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Financial Services Law Insights and Observations

Federal Reserve seeks comments on capital assessments and stress testing reporting for U.S. subsidiaries of foreign banking organizations

Agency Rule-Making & Guidance Federal Reserve Stress Test Of Interest to Non-US Persons

Agency Rule-Making & Guidance

On July 31, the Federal Reserve Board published two notices and requests for comments in the Federal Register seeking input on information collections that would affect reporting requirements for bank holding companies with total consolidated assets of $100 billion or more as well as U.S. intermediate holding companies with $50 billion or more in total consolidated assets that are subsidiaries of foreign banking organizations. The Fed uses the information in the Capital Assessments and Stress Testing Reports (FR Y-14A/Q/M) to help ensure that these firms implement “strong, firm-wide risk measurement and management processes [that support] their internal assessments of capital adequacy and that their capital resources are sufficient given their business focus, activities, and resulting risk exposures.” These reports are also used to support the Fed’s annual Comprehensive Capital Analysis and Review exercise.

The first notice announces several proposed schedule changes, as well as the Fed’s intent to modify and clarify instructions for existing data items in the FR Y-14A/Q/M reports. These changes, the Fed notes, are designed to reduce reporting burdens, clarify reporting requirements, address inconsistencies between FR Y-14 reports and other regulatory reports, and account for revised rules and accounting principles. The Fed proposes to implement these revisions as of September 30.

The second notice addresses, among other things, the revised accounting for credit losses under the Financial Accounting Standards Board’s Accounting Standards Update No. 2016-13 and will implement the current expected credit loss accounting methodology across all of the FR Y-14 reports. According to the Fed, these revisions will “address the broadening of the scope of financial assets for which an allowance for credit losses assessment must be established and maintained, along with the elimination of the existing model for [purchased credit-impaired] assets.”

Comments on both notices must be received by September 30.