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TCH Files Comment Letter on Proposed Amendments to the Capital Plan and Stress Test Rules

The Clearing House Association (TCH) comment letter to the U.S. Banking Agencies expresses general support for the agencies’ proposed rules regarding amendments to the capital plan and stress test rules, with several recommended enhancements. Most notably, TCH commends the proposed rules’ three-month shift forward in the start date of the annual capital plan and supervisory and company-run stress test cycles. The proposed rules would prevent a BHC from making capital distributions in a given quarter to the extent that it does not execute capital issuances for that same quarter reflected in its capital plan. TCH urges the Federal Reserve to abandon this proposed mechanical approach altogether or, at most, adopt an alternative requirement that would allow a BHC to make planned distributions in a given quarter so long as it has completed capital issuances totaling at least the amount necessary to maintain (i) the required Tier 1 Common 5% ratio and (ii) remain above the applicable minimum regulatory capital ratios under CCAR’s severely adverse scenario, taking into account the planned distribution on a pro forma basis. Further, TCH does not believe that the NPR commentary’s expectation that the bank-designed stress scenario result in an impact on projected pre-tax net income that is “at least as severe as” the results of the company-run stress test under the Federal Reserve’s severely adverse scenario contributes to robust stress scenario development, and should therefore be eliminated from the commentary to the final rules.

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