ABA and the Financial Services Roundtable last week filed comments on the Federal Reserve’s September proposal that would exempt many regional banks from the complex qualitative requirements of its annual Comprehensive Capital Analysis and Review, or CCAR, process. While welcoming the overall purpose of the proposal, ABA and FSR offered several recommendations to improve the proposal. Specifically, the groups recommended that the Fed clarify the supervisory review process and documentation requirements, raise the materiality threshold for Y-14 reporting, apply a risk-based rather than asset-based approach to setting thresholds and retain the de minimis exemption. For more information, contact ABA’s Hugh Carney.
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