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Financial Services Law Insights and Observations

FDIC Approves Proposal for Large Bank Stress Testing

FDIC Dodd-Frank

Consumer Finance

On January 17, the FDIC approved a proposed rule to implement annual capital-adequacy stress tests for FDIC-insured state nonmember banks and state-chartered savings associations with over $10 billion of total consolidated assets. As of September 30, 2011, there were twenty-three such institutions. Required by the Dodd-Frank Act, the stress tests would assist the FDIC in assessing risk presented by an institution’s capitalization and help ensure the bank’s financial stability. Under the proposal, the FDIC would annually provide covered banks with at least three sets of conditions – baseline, adverse, and severely adverse – that must be used in conducting an annual stress test. The tests would include calculations, for each quarter-end within a defined planning horizon, of the impact on the covered bank’s (i) potential losses, (ii) pre-provision revenues, (iii) loan loss reserves, and (iv) pro forma capital positions, including the impact on capital levels and ratios. Covered banks also would be required to establish an oversight and documentation system to ensure that stress testing procedures are effective. Following a test, a covered bank would be required to submit the results to the FDIC and later release a summary to the public. Under the proposed timeline, each year (i) the FDIC would provide scenarios no later than mid-November, (ii) covered banks would submit their stress test reports by January 5, and (iii) by early April covered banks would publicly release a summary of results. Public comments on the rule will be accepted sixty days following publication of the rule in the Federal Register.

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