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Top-Tier US Banks Capital Plans

Top-Tier US Banks Capital Plans

Aggregating results was particularly challenging for banks with antiquated, siloed and incompatible systems. The Fed noted far too frequent uses of standalone tools or spreadsheets in the banks’ aggregation processes, together with limited or no reconciliation procedures to ensure integrity, completeness and accuracy of the consolidated post-stress capital metrics. Whether or not, these remedial pointers were addressed by all the top-tier US banks in their 2014 CCAR submissions remains to be seen.

For the first time in 2014, the original group of eighteen were joined by the next twelve largest US banks in submitting their capital plans to the Federal Reserve on January The impact of relying on lagging practices will be all too evident to the examiners, given the extent and complexity of the 2014 CCAR reporting requirements: three supervisory scenarios (baseline, adverse and severely adverse), each with 28 macro-economic variables; two bank-chosen scenarios (baseline and stress) custom-designed to highlight risks in the bank’s specific business models , all estimated over 9 quarters.

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