings associations, and state chartered savings associations with more than $10 billion but less than $50 billion in total consolidated assets. Banking organizations with less than $10 billion in total consolidated assets are not subject to the stress testing requirements. The effective date of the final supervisory guidance is March 31, 2014 for banking organizations regulated by the FDIC and OCC and April 1, 2014 for banking organizations regulated by the FRB.


 

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