banks and bank holding companies with over $10 billion in consolidated assets to ..... Technical resources include more than hardware and software, it also ...
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DFAST & CCAR: One size does not fit all Charyn Faenza, F.N.B. Corporation ABSTRACT In 2014, for the first time, mid-market banks (consisting of banks and bank holding companies with 10-50 bn in consolidated assets) were required to submit Capital Stress Tests to the federal regulators under the Dodd-Frank Wall Street Reform and Consumer Protection Act (DFAST). This is a process large banks have been going through since 2011; however, mid-market banks are not positioned to commit as many resources to their annual stress tests as their largest peers. Limited human and technical resources, incomplete or non-existent detailed historical data, lack of enterprise-wide cross functional analytics teams, and limited exposure to rigorous model validations, are all challenges mid-market banks face. While there are fewer deliverables required from the DFAST banks, the scrutiny the regulators are placing on the analytical modes is just as high as their expectations for CCAR banks. This session is designed to discuss the differences in how DFAST and CCAR banks execute their stress tests, the challenges facing DFAST banks, and potential ways DFAST banks can leverage the analytics behind this exercise.
WHAT IS STRESS TESTING? Throughout the financial crisis of 2008 the regulators understood that, in order to stabilize the system and prevent a severe depression, banks would need to have enough capital to survive the losses of a crashing market. Additionally, in order for the markets to start working properly again, investors needed to be reassured that it was safe to put money back in them. The initial supervisory stress tests were developed as a means by which regulators could evaluate the capital position of a bank to determine if they would require an infusion of capital, while also providing much needed transparency to the investment community. This would give investors the confidence boost needed to avoid further runs on the banking system and to get the markets moving again. Since that time banks with consolidated assets of greater than $50 billion (“large banks”) have been required to perform these exercises as described in the Dodd-Frank Wall Street Reform and Consumer Protection Act (“DFA”). In 2014 banks with consolidated assets of $10 billion to $50 billion (“mid-sized banks”) were required to perform their own stress tests under the DFA for the first time.
DODD-FRANK ACT STRESS TEST (“DFAST”) The premise of the Dodd-Frank Act Stress Test is straightforward. It is a forecasting exercise required that requires banks and bank holding companies with over $10 billion in consolidated assets to evaluate and report their capital position under baseline, adverse, and severely adverse scenarios on an annual basis. These scenarios are created by the regulators and then presented to the banks at the start of the annual stress testing exercise. They include a wide array of forecasted macro-economic conditions such as GDP drops, unemployment spikes, stock or housing market crashes, etc. The banks are then to use the variables in their forecasting models to assess their effects on the firm’s revenues, losses, balance sheet (including risk-weighted assets), liquidity, and capital position for each of the scenarios over a nine quarter horizon. The guidance from the regulators during the first year of the DFAST for the mid-sized banks allowed for a wide range of interpretations. Recognizing that the banks in this segment have vastly different attributes, banks were given the latitude to conduct the tests in whatever way they felt was most suitable for their unique set of characteristics provided they fell within the established framework. The following excerpts from the most recent guidance available from the Office of the Comptroller of the Currency (“OCC”) highlight some of the regulators’ expectations with respect to the annual stress test (OCC, 2014): The Framework for Stress Testing 1.
A company’s stress testing framework should include activities and exercises that are tailored to and sufficiently capture the company’s exposures, activities, and risks;
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An effective stress testing framework should employ multiple conceptually sound stress testing activities and approaches;
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An effective stress testing framework should be forward-looking and flexible;
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Stress test results should be clear, actionable, well supported, and inform decision-making; and
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A company’s stress testing framework should include strong governance and effective internal controls.
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COMPREHENSIVE CAPITAL ANALYSIS & REVIEW (“CCAR”) While large banks must also conduct the DFAST annually, they have several additional regulatory requirements that the mid-sized banks do not. In addition to running their own stress tests, they must submit their data to the regulators who will then execute the supervisory test, the results of which are published annually. Large banks must also participate in the annual Comprehensive Capital Analysis and Review process. This test requires the banks must submit their proposed capital action plans (including changes to dividends, stock buybacks, etc.) to the regulators for review. The regulators then assesses whether the bank is able to maintain minimum regulatory capital ratios with the proposed capital plan under both adverse and severely adverse macroeconomic scenarios. Their assessment is issued as an object or a non-object opinion on the submitted plan. Plans cannot be made public until they are approved by the FRB and plans that are rejected must be redrawn and resubmitted.
THE DIFFERENCE BETWEEN DFAST AND CCAR The obvious difference between DFAST and CCAR is that they are two different tests. So the better question is what are the differences between DFAST for large banks and DFAST for mid-sized banks? A quote from the March 2014 guidance provides some insight: “For example, the expectations for data sources, data segmentation, sophistication of estimation practices approaches, reporting and public disclosures are elevated for larger and more complex organizations than for $10-50 billion companies (Federal Reserve, 2014).” The regulators clearly state that their expectations for mid-sized banks are not the same as their expectations for the large banks. In addition to differences in how the tests are administered (supervisory vs. company-run), there are several other notable differences:
Mid-sized banks are not required to create their own scenarios in addition to the scenarios issues by the regulators.
Data segmentation is much less granular for mid-sized banks and banks are permitted to use industry data as proxy data in some circumstances.
Specific drivers are not required for the individual components of Pre-Provision Net Revenue (“PPNR”) and a “top-of-the-house” approach can be taken.
The time table for the 10-50 banks is less aggressive than the time table for the large BHCs.
The following tables summarize the differences in the tests that were presented attachment 2 of the Federal Reserve Board Supervisory Letter, SR 14-3: Supervisory Guidance on Dodd-Frank Act Company-Run Stress Testing for Banking Organizations with Total Consolidated Assets of More Than $10 Billion but Less Than $50 Billion.
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SESUG 2014 Large banking organizations (≥$50 billion in total consolidated assets)
Mid‐size banking organizations (>$10 billion and 5% post‐stress Tier 1 Common ratio ● Must use both supervisory and BHC‐specific stress test scenarios
● No formal supervisory approval associated with stress tes ng ● Only required to use supervisory scenarios in Dodd‐Frank company‐run stress tests
Dodd‐Frank company‐run stress test th
th
st
Semi‐annual submissions by January 5 and July 5 of each year
Annual submission by March 31 of each year
Report on form FR Y‐14A
Report on form FR Y‐16
Semi‐annual public disclosures of summary results (March and September)
Annual public disclosure of summary results beginning in June 2015
Incorporation of U.S. Basel III into stress testing Must incorporate U.S. Basel III capital framework in capital projections
Not required to incorporate U.S. Basel III capital framework in capital projections until the 2015 stress testing cycle starting in October 2014
Tier 1 Common ratio is calculated using existing capital rules
Not required to calculate Tier 1 Common ratio for 2014 stress testing cycle
Table 1: General Stress Testing Requirements
Large banking organizations (≥$50 billion in total consolidated assets)
Mid‐size banking organizations (>$10 billion and $10 billion and
