On October 23, 2014, the Federal Reserve Board released supervisory scenarios for use in the 2015 capital planning and stress testing program, namely the Comprehensive Capital Analysis and Review (“CCAR”). The supervisory scenarios will apply to 31 bank holding companies with over $50 billion in consolidated assets and comes on the heels of recently issued final rules modifying the capital plan and stress test regulations. The Fed presents three supervisory scenarios (baseline, adverse and severely adverse) that will take into account 28 variables including, but not limited to, economic activity, unemployment and interest rates. The adverse and severely adverse scenarios are designed to test the resilience of banking institutions to stressed economic environments.

Banks will be required to use the 2015 supervisory scenarios for both the CCAR and the annual stress tests required by the Dodd–Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”) as a complementary exercise to CCAR. The Federal Reserve Board plans to provide further data regarding the 2015 global market shock scenario to be used by six bank holding companies with large trading positions on or before December 1, 2014. Capital plans must be submitted by January 5, 2015. Additionally, the OCC and FDIC have recently released economic scenarios to be used for stress tests required under Dodd-Frank.

The 2015 supervisory scenarios are available at:

http://www.federalreserve.gov/newsevents/press/bcreg/bcreg20141023a1.pdf,

the FDIC press release for the 2015 supervisory scenarios is available at:

https://www.fdic.gov/news/news/press/2014/pr14087.html

and the OCC press release for the 2015 supervisory scenarios is available at:

http://www.occ.gov/news-issuances/news-releases/2014/nr-occ-2014-141.html.