Guidance Proposed Guidance on Stress Testing for Banking Organizations with More Than $10 Billion in Total Consolidated Assets

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FDIC Financial Institution Letters › Guidance Proposed Guidance on Stress Testing for Banking Organizations with More Than $10 Billion in Total Consolidated Assets

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35072

Federal Register / Vol. 76, No. 115 / Wednesday, June 15, 2011 / Notices

(d) Any employee of the Treasury or

the CFPB in his or her individual

capacity where DOJ has agreed to

represent the employee; or

(e) The United States, where the

Treasury or the CFPB determines that

litigation is likely to affect the Treasury

or any of its components or the CFPB.

(4) Appropriate agencies, entities, and

persons, to the extent necessary to

respond to or refer correspondence;

(5) A court, magistrate, or

administrative tribunal, including

disclosures to opposing counsel or

witnesses in the course of civil

discovery, litigation, or settlement

negotiations or in connection with

criminal law proceedings when the

Treasury or the CFPB is party to the

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(6) A grand jury pursuant either to a

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introduction to a grand jury, where the

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enforcing or implementing, a statute,

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the disclosing agency becomes aware of

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rd pertains;

(8) Appropriate Federal, foreign, state,

local, Tribal, or other public authorities

or self-regulatory organizations

responsible for investigating or

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amendment, or correction of records to

be made in consultation with or by that

agency, or (b) verify the identity of an

individual or the accuracy of

information submitted by an individual

who has requested access to,

amendment of, or correction of records.

POLICIES AND PRACTICES FOR STORING,

RETRIEVING, ACCESSING, RETAINING, AND

DISPENSING OF RECORDS IN THE SYSTEM:

STORAGE:

Records maintained in this system are

stored electronically and in file folders.

Paper copies of individual records are

made by the authorized CFPB

implementation team staff.

RETRIEVABILITY:

Records are retrievable by the name of

the individual covered by the system,

date of correspondence, or

correspondence control number.

SAFEGUARDS:

Access to electronic records is

restricted to authorized personnel who

have been issued non-transferrable

access codes and passwords. Other

records are maintained in locked file

cabinets or rooms with access limited to

those personnel whose official duties

require access.

RETENTION AND DISPOSAL:

Computer and paper records will be

maintained indefinitely until a records

disposition schedule is approved by the

National Archives and Records

Administration.

SYSTEM MANAGER(S) AND ADDRESS:

Consumer Financial Protection

Bureau implementation team, 1801 L

Street, NW., Washington, DC 20036

h access limited to

those personnel whose official duties

require access.

RETENTION AND DISPOSAL:

Computer and paper records will be

maintained indefinitely until a records

disposition schedule is approved by the

National Archives and Records

Administration.

SYSTEM MANAGER(S) AND ADDRESS:

Consumer Financial Protection

Bureau implementation team, 1801 L

Street, NW., Washington, DC 20036.

NOTIFICATION PROCEDURE:

Individuals seeking notification and

access to any record contained in this

database, or seeking to contest its

content, may inquire in writing in

accordance with instructions appearing

at 31 CFR part 1, subpart C, appendix

A. Address such requests to: Director,

Disclosure Services, Department of

Treasury, 1500 Pennsylvania Avenue,

NW., Washington, DC 20220.

RECORD ACCESS PROCEDURES:

See ‘‘Notification Procedures,’’ above.

CONTESTING RECORD PROCEDURES:

See ‘‘Notification Procedures,’’ above.

RECORD SOURCE CATEGORIES:

Information in this system is

maintained about individuals who

submit correspondence to the CFPB

implementation team and employees

assigned to help process, review, or

respond to correspondence.

EXEMPTIONS CLAIMED FOR THE SYSTEM:

None.

[FR Doc. 2011–14834 Filed 6–14–11; 8:45 am]

BILLING CODE 4810–25–P

DEPARTMENT OF THE TREASURY

Office of the Comptroller of the

Currency

[Docket No. OCC–2011–0011]

FEDERAL RESERVE SYSTEM

[Docket No. OP–1421]

FEDERAL DEPOSIT INSURANCE

CORPORATION

Proposed Guidance on Stress Testing

for Banking Organizations With More

Than $10 Billion in Total Consolidated

Assets

AGENCIES: Office of the Comptroller of

the Currency, Treasury (‘‘OCC’’); Board

of Governors of the Federal Reserve

System (‘‘Board’’ or ‘‘Federal Reserve’’);

Federal Deposit Insurance Corporation

(‘‘FDIC’’).

ACTION: Proposed joint guidance with

request for public comment.

SUMMARY: The OCC, Board, and the

FDIC (collectively, the ‘‘agencies’’)

request comment on proposed guidance

on stress testing (proposed guidance)

roller of

the Currency, Treasury (‘‘OCC’’); Board

of Governors of the Federal Reserve

System (‘‘Board’’ or ‘‘Federal Reserve’’);

Federal Deposit Insurance Corporation

(‘‘FDIC’’).

ACTION: Proposed joint guidance with

request for public comment.

SUMMARY: The OCC, Board, and the

FDIC (collectively, the ‘‘agencies’’)

request comment on proposed guidance

on stress testing (proposed guidance).

The proposed joint guidance outlines

high-level principles for stress testing

practices, applicable to all Federal

Reserve-supervised, FDIC-supervised,

and OCC-supervised banking

organizations with more than $10

billion in total consolidated assets. The

proposed guidance highlights the

importance of stress testing as an

ongoing risk management practice that

supports a banking organization’s

forward-looking assessment of its risks.

DATES: Comments must be submitted on

or before July 29, 2011.

ADDRESSES: OCC: Please use the title

‘‘Proposed Guidance on Stress Testing’’

to facilitate the organization and

distribution of the comments. You may

submit comments by any of the

following methods:

• E-mail:

regs.comments@occ.treas.gov.

• Mail: Office of the Comptroller of

the Currency, 250 E Street, SW., Mail

Stop 2–3, Washington, DC 20219.

• Fax: (202) 874–5274.

• Hand Delivery/Courier: 250 E

Street, SW., Mail Stop 2–3, Washington,

DC 20219.

Instructions: You must include

‘‘OCC’’ as the agency name and ‘‘Docket

Number OCC–2011–0011’’ in your

comment. In general, OCC will enter all

comments received into the docket and

publish them on the Regulations.gov

Web site without change, including any

business or personal information that

you provide such as name and address

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’ in your

comment. In general, OCC will enter all

comments received into the docket and

publish them on the Regulations.gov

Web site without change, including any

business or personal information that

you provide such as name and address

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35073

Federal Register / Vol. 76, No. 115 / Wednesday, June 15, 2011 / Notices

1 For purposes of this guidance, the term

‘‘banking organization’’ means national banks and

Federal branches and agencies supervised by the

OCC; state member banks, bank holding companies,

and all other institutions for which the Federal

Reserve is the primary Federal supervisor; and state

nonmember insured banks and other institutions

supervised by the FDIC.

2 See, for example, Supervision and Regulation

(SR) letter 10–6 or OCC Bulletin 2010–13 or FDIC

FIL–13–2010, ‘‘Interagency Policy Statement on

Funding and Liquidity Risk Management’’; SR 10–

1 or OCC Bulletin 2010–1 or FDIC Financial

Institution Letter (FIL–2–2010), ‘‘Interagency

Advisory on Interest Rate Risk’’; SR letter 09–04,

‘‘Applying Supervisory Guidance and Regulations

on the Payment of Dividends, Stock Redemptions,

and Stock Repurchases at Bank Holding

Companies’’; SR letter 07–1, ‘‘Interagency Guidance

on Concentrations in Commercial Real Estate’’ or

OCC Bulletin 2006–46 or FDIC FIL–104–2006,

‘‘Interagency Guidance on CRE Concentration Risk

Management’’; SR letter 99–18, ‘‘Assessing Capital

Adequacy in Relation to Risk at Large Banking

Organizations and Others with Complex Risk

Profiles’’; OCC Bulletin 2008–20 or FDIC FIL–71–

2008 ‘‘Supervisory Guidance: Supervisory Review

Process of Capital Adequacy (Pillar 2) Related to the

Implementation of the Basel II Advanced Capital

Framework’’; the Supervisory Capital Assessment

Program (see http://www.federalreserve.gov/

newsevents/press/bcreg/bcreg20080715a1.pdf); and

Comprehensive Capital Analysis a

s with Complex Risk

Profiles’’; OCC Bulletin 2008–20 or FDIC FIL–71–

2008 ‘‘Supervisory Guidance: Supervisory Review

Process of Capital Adequacy (Pillar 2) Related to the

Implementation of the Basel II Advanced Capital

Framework’’; the Supervisory Capital Assessment

Program (see http://www.federalreserve.gov/

newsevents/press/bcreg/bcreg20080715a1.pdf); and

Comprehensive Capital Analysis and Review:

Objectives and Overview (see

www.federalreserve.gov/newsevents/press/bcreg/

20110318a.htm ).

3 See ‘‘Principles for Sound Stress Testing

Practices and Supervision,’’ Basel Committee on

Banking Supervision, May 2009.

information, e-mail addresses, or phone

numbers. Comments received, including

attachments and other supporting

materials, are part of the public record

and subject to public disclosure. Do not

enclose any information in your

comment or supporting materials that

you consider confidential or

inappropriate for public disclosure.

You may review comments and other

related materials that pertain to this

notice by any of the following methods:

• Viewing Comments Personally: You

may personally inspect and photocopy

comments at the OCC, 250 E Street,

SW., Washington, DC. For security

reasons, the OCC requires that visitors

make an appointment to inspect

comments. You may do so by calling

(202) 874–4700. Upon arrival, visitors

will be required to present valid

government-issued photo identification

and to submit to security screening in

order to inspect and photocopy

comments.

• Docket: You may also view or

request available background

documents and project summaries using

the methods described above.

Board: When submitting comments,

please consider submitting your

comments by e-mail or fax because

paper mail in the Washington, DC area

and at the Board may be subject to

delay. You may submit comments,

identified by Docket No. OP–1411, by

any of the following methods:

• Agency Web Site: http://

www.federalreserve.gov

documents and project summaries using

the methods described above.

Board: When submitting comments,

please consider submitting your

comments by e-mail or fax because

paper mail in the Washington, DC area

and at the Board may be subject to

delay. You may submit comments,

identified by Docket No. OP–1411, by

any of the following methods:

• Agency Web Site: http://

www.federalreserve.gov. Follow the

instructions for submitting comments at

http://www.federalreserve.gov/

generalinfo/foia/ProposedRegs.cfm.

• Federal eRulemaking Portal: http://

www.regulations.gov. Follow the

instructions for submitting comments.

• E-mail:

regs.comments@federalreserve.gov.

Include docket number in the subject

line of the message.

• Fax: (202) 452–3819 or (202) 452–

3102.

• Mail: Jennifer J. Johnson, Secretary,

Board of Governors of the Federal

Reserve System, 20th Street and

Constitution Avenue, NW., Washington,

DC 20551.

All public comments are available

from the Board’s Web site at http://

www.federalreserve.gov/generalinfo/

foia/ProposedRegs.cfm as submitted,

unless modified for technical reasons.

Accordingly, your comments will not be

edited to remove any identifying or

contact information. Public comments

may also be viewed electronically or in

paper form in Room MP–500 of the

Board’s Martin Building (20th and C

Street, NW.,Washington, DC 20551)

between 9 a.m. and 5 p.m. on weekdays.

FDIC: You may submit comments by

any of the following methods:

• Agency Web site: http://

www.FDIC.gov/regulations/laws/

federal/propose.html. Follow the

instructions for submitting comments.

• Federal eRulemaking Portal: http://

www.regulations.gov. Follow the

instructions for submitting comments.

• E-mail: comments@FDIC.gov.

Include ‘‘Stress Testing Guidance’’ in

the subject line of the message.

Comments received will be posted

without change to http://www.FDIC.gov/

regulations/laws/federal/propose.html,

including any personal information

provided.

• Mail: Robert E

ments.

• Federal eRulemaking Portal: http://

www.regulations.gov. Follow the

instructions for submitting comments.

• E-mail: comments@FDIC.gov.

Include ‘‘Stress Testing Guidance’’ in

the subject line of the message.

Comments received will be posted

without change to http://www.FDIC.gov/

regulations/laws/federal/propose.html,

including any personal information

provided.

• Mail: Robert E. Feldman, Executive

Secretary, Attention: Comments/Legal

ESS, Federal Deposit Insurance

Corporation, 550 17th Street, NW.,

Washington, DC 20429.

• Hand Delivery/Courier: Guard

station at the rear of the 550 17th Street

Building (located on F Street), on

business days between 7 a.m. and 5 p.m.

(EDT).

FOR FURTHER INFORMATION CONTACT:

OCC: Robert Scavotto, Lead

International Expert, International

Analysis and Banking Condition (202)

874–4943, Tanya Smith, NBE, Basel II

Program Manager, Large Bank

Supervision (202) 874–4464, Akhtarur

Siddique, Deputy Director, Enterprise

Risk Analysis Division (202) 874–4665,

or Jeanette Quick, Attorney, Legislative

and Regulatory Activities Division (202)

874–5090, Office of the Comptroller of

the Currency, 250 E Street, SW.,

Washington, DC 20219.

Board: Anna Lee Hewko, Assistant

Director, Capital and Regulatory Policy

(202) 530–6260, or Constance M.

Horsley, Manager, Capital and

Regulatory Policy (202) 452–5239,

David Palmer, Senior Supervisory

Analyst, Risk Section, (202) 452–2904,

Sviatlana Phelan, Financial Analyst,

Capital and Regulatory Policy (202)

912–4306, Division of Banking

Supervision and Regulation; or

Benjamin W. McDonough, Counsel,

(202) 452–2036, or Dominic A. Labitzky,

Senior Attorney, (202) 452–3428, Legal

Division, Board of Governors of the

Federal Reserve System, 20th and C

Streets, NW., Washington, DC 20551.

FDIC: George French, Deputy

Director, Policy, (202) 898–3929; Robert

Burns, Chief, Exam Support & Analysis

Section, (704) 333–3132 x4215; Karl

Reitz, Senior Capital Markets Specialist,

cDonough, Counsel,

(202) 452–2036, or Dominic A. Labitzky,

Senior Attorney, (202) 452–3428, Legal

Division, Board of Governors of the

Federal Reserve System, 20th and C

Streets, NW., Washington, DC 20551.

FDIC: George French, Deputy

Director, Policy, (202) 898–3929; Robert

Burns, Chief, Exam Support & Analysis

Section, (704) 333–3132 x4215; Karl

Reitz, Senior Capital Markets Specialist,

(202) 898–6775, Division of Risk

Management Supervision; or Mark

Flanigan, Counsel, (202) 898–7426;

Ryan Clougherty, Senior Attorney, (202)

898–3843, Supervision Branch, Legal

Division.

SUPPLEMENTARY INFORMATION:

I. Background

All banking organizations should

have the capacity to understand their

risks and the potential impact of

stressful events and circumstances on

their financial condition.1 The U.S.

Federal banking agencies have

previously highlighted the use of stress

testing as a means to better understand

the range of a banking organization’s

potential risk exposures.2 The 2007–

2009 financial crisis further

underscored the need for banking

organizations to incorporate stress

testing into their risk management, as

banking organizations unprepared for

stressful events and circumstances can

suffer acute threats to their financial

condition and viability. The proposed

guidance is intended to be consistent

with industry practices and with

international supervisory standards.3

Building upon previously issued

supervisory guidance that discusses the

uses and merits of stress testing in

specific areas of risk management, the

proposed guidance provides an

overview of how a banking organization

should structure its stress testing

activities and ensure they fit into overall

risk management. The purpose of this

guidance is to outline broad principles

for a satisfactory stress testing

framework and describe the manner in

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anization

should structure its stress testing

activities and ensure they fit into overall

risk management. The purpose of this

guidance is to outline broad principles

for a satisfactory stress testing

framework and describe the manner in

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Federal Register / Vol. 76, No. 115 / Wednesday, June 15, 2011 / Notices

4 Public Law 111–203, 124 Stat. 1376. Section

165(i) of the Dodd-Frank Act is codified at 12 U.S.C.

5365(i).

which stress testing should be employed

as an integral component of risk

management that is applicable at

various levels of aggregation within a

banking organization, as well as for

contributing to capital and liquidity

planning. While the guidance is not

intended to provide detailed

instructions for conducting stress testing

for any particular risk or business area,

the proposed guidance aims to describe

several types of stress testing activities

and how they may be most

appropriately used by banking

organizations. The guidance does not

explicitly address the stress testing

requirements imposed upon certain

companies by section 165(i) of the

Dodd-Frank Wall Street Reform and

Consumer Protection Act.4 The Board,

FDIC, and OCC expect to implement

that provision in a future rulemaking

that would be consistent with the

principles in the proposed guidance.

II. Principal Elements of the Proposed

Guidance

The agencies are issuing this

proposed guidance to emphasize the

importance of stress testing as an

ongoing risk management practice that

supports banking organizations’

forward-looking assessment of risks and

better equips them to address a range of

adverse outcomes. The proposed joint

guidance is applicable to all banking

organizations supervised by the

agencies with more than $10 billion in

total consolidated assets

oposed guidance to emphasize the

importance of stress testing as an

ongoing risk management practice that

supports banking organizations’

forward-looking assessment of risks and

better equips them to address a range of

adverse outcomes. The proposed joint

guidance is applicable to all banking

organizations supervised by the

agencies with more than $10 billion in

total consolidated assets. Specifically,

with respect to the OCC, these banking

organizations would include national

banking associations and Federal

branches and agencies; with respect to

the Board, these banking organizations

would include state member banks,

bank holding companies, and all other

institutions for which the Federal

Reserve is the primary Federal

supervisor; with respect to the FDIC,

these banking organizations would

include state nonmember insured banks

or insured branches of foreign banks. A

banking organization should develop

and implement its stress testing

framework in a manner commensurate

with its size, complexity, business

activities, and overall risk profile.

The uses of a banking organization’s

stress testing framework should include,

but are not limited to, augmenting risk

identification and measurement;

estimating business line revenues and

losses and informing business line

strategies; identifying vulnerabilities

and assessing their potential impact;

assessing capital adequacy and

enhancing capital planning; assessing

liquidity adequacy and informing

contingency funding plans; contributing

to strategic planning; enabling senior

management to better integrate strategy,

risk management, and capital and

liquidity planning decisions; and

assisting with recovery planning.

A. Stress Testing Principles

Principle 1: A banking organization’s

stress testing framework should include

activities and exercises that are tailored

to and sufficiently capture the banking

organization’s exposures, activities, and

risks

ng senior

management to better integrate strategy,

risk management, and capital and

liquidity planning decisions; and

assisting with recovery planning.

A. Stress Testing Principles

Principle 1: A banking organization’s

stress testing framework should include

activities and exercises that are tailored

to and sufficiently capture the banking

organization’s exposures, activities, and

risks.

An effective stress testing framework

covers a banking organization’s full set

of material activities, exposures, and

risks, whether on or off the balance

sheet. An effective stress testing

framework should be applied at various

levels in the banking organization, such

as business line, portfolio, and risk type,

as well as on an enterprise-wide basis.

Each stress test should be tailored to the

relevant level of aggregation, capturing

critical risk drivers, internal and

external influences, and other key

considerations at the relevant level.

Stress testing should capture the

interplay among different exposures,

activities, and risks and their combined

effects. Scenarios used in a banking

organization’s stress tests should be

relevant to the direction and strategy set

by its board of directors.

Principle 2: An effective stress testing

framework employs multiple

conceptually sound stress testing

activities and approaches.

Banking organizations should use

multiple stress testing activities and

approaches and ensure that each is

conceptually sound. Stress tests usually

vary in design and complexity,

including the number of factors

employed and the degree of stress

applied. Effective stress testing relies on

high-quality input data and information

to produce credible outcomes. A

banking organization should document

the assumptions used in its stress tests

and note the degree of uncertainty that

may be incorporated into the tools used

for stress testing

vary in design and complexity,

including the number of factors

employed and the degree of stress

applied. Effective stress testing relies on

high-quality input data and information

to produce credible outcomes. A

banking organization should document

the assumptions used in its stress tests

and note the degree of uncertainty that

may be incorporated into the tools used

for stress testing. Furthermore, almost

all stress tests, including well-

developed quantitative tests supported

by high-quality data, employ a certain

amount of expert or business judgment

that should be made transparent to users

of stress test results.

Principle 3: An effective stress testing

framework is forward-looking and

flexible.

A stress testing framework should be

sufficiently dynamic and flexible to

incorporate changes in a banking

organization’s on- and off-balance-sheet

activities, portfolio composition, asset

quality, operating environment,

business strategy, and other risks that

may arise. While stress testing should

utilize available historical information,

a banking organization should look

beyond assumptions based only on

historical data and challenge

conventional assumptions. A banking

organization should carefully consider

the incremental and cumulative effects

of stress conditions. In addition to

conducting formal, routine stress tests, a

banking organization should have the

flexibility to conduct new or ad hoc

stress tests in a timely manner to

address rapidly emerging risks. A

banking organization should continue

updating and maintaining its stress

testing framework in light of new risks,

better understanding of the banking

organization’s exposures and activities,

and any changes in its operating

structure and environment.

Principle 4: Stress test results should

be clear, actionable, well supported, and

inform decision-making.

Stress testing should incorporate

measures that adequately and effectively

convey the results of its tests

testing framework in light of new risks,

better understanding of the banking

organization’s exposures and activities,

and any changes in its operating

structure and environment.

Principle 4: Stress test results should

be clear, actionable, well supported, and

inform decision-making.

Stress testing should incorporate

measures that adequately and effectively

convey the results of its tests. In

addition, all stress test results should be

accompanied by descriptive and

qualitative information (such as key

assumptions and limitations) to allow

users to interpret the exercises in

context. A banking organization should

regularly communicate stress test results

to appropriate levels within the banking

organization to foster dialogue around

stress testing, keep management and

staff apprised, and to inform stress

testing approaches, results, and

decisions in other areas of the banking

organization. In addition, management

should review stress testing activities on

a regular basis to determine, among

other things, the validity of the

assumptions, the severity of scenarios

and sensitivity tests, the robustness of

the estimates, the performance of any

underlying models, and the stability and

reasonableness of the results. Finally,

stress test results should inform a

banking organization’s analysis and

decision-making.

B. Stress Testing Approaches and

Applications

The proposed guidance describes

certain stress testing approaches and

applications—scenario analysis,

sensitivity analysis, enterprise-wide

testing, and reverse stress testing—that

a banking organization should strongly

consider using within its stress testing

framework, as appropriate. Each

banking organization should apply these

approaches and applications

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enterprise-wide

testing, and reverse stress testing—that

a banking organization should strongly

consider using within its stress testing

framework, as appropriate. Each

banking organization should apply these

approaches and applications

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Federal Register / Vol. 76, No. 115 / Wednesday, June 15, 2011 / Notices

5 The portions of the proposed guidance that

discuss stress testing for capital adequacy do not

apply to U.S. branches and agencies of foreign

banking organizations.

6 See SR letter 10–6, SR letter 10–1; OCC Bulletin

2010–13, OCC Bulletin 2010–1; FDIC FIL 13–2010

and FIL 2–2010.

commensurate with its size, complexity,

and business profile, and may not need

to incorporate all of the details

described in the proposed guidance.

Scenario Analysis

Scenario analysis refers to a type of

stress testing in which a banking

organization applies historical or

hypothetical scenarios to assess the

impact of various events and

circumstances, including extreme ones.

Scenarios usually involve some kind of

coherent, logical narrative or ‘‘story’’ as

to why certain events and circumstances

are occurring and in which combination

and order they occur, such as a severe

recession, failure of a major

counterparty, loss of major clients,

natural or man-made disaster, localized

economic downturn, or a sudden

change in interest rates brought about by

unfavorable inflation developments.

Stress scenarios should reflect a banking

organization’s unique vulnerabilities to

factors that affect its exposures,

activities, and risks

order they occur, such as a severe

recession, failure of a major

counterparty, loss of major clients,

natural or man-made disaster, localized

economic downturn, or a sudden

change in interest rates brought about by

unfavorable inflation developments.

Stress scenarios should reflect a banking

organization’s unique vulnerabilities to

factors that affect its exposures,

activities, and risks.

Sensitivity Analysis

Sensitivity analysis refers to a banking

organization’s assessment of its

exposures, activities, and risks when

certain variables, parameters, and inputs

are ‘‘stressed’’ or ‘‘shocked.’’ Generally,

sensitivity analysis differs from scenario

analysis in that it involves changing

variables, parameters, or inputs without

an explicit underlying reason or

narrative, in order to explore what

occurs under a range of inputs and at

extreme or highly adverse levels.

Sensitivity analysis can also help to

assess the combined impact on a

banking organization of several

variables, parameters, factors, or drivers.

Enterprise-Wide Stress Testing

Enterprise-wide stress testing involves

assessing the impact of certain specified

scenarios on the banking organization as

a whole, particularly on capital and

liquidity. As is the case with scenario

analysis more generally, enterprise-wide

stress testing involves robust scenario

design and effective translation of

scenarios into measures of impact.

Enterprise-wide stress tests can help a

banking organization in its efforts to

assess the impact of its full set of risks

under adverse events and

circumstances, but should be

supplemented with other stress tests

and other risk measurement tools given

inherent limitations in capturing all

risks and all adverse outcomes.

Selection of scenario variables is

important for enterprise-wide tests,

because they generally serve as the link

between the overall narrative of the

scenario and tangible impact on the

banking organization as a whole

rcumstances, but should be

supplemented with other stress tests

and other risk measurement tools given

inherent limitations in capturing all

risks and all adverse outcomes.

Selection of scenario variables is

important for enterprise-wide tests,

because they generally serve as the link

between the overall narrative of the

scenario and tangible impact on the

banking organization as a whole. For an

enterprise-wide test, assumptions across

business lines and risk areas should

remain constant for the chosen scenario,

since the objective is to see how the

banking organization as a whole

responds to a common outcome.

Reverse Stress Testing

Reverse stress testing is a tool that

allows a banking organization to assume

a known adverse outcome, such as

suffering a credit loss that breaches

regulatory capital ratios or suffering

severe liquidity constraints making it

unable to meet its obligations, and then

deduce the types of events that could

lead to such an outcome. This type of

stress testing may help a banking

organization to consider scenarios

beyond its normal business expectations

and see the impact of severe systemic

effects on the banking organization. It

also allows a banking organization to

challenge common assumptions about

its performance and expected mitigation

strategies. Reverse stress testing helps a

banking organization evaluate the

combined effect of several types of

extreme events and circumstances that

might threaten the survival of the

banking organization, even if in

isolation each of the effects might be

manageable.

C. Stress Testing for Assessing

Adequacy of Capital and Liquidity

Given the importance of capital and

liquidity to a banking organization’s

viability, stress testing should be

applied to these two areas on a regular

basis. Stress testing for capital and

liquidity adequacy should be conducted

in coordination with a banking

organization’s overall strategy and

annual and planning cycles

e.

C. Stress Testing for Assessing

Adequacy of Capital and Liquidity

Given the importance of capital and

liquidity to a banking organization’s

viability, stress testing should be

applied to these two areas on a regular

basis. Stress testing for capital and

liquidity adequacy should be conducted

in coordination with a banking

organization’s overall strategy and

annual and planning cycles. Results

should be refreshed in the event of

major strategic decisions, or other

decisions that can materially impact

capital or liquidity. Banking

organizations should conduct stress

testing for capital and liquidity

adequacy periodically.

Capital stress testing supplements a

banking organization’s regulatory

capital analysis by providing a forward-

looking assessment of capital adequacy,

usually with a forecast horizon of at

least two years, and highlighting the

potential adverse effects on capital

levels and ratios of risks not fully

captured in regulatory capital

requirements.5 Stress testing can aid

capital contingency planning by helping

management identify exposures or risks

that would need to be reduced and

actions that could be taken to bolster

capital levels or otherwise maintain

capital adequacy, as well as actions that

in times of stress might not be

possible—such as raising capital.

Using liquidity stress testing, a

banking organization can work to

identify vulnerabilities related to

liquidity adequacy in light of both firm-

specific and market-wide stress events

and circumstances.6 Effective stress

testing helps a banking organization

identify and quantify the depth, source,

and degree of potential liquidity strain

and to analyze possible impacts on its

cash flows, liquidity position,

profitability, and other aspects of its

financial condition over various time

horizons. These tests also help

determine whether the banking

organization has a sufficient liquidity

buffer to meet various types of future

liquidity demands

identify and quantify the depth, source,

and degree of potential liquidity strain

and to analyze possible impacts on its

cash flows, liquidity position,

profitability, and other aspects of its

financial condition over various time

horizons. These tests also help

determine whether the banking

organization has a sufficient liquidity

buffer to meet various types of future

liquidity demands. In this regard,

liquidity stress testing should be an

integral part of the development and

maintenance of a banking organization’s

contingency funding planning.

An effective stress testing framework

should explore the potential for capital

and liquidity problems to arise at the

same time or exacerbate one another. A

banking organization’s liquidity stress

analysis should explore situations in

which the banking organization may be

operating with a capital position that

exceeds regulatory minimums, but is

nonetheless viewed within the financial

markets or by its counterparties as being

of questionable viability. For its capital

and liquidity stress tests, a banking

organization should articulate clearly its

objectives for a post-stress outcome, for

instance to remain a viable financial

market participant that is able to meet

its existing and prospective obligations

and commitments.

D. Governance Over the Stress Testing

Framework

Similar to other aspects of its risk

management, a banking organization’s

stress testing framework will be

effective only if it is subject to strong

governance and controls to ensure that

the framework is functioning as

intended. Strong governance and

controls also help ensure that the

framework contains core elements, from

clearly defined stress testing objectives

to recommended actions

Similar to other aspects of its risk

management, a banking organization’s

stress testing framework will be

effective only if it is subject to strong

governance and controls to ensure that

the framework is functioning as

intended. Strong governance and

controls also help ensure that the

framework contains core elements, from

clearly defined stress testing objectives

to recommended actions. Importantly,

strong governance provides critical

review of elements of the stress testing

framework, especially regarding key

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assumptions, uncertainties, and

limitations. A banking organization

should ensure that the stress testing

framework is not isolated within a

banking organization’s risk management

function, but is firmly integrated into

business lines, capital and asset-liability

committees, and other decision-making

bodies.

The results of stress testing analyses

should facilitate decision-making by the

board and senior management. Stress

testing results should be used to inform

the board about alignment of the

banking organization’s risk profile with

the board’s chosen risk appetite, as well

as inform operating and strategic

decisions. Stress testing results should

be considered directly by the board and

senior management for decisions

relating to capital and liquidity

adequacy. The board and senior

management should ensure that the

stress testing framework includes a

sufficient range of stress testing

activities applied at the appropriate

levels of the banking organization (i.e.,

not just one enterprise-wide stress test).

III. Request for Comment

The agencies invite comment on all

aspects of the proposed guidance

ons

relating to capital and liquidity

adequacy. The board and senior

management should ensure that the

stress testing framework includes a

sufficient range of stress testing

activities applied at the appropriate

levels of the banking organization (i.e.,

not just one enterprise-wide stress test).

III. Request for Comment

The agencies invite comment on all

aspects of the proposed guidance. More

specifically, what, if any, additional

elements or aspects of an effective stress

testing framework should the agencies

consider including in this guidance?

What additional approaches and

applications of stress testing have been

found to be particularly useful aside

from those included in the proposed

guidance? What challenges, if any, exist

in applying this guidance generally or at

particular banking organizations and

why? Are there any terms described by

the proposed guidance that require

further clarification and how should

they be defined?

IV. Administrative Law Matters

A. Paperwork Reduction Act Analysis

In accordance with the Paperwork

Reduction Act (‘‘PRA’’) of 1995 (44

U.S.C. 3506; 5 CFR part 1320 Appendix

A.1), the agencies reviewed the

proposed guidance. The agencies may

not conduct or sponsor, and an

organization is not required to respond

to, an information collection unless the

information collection displays a

currently valid OMB control number.

The agencies have determined that

certain aspects of the proposed guidance

may constitute a collection of

information. In particular, these aspects

are the provisions that state a banking

organization should (i) have a stress

testing framework that includes clearly

defined objectives, well-designed

scenarios tailored to the banking

organization’s business and risks, well-

documented assumptions, conceptually

sound methodologies to assess potential

impact on the banking organization’s

financial condition, informative

management reports, and recommended

actions based on stress test results and

i) have a stress

testing framework that includes clearly

defined objectives, well-designed

scenarios tailored to the banking

organization’s business and risks, well-

documented assumptions, conceptually

sound methodologies to assess potential

impact on the banking organization’s

financial condition, informative

management reports, and recommended

actions based on stress test results and

(ii) have policies and procedures for a

stress testing framework. The agencies

estimate that the above-described

information collections included in the

proposed guidance would take

respondents, on average, 260 hours each

year. The frequency of information

collection is estimated to be annual.

Respondents are banking organizations

with more than $10 billion in total

consolidated assets, as defined in the

guidance:

OCC:

Respondents: 50.

Estimated annual burden: 13,000

hours.

Board:

Respondents: 120.

Estimated annual burden: 31,200

hours.

FDIC:

Respondents: 22.

Estimated annual burden: 5,720

hours.

OCC: For purposes of the PRA, this

information collection will be titled

Recordkeeping and Disclosure

Provisions Associated with Stress

Testing Guidance.

This information collection is

authorized pursuant to the National

Bank Act, (12 U.S.C. 1 et seq.; 12 U.S.C.

161) and the International Banking Act

(12 U.S.C. 3101 et seq.). The OCC

expects to review the policies and

procedures for stress testing as part of

its supervisory process. To the extent

the OCC collects information during an

examination of a banking organization,

confidential treatment may be afforded

to the records under exemption 8 of the

Freedom of Information Act (‘‘FOIA’’), 5

U.S.C. 552(b)(8). Comments should also

be sent to the Communications Division,

Office of the Comptroller of the

Currency, Mailstop 2–3, Attention:

1557–NEW, 250 E Street, SW.,

Washington, DC 20219. In addition,

comments may be sent by fax to (202)

874–5274 or by electronic mail to

regs.comments@occ.treas.gov

to the records under exemption 8 of the

Freedom of Information Act (‘‘FOIA’’), 5

U.S.C. 552(b)(8). Comments should also

be sent to the Communications Division,

Office of the Comptroller of the

Currency, Mailstop 2–3, Attention:

1557–NEW, 250 E Street, SW.,

Washington, DC 20219. In addition,

comments may be sent by fax to (202)

874–5274 or by electronic mail to

regs.comments@occ.treas.gov. You may

personally inspect and photocopy

comments at the OCC, 250 E Street,

SW., Washington, DC 20219. For

security reasons, the OCC requires that

visitors make an appointment to inspect

comments. You may do so by calling

(202) 874–4700. Upon arrival, visitors

will be required to present valid

government-issued photo identification

and to submit to security screening in

order to inspect and photocopy

comments. Additionally, please send a

copy of your comments by mail to: OCC

Desk Officer, 1557–NEW, U.S. Office of

Management and Budget, 725 17th

Street, NW., #10235, Washington, DC

20503, or by fax to (202) 395–6974. For

further information or to request a copy

of the OCC’s collection, please contact

Mary H. Gottlieb, OCC Clearance

Officer, (202) 874–5090, Legislative and

Regulatory Activities Division, OCC,

250 E Street, SW., Washington, DC

20219.

Board: For purposes of the PRA, this

information collection will be titled

Recordkeeping and Disclosure

Provisions Associated with Stress

Testing Guidance. The agency form

number for the collection is FR 4202.

The agency control number for this new

collection will be assigned by OMB.

This information collection is

authorized pursuant to sections 11(a),

11(i), 25, and 25A of the Federal Reserve

Act (12 U.S.C. 248(a), 248(i), 602, and

611), section 5 of the Bank Holding

Company Act (12 U.S.C. 1844), and

section 7(c) of the International Banking

Act (12 U.S.C. 3105(c)). The Board

expects to review the policies and

procedures for stress testing as part of

the Board’s supervisory process

collection is

authorized pursuant to sections 11(a),

11(i), 25, and 25A of the Federal Reserve

Act (12 U.S.C. 248(a), 248(i), 602, and

611), section 5 of the Bank Holding

Company Act (12 U.S.C. 1844), and

section 7(c) of the International Banking

Act (12 U.S.C. 3105(c)). The Board

expects to review the policies and

procedures for stress testing as part of

the Board’s supervisory process. To the

extent the Board collects information

during an examination of a banking

organization, confidential treatment

may be afforded to the records under

exemption 8 of the Freedom of

Information Act (‘‘FOIA’’), 5 U.S.C.

552(b)(8).

Comments on the collection of

information should be sent to Cynthia

Ayouch, Acting Federal Reserve Board

Clearance Officer, Division of Research

and Statistics, Mail Stop 95–A, Board of

Governors of the Federal Reserve

System, Washington, DC 20551, with

copies of such comments sent to the

Office of Management and Budget,

Paperwork Reduction Project (Docket

No. OP–1374), Washington, DC 20503.

Comments are invited on:

(1) Whether the proposed collection

of information is necessary for the

proper performance of the Federal

Reserve’s functions, including whether

the information has practical utility;

(2) The accuracy of the Federal

Reserve’s estimate of the burden of the

proposed information collection,

including the cost of compliance;

(3) Ways to enhance the quality,

utility, and clarity of the information to

be collected; and

lection

of information is necessary for the

proper performance of the Federal

Reserve’s functions, including whether

the information has practical utility;

(2) The accuracy of the Federal

Reserve’s estimate of the burden of the

proposed information collection,

including the cost of compliance;

(3) Ways to enhance the quality,

utility, and clarity of the information to

be collected; and

(4) Ways to minimize the burden of

information collection on respondents,

including through the use of automated

collection techniques or other forms of

information technology.

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1 See, for example, Supervision and Regulation

(SR) letter 10–6 or OCC Bulletin 2010–13 or FDIC

FIL–13–2010, ‘‘Interagency Policy Statement on

Funding and Liquidity Risk Management’’; SR 10–

1 or OCC Bulletin 2010–1 or FDIC FIL–2–2010,

‘‘Interagency Advisory on Interest Rate Risk’’; SR

letter 09–04, ‘‘Applying Supervisory Guidance and

Regulations on the Payment of Dividends, Stock

Redemptions, and Stock Repurchases at Bank

Holding Companies’’; SR letter 07–1, ‘‘Interagency

Guidance on Concentrations in Commercial Real

Estate’’ or OCC Bulletin 2006–46 or FDIC FIL–104–

2006, ‘‘Interagency Guidance on CRE Concentration

Risk Management’’; SR letter 99–18, ‘‘Assessing

Capital Adequacy in Relation to Risk at Large

Banking Organizations and Others with Complex

Risk Profiles’’; OCC Bulletin 2008–20 or FDIC FIL–

71–2008 ‘‘Supervisory Guidance: Supervisory

Review Process of Capital Adequacy (Pillar 2)

Related to the Implementation of the Basel II

Advanced Capital Framework’’; the Supervisory

Capital Assessment Program (see http://

www.federalreserve.gov/newsevents/press/bcreg/

bcreg20080715a1.pdf); and Comprehensive Capital

Analysis and Review: Objectives and Overview (see

www.federalreserve.g

IL–

71–2008 ‘‘Supervisory Guidance: Supervisory

Review Process of Capital Adequacy (Pillar 2)

Related to the Implementation of the Basel II

Advanced Capital Framework’’; the Supervisory

Capital Assessment Program (see http://

www.federalreserve.gov/newsevents/press/bcreg/

bcreg20080715a1.pdf); and Comprehensive Capital

Analysis and Review: Objectives and Overview (see

www.federalreserve.gov/newsevents/press/bcreg/

20110318a.htm).

2 Moreover, the Dodd-Frank Wall Street Reform

and Consumer Protection Act (Pub. L. 111–203, 124

Stat. 1376) requires financial organizations with

more than $10 billion in total consolidated assets

to conduct a stress test at least annually. See

generally 12 U.S.C. 5365(i)(2).

FDIC: You may submit comments by

any of the following methods:

• Agency Web site: http://

www.FDIC.gov/regulations/laws/

federal/propose.html. Follow the

instructions for submitting comments.

• Federal eRulemaking Portal: http://

www.regulations.gov. Follow the

instructions for submitting comments.

• E-mail: comments@FDIC.gov.

Include ‘‘Stress Testing Guidance’’ in

the subject line of the message.

Comments received will be posted

without change to http://www.FDIC.gov/

regulations/laws/federal/propose.html,

including any personal information

provided.

• Mail: Robert E. Feldman, Executive

Secretary, Attention: Comments/Legal

ESS, Federal Deposit Insurance

Corporation, 550 17th Street, NW.,

Washington, DC 20429.

• Hand Delivery/Courier: Guard

station at the rear of the 550 17th Street

Building (located on F Street), on

business days between 7 a.m. and 5 p.m.

(EDT). Comments are invited on:

(1) Whether the proposed collection

of information is necessary for the

proper performance of the Federal

Reserve’s functions, including whether

the information has practical utility;

(2) The accuracy of the agencies’

estimate of the burden of the proposed

information collection, including the

cost of compliance;

n

business days between 7 a.m. and 5 p.m.

(EDT). Comments are invited on:

(1) Whether the proposed collection

of information is necessary for the

proper performance of the Federal

Reserve’s functions, including whether

the information has practical utility;

(2) The accuracy of the agencies’

estimate of the burden of the proposed

information collection, including the

cost of compliance;

(3) Ways to enhance the quality,

utility, and clarity of the information to

be collected; and

(4) Ways to minimize the burden of

information collection on respondents,

including through the use of automated

collection techniques or other forms of

information technology.

B. Regulatory Flexibility Act Analysis

Board:

While the guidance is not being

adopted as a rule, the Board has

considered the potential impact of the

proposed guidance on small banking

organizations in accordance with the

Regulatory Flexibility Act (5 U.S.C.

603(b)). For the reason discussed in the

Supplementary Information above, the

Board is issuing the proposed guidance

to emphasize the importance of stress

testing as an ongoing risk management

practice to support a banking

organization’s forward-looking

assessment of risks in order to better

equip such organization to address a

range of adverse outcomes. The

guidance provides an overview of how

a banking organization should structure

its stress testing activities to ensure they

fit into the organization’s overall risk

management program. The guidance

outlines broad principles for a

satisfactory stress testing framework,

and describes the manner in which a

banking organization should employ

stress testing as an integral component

of risk management. Based on its

analysis and for the reasons stated

below, the Board believes that the

proposed guidance will not have a

significant economic impact on a

substantial number of small entities

outlines broad principles for a

satisfactory stress testing framework,

and describes the manner in which a

banking organization should employ

stress testing as an integral component

of risk management. Based on its

analysis and for the reasons stated

below, the Board believes that the

proposed guidance will not have a

significant economic impact on a

substantial number of small entities.

Nevertheless, the Board is publishing an

initial regulatory flexibility analysis,

and seeking comment on whether the

proposed guidance would impose

undue burdens on, or have unintended

consequences for, small organizations.

Under regulations issued by the Small

Business Administration (‘‘SBA’’), a

small banking organization is defined as

a banking organization with total assets

of $175 million or less. See 13 CFR

121.201. The guidance being proposed

by the Board is intended for banking

organizations supervised by the

agencies with more than $10 billion in

total assets, including state member

banks, bank holding companies, and

U.S. branches and agencies of foreign

banking organizations. Banking

organizations that are subject to the

proposed guidance therefore

substantially exceed the $175 million

total asset threshold at which a banking

organization is considered a small

banking organization under SBA

regulations.

In light of the foregoing, the Board

does not believe that the proposed

guidance, if adopted in final form,

would have a significant economic

impact on a substantial number of small

entities. As noted above, the Board

specifically seeks comment on whether

the proposed guidance would impose

undue burdens on, or have unintended

consequences for, small organizations

and whether there are ways such

potential burdens or consequences

could be addressed in a manner

consistent with the guidance.

V

,

would have a significant economic

impact on a substantial number of small

entities. As noted above, the Board

specifically seeks comment on whether

the proposed guidance would impose

undue burdens on, or have unintended

consequences for, small organizations

and whether there are ways such

potential burdens or consequences

could be addressed in a manner

consistent with the guidance.

V. Proposed Guidance

The text of the proposed guidance is

as follows:

Office of the Comptroller of the

Currency

Federal Reserve System

Federal Deposit Insurance Corporation

Guidance on Stress Testing for Banking

Organizations With Total Consolidated

Assets of More Than $10 Billion

I. Introduction

All banking organizations should

have the capacity to understand fully

their risks and the potential impact of

stressful events and circumstances on

their financial condition. The U.S.

Federal banking agencies have

previously highlighted the use of stress

testing as a means to better understand

the range of a banking organization’s

potential risk exposures.1 The 2007–

2009 financial crisis further

underscored the need for banking

organizations to incorporate stress

testing into their risk management

practices, demonstrating that banking

organizations unprepared for stressful

events and circumstances can suffer

acute threats to their financial condition

and viability.2 The Federal Reserve, the

Office of the Comptroller of the

Currency, and the Federal Deposit

Insurance Corporation (collectively, the

‘‘agencies’’) are issuing this guidance to

emphasize the importance of stress

testing as an ongoing risk management

practice that supports banking

organizations’ forward-looking

assessment of risks and better equips

them to address a range of adverse

outcomes. This proposed joint guidance

is applicable to all institutions

supervised by the agencies with more

than $10 billion in total consolidated

assets

issuing this guidance to

emphasize the importance of stress

testing as an ongoing risk management

practice that supports banking

organizations’ forward-looking

assessment of risks and better equips

them to address a range of adverse

outcomes. This proposed joint guidance

is applicable to all institutions

supervised by the agencies with more

than $10 billion in total consolidated

assets. Specifically, with respect to the

OCC, these banking organizations would

include national banking associations

and Federal branches and agencies; with

respect to the Board, these banking

organizations would include state

member banks, bank holding

companies, and all other institutions for

which the Federal Reserve is the

primary Federal supervisor; with

respect to the FDIC, these banking

organizations would include state

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3 For purposes of this guidance, the term

‘‘concentrations’’ refers to groups of exposures and/

or activities that have the potential to produce

losses large enough to bring about a material change

in a banking organization’s risk profile or financial

condition.

nonmember insured banks or insured

branches of foreign banks.

Building upon previously issued

supervisory guidance that discusses the

uses and merits of stress testing in

specific areas of risk management, this

guidance provides an overview of how

a banking organization should structure

its stress testing activities and ensure

they fit into overall risk management

r financial

condition.

nonmember insured banks or insured

branches of foreign banks.

Building upon previously issued

supervisory guidance that discusses the

uses and merits of stress testing in

specific areas of risk management, this

guidance provides an overview of how

a banking organization should structure

its stress testing activities and ensure

they fit into overall risk management.

The guidance outlines broad principles

for a satisfactory stress testing

framework and describes the manner in

which stress testing should be employed

as an integral component of risk

management that is applicable at

various levels of aggregation within a

banking organization, as well as for

contributing to capital and liquidity

planning. While the guidance is not

intended to provide detailed

instructions for conducting stress testing

for any particular risk or business area,

the document describes several types of

stress testing activities and how they

may be most appropriately used by

banking organizations.

II. Overview of Stress Testing

Framework

For purposes of this guidance, stress

testing refers to exercises used to

conduct a forward-looking assessment

of the potential impact of various

adverse events and circumstances on a

banking organization. Stress testing

occurs at various levels of aggregation,

including on an enterprise-wide basis.

As outlined in section IV, there are

several approaches and applications for

stress testing and a banking organization

should consider the use of each in its

stress testing framework.

An effective stress testing framework

provides a comprehensive, integrated,

and forward-looking set of activities for

a banking organization to employ along

with other practices in order to assist in

the identification and measurement of

its material risks and vulnerabilities,

including those that may only manifest

themselves during stressful economic or

financial environments, or arise from

firm-specific adverse events

work

provides a comprehensive, integrated,

and forward-looking set of activities for

a banking organization to employ along

with other practices in order to assist in

the identification and measurement of

its material risks and vulnerabilities,

including those that may only manifest

themselves during stressful economic or

financial environments, or arise from

firm-specific adverse events. Such a

framework should supplement other

quantitative risk management practices,

such as those that rely primarily on

statistical estimates of risk or loss

estimates based on historical data, as

well as qualitative practices. In this

manner, stress testing can assist in

highlighting unidentified or under-

assessed risk concentrations and

interrelationships and their potential

impact on the banking organization

during times of stress.3

A banking organization should

develop and implement its stress testing

framework in a manner commensurate

with its size, complexity, business

activities, and overall risk profile. Its

stress testing framework should include

clearly defined objectives, well-

designed scenarios tailored to the

banking organization’s business and

risks, well-documented assumptions,

sound methodologies to assess potential

impact on the banking organization’s

financial condition, informative

management reports, ongoing and

effective review of stress testing

processes, and recommended actions

based on stress test results. Stress

testing should incorporate the use of

high-quality data to ensure that the

outputs are sufficiently credible to

support decision-making. Importantly, a

banking organization should have a

sound governance and control

infrastructure with objective, critical

review to ensure the stress testing

framework is functioning as intended

and recommended actions

based on stress test results. Stress

testing should incorporate the use of

high-quality data to ensure that the

outputs are sufficiently credible to

support decision-making. Importantly, a

banking organization should have a

sound governance and control

infrastructure with objective, critical

review to ensure the stress testing

framework is functioning as intended.

A stress testing framework should

allow a banking organization to conduct

consistent, repeatable exercises that

focus on its material risks, exposures,

activities, and strategies, and also

conduct ad hoc scenarios as needed.

The framework should consider the

impact of both firm-specific and

systemic stress events and

circumstances that are based on

historical experience as well as on

hypothetical occurrences that could

have an adverse impact on a banking

organization’s operations and financial

condition. Banking organizations

subject to this guidance should formally

review and assess the effectiveness of

their stress testing frameworks at least

once per year.

III. General Stress Testing Principles

A banking organization should

develop and implement an effective

stress testing framework as part of its

broader risk management and

governance processes. The framework

should include several activities and

exercises, and not just rely on any single

test or type of test, since every stress test

has limitations and relies on certain

assumptions

ear.

III. General Stress Testing Principles

A banking organization should

develop and implement an effective

stress testing framework as part of its

broader risk management and

governance processes. The framework

should include several activities and

exercises, and not just rely on any single

test or type of test, since every stress test

has limitations and relies on certain

assumptions.

The uses of a banking organization’s

stress testing framework should include,

but are not limited to, augmenting risk

identification and measurement;

estimating business line revenues and

losses and informing business line

strategies; identifying vulnerabilities

and assessing their potential impact;

assessing capital adequacy and

enhancing capital planning; assessing

liquidity adequacy and informing

contingency funding plans; contributing

to strategic planning; enabling senior

management to better integrate strategy,

risk management, and capital and

liquidity planning decisions; and

assisting with recovery planning. This

section describes general principles that

a banking organization should apply in

implementing such a framework.

Principle 1: A banking organization’s

stress testing framework should include

activities and exercises that are tailored

to and sufficiently capture the banking

organization’s exposures, activities, and

risks.

An effective stress testing framework

covers a banking organization’s full set

of material activities, exposures, and

risks, whether on or off the balance

sheet. The framework should also

address non-contractual sources of risks,

such as those related to a banking

organization’s reputation. Appropriate

coverage is important as stress test

results could give a false sense of

comfort if certain portfolios, exposures,

or business line activities are not

captured. Stress testing exercises should

be part of a banking organization’s

regular risk identification and

measurement activities

on-contractual sources of risks,

such as those related to a banking

organization’s reputation. Appropriate

coverage is important as stress test

results could give a false sense of

comfort if certain portfolios, exposures,

or business line activities are not

captured. Stress testing exercises should

be part of a banking organization’s

regular risk identification and

measurement activities. For example, in

assessing credit risk a banking

organization should evaluate the

potential impact of adverse outcomes,

such as an economic downturn or

declining asset values, on the condition

of its borrowers and counterparties, and

on the value of any supporting

collateral. As another example, in

assessing interest-rate risk, banking

organizations should analyze the effects

of significant interest rate shocks or

other yield-curve movements.

An effective stress testing framework

should be applied at various levels in

the banking organization, such as

business line, portfolio, and risk type, as

well as on an enterprise-wide basis. In

many cases, stress testing may be more

effective at business line and portfolio

levels, as a higher level of aggregation

may cloud or underestimate the

potential impact of adverse outcomes on

a banking organization’s financial

condition. In some cases, stress testing

can also be applied to individual

exposures or instruments. Each stress

test should be tailored to the relevant

level of aggregation, capturing critical

risk drivers, internal and external

influences, and other key considerations

at the relevant level.

Stress testing should capture the

interplay among different exposures,

activities, and risks and their combined

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ation, capturing critical

risk drivers, internal and external

influences, and other key considerations

at the relevant level.

Stress testing should capture the

interplay among different exposures,

activities, and risks and their combined

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4 For purposes of this guidance, risk appetite is

defined as the level and type of risk an organization

is able and willing to assume in its exposures and

business activities, given its business objectives and

obligations to stakeholders. See Senior Supervisors

Group report, ‘‘Observations on Developments in

Risk Appetite Frameworks and IT Infrastructure,’’

December 2010 (see http://www.newyorkfed.org/

newsevents/news/banking/2010/an101223.pdf).

effects. While stress testing several types

of risks or business lines simultaneously

may prove operationally challenging, a

banking organization should aim to

identify common risk drivers across risk

types and business lines that can

adversely affect its financial condition.

Accordingly, stress tests should provide

a banking organization with the ability

to identify potential concentrations—

including those that may not be readily

observable during benign periods and

whose sensitivity to a common set of

factors is apparent only during times of

stress—and to assess the impact of

identified concentrations of exposures,

activities, and risks within and across

portfolios and business lines.

Stress testing should be tailored to the

banking organization’s idiosyncrasies

and specific business mix and include

all major business lines and significant

individual counterparties

to a common set of

factors is apparent only during times of

stress—and to assess the impact of

identified concentrations of exposures,

activities, and risks within and across

portfolios and business lines.

Stress testing should be tailored to the

banking organization’s idiosyncrasies

and specific business mix and include

all major business lines and significant

individual counterparties. For example,

a banking organization that is

geographically concentrated may

determine that a certain segment of its

business may be more adversely affected

by shocks to economic activity at the

state or local level than by a severe

national recession. On the other hand, if

the banking organization has significant

global operations, it should consider

scenarios that have an international

component and stress conditions that

could affect the different aspects of its

operations in different ways, as well as

conditions that could adversely affect

all of its operations at the same time.

A banking organization should use its

stress testing framework to determine

whether exposures, activities, and risks

are aligned with the banking

organization’s risk appetite.4 A banking

organization can use stress testing to

help inform decisions about its strategic

direction and/or risk appetite by better

understanding the risks of its exposures

or of engaging in certain business

practices. For example, if a banking

organization pursues a business strategy

for a new or modified product, and the

banking organization does not have

long-standing experience with that

product or lacks extensive data, the

banking organization can use stress

testing to identify the product’s

potential downsides and unanticipated

risks. Scenarios used in a banking

organization’s stress tests should be

relevant to the direction and strategy set

by its board of directors, as well as

sufficiently severe to be credible to

internal and external stakeholders

perience with that

product or lacks extensive data, the

banking organization can use stress

testing to identify the product’s

potential downsides and unanticipated

risks. Scenarios used in a banking

organization’s stress tests should be

relevant to the direction and strategy set

by its board of directors, as well as

sufficiently severe to be credible to

internal and external stakeholders.

Principle 2: An effective stress testing

framework employs multiple

conceptually sound stress testing

activities and approaches.

All estimates of risk, including stress

tests, have an element of uncertainty

due to assumptions, limitations, and

other factors associated with using past

performance measures and forward-

looking estimates. Banking

organizations should, therefore, use

multiple stress testing activities and

approaches (consistent with section IV),

and ensure that each is conceptually

sound. Stress tests usually vary in

design and complexity, including the

number of factors employed and the

degree of stress applied. A banking

organization should ensure that the

complexity of any given test does not

undermine its integrity, usefulness, or

clarity. In many cases, relatively simple

tests can be very useful and informative.

Additionally, effective stress testing

relies on high-quality input data and

information to produce credible

outcomes. A banking organization

should ensure that it has readily

available data and other information for

the types of stress tests it uses,

including key variables that drive

performance. In addition, a banking

organization should have appropriate

management information systems (MIS)

and data processes that enable it to

collect, sort, aggregate, and update data

and other information efficiently and

reliably within business lines and across

the banking organization for use in

stress testing

the types of stress tests it uses,

including key variables that drive

performance. In addition, a banking

organization should have appropriate

management information systems (MIS)

and data processes that enable it to

collect, sort, aggregate, and update data

and other information efficiently and

reliably within business lines and across

the banking organization for use in

stress testing. If certain data and

information are not current or not

available, a banking organization should

analyze the stress test outputs with an

understanding of those data limitations.

A banking organization should also

document the assumptions used in its

stress tests and note the degree of

uncertainty that may be incorporated

into the tools used for stress testing. In

some cases, it may be appropriate to

present and analyze test results not just

in terms of point estimates, but also

including the potential margin of error

or statistical uncertainty around the

estimates. Furthermore, almost all stress

tests, including well-developed

quantitative tests supported by high-

quality data, employ a certain amount of

expert or business judgment; the role

and impact of such judgment should be

clearly documented. In some cases,

when credible data are lacking and more

quantitative tests are operationally

challenging or in the early stages of

development, a banking organization

may choose to employ more

qualitatively based tests, provided that

the tests are properly documented and

their assumptions are transparent.

Regardless of the type of stress tests

used, a banking organization should

understand and clearly document all

assumptions, uncertainties, and

limitations, and provide that

information to users of the stress testing

results.

Principle 3: An effective stress testing

framework is forward-looking and

flexible

ed that

the tests are properly documented and

their assumptions are transparent.

Regardless of the type of stress tests

used, a banking organization should

understand and clearly document all

assumptions, uncertainties, and

limitations, and provide that

information to users of the stress testing

results.

Principle 3: An effective stress testing

framework is forward-looking and

flexible.

A stress testing framework should be

sufficiently dynamic and flexible to

incorporate changes in a banking

organization’s on- and off-balance-sheet

activities, portfolio composition, asset

quality, operating environment,

business strategy, and other risks that

may arise over time from firm-specific

events, macroeconomic and financial

market developments, or some

combination of these events. A banking

organization should also ensure that its

MIS are capable of incorporating

relatively rapid changes in exposures,

activities, and risks.

While stress testing should utilize

available historical information, a

banking organization should look

beyond assumptions based only on

historical data and challenge

conventional assumptions. A banking

organization should ensure that it is not

constrained by past experience and that

it considers a multiple scenarios, even

scenarios that have not occurred in the

recent past or during the banking

organization’s history. For example, a

banking organization should not assume

that if it has suffered no or minimal

losses in a certain business line or

product that such a pattern will

continue. Structural changes in

customer, product, and financial

markets can present unprecedented

situations for a banking organization. A

banking organization with any type of

significant concentration can be

particularly vulnerable to rapid changes

in economic and financial conditions

and should try to identify and better

understand the impact of those

vulnerabilities in advance

will

continue. Structural changes in

customer, product, and financial

markets can present unprecedented

situations for a banking organization. A

banking organization with any type of

significant concentration can be

particularly vulnerable to rapid changes

in economic and financial conditions

and should try to identify and better

understand the impact of those

vulnerabilities in advance. For example,

the risks related to residential mortgages

were underestimated for a number of

years by a large number of banking

organizations, and those risks

eventually affected the banking

organizations in a variety of ways.

Effective stress testing can help a

banking organization identify any such

concentrations and help understand the

potential impact of several key aspects

of the business being exposed to

common drivers.

Stress testing should be conducted

over various relevant time horizons to

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adequately capture both conditions that

may materialize in the near term and

adverse situations that take longer to

develop. For example, when a banking

organization stress tests a portfolio for

market and credit risks simultaneously,

it should consider that certain credit

risk losses may take longer to

materialize than market risk losses, and

also that the severity and speed of mark-

to-market losses may create significant

vulnerabilities for the firm, even if a

more fundamental analysis of how

realized losses may play out over time

seems to show less threatening results.

A banking organization should carefully

consider the incremental and

cumulative effects of stress conditions,

particularly with respect to potential

interactions among exposures, activities,

and risks and possible second-order or

‘‘knock-on’’ effects

ies for the firm, even if a

more fundamental analysis of how

realized losses may play out over time

seems to show less threatening results.

A banking organization should carefully

consider the incremental and

cumulative effects of stress conditions,

particularly with respect to potential

interactions among exposures, activities,

and risks and possible second-order or

‘‘knock-on’’ effects.

In addition to conducting formal,

routine stress tests, a banking

organization should have the flexibility

to conduct new or ad hoc stress tests in

a timely manner to address rapidly

emerging risks. These less routine tests

usually can be conducted in a short

amount of time and may be simpler and

less extensive than a banking

organization’s more formal, regular

tests. However, for its ad hoc tests, a

banking organization should still have

the capacity to bring together

approximated information on risks,

exposures, and activities and assess

their impact.

More broadly, a banking organization

should continue updating and

maintaining its stress testing framework

in light of new risks, better

understanding of the banking

organization’s exposures and activities,

new stress testing techniques, and any

changes in its operating structure and

environment. A banking organization’s

stress testing development should be

iterative, with ongoing adjustments and

refinements to better calibrate the tests

to provide current and relevant

information. Banking organizations

should document the ongoing

development of their stress testing

practices.

Principle 4: Stress test results should

be clear, actionable, well supported, and

inform decision-making.

Stress testing should incorporate

measures that adequately and effectively

convey results of the impact of adverse

outcomes

ibrate the tests

to provide current and relevant

information. Banking organizations

should document the ongoing

development of their stress testing

practices.

Principle 4: Stress test results should

be clear, actionable, well supported, and

inform decision-making.

Stress testing should incorporate

measures that adequately and effectively

convey results of the impact of adverse

outcomes. Such measures may include,

for example, changes to asset values,

accounting and economic profit and

loss, revenue streams, liquidity levels,

cash flows, regulatory capital, risk-

weighted assets, loan loss provisions,

internal capital estimates, levels of

problem assets, breaches in covenants or

key trigger levels, or other relevant

measures. Stress test measures should

be tailored to the type of test and the

particular level at which the test is

applied (for example, at the business

line or risk level). Some stress tests may

require using a range of measures to

evaluate the full impact of certain

events, such as a severe systemic event.

In addition, all stress test results should

be accompanied by descriptive and

qualitative information (such as key

assumptions and limitations) to allow

users to interpret the exercises in

context. The analysis and the process

should be well documented so that

stress testing processes can be replicated

if need be.

A banking organization should

regularly communicate stress test results

to appropriate levels within the banking

organization to foster dialogue around

stress testing, to keep the board of

directors, management, and staff

apprised, and to inform stress testing

approaches, results, and decisions in

other areas of the banking organization.

A banking organization should maintain

an internal summary of test results to

document at a high level the range of its

stress testing activities and outcomes, as

well as proposed follow-up actions

ound

stress testing, to keep the board of

directors, management, and staff

apprised, and to inform stress testing

approaches, results, and decisions in

other areas of the banking organization.

A banking organization should maintain

an internal summary of test results to

document at a high level the range of its

stress testing activities and outcomes, as

well as proposed follow-up actions. In

addition, management should review

stress testing activities on a regular basis

to determine, among other things, the

validity of the assumptions, the severity

of tests, the robustness of the estimates,

the performance of any underlying

models, and the stability and

reasonableness of the results.

Stress test results should inform

analysis and decision-making related to

business strategies, limits, risk profile,

and other aspects of risk management,

consistent with the banking

organization’s established risk appetite.

A banking organization should review

the results of its various stress tests with

the strengths and limitations of each test

in mind (consistent with Principle 2),

determine which results should be

given greater or lesser weight, analyze

the combined impact of its tests, and

then evaluate potential courses of action

based on that analysis. A banking

organization may decide to maintain its

current course based on test results;

indeed, the results of highly severe

stress tests need not always indicate that

immediate action has to be taken.

Wherever possible, tools such as

benchmarking or other comparative

analysis should be used to evaluate the

stress testing results relative to other

tools and measures, both internal and

external to the banking organization, to

provide proper context and a check on

results.

IV. Stress Testing Approaches and

Applications

This section discusses some general

types of stress testing approaches and

applications. For any type of stress test,

banking organizations should indicate

the specific purpose and the focus of the

test

ive to other

tools and measures, both internal and

external to the banking organization, to

provide proper context and a check on

results.

IV. Stress Testing Approaches and

Applications

This section discusses some general

types of stress testing approaches and

applications. For any type of stress test,

banking organizations should indicate

the specific purpose and the focus of the

test. Defining the scope of a given stress

test is also important, whether it applies

at the portfolio, business line, risk type,

or enterprise-wide level, or even just for

an individual exposure. Based on the

purpose and scope of the test, different

stress testing techniques are most

useful. Thus, a banking organization

should employ several stress testing

approaches and applications, as needed.

Among them should be approaches or

applications such as scenario analysis,

sensitivity analysis, enterprise-wide

stress testing, and reverse stress testing.

Consistent with Principle 1, banking

organizations should apply these

commensurate with their size,

complexity, and business profile, and

may not need to incorporate all of the

details described below. Consistent with

Principle 3, banking organizations

should also recognize that stress testing

approaches will evolve over time and

they should update their practices as

needed.

Scenario Analysis

Scenario analysis refers to a type of

stress testing in which a banking

organization applies historical or

hypothetical scenarios to assess the

impact of various events and

circumstances, including extreme ones.

Scenarios usually involve some kind of

coherent, logical narrative or ‘‘story’’ as

to why certain events and circumstances

are occurring and in which combination

and order, such as a severe recession,

failure of a major counterparty, loss of

major clients, natural or man-made

disaster, localized economic downturn,

or a sudden change in interest rates

brought about by unfavorable inflation

developments

lly involve some kind of

coherent, logical narrative or ‘‘story’’ as

to why certain events and circumstances

are occurring and in which combination

and order, such as a severe recession,

failure of a major counterparty, loss of

major clients, natural or man-made

disaster, localized economic downturn,

or a sudden change in interest rates

brought about by unfavorable inflation

developments. Scenario analysis can be

applied at various levels of the banking

organization, such as within individual

business lines to help identify factors

that could harm those business lines

most.

Stress scenarios should reflect a

banking organization’s unique

vulnerabilities to factors that affect its

exposures, activities, and risks. For

example, if a banking organization is

concentrated in a particular line of

business, such as commercial real estate

or residential mortgage lending, it

would be appropriate to explore the

impact of a downturn in those particular

market segments. Similarly, a banking

organization with lending

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concentrations to oil and gas companies

should include scenarios related to the

energy sector. Other relevant factors to

be considered in scenario analysis relate

to reputational and legal risks to a

banking organization, such as an

existing major lawsuit, potential

litigation, or a situation when a banking

organization feels compelled to provide

support to an affiliate or provide other

types of non-contractual support to

avoid reputational damage. Scenarios

should be internally consistent and

portray realistic outcomes based on

underlying relationships among

variables, and should include only those

mitigating developments that are

consistent with the scenario

or a situation when a banking

organization feels compelled to provide

support to an affiliate or provide other

types of non-contractual support to

avoid reputational damage. Scenarios

should be internally consistent and

portray realistic outcomes based on

underlying relationships among

variables, and should include only those

mitigating developments that are

consistent with the scenario.

Additionally, a banking organization

should consider the best manner to try

to capture combinations of stressful

events and circumstances, including

second-order and ‘‘knock-on’’ effects.

Ultimately, a banking organization

should select and design multiple

scenarios that are relevant to its profile

and make intuitive sense, use enough

scenarios to explore the range of

potential outcomes, and ensure that the

scenarios continue to be timely.

A banking organization may apply

scenario analysis within the context of

its existing risk measurement tools (e.g.,

the impact of a severe decline in market

prices on a banking organization’s

value-at-risk (VaR) measure) or use it as

an alternative, supplemental measure.

For instance, a banking organization

may use scenario analysis to measure

the impact of a severe financial market

disturbance and compare those results

to what is produced by its VaR or other

measures. This type of scenario analysis

should account for known shortcomings

of other risk measurement frameworks.

For example, market risk VaR models

generally assume liquid markets with

known prices. Scenario analysis could

shed light on the effects of a breakdown

in liquidity and valuation difficulties.

One of the key challenges with

scenario analysis is to translate a

scenario into balance sheet impact,

changes in risk measures, potential

losses, or other measures of adverse

financial impact, which would vary

depending on the test design and the

type of scenario used

known prices. Scenario analysis could

shed light on the effects of a breakdown

in liquidity and valuation difficulties.

One of the key challenges with

scenario analysis is to translate a

scenario into balance sheet impact,

changes in risk measures, potential

losses, or other measures of adverse

financial impact, which would vary

depending on the test design and the

type of scenario used. For some aspects

of scenario analysis, banking

organizations may use econometric or

similar types of analysis to estimate a

relationship between some underlying

factors or drivers and risk estimates or

loss projections based on a given data

set, and then extrapolate to see the

impact of more severe inputs. Care

should be taken not to make

assumptions that relationships from

benign or mildly adverse times will

hold during more severe times or that

estimating such relationships is

relatively straightforward. For example,

linear relationships between risk drivers

and losses may become nonlinear

during times of stress.

Sensitivity Analysis

Sensitivity analysis refers to a banking

organization’s assessment of its

exposures, activities, and risks when

certain variables, parameters, and inputs

are ‘‘stressed’’ or ‘‘shocked.’’ A key goal

of sensitivity analysis is to test the

impact of assumptions on outcomes.

Generally, sensitivity analysis differs

from scenario analysis in that it involves

changing variables, parameters, or

inputs without an explicit underlying

reason or narrative, in order to explore

what occurs under a range of inputs and

at extreme or highly adverse levels. In

this type of analysis a banking

organization may realize, for example,

that a given relationship is much more

difficult to estimate at extreme levels.

A banking organization may apply

sensitivity analysis at various levels of

aggregation to estimate the impact from

a change in one or more key variables

xplore

what occurs under a range of inputs and

at extreme or highly adverse levels. In

this type of analysis a banking

organization may realize, for example,

that a given relationship is much more

difficult to estimate at extreme levels.

A banking organization may apply

sensitivity analysis at various levels of

aggregation to estimate the impact from

a change in one or more key variables.

The results may help a banking

organization better understand the range

of outcomes from some of its models,

such as developing a distribution of

output based on a variety of extreme

inputs. For example, a banking

organization may choose to calculate a

range of changes to a structured

security’s overall value using a range of

different assumptions about the

performance and linkage of underlying

cash flows. Sensitivity analysis should

be conducted periodically due to

potential changes in a banking

organization’s exposures, activities,

operating environment, or the

relationship of variables to one another.

Sensitivity analysis can also help to

assess a combined impact on a banking

organization of several variables,

parameters, factors, or drivers. For

example, a banking organization could

better understand the impact on its

credit losses from a combined increase

in default rates and a decrease in

collateral values. A banking

organization could also explore the

impact of highly adverse capitalization

rates, declines in net operating income,

and reductions in collateral when

evaluating its risks from commercial

real estate exposures. Sensitivity

analysis can be especially useful

because it is not necessarily

accompanied by a particular narrative or

scenario; that is, sensitivity analysis can

provide banking organizations more

flexibility to explore the impact of

potential stresses that they may not be

able to capture in designed scenarios

in collateral when

evaluating its risks from commercial

real estate exposures. Sensitivity

analysis can be especially useful

because it is not necessarily

accompanied by a particular narrative or

scenario; that is, sensitivity analysis can

provide banking organizations more

flexibility to explore the impact of

potential stresses that they may not be

able to capture in designed scenarios.

Furthermore, banking organizations may

decide to conduct sensitivity analysis of

their scenarios, i.e., choosing different

levels or paths of variables to

understand the sensitivities of choices

made during scenario design. For

instance, banking organizations may

decide to apply a few different interest-

rate paths for a given scenario.

Enterprise-Wide Stress Testing

Enterprise-wide stress testing is an

application of stress testing that

involves assessing the impact of certain

specified scenarios on the banking

organization as a whole, particularly on

capital and liquidity. As is the case with

scenario analysis more generally,

enterprise-wide stress testing involves

robust scenario design and effective

translation of scenarios into measures of

impact. Enterprise-wide stress tests can

help a banking organization in its efforts

to assess the impact of its full set of risks

under adverse events and

circumstances, but should be

supplemented with other stress tests

and other risk measurement tools given

inherent limitations in capturing all

risks and all adverse outcomes in one

test.

Scenario design for enterprise-wide

stress testing involves developing

scenarios that affect the banking

organization as a whole that stem from

macroeconomic, market-wide, and firm-

specific events. These scenarios should

incorporate the potential simultaneous

occurrence of both firm-specific and

macroeconomic and market-wide

events, considering system-wide

interactions and feedback effects

nario design for enterprise-wide

stress testing involves developing

scenarios that affect the banking

organization as a whole that stem from

macroeconomic, market-wide, and firm-

specific events. These scenarios should

incorporate the potential simultaneous

occurrence of both firm-specific and

macroeconomic and market-wide

events, considering system-wide

interactions and feedback effects. For

example, price shocks may lead to

significant portfolio losses, rising

funding gaps, a ratings downgrade, and

diminished access to funding. In

general, it is a good practice to consult

with a large set of individuals within

the banking organization—in various

business lines, research and risk areas—

to gain a wide perspective on how

enterprise-wide scenarios should be

designed and to ensure that the

scenarios capture the relevant aspects of

the banking organization’s business and

risks. Banking organizations should also

conduct scenarios of varying severity to

gauge the relative impact. At least some

scenarios should be of sufficient

severity to challenge the viability of the

banking organization, and should

include instant market shocks and

stressful periods of extensive duration

(e.g., not just a one or two-quarter shock

after which conditions return to

normal).

Selection of scenario variables is

important for enterprise-wide tests,

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hould

include instant market shocks and

stressful periods of extensive duration

(e.g., not just a one or two-quarter shock

after which conditions return to

normal).

Selection of scenario variables is

important for enterprise-wide tests,

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5 The portions of this guidance related to capital

stress testing do not apply to U.S. branches and

agencies of foreign banking organizations.

6 In this manner, stress testing can form an

integral part of an organization’s internal capital

adequacy process, consistent with supervisory

standards outlined in SR letter 09–04, SR letter 99–

18, OCC Bulletin 2008–20 or FDIC FIL–71–2008

‘‘Supervisory Guidance: Supervisory Review

Process of Capital Adequacy (Pillar 2) Related to the

Implementation of the Basel II Advanced Capital

Framework.’’

because they generally serve as the link

between the overall narrative of the

scenario and tangible impact on the

banking organization as a whole. For

instance, in aiming to capture the

combined impact of a severe recession

and a financial market downturn, a

banking organization may choose a set

of variables such as changes in GDP,

unemployment rate, interest rates, stock

market levels, or home price levels.

However, particularly when assessing

the impact on the whole banking

organization, using a large number of

variables can make a test more

cumbersome and complicated—so a

banking organization may also benefit

from simpler scenarios or from those

with fewer variables. Banking

organizations should balance the

comprehensiveness of contributing

variables and tractability of the exercise.

As with scenario analysis generally,

translating scenarios into tangible

effects on the banking organization as a

whole presents certain challenges

rsome and complicated—so a

banking organization may also benefit

from simpler scenarios or from those

with fewer variables. Banking

organizations should balance the

comprehensiveness of contributing

variables and tractability of the exercise.

As with scenario analysis generally,

translating scenarios into tangible

effects on the banking organization as a

whole presents certain challenges. An

institution should identify appropriate

and meaningful mechanisms for

translating scenarios into relevant

internal risk parameters that provide a

banking organization-wide view of risks

and understanding of how the risks are

translated into loss estimates. Not all

business areas are equally affected by a

given scenario, and problems in one

business area can have effects on other

units. However, for an enterprise-wide

test, assumptions across business lines

and risk areas should remain constant

for the chosen scenario, since the

objective is to see how the banking

organization as a whole responds to a

common outcome.

Reverse Stress Testing

Reverse stress testing is a tool that

allows a banking organization to assume

a known adverse outcome, such as

suffering a credit loss that breaches

regulatory capital ratios or suffering

severe liquidity constraints making it

unable to meet its obligations, and then

deduce the types of events that could

lead to such an outcome. This type of

stress testing may help a banking

organization to consider scenarios

beyond its normal business expectations

and see the impact of severe systemic

effects on the banking organization. It

also allows a banking organization to

challenge common assumptions about

its performance and expected mitigation

strategies.

Reverse stress testing helps to explore

so-called ‘‘break the bank’’ situations,

allowing a banking organization to set

aside the issue of estimating the

likelihood of severe events and to focus

more on what kinds of events could

threaten the viability of the banking

organization

nking organization to

challenge common assumptions about

its performance and expected mitigation

strategies.

Reverse stress testing helps to explore

so-called ‘‘break the bank’’ situations,

allowing a banking organization to set

aside the issue of estimating the

likelihood of severe events and to focus

more on what kinds of events could

threaten the viability of the banking

organization. Reverse stress testing

helps a banking organization evaluate

the combined effect of several types of

extreme events and circumstances that

might threaten the survival of the

banking organization, even if in

isolation each of the effects might be

manageable. For instance, reverse stress

testing may help a banking organization

recognize that a certain level of

unemployment would have a severe

impact on credit losses, that a market

disturbance could create additional

losses and result in rising funding costs,

and that a firm-specific case of fraud

would cause even further losses and

reputational impact that could threaten

a banking organization’s viability. In

some cases, reverse stress tests could

reveal to a banking organization that

‘‘breaking the bank’’ is not as remote an

outcome as originally thought.

Given the numerous potential threats

to a banking organization’s viability, the

organization should ensure that it

focuses first on those scenarios that

have the largest firm-wide impact, such

as insolvency or illiquidity, but also on

those that seem most imminent given

the current environment. Focusing on

the most prominent vulnerabilities

helps a banking organization prioritize

its choice of scenarios for reverse stress

testing. However, a banking

organization should also consider a

wider range of possible scenarios that

could jeopardize the viability of the

banking organization, exploring what

could represent potential blind spots.

V. Stress Testing for Assessing the

Adequacy of Capital and Liquidity

There are many uses of stress testing

within banking organizations

oice of scenarios for reverse stress

testing. However, a banking

organization should also consider a

wider range of possible scenarios that

could jeopardize the viability of the

banking organization, exploring what

could represent potential blind spots.

V. Stress Testing for Assessing the

Adequacy of Capital and Liquidity

There are many uses of stress testing

within banking organizations.

Prominent among these are stress tests

designed to assess the adequacy of

capital and liquidity. Given the

importance of capital and liquidity to a

banking organization’s viability, stress

testing should be applied in these two

areas in particular, including an

evaluation of the interaction between

capital and liquidity and the potential

for both to become impaired at the same

time. Depletions and shortages of capital

or liquidity can cause a banking

organization to no longer perform

effectively as a financial intermediary,

be viewed by its counterparties as no

longer viable, become insolvent, or

diminish its capacity to meet legal and

financial obligations. A banking

organization’s capital and liquidity

stress testing should consider how

earnings, capital, and liquidity would be

affected in an environment in which

multiple risks manifest themselves at

the same time, for example, an increase

in credit losses during an adverse

interest-rate environment. Additionally,

banking organizations should recognize

that at the end of the time horizon

considered by a given stress test, the

banking organization may still have

substantial residual risks or problem

exposures that may continue to pressure

capital and liquidity resources.

Stress testing for capital and liquidity

adequacy should be conducted in

coordination with a banking

organization’s overall strategy and

annual planning cycles. Results should

be refreshed in the event of major

strategic decisions, or other decisions

that can materially impact capital or

liquidity

risks or problem

exposures that may continue to pressure

capital and liquidity resources.

Stress testing for capital and liquidity

adequacy should be conducted in

coordination with a banking

organization’s overall strategy and

annual planning cycles. Results should

be refreshed in the event of major

strategic decisions, or other decisions

that can materially impact capital or

liquidity. Banking organizations should

conduct stress testing for capital and

liquidity adequacy periodically.

Capital Stress Testing 5

Capital stress testing results can serve

as a useful tool to support a banking

organization’s capital planning and

corporate governance.6 They may help a

banking organization better understand

its risks and evaluate the impact of

adverse outcomes on its capital position

and ensure that the banking

organization holds adequate capital

given its business model, including the

complexity of its activities and its risk

profile. Capital stress testing

supplements a banking organization’s

regulatory capital analysis by providing

a forward-looking assessment of capital

adequacy, usually with a forecast

horizon of at least two years, and

highlighting the potential adverse

effects on capital levels and ratios of

risks not fully captured in regulatory

capital requirements. It should also be

used to help a banking organization

assess the quality and composition of

capital and its ability to absorb losses.

Stress testing can aid capital

contingency planning by helping

management identify exposures or risks

that would need to be reduced and

actions that could be taken to bolster

capital levels or otherwise maintain

capital adequacy, as well as actions that

in times of stress might not be

possible—such as raising capital

he quality and composition of

capital and its ability to absorb losses.

Stress testing can aid capital

contingency planning by helping

management identify exposures or risks

that would need to be reduced and

actions that could be taken to bolster

capital levels or otherwise maintain

capital adequacy, as well as actions that

in times of stress might not be

possible—such as raising capital.

A capital stress testing framework

should include exercises that analyze

the potential for changes in earnings,

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7 For regulated subsidiaries, stress testing

activities should be fully consistent with the

regulations and guidance of the relevant primary

Federal supervisor.

8 See SR letter 10–6, OCC Bulletin 2010–13, OCC

Bulletin 2010–1, and SR letter 10–1.

losses, reserves, and other potential

effects on capital under a variety of

stressful circumstances. The framework

should also capture any potential

change in risk-weighted assets, the

ability of capital to absorb losses, and

any resulting impact on the banking

organization’s capital ratios. The

framework should include all relevant

risk types that have a potential to affect

capital adequacy, whether directly or

indirectly. A banking organization

should also explore the potential for

possible balance sheet expansion to put

pressure on capital ratios and consider

mitigation options, other than simply

shrinking the balance sheet. Capital

stress testing should assess the potential

impact of a banking organization’s

material subsidiaries suffering capital

problems on their own, even if the

consolidated banking organization is not

encountering problems.7

Enterprise-wide stress testing, as

described in section IV, should be an

integral part of a banking organization’s

capital stress testing

rinking the balance sheet. Capital

stress testing should assess the potential

impact of a banking organization’s

material subsidiaries suffering capital

problems on their own, even if the

consolidated banking organization is not

encountering problems.7

Enterprise-wide stress testing, as

described in section IV, should be an

integral part of a banking organization’s

capital stress testing. Such enterprise-

wide testing should include pro forma

estimates of not only potential losses

and resources available to absorb losses,

but also potential planned capital

actions (such as dividends or share

repurchases) that would affect the

banking organization’s capital position,

including regulatory and other capital

ratios. There should also be

consideration of the impact on the

banking organization’s provision for

loan and lease losses and other relevant

financial metrics. Even with very

effective enterprise-wide tests, banking

organizations should use capital stress

testing in conjunction with other

internal approaches (in addition to

regulatory measures) for assessing

capital adequacy, such as those that rely

primarily on statistical estimates of risk

or loss estimates based on historical

data.

Liquidity Stress Testing

A banking organization should also

conduct stress testing for liquidity

adequacy.8 Through such stress testing

a banking organization can work to

identify vulnerabilities related to

liquidity adequacy in light of both firm-

specific and market-wide stress events

and circumstances. Effective stress

testing helps a banking organization

identify and quantify the depth, source,

and degree of potential liquidity strain

and to analyze possible impacts on its

cash flows, liquidity position,

profitability, and other aspects of its

financial condition over various time

horizons

uidity adequacy in light of both firm-

specific and market-wide stress events

and circumstances. Effective stress

testing helps a banking organization

identify and quantify the depth, source,

and degree of potential liquidity strain

and to analyze possible impacts on its

cash flows, liquidity position,

profitability, and other aspects of its

financial condition over various time

horizons. For example, stress testing can

be used to explore potential funding

shortfalls, shortages in liquid assets, the

inability to issue debt, exposure to

possible deposit outflows, volatility in

short-term brokered deposits, and the

impact of reduced collateral values on

borrowing capacity at the Federal Home

Loan Banks, the Federal Reserve

discount window, or other secured

wholesale funding sources.

Liquidity stress testing should explore

the potential impact of adverse

developments that may affect market

and asset liquidity, including the

freezing up of credit and funding

markets, and the corresponding impact

on the banking organization. Such tests

can also help identify the conditions

under which balance sheets might

expand, thus creating additional

funding needs (e.g., through accelerated

drawdowns on unfunded

commitments). These tests also help

determine whether the banking

organization has a sufficient liquidity

buffer to meet various types of future

liquidity demands. In this regard,

liquidity stress testing should be an

integral part of the development and

maintenance of a banking organization’s

contingency funding planning.

Liquidity stress testing should include

enterprise-wide tests as discussed in

section IV, but should also be applied,

as appropriate, at lower levels of the

banking organization, particularly for

entities that might face regulatory

restrictions or limitations on receiving

or providing funds. As with capital

stress testing, banking organizations

may need to conduct liquidity stress

tests at both the consolidated and

subsidiary level

prise-wide tests as discussed in

section IV, but should also be applied,

as appropriate, at lower levels of the

banking organization, particularly for

entities that might face regulatory

restrictions or limitations on receiving

or providing funds. As with capital

stress testing, banking organizations

may need to conduct liquidity stress

tests at both the consolidated and

subsidiary level. In undertaking

enterprise-wide liquidity tests banking

organizations should make realistic

assumptions as to the implications of

liquidity stresses in one part of the

banking organization on other parts.

An effective stress testing framework

should explore the potential for capital

and liquidity problems to arise at the

same time or exacerbate one another.

For example, a banking organization in

a stressed liquidity position is often

required to take actions that have a

negative direct or indirect capital

impact (e.g., selling assets at a loss or

incurring funding costs at above market

rates to meet funding needs). A banking

organization’s liquidity stress analysis

should explore situations in which the

banking organization may be operating

with a capital position that exceeds

regulatory minimums, but is

nonetheless viewed within the financial

markets or by its counterparties as being

of questionable viability. As with other

applications of stress testing, for its

capital and liquidity stress tests, it is

beneficial for a banking organization to

articulate clearly its objectives for a

post-stress outcome, for instance to

remain a viable financial market

participant that is able to meet its

existing and prospective obligations and

commitments.

VI. Governance

Similar to other aspects of its risk

management, a banking organization’s

stress testing framework will be

effective only if it is subject to strong

governance and controls to ensure the

framework is functioning as intended

s outcome, for instance to

remain a viable financial market

participant that is able to meet its

existing and prospective obligations and

commitments.

VI. Governance

Similar to other aspects of its risk

management, a banking organization’s

stress testing framework will be

effective only if it is subject to strong

governance and controls to ensure the

framework is functioning as intended.

Strong governance and controls help

ensure that the framework contains core

elements, from clearly defined stress

testing objectives to recommended

actions. Importantly, strong governance

provides critical review of elements of

the stress testing framework, especially

regarding key assumptions,

uncertainties, and limitations. A

banking organization should ensure that

the stress testing framework is not

isolated within a banking organization’s

risk management function, but is firmly

integrated into business lines, capital

and asset-liability committees, and other

decision-making bodies. The extent and

sophistication of a banking

organization’s governance over its stress

testing framework should align with the

extent and sophistication of that

framework.

Governance over a banking

organization’s stress testing framework

rests with the banking organization’s

board of directors and senior

management. As part of their overall

responsibilities, a banking

organization’s board and senior

management should establish a

comprehensive, integrated and effective

stress testing framework that fits into

the broader risk management of the

banking organization. While the board is

ultimately responsible for ensuring that

the banking organization has an

effective stress testing framework, senior

management generally has

responsibility for implementing that

framework

oard and senior

management should establish a

comprehensive, integrated and effective

stress testing framework that fits into

the broader risk management of the

banking organization. While the board is

ultimately responsible for ensuring that

the banking organization has an

effective stress testing framework, senior

management generally has

responsibility for implementing that

framework. Senior management duties

should include establishing adequate

policies and procedures and ensuring

compliance with those policies and

procedures, assigning competent staff,

overseeing stress test development and

implementation, evaluating stress test

results, reviewing any findings related

to the functioning of stress test

processes, and taking prompt remedial

action where necessary. Senior

management, directly and through

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9 For validation of models and other quantitative

tools used for stress testing, see OCC Bulletin 2011–

12 ‘‘Supervisory Guidance on Model Risk

Management’’, or SR letter 11–7, ‘‘Guidance on

Model Risk Management.’’

relevant committees, also should be

responsible for regularly reporting to the

board on stress testing developments

and results from individual and

collective stress tests as well as on

compliance with stress testing policy.

Board members should actively evaluate

and discuss these reports, ensuring that

the stress testing framework is in line

with the banking organization’s risk

appetite, overall strategy and business

plans, and directing changes where

appropriate.

A banking organization should have

written policies, approved and annually

reviewed by the board, that direct and

govern the implementation of the stress

testing framework in a comprehensive

manner

ese reports, ensuring that

the stress testing framework is in line

with the banking organization’s risk

appetite, overall strategy and business

plans, and directing changes where

appropriate.

A banking organization should have

written policies, approved and annually

reviewed by the board, that direct and

govern the implementation of the stress

testing framework in a comprehensive

manner. Policies, along with procedures

to implement them, should:

• Describe the overall purpose of

stress testing activities;

• Articulate consistent and

sufficiently rigorous stress testing

practices across the entire banking

organization;

• Indicate stress testing roles and

responsibilities, including controls over

external resources used for any part of

stress testing (such as vendors and data

providers);

• Describe the frequency and priority

with which stress testing activities

should be conducted;

• Indicate how stress test results are

used and by whom;

• Be reviewed and updated as

necessary to ensure that stress testing

practices remain appropriate and keep

up to date with changes in market

conditions, banking organization

products and strategies, banking

organization exposures and activities,

the banking organization’s established

risk appetite, and industry stress testing

practices.

A stress testing framework should

incorporate validation or other type of

independent review to ensure the

integrity of stress testing processes and

results, consistent with existing

supervisory expectations.9 If a banking

organization engages a third party

vendor to support some or all of its

stress testing activities, there should be

appropriate controls in place to ensure

that those externally-developed systems

and processes are sound, applied

correctly, and appropriate for the

banking organization’s risks, activities,

and exposures

sults, consistent with existing

supervisory expectations.9 If a banking

organization engages a third party

vendor to support some or all of its

stress testing activities, there should be

appropriate controls in place to ensure

that those externally-developed systems

and processes are sound, applied

correctly, and appropriate for the

banking organization’s risks, activities,

and exposures. Additionally, senior

management should be mindful of any

potential inconsistencies,

contradictions, or gaps among its stress

tests and assess what actions should be

taken as a result. Internal audit should

also play a role focused on ensuring the

ongoing performance, integrity, and

reliability of the stress testing

framework. A banking organization

should ensure that its stress tests are

documented appropriately, including a

description of the types of stress tests

and methodologies used, key

assumptions, results, and suggested

actions. The board and senior

management should review stress

testing activities and results with an

appropriately critical eye and ensure

that there is objective review of all stress

testing processes.

The results of stress testing analyses

should facilitate decision-making by the

board and senior management. Stress

testing results should be used to inform

the board about alignment of the

banking organization’s risk profile with

the board’s chosen risk appetite, as well

as inform operating and strategic

decisions. Stress testing results should

be considered directly by the board and

senior management for decisions

relating to capital and liquidity

adequacy, including capital contingency

plans and contingency funding plans.

The board and senior management

should ensure that the stress testing

framework includes a sufficient range of

stress testing activities applied at the

appropriate levels of the banking

organization (i.e., not just one

enterprise-wide stress test)

senior management for decisions

relating to capital and liquidity

adequacy, including capital contingency

plans and contingency funding plans.

The board and senior management

should ensure that the stress testing

framework includes a sufficient range of

stress testing activities applied at the

appropriate levels of the banking

organization (i.e., not just one

enterprise-wide stress test). Sound

governance also includes using stress

testing to consider the effectiveness of a

banking organization’s risk mitigation

techniques for various risk types over

their respective time horizons, such as

to explore what could occur if expected

mitigation techniques break down

during stressful periods.

VII. Conclusion

A banking organization should use

the principles laid out in this guidance

to develop, implement, and maintain an

effective stress testing framework. Such

a framework should be adequately

tailored to the banking organization’s

size, complexity, risks, exposures, and

activities. A key purpose of stress

testing is to explore various types of

possible outcomes, including rare and

extreme events and circumstances,

assess their impact on the banking

organization, and then evaluate the

boundaries up to which the banking

organization plans to be able to

withstand such outcomes.

While stress testing can provide

valuable information regarding potential

future outcomes, similar to any other

risk management tool it has limitations

and cannot provide absolute certainty

regarding the implications of assumed

events and impacts. Furthermore,

management should ensure that stress

testing activities are not constrained to

reflect past experiences, but instead

consider a broad range of possibilities

ovide

valuable information regarding potential

future outcomes, similar to any other

risk management tool it has limitations

and cannot provide absolute certainty

regarding the implications of assumed

events and impacts. Furthermore,

management should ensure that stress

testing activities are not constrained to

reflect past experiences, but instead

consider a broad range of possibilities.

No single stress test can accurately

estimate the impact of all stressful

events and circumstances; therefore, a

banking organization should understand

and account for stress testing limitations

and uncertainties, and use stress tests in

combination with other risk

management tools to make informed

risk management and business

decisions.

This concludes the text of the

proposed guidance.

Dated: June 2, 2011.

John Walsh,

Acting Comptroller of the Currency.

By order of the Board of Governors of the

Federal Reserve System, June 8, 2011.

Jennifer J. Johnson,

Secretary of the Board.

Dated at Washington, DC, this 7th of June

2011.

By order of the Board of Directors.

Federal Deposit Insurance Corporation.

Valerie J. Best,

Assistant Executive Secretary.

[FR Doc. 2011–14777 Filed 6–14–11; 8:45 am]

BILLING CODE 4810–33–P; 6210–01–P

DEPARTMENT OF THE TREASURY

Office of Thrift Supervision

Mutual to Stock Conversion

Application

AGENCY: Office of Thrift Supervision

(OTS), Treasury.

ACTION: Notice and request for comment.

SUMMARY: The proposed information

collection request (ICR) described below

has been submitted to the Office of

Management and Budget (OMB) for

review and approval, as required by the

Paperwork Reduction Act of 1995, 44

U.S.C. 3507. OTS is soliciting public

comments on the proposal.

DATES: Submit written comments on or

before July 15, 2011. A copy of this ICR,

with applicable supporting

documentation, can be obtained from

RegInfo.gov at http://www.reginfo.gov/

public/do/PRAMain

d to the Office of

Management and Budget (OMB) for

review and approval, as required by the

Paperwork Reduction Act of 1995, 44

U.S.C. 3507. OTS is soliciting public

comments on the proposal.

DATES: Submit written comments on or

before July 15, 2011. A copy of this ICR,

with applicable supporting

documentation, can be obtained from

RegInfo.gov at http://www.reginfo.gov/

public/do/PRAMain.

ADDRESSES: Send comments, referring to

the collection by title of the proposal or

by OMB approval number, to OMB and

OTS at these addresses: Office of

Information and Regulatory Affairs,

Attention: Desk Officer for OTS, U.S.

Office of Management and Budget, 725

17th Street, NW., Room 10235,

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Guidance Proposed Guidance on Stress Testing for Banking Organizations with More Than $10 Billion in Total Consolidated Assets · FDIC FIL-47-2011 | Frix