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Board of Governors of the Federal Reserve System
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Comprehensive Capital Analysis and Review 2016: Assessment Framework and Results

Summary of Results

As noted above, in CCAR, the Federal Reserve evaluates a BHC's capital adequacy on a forward-looking, post-stress basis by reviewing the BHC's ability to maintain capital above all minimum regulatory capital requirements under expected and stressful conditions. In addition, in CCAR, the Federal Reserve performs a qualitative assessment of practices supporting the BHC's capital planning process. The Federal Reserve may object to a firm's capital plan on either quantitative or qualitative grounds.

When the Federal Reserve objects to a BHC's capital plan, the BHC may not make any capital distribution unless the Federal Reserve indicates in writing that it does not object to the distribution.23

The Federal Reserve did not object to the capital plan or planned capital distributions for the BHCs listed in the "Non-objection to capital plan" or the "Conditional non-objection to capital plan" column in table 3. A firm that receives a conditional non-objection will be required to resubmit their capital plan within six months to address deficiencies observed in the firm's capital planning process; however, the firm will be allowed to continue with their planned distributions until the Federal Reserve makes a determination on the resubmitted capital plan. The Federal Reserve objected to the capital plans of the BHCs listed in the "Objection to capital plan" column in the table. Each of these BHCs had critical or widespread significant deficiencies in their capital planning process that undermine the overall reliability of the BHC's capital planning process.

The Federal Reserve objected to the capital plans of Deutsche Bank Trust Corporation and Santander Holdings USA, Inc. based on the qualitative assessments conducted by the Federal Reserve in CCAR 2016. These BHCs may only make capital distributions that are expressly permitted by the Federal Reserve. These BHCs may choose to resubmit their capital plans to the Federal Reserve following substantial progress in the remediation of the issues that led to the objections, consistent with the requirements in the Federal Reserve's capital plan rule.24

The Federal Reserve also issued a conditional non-objection to Morgan Stanley. The BHC must address weaknesses observed in the firm's capital planning process and resubmit a capital plan by December 29, 2016.

The Federal Reserve did not object to any CCAR firm based on quantitative assessments.

Table 3. Summary of the Federal Reserve's actions on capital plans in CCAR 2016
Non-objection to capital plan Conditional non-objection to capital plan Objection to capital plan
Ally Financial Inc. Morgan Stanley Deutsche Bank Trust Corporation
American Express Company   Santander Holdings USA, Inc.
BancWest Corporation    
Bank of America Corporation    
The Bank of New York Mellon Corporation    
BB&T Corporation    
BBVA Compass Bancshares, Inc.    
BMO Financial Corp.    
Capital One Financial Corporation    
Citigroup Inc.    
Citizens Financial Group, Inc.    
Comerica Incorporated    
Discover Financial Services    
Fifth Third Bancorp    
The Goldman Sachs Group, Inc.    
HSBC North America Holdings Inc.    
Huntington Bancshares Incorporated    
JPMorgan Chase & Co.    
KeyCorp    
M&T Bank Corporation    
MUFG Americas Holdings Corporation    
Northern Trust Corporation    
The PNC Financial Services Group, Inc.    
Regions Financial Corporation    
State Street Corporation    
SunTrust Banks, Inc.    
TD Group US Holdings LLC    
U.S. Bancorp    
Wells Fargo & Co.    
Zions Bancorporation    

Qualitative Assessment Results

The qualitative assessment conducted as part of CCAR 2016 found that many BHCs continued to improve their capital planning practices, both in terms of the estimation methods used to conduct their stress tests and the risk measurement and management, internal controls, and governance supporting the BHCs' capital planning practices. Strong practices in these areas are critical for ensuring the integrity of the inputs into assessing capital adequacy and making decisions about capital distributions.

Improvements were particularly evident for the large and non-complex BHCs that were subject to the qualitative evaluation during this year's program.25 As a group, most of the large and non-complex BHCs are meeting or close to meeting supervisory expectations. With one noted exception, these BHCs have generally been able to

  • remediate outstanding concerns with respect to loss and revenue estimation approaches used for their internal stress tests,
  • ensure appropriate consideration of their material risks in stress testing, and
  • extend the coverage of key controls and governance processes to the material elements of their capital planning processes.

Most LISCC and other large and complex BHCs 26 have made progress since CCAR 2015, though many continue to fall short of meeting the higher supervisory expectations that the Federal Reserve has for the largest firms. While this group of BHCs has, in many cases, been able to address some of the more technical deficiencies in loss and revenue estimation approaches used for stress testing, many continue to fall short of expectations that they develop and
maintain

  • satisfactory risk identification processes that link the risks associated with their specific business activities to their vulnerabilities under stress,
  • the capacity for critical assessment of the weaknesses in their stress scenario assumptions and stress testing results, and
  • strong internal controls around various elements of capital planning.

In addition, a number of the largest BHCs have weaknesses in their internal audit programs for capital planning, which may limit their effectiveness in assessing the quality of key components of their capital planning practices. An effective internal audit program actively identifies weaknesses in BHCs' capital planning practices, as well as gaps in controls and governance around those practices, including those related to risk management, data infrastructure, regulatory reporting, and model risk. As part of the year-round supervisory program supporting CCAR, the Federal Reserve plans to conduct a thorough review of the largest firms' internal audit coverage of capital planning practices starting later in 2016.

The Federal Reserve expects LISCC and other large and complex firms to make continued progress toward meeting and exceeding supervisory expectations in all aspects of capital planning, and will continue to assess the firms' progress throughout the year and in evaluations of the firms' annual CCAR capital plan submissions.

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Reasons for Qualitative Objections to Specific BHCs' Capital Plans

The Board objected to the CCAR 2016 capital plan of Deutsche Bank Trust Corporation (DBTC) on qualitative grounds. Although there were some improvements in certain aspects of capital planning at DBTC, the firm overall continues to have material unresolved supervisory issues that critically undermine its capital planning process. The Federal Reserve determined that the assumptions and analysis underlying the capital plan of DBTC, and the capital adequacy process of DBTC, are not reasonable or appropriate. In particular, the Federal Reserve identified deficiencies in the risk management and control infrastructure at DBTC, including risk measurement processes; stress testing processes; and data infrastructure. These deficiencies limit the reliability of the capital planning process of DBTC and its ability to conduct a comprehensive assessment of its capital adequacy.

The Board also objected on qualitative grounds to the 2016 capital plan of Santander Holdings USA, Inc. (Santander). Although Santander has made progress in improving certain approaches to loss and revenue projection, the firm continues to have material unresolved supervisory issues that critically undermine its capital planning process. The assumptions and analysis underlying the capital plan, and the capital adequacy process, are not reasonable or appropriate. The Federal Reserve's review of the capital planning processes at Santander revealed ongoing deficiencies in the risk management framework, including important features of the risk measurement and monitoring function; stress testing processes; and internal controls, governance, and oversight functions. These deficiencies limit the reliability of the capital planning processes of Santander and its ability to conduct a comprehensive assessment of its capital adequacy.

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Reasons for Conditional Non-objection to Morgan Stanley's Capital Plan

The Board of Governors did not object to Morgan Stanley's capital plan. However, Morgan Stanley exhibited material weaknesses in its capital planning process. These weaknesses warrant further near-term attention but do not undermine the quantitative results of the stress tests for the firm. They include shortcomings in the firm's scenario design practices, which do not adequately reflect risks and vulnerabilities specific to the firm, weaknesses in some aspects of the firm's modeling practices, and weaknesses in governance and controls around both scenario design and modeling practices. Accordingly, as a condition of not objecting to Morgan Stanley's capital plan, the Board of Governors is requiring Morgan Stanley to address these weaknesses and resubmit its capital plan by December 29, 2016. If Morgan Stanley does not satisfactorily address the identified weaknesses in its capital planning process by that time, the Board of Governors would expect to object to the resubmitted capital plan and may restrict Morgan Stanley's capital distributions.

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Results of Quantitative Assessment

As noted above, no firm was objected to on quantitative grounds in CCAR 2016.Tables 4 and 5 contain minimum post-stress common equity tier 1 ratios for each of the 33 BHCs under the supervisory severely adverse and adverse scenarios. The middle column of the table incorporates the original planned capital distributions included in the capital plans submitted by the BHCs in April 2016. The ratios reported in the right-hand column incorporate any adjusted capital distributions submitted by a BHC after receiving the Federal Reserve's preliminary CCAR post-stress capital analysis.

Tables 6.A and 6.B report minimum capital ratios under the supervisory severely adverse scenario based on both the original and adjusted planned capital actions, where applicable. The ratios based on adjusted capital actions are only reported for those BHCs that submitted adjusted capital actions.

In the supervisory severely adverse scenario, one BHC--M&T Bank Corporation--was projected to have at least one minimum post-stress capital ratio lower than minimum required regulatory capital ratios based on its original planned capital actions. M&T Bank Corporation fell below the minimum required post-stress tier 1 and total capital ratios. (See the applicable minimum capital ratios for LISCC and large and complex BHCs provided in table 6.A and the applicable minimum capital ratios for large and noncomplex BHCs provide in table 6.B.) However, M&T was able to maintain its post-stress regulatory capital ratios above minimum requirements in the severely adverse scenario after submitting adjusted capital actions.

Tables 7.A and 7.B report minimum capital ratios in the supervisory adverse scenario based on both the original and adjusted planned capital actions, where applicable. The minimum capital ratios were generally higher in the supervisory adverse scenario than in the supervisory severely adverse scenario.

Table 4. Projected minimum common equity tier 1 ratio in the severely adverse, 2016:Q1 to 2018:Q1
Bank holding company Stressed ratio with original
planned capital actions
Stressed ratio with adjusted
planned capital actions
Ally Financial Inc. 5.2  
American Express Company 6.6  
BancWest Corporation 9.0  
Bank of America Corporation 7.1  
The Bank of New York Mellon Corporation 8.4  
BB&T Corporation 6.1  
BBVA Compass Bancshares, Inc. 6.4  
BMO Financial Corp. 5.9  
Capital One Financial Corporation 6.4  
Citigroup Inc. 7.7  
Citizens Financial Group, Inc. 7.7  
Comerica Incorporated 6.8  
Deutsche Bank Trust Corporation 30.1  
Discover Financial Services 8.7  
Fifth Third Bancorp 5.9  
The Goldman Sachs Group, Inc. 7.6  
HSBC North America Holdings Inc. 7.0  
Huntington Bancshares Incorporated 5.6  
JPMorgan Chase & Co. 6.8  
KeyCorp 6.4  
M&T Bank Corporation 4.6 5.0
Morgan Stanley 7.7  
MUFG Americas Holdings Corporation 10.2  
Northern Trust Corporation 8.7  
The PNC Financial Services Group, Inc. 6.1  
Regions Financial Corporation 6.2  
Santander Holdings USA, Inc. 11.9  
State Street Corporation 6.6  
SunTrust Banks, Inc. 6.4  
TD Group US Holdings LLC 8.7  
U.S. Bancorp 6.2  
Wells Fargo & Company 6.1  
Zions Bancorporation 6.0  

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2016 by the bank holding companies in their annual capital plans and the minimum ratios incorporating any adjustments to capital distributions made by a bank holding company after reviewing the Federal Reserve's stress test. The minimum capital ratios are for the period 2016:Q1 to 2018:Q1 and do not necessarily occur in the same quarter.

Source: Federal Reserve estimates in the severely adverse scenario.

Table 5. Projected minimum common equity tier 1 ratio in the adverse, 2016:Q1 to 2018:Q1
Bank holding company Stressed ratio with original
planned capital actions
Stressed ratio with adjusted
planned capital actions
Ally Financial Inc. 7.2  
American Express Company 9.0  
BancWest Corporation 11.6  
Bank of America Corporation 9.5  
The Bank of New York Mellon Corporation 9.7  
BB&T Corporation 8.1  
BBVA Compass Bancshares, Inc. 9.0  
BMO Financial Corp. 8.5  
Capital One Financial Corporation 8.2  
Citigroup Inc. 9.8  
Citizens Financial Group, Inc. 9.7  
Comerica Incorporated 8.5  
Deutsche Bank Trust Corporation 31.9  
Discover Financial Services 10.7  
Fifth Third Bancorp 8.1  
The Goldman Sachs Group, Inc. 9.8  
HSBC North America Holdings Inc. 8.2  
Huntington Bancshares Incorporated 7.7  
JPMorgan Chase & Co. 9.1  
KeyCorp 8.3  
M&T Bank Corporation 7.3 7.7
Morgan Stanley 10.6  
MUFG Americas Holdings Corporation 12.6  
Northern Trust Corporation 9.6  
The PNC Financial Services Group, Inc. 7.7  
Regions Financial Corporation 8.5  
Santander Holdings USA, Inc. 12.2  
State Street Corporation 7.6  
SunTrust Banks, Inc. 8.1  
TD Group US Holdings LLC 12.0  
U.S. Bancorp 7.9  
Wells Fargo & Company 8.1  
Zions Bancorporation 9.4  

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2016 by the bank holding companies in their annual capital plans and the minimum ratios incorporating any adjustments to capital distributions made by a bank holding company after reviewing the Federal Reserve's stress test. The minimum capital ratios are for the period 2016:Q1 to 2018:Q1 and do not necessarily occur in the same quarter.

Source: Federal Reserve estimates in the adverse scenario.

Table 6.A. Projected minimum regulatory capital ratios in the severely adverse, 2016:Q1 to 2018:Q1:
LISCC and large and complex BHCs
Bank holding company Capital actions Common equity tier 1
capital ratio (%)
Tier 1
capital ratio (%)
Total capital
ratio (%)
Tier 1 leverage ratio (%)
Actual 2015:Q4 Projected minimum Actual 2015:Q4 Projected minimum Actual 2015:Q4 Projected minimum Actual 2015:Q4 Projected minimum
American Express Company Original 12.4 6.6 13.5 7.7 15.2 9.4 11.7 6.3
Adjusted                
Bank of America Corporation Original 11.6 7.1 12.9 8.8 15.7 11.9 8.6 5.9
Adjusted                
The Bank of New York Mellon Corporation Original 11.5 8.4 13.1 10.2 13.5 11.0 6.0 4.6
Adjusted                
Capital One Financial Corporation Original 11.1 6.4 12.4 7.9 14.6 10.9 10.6 6.8
Adjusted                
Citigroup Inc. Original 15.3 7.7 15.5 9.2 18.5 12.4 10.2 6.1
Adjusted                
Deutsche Bank Trust Corporation Original 34.1 30.1 34.1 30.1 34.3 31.2 13.9 12.2
Adjusted                
The Goldman Sachs Group, Inc. Original 13.6 7.6 15.6 9.0 18.7 11.7 9.3 5.8
Adjusted                
HSBC North America Holdings Inc. Original 15.7 7.0 17.3 8.8 22.6 13.0 10.0 5.0
Adjusted                
JPMorgan Chase & Co. Original 12.0 6.8 13.7 8.9 16.0 11.2 8.5 5.6
Adjusted                
Morgan Stanley Original 16.4 7.7 18.4 9.3 22.0 12.2 8.3 4.5
Adjusted                
Northern Trust Corporation Original 10.8 8.7 11.4 9.8 13.2 12.0 7.5 6.3
Adjusted                
The PNC Financial Services Group, Inc. Original 10.6 6.1 12.0 7.5 14.6 9.8 10.2 6.4
Adjusted                
State Street Corporation Original 13.0 6.6 15.9 10.3 18.2 11.4 6.9 4.3
Adjusted                
TD Group US Holdings LLC Original 13.1 8.7 13.2 8.7 14.3 10.0 8.3 5.2
Adjusted                
U.S. Bancorp Original 9.6 6.2 11.3 7.8 13.3 10.2 9.5 6.6
Adjusted                
Wells Fargo & Company Original 11.1 6.1 12.6 7.7 15.8 11.0 9.4 5.8
Adjusted                

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2016 by the bank holding companies in their annual capital plans and the minimum ratios incorporating any adjustments to capital distributions made by a bank holding company after reviewing the Federal Reserve's stress test. The minimum capital ratios are for the period 2016:Q1 to 2018:Q1 and do not necessarily occur in the same quarter.

Source: Federal Reserve estimates in the severely adverse scenario.

Required minimum capital ratios in CCAR 2016
Regulatory ratio Minimum
Common equity tier 1 capital ratio 4.5 percent
Tier 1 capital ratio 6 percent
Total capital ratio 8 percent
Tier 1 leverage ratio 4 percent

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework. See 12 CFR 217. The use of the advanced approaches for calculating risk-weighted assets for projected regulatory capital ratios has been delayed indefinitely. See 12 CFR 225(d)(8).

Table 6B. Projected minimum regulatory capital ratios in the severely adverse, 2016:Q1 to 2018:Q1:
Large and noncomplex BHCs
Bank holding company Capital actions Common equity tier 1
capital ratio (%)
Tier 1
capital ratio (%)
Total capital
ratio (%)
Tier 1 leverage ratio (%)
Actual 2015:Q4 Projected minimum Actual 2015:Q4 Projected minimum Actual 2015:Q4 Projected minimum Actual 2015:Q4 Projected minimum
Ally Financial Inc. Original 9.2 5.2 11.1 6.8 12.5 8.8 9.7 5.9
Adjusted                
BancWest Corporation Original 12.3 9.0 12.3 9.0 14.6 11.5 10.1 7.4
Adjusted                
BB&T Corporation Original 10.3 6.1 11.8 7.8 14.3 10.1 9.8 6.4
Adjusted                
BBVA Compass Bancshares, Inc. Original 10.7 6.4 11.1 6.7 13.7 9.3 9.0 5.4
Adjusted                
BMO Financial Corp. Original 11.9 5.9 11.9 6.4 14.9 9.6 9.3 4.9
Adjusted                
Citizens Financial Group, Inc. Original 11.7 7.7 12.0 7.9 15.3 10.6 10.5 6.9
Adjusted                
Comerica Incorporated Original 10.5 6.8 10.5 6.8 12.7 9.1 10.2 6.5
Adjusted                
Discover Financial Services Original 13.9 8.7 14.7 9.4 16.5 11.2 12.9 8.2
Adjusted                
Fifth Third Bancorp Original 9.8 5.9 10.9 7.2 14.1 10.6 9.5 6.3
Adjusted                
Huntington Bancshares Incorporated Original 9.8 5.6 10.5 6.9 12.6 9.2 8.8 5.5
Adjusted                
KeyCorp Original 10.9 6.4 11.4 7.3 13.0 9.4 10.7 6.4
Adjusted                
M&T Bank Corporation Original 11.1 4.6 12.7 5.3 14.9 7.5 10.9 4.5
Adjusted 11.1 5.0 12.7 6.2 14.9 8.4 10.9 5.3
MUFG Americas Holdings Corporation Original 13.6 10.2 13.6 10.2 15.6 12.3 11.4 7.1
Adjusted                
Regions Financial Corporation Original 10.9 6.2 11.7 7.5 13.9 10.2 10.3 6.5
Adjusted                
Santander Holdings USA, Inc. Original 12.0 11.9 13.5 12.9 15.3 14.7 11.6 10.1
Adjusted                
SunTrust Banks, Inc. Original 10.0 6.4 10.8 7.5 12.5 10.0 9.7 6.8
Adjusted                
Zions Bancorporation Original 12.2 6.0 14.1 7.1 16.1 8.9 11.3 5.6
Adjusted                

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2016 by the bank holding companies in their annual capital plans and the minimum ratios incorporating any adjustments to capital distributions made by a bank holding company after reviewing the Federal Reserve's stress test. The minimum capital ratios are for the period 2016:Q1 to 2018:Q1 and do not necessarily occur in the same quarter.

Source: Federal Reserve estimates in the severely adverse scenario.

Required minimum capital ratios in CCAR 2016
Regulatory ratio Minimum
Common equity tier 1 capital ratio 4.5 percent
Tier 1 capital ratio 6 percent
Total capital ratio 8 percent
Tier 1 leverage ratio 4 percent

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework. See 12 CFR 217. The use of the advanced approaches for calculating risk-weighted assets for projected regulatory capital ratios has been delayed indefinitely. See 12 CFR 225(d)(8).

Table 7.A. Projected minimum regulatory capital ratios in the adverse, 2016:Q1 to 2018:Q1:
LISCC and large and complex BHCs
Bank holding company Capital actions Common equity tier 1
capital ratio (%)
Tier 1
capital ratio (%)
Total capital
ratio (%)
Tier 1 leverage ratio (%)
Actual 2015:Q4 Projected minimum Actual 2015:Q4 Projected minimum Actual 2015:Q4 Projected minimum Actual 2015:Q4 Projected minimum
American Express Company Original 12.4 9.0 13.5 10.1 15.2 11.8 11.7 8.1
Adjusted                
Bank of America Corporation Original 11.6 9.5 12.9 11.2 15.7 13.6 8.6 7.5
Adjusted                
The Bank of New York Mellon Corporation Original 11.5 9.7 13.1 11.5 13.5 12.0 6.0 5.1
Adjusted                
Capital One Financial Corporation Original 11.1 8.2 12.4 9.7 14.6 12.7 10.6 8.3
Adjusted                
Citigroup Inc. Original 15.3 9.8 15.5 11.2 18.5 14.2 10.2 7.5
Adjusted                
Deutsche Bank Trust Corporation Original 34.1 31.9 34.1 31.9 34.3 32.5 13.9 12.8
Adjusted                
The Goldman Sachs Group, Inc. Original 13.6 9.8 15.6 11.2 18.7 13.7 9.3 6.7
Adjusted                
HSBC North America Holdings Inc. Original 15.7 8.2 17.3 10.3 22.6 13.8 10.0 5.8
Adjusted                
JPMorgan Chase & Co. Original 12.0 9.1 13.7 11.2 16.0 13.1 8.5 6.9
Adjusted                
Morgan Stanley Original 16.4 10.6 18.4 12.8 22.0 15.4 8.3 6.0
Adjusted                
Northern Trust Corporation Original 10.8 9.6 11.4 10.7 13.2 12.6 7.5 6.9
Adjusted                
The PNC Financial Services Group, Inc. Original 10.6 7.7 12.0 9.1 14.6 11.0 10.2 7.7
Adjusted                
State Street Corporation Original 13.0 7.6 15.9 11.2 18.2 12.3 6.9 4.7
Adjusted                
TD Group US Holdings LLC Original 13.1 12.0 13.2 12.0 14.3 13.2 8.3 7.1
Adjusted                
U.S. Bancorp Original 9.6 7.9 11.3 9.4 13.3 11.7 9.5 7.9
Adjusted                
Wells Fargo & Company Original 11.1 8.1 12.6 9.7 15.8 12.6 9.4 7.3
Adjusted                

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2016 by the bank holding companies in their annual capital plans and the minimum ratios incorporating any adjustments to capital distributions made by a bank holding company after reviewing the Federal Reserve's stress test. The minimum capital ratios are for the period 2016:Q1 to 2018:Q1 and do not necessarily occur in the same quarter.

Source: Federal Reserve estimates in the adverse scenario.

Required minimum capital ratios in CCAR 2016
Regulatory ratio Minimum
Common equity tier 1 capital ratio 4.5 percent
Tier 1 capital ratio 6 percent
Total capital ratio 8 percent
Tier 1 leverage ratio 4 percent

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework. See 12 CFR 217. The use of the advanced approaches for calculating risk-weighted assets for projected regulatory capital ratios has been delayed indefinitely. See 12 CFR 225(d)(8).

Table 7B. Projected minimum regulatory capital ratios in the adverse, 2016:Q1 to 2018:Q1:
Large and noncomplex BHCs
Bank holding company Capital actions Common equity tier 1
capital ratio (%)
Tier 1
capital ratio (%)
Total capital
ratio (%)
Tier 1 leverage ratio (%)
Actual 2015:Q4 Projected minimum Actual 2015:Q4 Projected minimum Actual 2015:Q4 Projected minimum Actual 2015:Q4 Projected minimum
Ally Financial Inc. Original 9.2 7.2 11.1 8.8 12.5 10.7 9.7 7.7
Adjusted                
BancWest Corporation Original 12.3 11.6 12.3 11.6 14.6 14.0 10.1 9.4
Adjusted                
BB&T Corporation Original 10.3 8.1 11.8 9.7 14.3 11.6 9.8 7.9
Adjusted                
BBVA Compass Bancshares, Inc. Original 10.7 9.0 11.1 9.3 13.7 11.4 9.0 7.4
Adjusted                
BMO Financial Corp. Original 11.9 8.5 11.9 8.9 14.9 12.0 9.3 6.8
Adjusted                
Citizens Financial Group, Inc. Original 11.7 9.7 12.0 9.9 15.3 12.4 10.5 8.5
Adjusted                
Comerica Incorporated Original 10.5 8.5 10.5 8.5 12.7 10.4 10.2 8.1
Adjusted                
Discover Financial Services Original 13.9 10.7 14.7 11.4 16.5 12.9 12.9 9.9
Adjusted                
Fifth Third Bancorp Original 9.8 8.1 10.9 9.4 14.1 12.2 9.5 8.1
Adjusted                
Huntington Bancshares Incorporated Original 9.8 7.7 10.5 8.9 12.6 11.1 8.8 7.0
Adjusted                
KeyCorp Original 10.9 8.3 11.4 9.2 13.0 11.0 10.7 8.1
Adjusted                
M&T Bank Corporation Original 11.1 7.3 12.7 8.0 14.9 9.9 10.9 6.7
Adjusted 11.1 7.7 12.7 8.9 14.9 10.8 10.9 7.5
MUFG Americas Holdings Corporation Original 13.6 12.6 13.6 12.6 15.6 14.0 11.4 8.7
Adjusted                
Regions Financial Corporation Original 10.9 8.5 11.7 9.9 13.9 12.2 10.3 8.5
Adjusted                
Santander Holdings USA, Inc. Original 12.0 12.2 13.5 13.4 15.3 15.1 11.6 11.3
Adjusted                
SunTrust Banks, Inc. Original 10.0 8.1 10.8 9.2 12.5 11.4 9.7 8.2
Adjusted                
Zions Bancorporation Original 12.2 9.4 14.1 10.5 16.1 12.1 11.3 8.3
Adjusted                

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2016 by the bank holding companies in their annual capital plans and the minimum ratios incorporating any adjustments to capital distributions made by a bank holding company after reviewing the Federal Reserve's stress test. The minimum capital ratios are for the period 2016:Q1 to 2018:Q1 and do not necessarily occur in the same quarter.

Source: Federal Reserve estimates in the adverse scenario.

Required minimum capital ratios in CCAR 2016
Regulatory ratio Minimum
Common equity tier 1 capital ratio 4.5 percent
Tier 1 capital ratio 6 percent
Total capital ratio 8 percent
Tier 1 leverage ratio 4 percent

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework. See 12 CFR 217. The use of the advanced approaches for calculating risk-weighted assets for projected regulatory capital ratios has been delayed indefinitely. See 12 CFR 225(d)(8).

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References

23. See 12 CFR 225.8(f)(2)(iv). Return to text

24. See 12 CFR 225.8(e)(4). Return to text

25. These firms are listed in table 6.B and table 7.B. Return to text

26. These firms are listed in table 6.A and table 7.A. Return to text

Last update: July 26, 2016

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