The Federal Reserve's February 3 final rule separates three questions that a single bank-size headline cannot answer: whether capital-planning requirements apply, whether a firm qualifies as large and noncomplex, and when existing requirements cease to apply. The change was scheduled for March 6, so it was not yet effective at this February 5 coverage date. [2017-02257][2016-23629]

Ordinary entry for a top-tier U.S. bank holding company starts at $50 billion in average consolidated assets, subject to transition provisions. The Board can also impose applicability by order. Continuing applicability uses a different test: consolidated assets must fall below $50 billion in each of four consecutive FR Y-9C reports, with effect at the fourth report's as-of date. A low four-quarter average alone is not that exit test. [2017-02257][2016-23629]

For covered companies, large-and-noncomplex classification looks to the preceding December 31. It requires average consolidated assets below $250 billion, defined average nonbank assets below $75 billion and no U.S. global systemically important bank designation. The nonbank measure has a special 2017 calculation; it should not be assumed to match consolidated-asset averaging. [2017-02257][2016-23629]

The September proposal supplies a useful comparison. It included a foreign-exposure ceiling below $10 billion and expressly retained quantitative CCAR assessment while placing qualitative review in supervision. The final definition instead uses the systemic-bank exclusion. Qualitative CCAR objection relief thus describes a particular regulatory change, not withdrawal of supervision or proof that any bank has become safer. [2017-02257][2016-23629]

Source documents

  1. Amendments to the Capital Plan and Stress Test Rules; Regulations Y and YYhttps://www.govinfo.gov/content/pkg/FR-2017-02-03/html/2017-02257.htm
  2. Amendments to the Capital Plan and Stress Test Ruleshttps://www.govinfo.gov/content/pkg/FR-2016-09-30/html/2016-23629.htm