Dodd-Frank Act Stress Test (Company Run)
Section 165(i)(2) of the Dodd-Frank Wall Street Reform and Consumer Protection Act ("Dodd-Frank Act") requires certain national banks and federal savings associations to conduct company-run stress tests. On October 9, 2012, the Office of the Comptroller of the Currency (OCC) published a rule (12 CFR 46) implementing the stress testing requirement and establishing definitions and requirements for the scope of application, scenarios, reporting, and disclosure. On October 10, 2019, the OCC issued another final rule, implementing changes made by the Economic Growth, Regulatory Relief, and Consumer Protection Act, which revised the minimum threshold for stress testing to $250 billion, modified the frequency of company-run stress tests for certain national banks and federal savings associations, and reduced the number of required stress testing scenarios.
Covered institutions are required to submit the results of their company-run stress tests to the OCC by April 5 and publish those results between June 15 and July 15. The OCC will provide the required scenarios to the covered institutions by February 15 of each year.
The results of the company-run stress tests provide the OCC with forward-looking information used in bank supervision and assist the agency in assessing the company's risk profile and capital adequacy. The objective of the company-run stress test is to ensure that institutions have robust, forward-looking capital planning processes that account for their unique risks and to help ensure that institutions have sufficient capital to continue operations throughout times of economic and financial stress. The OCC intends to use the data to assess the reasonableness of the stress test results and determine whether additional analytical techniques are needed to identify, measure, and monitor risk. These stress test results are also expected to support ongoing improvement in a covered institution's stress testing practices with respect to its internal assessments of capital adequacy and overall capital planning.
Frequency of Stress Testing
The stress testing rule (12 CFR 46.5) requires a covered institution to conduct a stress test every other year, on even-numbered years, unless it is consolidated under a holding company that is required by the Board of Governors of the Federal Reserve (under 12 CFR 252.54(a)(2)) to conduct an annual company-run stress test. Generally, covered institutions subject to Category III standards will only conduct company-run stress tests in even-numbered reporting years (e.g., April 5, 2022, 2024, etc.). While the annual stress test requirement applies to covered institutions subject to Category I or Category II standards.
The OCC releases economic and financial market scenarios that are used in the company-run stress test no later than February 15. The scenarios, which are not forecasts, include baseline and severely adverse scenarios. Each scenario includes economic variables, including macroeconomic activity, unemployment, exchange rates, prices, income, and interest rates. The severely adverse scenario is a hypothetical scenario designed to assess the strength and resilience of financial institutions.
These reporting templates collect quantitative projections of balance sheet, capital, losses, and income across several macroeconomic scenarios, along with qualitative information on methodologies.
Covered institutions are required to complete reporting templates using financial information as of December 31 of each year. For 2022, the OCC has proposed the following templates and instructions:
2022 DFAST Templates and Instructions
Note: Category III banks are required to submit stress testing in 2022.
Disclosure of Annual Stress Test Results
The stress testing rule (12 CFR 46.8) requires a covered institution to publish a summary of the results of its stress test. The required summary of results may be published on the covered institution's website or in any other forum that is reasonably accessible to the public.
A covered institution must publish a summary of the results of its stress test in the period starting June 15 and ending July 15. Unless the OCC determines otherwise, if the covered institution is a consolidated subsidiary of a holding company subject to supervisory stress tests conducted by the Board of Governors of the Federal Reserve System (the Federal Reserve Board) pursuant to 12 CFR part 252, then within the June 15 to July 15 period such covered institution may not publish the required summary of its stress test earlier than the date that the Federal Reserve Board publishes the supervisory stress test results of the covered bank's parent holding company.
Covered institutions are generally able to satisfy the OCC’s disclosure requirement through actions taken to meet the Federal Reserve Board’s comparable requirement; however, the OCC reserves the right to require additional disclosure at its discretion.