First take: Capital Plan rule

June 2014


Yesterday the Federal Reserve proposed changes to the Capital Plan rule, with comments accepted until August 11, 2014. While some of these changes will be well-received by the banks, the proposal overall continues the trend toward heightened regulatory expectations.

  1. The Fed raises the bar on the severity of the BHC-designed stress scenarios.
  2. The Fed proposes saving Thanksgiving, Hanukkah, Christmas, and New Year’s.
  3. Mid-cycle DFAST also moved back one quarter, preserving the 4th of July.
  4. Capital distributions are restricted if actual capital issuance falls below planned levels.
  5. Foreign-owned BHCs continue to be subject to the Capital Plan rule until their parent IHC becomes subject to it.

This First take elaborates on these key points.

Contact us

Dan Ryan
US Banking and Capital Markets Leader
Tel: +1 (646) 471 8488

Alison Gilmore
US Asset and Wealth Management Marketing Leader
Tel: +1 (646) 471 0588