Regulators Finalize Stress Test Rules

On Tuesday, October 9, 2012, the Federal Reserve Board, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation (collectively, the "Regulators") each published final rules with stress testing requirements for certain covered institutions.  The final rules implement Section 165(i)(1) and Section 165(i)(2) of the Dodd-Frank Wall Street Reform and Consumer Protection Act, which requires all financial companies with total consolidated assets of more than $10 billion that are regulated by a primary federal financial regulatory agency or by the Financial Stability Oversight Council to conduct an annual company-run stress test.  The final rules require institutions with average total consolidated assets of $50 billion or greater to begin conducting annual stress tests this year, although the Regulators have reserved the authority to allow covered institutions to delay implementation on a case-by-case basis where warranted.  The final rules delay implementation for covered institutions with total consolidated assets of between $10 billion and $50 billion until October 2013.

Read the Fed press release

Read the OCC press release

Read the FDIC press release

© 2012 Perkins Coie LLP