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To: Chief Executive Officers of All National Banks and Federal Savings Associations, Department and Division Heads, All Examining Personnel, and Other Interested Parties

Description: Notice of Proposed Rulemaking—Technical and Conforming Changes


The Office of the Comptroller of the Currency (OCC) proposes to implement several technical and conforming changes to the OCC’s Annual Stress Test rule (12 CFR 46). The proposed rule would change the range of possible “as-of” dates used in the global market shock component to conform to changes recently made by the Board of Governors of the Federal Reserve System to its stress testing regulations. The proposed rule would also change the transition period for an institution that becomes an over $50 billion covered institution. Finally, the proposed rule would make certain technical changes to clarify the requirements of the OCC’s stress testing regulation. The notice of proposed rulemaking was issued in the Federal Register on October 27, 2017, with a 60-day comment period.

Note for Community Banks

The annual stress test under section 165(i) of the Dodd–Frank Wall Street Reform and Consumer Protection Act only applies to national banks and federal savings associations with more than $10 billion in assets.


The proposal would

  • extend the range of possible “as-of” dates used in the trading and counterparty default component of the annual stress tests by three months. The rule currently states that the as-of date may occur between January 1 and March 1 of the calendar year of the stress test. The proposed rule extends this window to incorporate the prior three months, so that the new window would be October 1 through March 1.
  • extend the transition process for certain covered national banks and federal savings associations that cross the $50 billion asset threshold.
  • make technical and linguistic changes to the OCC’s stress testing regulation in order to promote clarity. The proposed rule would remove certain obsolete transition provisions. The proposed rule would also change the defined term “over $50 billion covered institution” to “$50 billion or over covered institution” in order to be more precise.

Further Information

Please contact Hein Bogaard, Lead Economic Expert, International Analysis and Banking Condition, (202) 649-5450, Andrew Tschirhart, Financial Analyst, Large Bank Supervision, (202) 649-6210, or Kari Falkenborg, Senior Financial Analyst, Midsize and Community Bank Supervision, (312) 917-5000.


Morris R. Morgan
Senior Deputy Comptroller for Large Bank Supervision

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