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Bank Capital Plans and Stress Tests: Federal Reserve Proposes New Submission Deadlines and Other Revisions to Its Capital Plan Rule; Federal Banking Agencies Propose New Submission Deadlines for Dodd-Frank Act Company-Run Stress Tests

by Sullivan Cromwell LLP - New York Office

July 9, 2014

Previously published on June 30, 2014

The Board of Governors of the Federal Reserve System (the “FRB”) recently released a notice of proposed rulemaking (the “FRB NPR”, and the rules set forth therein, the “FRB Proposed Rules”) that would amend the FRB’s capital plan rule (the “Capital Plan Rule”) as well as its supervisory stress test rule (the “FRB Supervisory Stress Test Rule”) and company-run stress test rules (the “FRB Stress Test Rules”). The FRB Proposed Rules would shift the start date of the annual capital plan and supervisory and company-run stress test cycles, the filing date for capital plans and company-run stress tests and the related planning horizon back by approximately three months. The FRB Proposed Rules would not modify the upcoming capital plan and stress test cycle beginning on October 1, 2014 and ending September 30, 2015. Rather, they would amend the cycle that would otherwise begin on October 1, 2015 to instead begin on January 1, 2016 and end December 31, 2016 and correspondingly amend subsequent cycles. Key dates under the FRB Proposed Rules applicable to bank holding companies (“BHCs”) and state member banks are summarized in the tables below. Savings and loan holding companies (“SLHCs”), once they are subject to the FRB Stress Test Rules, would be required to follow the schedule outlined below for BHCs of comparable size.


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