Resubmissions and Feedback

Consistent with the capital plan rule, the BHCs with capital plans that the Federal Reserve objected to are required to resubmit their capital plans following substantial remediation of the issues that led to the objection. In addition, the Federal Reserve may require a capital plan resubmission in future quarters if a BHC exhibits a material decline in performance or if a deteriorating outlook materially increases BHC-specific risks.²⁶ As detailed in the capital plan rule, a BHC must update and resubmit its capital plan if it determines there has been or will be a material change in the BHC's risk profile (including a material change in its business strategy or any material risk exposures), financial condition, or corporate structure since the BHC adopted the capital plan.²⁷ Further, the Federal Reserve may direct a BHC to revise and resubmit its capital plan for a number of reasons, including if changes in the macroeconomic outlook that could have a material impact on a BHC's risk profile and financial condition require the use of updated scenarios.²⁸

Following the conclusion of CCAR, all 30 BHCs will receive detailed assessments of their capital plans and the full range of practices supporting their internal capital assessment processes, including feedback on areas where the plans and processes need to be strengthened. This feedback will be based on assessments of all major elements of the 2014 capital plans. These assessments will provide detailed discussions of how each BHC is progressing in efforts to meet the Federal Reserve's supervisory expectations for capital planning, and will clarify specific areas that each BHC must address in order to strengthen their capital planning processes.

References

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