The infrastructure changes prompted by the DFA capital planning regime fall into two categories: organizational and technical. From an organizational perspective, the principal areas of change are in project planning, processes, collaboration, governance and ownership. From a technical perspective, they are portfolio segmentation, exposure aggregation, derivative valuation and modeling.

Bank policies for forecasting, stress testing and capital planning are not always updated as often as necessary. Knowing that the Federal Reserve is likely to mark down a bank’s capital planning process if it finds these policies to be out of date, is motivation enough to update them in a more timely manner