On August 27, 2012 the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency announced they are considering changes to the timeline for the annual company-run stress tests required by section 165 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. The agencies are considering delaying the effective date of the rule until September 2013 for institutions with between $10 billion and $50 billion in total consolidated assets. The agencies have not officially asked for comment on the delayed implementation, but noted that the final implementation timeline for all covered institutions will be specified in the final rule.

We will continue to monitor this and other Dodd-Frank rulemakings