Policy Statement on the Scenario Design Framework for Stress Testing, 59533-59547 [2017-26858]
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supervisory models are not provided as
required by the Capital Assessments and
Stress Testing (FR Y–14) information
collection or are reported erroneously, then
a conservative value will be assigned to the
specific data based on all available data
reported by covered companies, depending
on the extent of the data deficiency. If the
data deficiency is severe enough that a
modeled estimate cannot be produced for a
portfolio segment or portfolio, then the
Federal Reserve may assign a conservative
rate (e.g., 10th or 90th percentile PPNR or
loss rate, respectively) to that segment or
portfolio.
This policy reflects a conservative
assumption given a lack of information
sufficient to produce a risk-sensitive estimate
of losses or revenues. This policy promotes
policy 1.3 by ensuring consistent treatment
for all covered companies that report data
deemed insufficient to produce a modeled
estimate. Finally, this policy is simple and
transparent, consistent with Principle 1.4.
2.10. Treatment of Immaterial Portfolio Data
The Federal Reserve makes a distinction
between missing or insufficient data reported
by covered companies for material and
immaterial portfolios. To limit regulatory
burden, the Federal Reserve allows covered
companies not to report detailed loan-level or
portfolio-level data for loan types that are not
material as defined in the FR Y–14 reporting
instructions. In these cases, a loss rate
representing the median rates among covered
companies for whom the rate is calculated
will be applied to immaterial portfolios. This
approach is consistent across covered
companies, simple, and transparent,
promoting Principles 1.3 and 1.4.
Question number 5: Each of the modeling
policies described in Section 2 are consistent
with at least one of the central principles of
supervisory stress test modeling described
herein. Are there other policies the Federal
Reserve could implement to further promote
the principles of independence, forwardlooking perspective, consistency and
comparability, simplicity, robustness and
stability, or conservativism, or that would
focus on the ability to evaluate the impact of
severe economic stress?
3. Principles and Policies of Supervisory
Model Validation
Independent and comprehensive model
validation is key to the credibility of the
supervisory stress test. An independent unit
of validation staff within the Federal Reserve,
with input from an advisory council of
academic experts not affiliated with the
Federal Reserve, ensures that stress test
models are subject to effective challenge,
defined as critical analysis by objective,
informed parties that can identify model
limitations and recommend appropriate
changes.
The Federal Reserve’s supervisory model
validation program, built upon the principles
of independence, technical competence, and
stature, is able to subject models to effective
challenge, expanding upon supervisory
modeling teams’ efforts to manage model risk
and confirming that supervisory models are
appropriate for their intended uses. The
supervisory model validation program
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produces reviews that are consistent,
thorough, and comprehensive. Its structure
ensures independence from the Federal
Reserve’s model development function, and
its prominent role in communicating the
state of model risk to the Board of Governors
assures its stature within the Federal Reserve.
3.1. Structural Independence
The management and staff of the internal
model validation program are structurally
independent from the model development
teams. Validators do not report to model
developers, and vice versa. This ensures that
model validation is conducted and overseen
by objective parties. Validation staff’s
performance criteria include an ability to
review all aspects of the models rigorously,
thoroughly, and objectively, and to provide
meaningful and clear feedback to model
developers and users.
In addition, a council of external academic
experts provides independent advice on the
Federal Reserve’s process to assess models
used in the supervisory stress test. In
biannual meetings with Federal Reserve
officials, members of the council discuss
selected supervisory models, after being
provided with detailed model documentation
for those models, including some
confidential supervisory information. The
documentation and discussions enable the
council to assess the effectiveness of the
models used in the supervisory stress tests
and of the overarching model validation
program.
3.2. Technical Competence of Validation
Staff
The model validation program is designed
to provide thorough, high-quality reviews
that are consistent across supervisory
models.
First, the model validation program
employs technically expert staff with
knowledge across model types. Second,
reviews for every supervisory model follow
the same set of review guidelines, and take
place on an ongoing basis. The model
validation program is comprehensive, in the
sense that validators assess all models
currently in use, and expand the scope of
validation beyond basic model use, and cover
both model soundness and performance.
The model validation program covers three
main areas of validation: (1) Conceptual
soundness; (2) ongoing monitoring; and (3)
outcomes analysis. Validation staff evaluate
all aspects of model development,
implementation, and use, including but not
limited to theory, design, methodology, input
data, testing, performance, documentation
standards, implementation controls
(including access and change controls), and
code verification. Finally, the model
validation program seeks to balance technical
expertise with fresh scrutiny of supervisory
models. In order to provide a new
perspective on established models and
practices, validation staff are re-allocated
across models at regular intervals.
3.3. Stature of Validation Function
Through clear communication and
participation in the model decision making
process, the validation function has the
influence and stature within the Federal
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59533
Reserve to ensure that any issues and
deficiencies are appropriately addressed in a
timely and substantive manner.
The model validation program
communicates its findings and
recommendations regarding model risk to all
internal stakeholders. Validators provide
detailed feedback to model developers and
provide thematic feedback or observations on
the overall system of models to the
management of the modeling teams. Model
validation feedback is also communicated to
the users of supervisory model output for use
in their deliberations and decisions about
supervisory stress testing. In addition, the
Federal Reserve Board’s Director of
Supervision and Regulation approves all
models used in the supervisory stress test in
advance of each exercise, based on
validators’ recommendations, development
responses, and suggestions for risk mitigants.
In several cases, models have been modified
or implemented differently based on
validators’ feedback. The advisory council of
academic experts also contributes to the
stature of the Federal Reserve’s validation
program, by providing an external point of
view on modifications to supervisory models
and on validation program governance.
Ultimately, the validation program serves
to inform the Board of Governors about the
state of model risk in the overall stress testing
program, along with ongoing practices to
control and mitigate model risk.
By order of the Board of Governors of the
Federal Reserve System, December 7, 2017.
Ann E. Misback,
Secretary of the Board.
[FR Doc. 2017–26857 Filed 12–14–17; 8:45 am]
BILLING CODE 6210–01–P
FEDERAL RESERVE SYSTEM
12 CFR Part 252
[Regulation YY; Docket No. OP–1588]
Policy Statement on the Scenario
Design Framework for Stress Testing
Board of Governors of the
Federal Reserve System (Board).
ACTION: Proposed rule; policy statement
with request for public comment.
AGENCY:
The Board is requesting
public comment on amendments to its
policy statement on the scenario design
framework for stress testing. The
proposed amendments to the policy
statement would clarify when the Board
may adopt a change in the
unemployment rate in the severely
adverse scenario of less than 4
percentage points; institute a countercyclical guide for the change in the
house price index in the severely
adverse scenario; and provide notice
that the Board plans to incorporate
wholesale funding costs for banking
organizations in the scenarios. The
Board would continue to use the policy
SUMMARY:
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statement to develop the
macroeconomic scenarios and
additional scenario components that are
used in the supervisory and companyrun stress tests conducted under the
Board’s stress test rules and the Board’s
capital plan rule.
DATES: Comments must be received by
January 22, 2018.
ADDRESSES: You may submit comments,
identified by Docket No. OP–1588 by
any of the following methods:
• Agency website: https://
www.federalreserve.gov. Follow the
instructions for submitting comments at
https://www.federalreserve.gov/
generalinfo/foia/ProposedRegs.aspx.
• Federal eRulemaking Portal: https://
www.regulations.gov. Follow the
instructions for submitting comments.
• Email:
regs.comments@federalreserve.gov.
Include the docket number and RIN
number in the subject line of the
message.
• Fax: (202) 452–2819 or (202) 452–
3102.
• Mail: Ann Misback, Secretary,
Board of Governors of the Federal
Reserve System, 20th Street and
Constitution Avenue NW, Washington,
DC 20551.
All public comments will be made
available on the Board’s website at
https://www.federalreserve.gov/
generalinfo/foia/ProposedRegs.aspx as
submitted, unless modified for technical
reasons. Accordingly, your comments
will not be edited to remove any
identifying or contact information.
Public comments may also be viewed
electronically or in paper form in Room
3515, 1801 K St. NW (between 18th and
19th Streets NW), Washington, DC
20006 between 9:00 a.m. and 5:00 p.m.
on weekdays. For security reasons, the
Board requires that visitors make an
appointment to inspect comments. You
may do so by calling (202) 452–3684.
Upon arrival, visitors will be required to
present valid government-issued photo
identification and to submit to security
screening in order to inspect and
photocopy comments.
FOR FURTHER INFORMATION CONTACT: Lisa
Ryu, Associate Director, (202) 263–4833,
Joseph Cox, Supervisory Financial
Analyst, (202) 452–3216, or Aurite
Werman, Financial Analyst (202) 263–
4802, Division of Supervision and
Regulation; Benjamin W. McDonough,
Assistant General Counsel, (202) 452–
2036, or Julie Anthony, Counsel, (202)
475–6682, Legal Division; or William
Bassett, Associate Director, (202) 736–
5644, Luca Guerrieri, Deputy Associate
Director, (202) 452–2550, or Bora
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Durdu, Chief, (202) 452–3755, Division
of Financial Stability.
SUPPLEMENTARY INFORMATION:
I. Background
A. Supervisory Scenarios
Pursuant to the Board’s stress test
rules, the Board conducts supervisory
stress tests of bank holding companies
and U.S. intermediate holding
companies subsidiaries of foreign
banking organizations with total
consolidated assets of $50 billion or
more (covered companies) and requires
covered companies to conduct semiannual company-run stress tests.1 In
addition, savings and loan holding
companies, state member banks with
greater than $10 billion in total
consolidated assets, and bank holding
companies with assets of more than $10
billion but less than $50 billion are
required to conduct annual companyrun stress tests.2
To conduct the supervisory stress
tests, the Board develops three
scenarios—a baseline, adverse, and
severely adverse scenario—and projects
a firm’s balance sheet, risk-weighted
assets, net income, and resulting poststress capital levels and regulatory
capital ratios under each scenario.
Similarly, a firm subject to company-run
stress tests under the Board’s rules uses
the same adverse and severely adverse
scenarios that apply in the supervisory
stress test to conduct an annual
company-run stress test. The scenarios
also serve as an input into a covered
company’s capital plan under the
Board’s capital plan rule (12 CFR 225.8),
and the Federal Reserve also uses these
scenarios to evaluate each firm’s capital
plan in the supervisory post-stress
capital assessment.3
On November 29, 2013, the Board
adopted a final policy statement on its
scenario design framework for stress
testing (policy statement).4 The policy
statement outlined the characteristics of
the supervisory stress test scenarios and
explained the considerations and
procedures that underlie the
formulation of these scenarios. The
1 12 CFR part 252, subparts E and F. In addition,
the supervisory stress test rules would apply to any
nonbank financial company supervised by the
Board that becomes subject to these requirements
pursuant to a rule or order of the Board. Currently,
no nonbank financial companies supervised by the
Board are subject to the capital planning or stress
test requirements.
2 12 CFR part 252, subpart B.
3 Bank holding companies with $50 billion or
more in total consolidated assets and U.S.
intermediate holding companies of foreign banking
organizations additionally conduct mid-cycle
company-run stress tests under scenarios that they
develop. See 12 CFR 252.55.
4 See 12 CFR part 252, appendix A.
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considerations and procedures
described in the policy statement apply
to the Board’s stress testing framework,
including to the stress tests required
under 12 CFR part 252, subparts B, E,
and F, and the Board’s capital plan rule.
The policy statement describes in
greater detail than the stress test rules
the baseline, adverse, and severely
adverse scenarios. The policy statement
also describes the Board’s approach for
developing these three macroeconomic
scenarios and additional components of
the stress test scenarios, which apply to
a subset of covered companies.
As described in the policy statement,
the severely adverse scenario is
designed to reflect conditions that have
characterized post-war U.S. recessions
(the ‘‘recession approach’’). Historically,
recessions typically feature increases in
the unemployment rate and contractions
in aggregate incomes and economic
activity. In light of the typical comovement of measures of economic
activity during economic downturns,
such as the unemployment rate and
gross domestic product, in developing
the severely adverse scenario, the Board
first specifies a path for the
unemployment rate and then develops
paths for other measures of activity
broadly consistent with the course of
the unemployment rate.
The Board’s scenario design
framework includes a counter-cyclical
design element in the change in the
unemployment rate in the severely
adverse scenario. The policy statement
provides that the Board anticipates the
unemployment rate in the severely
adverse scenario would increase by
between 3 and 5 percentage points from
its initial level. However, if a 3 to 5
percentage point increase in the
unemployment rate does not raise the
level of the unemployment rate to at
least 10 percent, the path of the
unemployment rate in most cases will
be specified so as to raise the
unemployment rate to at least 10
percent. The policy statement also notes
that the typical increase in the
unemployment rate in the severely
adverse scenario will be about 4
percentage points. The policy statement
provides that the Board intends to set
the unemployment rate at the higher
end of the 3 to 5 percentage point range
if the Board believes that cyclical
systemic risks are high (as they would
be after a sustained long expansion),
and to the lower end of the range if
cyclical systemic risks are low (as they
would be in the earlier stages of a
recovery).
The policy statement provides that
economic variables included in the
scenarios may change over time, or that
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the Board may augment the recession
approach to account for salient risks.5
The Board has not historically captured
stress to funding markets in the
supervisory stress test exercise.
However, it is exploring the inclusion of
such a stress in the scenarios, given the
potential impact that funding shocks
could have on firms subject to the
supervisory stress test.
B. Review of Stress Test Exercises
The Federal Reserve routinely reviews
its experience with each year’s stress
testing and capital planning programs as
implemented through DFAST and
CCAR. These reviews have included
formal engagements with public interest
groups, meetings with academics in the
fields of economics and finance, and
internal assessments.
In the course of its review of the stress
test exercises, the Federal Reserve has
received feedback on the Board’s
framework for designing stress
scenarios. Some participants advocated
developing a structured process for
strengthening scenario design over time.
Other participants were concerned that
the Federal Reserve would be pressured
to reduce the severity of the scenario
over time. As part of its internal
assessment of the stress test exercises,
the Federal Reserve also considered
ways to further enhance the
countercyclical elements, transparency,
and risk coverage of the scenario design
framework.
After considering feedback received
in these reviews and possible
improvements to the methodology for
specifying the macroeconomic scenarios
used in the supervisory stress test and
the annual company-run stress tests, the
Board is proposing to modify the policy
statement to enhance the
countercyclicality and transparency of
the Board’s scenario design framework
and improve the risk coverage of the
scenarios.
II. Review of the Supervisory Scenarios
A. Unemployment and House Prices in
the Severely Adverse Scenario
The Board investigated possible
improvements to the methodology for
specifying the macroeconomic scenarios
used in supervisory and company-run
stress tests. A main area of inquiry was
the severity of macroeconomic scenarios
used in previous stress test exercises. As
noted, the scenario design framework
was formulated to increase the severity
of the severely adverse scenario during
economic expansions in order to limit
the procyclicality of the financial
system by increasing the resilience of
the banking system to building risks.
The review evaluated the path of key
variables in the severely adverse
scenarios since 2011, and determined
that amendments to the scenario design
framework could further limit
procyclicality.6
The severity of a scenario can be
gauged by considering both the
maximum (or minimum) levels obtained
by key variables and changes of the
variables from their starting points.
Table 1 shows the peak and change in
the unemployment rate in the
supervisory severely adverse scenarios
since 2011.7 The peak unemployment
rate in the severely adverse scenario has
been falling since CCAR 2012 as the
economy improved. Beginning in 2016,
the countercyclical element of the
Board’s scenario design framework
acted to increase scenario severity, so
while the peak level of the
unemployment rate remained about the
same, the change in the unemployment
rate increased. The countercyclical
design of the scenarios is also reflected
in the change in real GDP, which, in
2017, declined by the largest amount
since 2012.
TABLE 1—UNEMPLOYMENT RATE AND REAL GDP IN THE SEVERELY ADVERSE SCENARIO
Stress test exercise
2011 a
2012 a
2013
2014
2015
2016
2017
Great
recession b
Severe
recessions c
Panel A: Developments as published in the supervisory scenarios
Unemployment Rate:
Peak Level (pct.) ............................................
Change Start-to-peak (pp.) ............................
Real GDP:
Change Start-to-trough (pct.) .........................
11.1
1.5
12.6
3.6
12.1
4.0
11.3
4.0
10.1
4.0
10.0
5.0
10.0
5.3
10.0
4.5
9.3
3.6
¥4.1
¥6.9
¥4.8
¥4.7
¥4.7
¥6.2
¥6.6
¥4.7
¥3.4
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Note:
a In 2011 and 2012 the scenario was referred to as the ‘‘supervisory stress scenario.’’
b Great Recession is defined as that which occurred in Q4:2007–Q2:2009.
c Recessions classified as severe: 1957:Q3–1958:Q2, 1973:Q4–1975:Q1, 1981:Q3–1982:Q4, and 2007:Q4–2009:Q2.
The Board also evaluated its approach
to developing the path of house prices,
which is a key scenario variable, to
assess whether it could improve the
transparency of the measure and to
identify a guide that would formalize
the Board’s countercyclical objectives.
To date, the Board has developed the
path of house prices using a judgmental
approach, and has not established a
quantitative guide for the trajectory of
house prices.
As demonstrated in Panel A of table
2, the existing approach to house prices
has resulted in increasing severity over
time. The declines in the nominal house
price index (nominal HPI) from the start
to the trough have increased from 21
percent (in 2012 and 2013) to about 25–
26 percent (in 2014 through 2017). The
increased severity in the decline in
nominal HPI in supervisory scenarios
beginning in 2014 offset the rise in
observed house prices over that period,
and hence limited procyclicality.
Assessing the procyclicality of house
price paths over time is complicated by
the fact that house prices—in contrast to
the unemployment rate—naturally trend
upward over time. The ratio of nominal
house prices to nominal, per capita,
disposable personal income (HPI–DPI
ratio, henceforth), does not exhibit an
upward trend and, as such, provides an
alternative way to assess the
5 For example, if scenario variables do not capture
material risks to capital, or if historical
relationships between macroeconomic variables
change such that one variable is no longer an
appropriate proxy for another, the Board may add
variables to a supervisory scenario. The Board may
also include additional scenario components or
additional scenarios that are designed to capture the
effects of different adverse events on revenue,
losses, and capital.
6 For completeness, the tables present data from
the 2017 severely adverse scenario, however, this
data was not available at the time of the review
conducted by the Board. The data from 2017 was
generally consistent with the analysis of the earlier
scenarios.
7 The change in real gross domestic product (real
GDP) is also presented as an additional gauge of
severity because the path of real GDP is formulated
based on the path of the unemployment.
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procyclicality of the scenarios’ house
price paths. The severity of a scenario
depends on both the change and the
trough level of the HPI–DPI ratio. Panel
A of table 2 indicates that the change in
the HPI–DPI ratio increased in absolute
terms in the years 2014 to 2017
compared to the years 2012 and 2013.
However, the trough of the HPI–DPI
ratio achieved in the severely adverse
scenarios has generally moved up since
2012. Scenarios with higher HPI–DPI
troughs may be less severe even if they
feature the same decline in the ratio.
TABLE 2—HOUSE PRICES IN THE SEVERELY ADVERSE SCENARIO
Stress test exercise
2011 a
2012 a
2013
2014
2015
2016
2017
Panel A: Developments as published in the supervisory scenarios
Nominal HPI:
Change Start-to-trough (pct.) .........................
¥11
¥21
¥21
¥26
¥26
¥25
Trough Level c ................................................
124
106
111
116
126
135
HPI–DPI Ratio:
Change Start-to-trough (pct.) .........................
¥11
¥19
¥18
¥27
¥25
¥25
Trough Level c ................................................
89
76
78
75
79
82
Great
recession b
Housing
recessions c
¥25
134
¥30
130
2.5
....................
¥24
81
¥41
87
¥25
95
Panel B: Developments as implied by the HPI–DPI Guide
Nominal HPI:
Change Start-to-trough (pct.) .........................
Trough Level c ................................................
HPI–DPI Ratio:
Change Start-to-trough (pct.) .........................
Trough Level d ................................................
¥25
104
¥27
98
¥27
102
¥24
119
¥25
127
¥25
134
¥26
134
¥30
130
2.5
....................
¥25
75
¥25
70
¥25
72
¥25
76
¥25
80
¥25
82
¥25
79
¥41
87
¥25
95
Note:
a In 2011 and 2012 the scenario was referred to as the ‘‘supervisory stress scenario.’’
b Great Recession is defined as that which occurred in Q4:2007–Q2:2009.
c Housing recessions are defined as the following date ranges: 1980–1985, 1989–1996, and 2006–2011. The date-ranges of housing recessions are based on the
timing of house-price retrenchments. These dates were also associated with sustained declines in real residential investment, although, the precise timings of housing
recessions would likely be slightly different were they to be classified based on real residential investment in addition to house prices.
d Both the nominal HPI and HPI–DPI ratios are indexed to 100 in 2000:Q1.
Based on this analysis, the Board
determined that its scenario design
framework could be strengthened by (1)
enhancing the counter-cyclicality of the
scenarios when conditions at the start of
the exercise already reflected stress; and
(2) improving the transparency of the
scenario design framework by
developing an explicit guide for
formulating the path of house prices in
the severely adverse scenario.
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B. Risk Coverage in Supervisory
Scenarios
The Board also has examined whether
there were important dimensions of risk
that had not featured in supervisory
scenarios to date. The review suggested
that a key risk dimension that had not
been directly addressed in the
supervisory stress test was banking
organizations’ reliance on certain types
of runnable liabilities, which has been
an important source of financial stress
on banking organizations, as well a
channel by which one firm’s distress
affects other firms. For example, shocks
to the costs of short-term wholesale
funding played a prominent role in the
recent financial crisis, and had a notable
effect on firms’ ability to operate as
financial intermediaries. Accordingly,
the Board is exploring incorporating an
increase in the cost of short-term
wholesale funding in its scenarios and
stress tests.
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III. Proposed Amendments to the Policy
Statement
The proposal includes three
modifications to the Board’s scenario
design framework. First, the proposal
would modify the current guide in the
policy statement for the peak
unemployment rate in the severely
adverse scenario to include a
description of the circumstances in
which an increase in the unemployment
rate at the lower end of the 3 to 5
percentage point range suggested by the
guide would be warranted. Second, the
proposal would add to the policy
statement an explicit guide for house
prices in the severely adverse scenario
based on the HPI–DPI ratio that features
both a minimum level and a fixed
change in the HPI–DPI ratio. Third, the
proposal would provide notice that the
Board is exploring the inclusion of an
increase in the cost of funds for banking
organizations as an explicit factor in the
scenarios. Finally, the policy statement
would be amended to update references
and remove obsolete text.
A. Unemployment Rate in the Severely
Adverse Scenario
The proposal would include more
specific guidance for the change in the
unemployment rate when the stress test
is conducted during a period in which
the unemployment rate is already
elevated. The Board currently calibrates
the peak unemployment rate in the
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severely adverse scenario as the greater
of a 3 to 5 percentage point increase
from the unemployment rate at the
beginning of the stress test planning
horizon, or 10 percent. This approach
introduces an element of countercyclicality to the scenario design
process, as lower levels of the
unemployment rate at the beginning of
the stress planning horizons imply a
larger increase in unemployment over
the severely adverse scenario to a level
that is at least consistent with past
severe recessions.
Consistent with the current policy
statement, the Board believes that the
typical increase in the unemployment
rate in the severely adverse scenario
will be about 4 percentage points, and
that a lower increase may be appropriate
in certain circumstances. In determining
the increase in the unemployment rate,
the Board would consider the level of
unemployment at the start of the
scenarios, the strength of the labor
market, and the strength of firms’
balance sheets. The proposed
framework would clarify that the Board
may adopt an increase in the
unemployment rate of less than 4
percentage points when the
unemployment rate at the start of the
scenarios is elevated but the labor
market is judged to be strengthening and
higher-than-usual credit losses
stemming from previously elevated
unemployment rates were either already
realized—or are in the process of being
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realized—and thus removed from banks’
balance sheets. Evidence of a
strengthening labor market could
include a declining unemployment rate,
steadily expanding nonfarm payroll
employment, or improving labor force
participation. Evidence that credit
losses are being realized could include
elevated charge-offs on loans and leases,
loan-loss provisions in excess of gross
charge-offs, or losses being realized in
securities portfolios that include
securities that are subject to credit risk.
This proposed change would keep the
unemployment rate in the
macroeconomic scenario broadly similar
to that in previous scenarios except
during times when a smaller change
would be appropriate based on the
credit cycle. By adopting a smaller
change in the unemployment rate when
the economy was recovering and losses
had already been broadly recognized by
the industry, the proposal would
complement the current countercyclical design elements.
Question number 1: In connection
with this proposal, the Federal Reserve
considered an alternative guide for the
unemployment rate, in which the path
of the unemployment rate would reach
the lesser of a level 4 percentage points
above its level at the beginning of the
scenario or 11 percent. On average, this
alternative would increase the severity
of severely adverse scenarios but also
would be more countercyclical than the
current guide. What are the advantages
or disadvantages to this alternative
relative to the proposed guide?
B. House Prices in the Severely Adverse
Scenario
The policy statement would also be
amended to include guidance for the
path of the nominal house price index
in the severely adverse scenario. The
nominal house price index is a key
scenario variable, and providing explicit
guidance for its path over the planning
horizon would enhance the
transparency and countercyclical design
of the scenario design framework.
The proposal would establish a
quantitative guide for house prices. The
guide for house prices would be
informed by the ratio of the nominal
house price index to nominal per capita
disposable income (HPI–DPI ratio).
Unlike the level of house prices, the
HPI–DPI ratio does not exhibit a trend
over time. Under most circumstances,
the decline in the HPI–DPI ratio in the
severely adverse scenario is expected to
be 25 percent from its starting value or
enough to bring the ratio down to its
Great Recession trough, whichever is
greater. A rule with both a minimum
change in the ratio and a level of
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severity that the ratio must reach is
consistent with the rule for the path of
the unemployment rate and would
further the Board’s countercyclical goals
in scenario design.
In its analysis, the Board identified
the HPI–DPI trough reached during the
Great Recession as the lowest trough
attained in housing recessions since
1976, and considered this trough an
appropriate basis for explicit guidance
for the path of house prices. Setting a
minimum decline in the HPI–DPI ratio
would ensure that additional economic
stress would be incorporated into the
macroeconomic scenario, even if house
prices were depressed at the outset of
the scenario. The Board would typically
set a minimum decline in the HPI–DPI
ratio of 25 percent from its starting
value. A decline of 25 percent is
consistent with the average decline in
housing recessions (see table 2 in the
Policy Statement) and with the path of
house prices in the supervisory severely
adverse scenarios since 2015.
Procyclicality in house prices would
be limited by setting a maximum level
for the trough of the HPI–DPI ratio in
the severely adverse scenario. This
would increase the severity of the
decline in house prices as house prices
rise relative to disposable personal
incomes, as is the case in times of
economic expansion. When the HPI–DPI
ratio rises above the level at which a 25
percent decline would bring the ratio to
its Great Recession trough, at the start of
the stress test, the change in the ratio
would be greater than 25 percent in
order to bring the ratio to its Great
Recession trough.8 This proposal would
offer a more systematic approach to
specifying house price paths than does
the current approach, and would limit
procyclicality while broadly preserving
the decline in the nominal HPI featured
in recent stress testing cycles.
Question number 2: In connection
with this proposal, the Federal Reserve
considered alternative guides for
projecting house prices, including
guides based on the ratio of the nominal
house price index to an index of
nominal rent prices for residential
housing. What are the advantages or
disadvantages to such alternatives
relative to the proposed guide?
8 The Great Recession trough depends on the
reference date used for indexing. For example, with
nominal HPI and HPI–DPI ratios indexed to 100 in
2000:Q1, a decline in the HPI–DPI index of more
than 25 percent would be necessary to reach the
Great Recession trough of 87 when the HPI–DPI
ratio at the start of the supervisory scenario was 116
or greater.
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59537
C. Incorporating Short-Term Wholesale
Funding Costs in the Adverse and
Severely Adverse Scenarios
To date, the Board’s adverse and
severely adverse scenarios have not
incorporated stress to funding markets.
The proposal states that the Board may
include variables or an additional
components in the scenario to capture
the cost of funds, particularly wholesale
funds, to banking organizations.
Including stress to funding costs in the
scenarios would account for the impact
of increased costs of certain runnable
liabilities on net income and capital of
banking organizations reliant on shortterm wholesale funding. The Board
would not expect to incorporate
wholesale funding costs in the scenarios
before 2019, and would expect to
include wholesale funding costs in the
adverse scenario before the severely
adverse scenario. Accordingly, the
Board would not expect to include a
stress to funding costs in the severely
adverse scenario until 2020 at the
earliest.
Question number 3: What variable or
combinations of variables would best
represent stress to funding costs or
availability in the supervisory
scenarios?
Question number 4: What, if any,
other risks should the Federal Reserve
consider capturing in the supervisory
scenarios?
D. Impact Analysis
Generally, the proposed amendments
would not affect the severity of the
scenarios in a manner that persists
throughout the economic cycle. The one
exception is the introduction of an
increase in the cost of certain runnable
liabilities. Generally, the inclusion of a
stress to wholesale funding would be
expected to increase the stringency of
the stress test. The extent of the
increased stringency would depend on
the implementation of the stress, such
as the type of liabilities stressed, and the
duration and magnitude of the stress
considered.
The proposed unemployment rate
clarification would reduce the
stringency of the scenario if the
economy had already experienced stress
and was recovering, and would not
impact the stringency of the scenario in
other points during the economic cycle.
The house price guide would formalize
an approach that was previously
judgmental with little persistent impact
on the severity of the stress to house
prices in the severely adverse scenarios.
However, the countercyclical element of
the guide would increase the severity of
the stress to house prices when the ratio
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of house prices to disposable personal
income was particularly elevated at the
start of the stress test.
Question number 5: The Federal
Reserve is proposing changes to the
Scenario Design Policy Statement to
enhance the countercyclicality, risk
coverage, and transparency of the
scenario development process. Are there
other modifications not included in this
proposal that could further enhance the
scenario development process?
IV. Administrative Law Matters
A. Use of Plain Language
Section 722 of the Gramm-LeachBliley Act (Pub. L. 106–102, 113 Stat.
1338, 1471, 12 U.S.C. 4809) requires the
Federal banking agencies to use plain
language in all proposed and final rules
published after January 1, 2000. The
Board has sought to present the
proposed rule in a simple and
straightforward manner, and invites
comment on the use of plain language.
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B. Paperwork Reduction Act
In accordance with the requirements
of the Paperwork Reduction Act of 1995
(44 U.S.C. 3506), the Board has
reviewed the proposed policy statement
to assess any information collections.
There are no collections of information
as defined by the Paperwork Reduction
Act in the proposal.
C. Regulatory Flexibility Act Analysis
In accordance with section 3(a) of the
Regulatory Flexibility Act (RFA), the
Board is publishing an initial regulatory
flexibility analysis of the proposed
policy statement. The RFA, 5 U.S.C. 601
et seq., requires each federal agency to
prepare an initial regulatory flexibility
analysis in connection with the
promulgation of a proposed rule, or
certify that the proposed rule will not
have a significant economic impact on
a substantial number of small entities.9
The RFA requires an agency either to
provide an initial regulatory flexibility
analysis with a proposed rule for which
a general notice of proposed rulemaking
is required or to certify that the
proposed rule will not have a significant
economic impact on a substantial
number of small entities. Based on its
analysis and for the reasons stated
below, the Board believes that the
proposed policy statement would not
have a significant economic impact on
a substantial number of small entities.
Under regulations issued by the Small
Business Administration (SBA), a
‘‘small entity’’ includes those firms
within the ‘‘Finance and Insurance’’
sector with asset sizes that vary from $7
9 See
5 U.S.C. 603, 604 and 605.
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million or less in assets to $175 million
or less in assets.10 The Board believes
that the Finance and Insurance sector
constitutes a reasonable universe of
firms for these purposes because such
firms generally engage in actives that are
financial in nature. Consequently, bank
holding companies, savings and loan
holding companies, state member banks,
or nonbank financial companies with
assets sizes of $175 million or less are
small entities for purposes of the RFA.
As discussed in the SUPPLEMENTARY
INFORMATION, the proposed policy
statement generally would affect the
scenario design framework used in
regulations that apply to covered
companies, savings and loan holding
companies, and state member banks
with greater than $10 billion in total
consolidated assets and bank holding
companies with assets of more than $10
billion but less than $50 billion.
Companies that are affected by the
proposed policy statement therefore
substantially exceed the $175 million
asset threshold at which a banking
entity is considered a ‘‘small entity’’
under SBA regulations.11 The proposed
policy statement would affect a nonbank
financial company designated by the
Council under section 113 of the DoddFrank Act regardless of such a
company’s asset size. Although the asset
size of nonbank financial companies
may not be the determinative factor of
whether such companies may pose
systemic risks and would be designated
by the Council for supervision by the
Board, it is an important
consideration.12 It is therefore unlikely
that a financial firm that is at or below
the $175 million asset threshold would
be designated by the Council under
section 113 of the Dodd-Frank Act
because material financial distress at
such firms, or the nature, scope, size,
scale, concentration,
interconnectedness, or mix of its
activities, are not likely to pose a threat
to the financial stability of the United
States.
As noted above, because the proposed
policy statement is not likely to apply
to any company with assets of $175
million or less, if adopted in final form,
it is not expected to affect any small
entity for purposes of the RFA. The
Board does not believe that the
proposed policy statement duplicates,
10 13
CFR 121.201.
Dodd-Frank Act provides that the Board
may, on the recommendation of the Council,
increase the $50 billion asset threshold for the
application of certain of the enhanced standards.
See 12 U.S.C. 5365(a)(2)(B). However, neither the
Board nor the Council has the authority to lower
such threshold.
12 See 76 FR 4555 (January 26, 2011).
11 The
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overlaps, or conflicts with any other
Federal rules. In light of the foregoing,
the Board does not believe that the
proposed policy statement, if adopted in
final form, would have a significant
economic impact on a substantial
number of small entities supervised.
Nonetheless, the Board seeks comment
on whether the proposed policy
statement would impose undue burdens
on, or have unintended consequences
for, small organizations, and whether
there are ways such potential burdens or
consequences could be minimized in a
manner consistent its purpose.
List of Subjects in 12 CFR Part 252
Administrative practice and
procedure, Banks, Banking, Federal
Reserve System, Holding companies,
Nonbank financial companies
supervised by the Board, Reporting and
recordkeeping requirements, Securities,
Stress testing.
Authority and Issuance
For the reasons stated in the
SUPPLEMENTARY INFORMATION, the Board
of Governors of the Federal Reserve
System proposes to amend 12 CFR part
252 as follows:
PART 252—ENHANCED PRUDENTIAL
STANDARDS (Regulation YY)
1. The authority citation for part 252
continues to read as follows:
■
Authority: 12 U.S.C. 321–338a, 1467a(g),
1818, 1831p–1, 1844(b), 1844(c), 5361, 5365,
5366.
2. Appendix A to part 252 is revised
to read as follows:
■
Appendix A to Part 252—Policy
Statement on the Scenario Design
Framework for Stress Testing
1. Background
a. The Board has imposed stress testing
requirements through its regulations (stress
test rules) implementing section 165(i) of the
Dodd-Frank Wall Street Reform and
Consumer Protection Act (Dodd-Frank Act or
Act) and through its capital plan rule (12 CFR
225.8). Under the stress test rules issued
under section 165(i)(1) of the Act, the Board
conducts an annual stress test (supervisory
stress tests), on a consolidated basis, of each
bank holding company with total
consolidated assets of $50 billion or more,
intermediate holding company of a foreign
banking organization, and nonbank financial
company that the Financial Stability
Oversight Council has designated for
supervision by the Board (together, covered
companies).1 In addition, under the stress
test rules issued under section 165(i)(2) of the
Act, covered companies must conduct stress
tests semi-annually and other financial
1 12
U.S.C. 5365(i)(1); 12 CFR part 252, subpart
E.
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companies with total consolidated assets of
more than $10 billion and for which the
Board is the primary regulatory agency must
conduct stress tests on an annual basis
(together, company-run stress tests).2 The
Board will provide for at least three different
sets of conditions (each set, a scenario),
including baseline, adverse, and severely
adverse scenarios for both supervisory and
company-run stress tests (macroeconomic
scenarios).3
b. The stress test rules provide that the
Board will notify covered companies by no
later than February 15 of each year of the
scenarios it will use to conduct its annual
supervisory stress tests and provide, also by
no later than February 15, covered companies
and other financial companies subject to the
final rules the set of scenarios they must use
to conduct their annual company-run stress
tests.4 Under the stress test rules, the Board
may require certain companies to use
additional components in the adverse or
severely adverse scenario or additional
scenarios. For example, the Board expects to
require large banking organizations with
significant trading activities to include a
trading and counterparty component (market
shock, described in the following sections) in
their adverse and severely adverse scenarios.
The Board will provide any additional
components or scenario by no later than
March 1 of each year.5 The Board expects
that the scenarios it will require the
companies to use will be the same as those
the Board will use to conduct its supervisory
stress tests (together, stress test scenarios).
c. In addition, § 225.8 of the Board’s
Regulation Y (capital plan rule) requires
covered companies to submit annual capital
plans, including stress test results, to the
Board to allow the Board to assess whether
they have robust, forward-looking capital
planning processes and have sufficient
capital to continue operations throughout
times of economic and financial stress.6
d. Stress tests required under the stress test
rules and under the capital plan rule require
the Board and financial companies to
calculate pro-forma capital levels—rather
than ‘‘current’’ or actual levels—over a
specified planning horizon under baseline
and stressful scenarios. This approach
integrates key lessons of the 2007–2009
financial crisis into the Board’s supervisory
framework. During the financial crisis,
investor and counterparty confidence in the
capitalization of financial companies eroded
rapidly in the face of changes in the current
and expected economic and financial
conditions, and this loss in market
confidence imperiled companies’ ability to
access funding, continue operations, serve as
a credit intermediary, and meet obligations to
creditors and counterparties. Importantly,
such a loss in confidence occurred even
2 12 U.S.C. 5365(i)(2); 12 CFR part 252, subparts
B and F.
3 The stress test rules define scenarios, baseline
scenario, adverse scenario, and severely adverse
scenario. See 12 CFR 252.12(b), (f), (p), and (q); 12
CFR 252.42(b), (e), (n), and (o); 12 CFR 252.52(b),
(e), (o), and (p).
4 Id.
5 Id.
6 See 12 CFR 225.8.
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when a financial institution’s capital ratios
were in excess of regulatory minimums. This
is because the institution’s capital ratios were
perceived as lagging indicators of its
financial condition, particularly when
conditions were changing.
e. The stress tests required under the stress
test rules and capital plan rule are a valuable
supervisory tool that provide a forwardlooking assessment of large financial
companies’ capital adequacy under
hypothetical economic and financial market
conditions. Currently, these stress tests
primarily focus on credit risk and market
risk—that is, risk of mark-to-market losses
associated with companies’ trading and
counterparty positions—and not on other
types of risk, such as liquidity risk. Pressures
stemming from these sources are considered
in separate supervisory exercises. No single
supervisory tool, including the stress tests,
can provide an assessment of a company’s
ability to withstand every potential source of
risk.
f. Selecting appropriate scenarios is an
especially significant consideration for stress
tests required under the capital plan rule,
which ties the review of a company’s
performance under stress scenarios to its
ability to make capital distributions. More
severe scenarios, all other things being equal,
generally translate into larger projected
declines in banks’ capital. Thus, a company
would need more capital today to meet its
minimum capital requirements in more
stressful scenarios and have the ability to
continue making capital distributions, such
as common dividend payments. This
translation is far from mechanical, however;
it will depend on factors that are specific to
a given company, such as underwriting
standards and the company’s business
model, which would also greatly affect
projected revenue, losses, and capital.
59539
c. The remainder of this policy statement
is organized as follows. Section 3 provides a
broad description of the baseline, adverse,
and severely adverse scenarios and describes
the types of variables that the Board expects
to include in the macroeconomic scenarios
and the market shock component of the stress
test scenarios applicable to companies with
significant trading activity. Section 4
describes the Board’s approach for
developing the macroeconomic scenarios,
and section 5 describes the approach for the
market shocks. Section 6 describes the
relationship between the macroeconomic
scenario and the market shock components.
Section 7 provides a timeline for the
formulation and publication of the
macroeconomic assumptions and market
shocks.
2. Overview and Scope
a. This policy statement provides more
detail on the characteristics of the stress test
scenarios and explains the considerations
and procedures that underlie the approach
for formulating these scenarios. The
considerations and procedures described in
this policy statement apply to the Board’s
stress testing framework, including to the
stress tests required under 12 CFR part 252,
subparts B, E, and F, as well as the Board’s
capital plan rule (12 CFR 225.8).7
b. Although the Board does not envision
that the broad approach used to develop
scenarios will change from year to year, the
stress test scenarios will reflect changes in
the outlook for economic and financial
conditions and changes to specific risks or
vulnerabilities that the Board, in consultation
with the other federal banking agencies,
determines should be considered in the
annual stress tests. The stress test scenarios
should not be regarded as forecasts; rather,
they are hypothetical paths of economic
variables that will be used to assess the
strength and resilience of the companies’
capital in various economic and financial
environments.
3. Content of the Stress Test Scenarios
a. The Board will publish a minimum of
three different scenarios, including baseline,
adverse, and severely adverse conditions, for
use in stress tests required in the stress test
rules.8 In general, the Board anticipates that
it will not issue additional scenarios. Specific
circumstances or vulnerabilities that in any
given year the Board determines require
particular vigilance to ensure the resilience
of the banking sector will be captured in
either the adverse or severely adverse
scenarios. A greater number of scenarios
could be needed in some years—for example,
because the Board identifies a large number
of unrelated and uncorrelated but
nonetheless significant risks.
b. While the Board generally expects to use
the same scenarios for all companies subject
to the final rule, it may require a subset of
companies—depending on a company’s
financial condition, size, complexity, risk
profile, scope of operations, or activities, or
risks to the U.S. economy—to include
additional scenario components or additional
scenarios that are designed to capture
different effects of adverse events on revenue,
losses, and capital. One example of such
components is the market shock that applies
only to companies with significant trading
activity. Additional components or scenarios
may also include other stress factors that may
not necessarily be directly correlated to
macroeconomic or financial assumptions but
nevertheless can materially affect companies’
risks, such as the unexpected default of a
major counterparty.
c. Early in each stress testing cycle, the
Board plans to publish the macroeconomic
scenarios along with a brief narrative
summary that provides a description of the
economic situation underlying the scenario
and explains how the scenarios have changed
relative to the previous year. In addition, to
assist companies in projecting the paths of
additional variables in a manner consistent
with the scenario, the narrative will also
provide descriptions of the general path of
some additional variables. These descriptions
will be general—that is, they will describe
developments for broad classes of variables
rather than for specific variables—and will
specify the intensity and direction of variable
7 12 CFR 252.14(a), 12 CFR 252.44(a), 12 CFR
252.54(a).
8 12 CFR 252.14(b), 12 CFR 252.44(b), 12 CFR
252.54(b).
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changes but not numeric magnitudes. These
descriptions should provide guidance that
will be useful to companies in specifying the
paths of the additional variables for their
company-run stress tests. Note that in
practice it will not be possible for the
narrative to include descriptions on all of the
additional variables that companies may
need for their company-run stress tests. In
cases where scenarios are designed to reflect
particular risks and vulnerabilities, the
narrative will also explain the underlying
motivation for these features of the scenario.
The Board also plans to release a broad
description of the market shock components.
3.1 Macroeconomic Scenarios
a. The macroeconomic scenarios will
consist of the future paths of a set of
economic and financial variables.9 The
economic and financial variables included in
the scenarios will likely comprise those
included in the ‘‘2014 Supervisory Scenarios
for Annual Stress Tests Required under the
Dodd-Frank Act Stress Testing Rules and the
Capital Plan Rule’’ (2013 supervisory
scenarios). The domestic U.S. variables
provided for in the 2013 supervisory
scenarios included:
i. Six measures of economic activity and
prices: Real and nominal gross domestic
product (GDP) growth, the unemployment
rate of the civilian non-institutional
population aged 16 and over, real and
nominal disposable personal income growth,
and the Consumer Price Index (CPI) inflation
rate;
ii. Four measures of developments in
equity and property markets: The Core Logic
National House Price Index, the National
Council for Real Estate Investment
Fiduciaries Commercial Real Estate Price
Index, the Dow Jones Total Stock Market
Index, and the Chicago Board Options
Exchange Market Volatility Index; and
iii. Six measures of interest rates: The rate
on the three-month Treasury bill, the yield
on the 5-year Treasury bond, the yield on the
10-year Treasury bond, the yield on a 10-year
BBB corporate security, the prime rate, and
the interest rate associated with a
conforming, conventional, fixed-rate, 30-year
mortgage.
b. The international variables provided for
in the 2014 supervisory scenarios included,
for the euro area, the United Kingdom,
developing Asia, and Japan:
i. Percent change in real GDP;
ii. Percent change in the Consumer Price
Index or local equivalent; and
iii. The U.S./foreign currency exchange
rate.10
c. The economic variables included in the
scenarios influence key items affecting
financial companies’ net income, including
pre-provision net revenue and credit losses
on loans and securities. Moreover, these
variables exhibit fairly typical trends in
9 The future path of a variable refers to its
specification over a given time period. For example,
the path of unemployment can be described in
percentage terms on a quarterly basis over the stress
testing time horizon.
10 The Board may increase the range of countries
or regions included in future scenarios, as
appropriate.
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adverse economic climates that can have
unfavorable implications for companies’ net
income and, thus, capital positions.
d. The economic variables included in the
scenario may change over time. For example,
the Board may add variables to a scenario if
the international footprint of companies that
are subject to the stress testing rules changed
notably over time such that the variables
already included in the scenario no longer
sufficiently capture the material risks of these
companies. Alternatively, historical
relationships between macroeconomic
variables could change over time such that
one variable (e.g., disposable personal
income growth) that previously provided a
good proxy for another (e.g., light vehicle
sales) in modeling companies’ pre-provision
net revenue or credit losses ceases to do so,
resulting in the need to create a separate
path, or alternative proxy, for the other
variable. However, recognizing the amount of
work required for companies to incorporate
the scenario variables into their stress testing
models, the Board expects to eliminate
variables from the scenarios only in rare
instances.
e. The Board expects that the company
may not use all of the variables provided in
the scenario, if those variables are not
appropriate to the company’s line of
business, or may add additional variables, as
appropriate. The Board expects the
companies will ensure that the paths of such
additional variables are consistent with the
scenarios the Board provided. For example,
the companies may use, as part of their
internal stress test models, local-level
variables, such as state-level unemployment
rates or city-level house prices. While the
Board does not plan to include local-level
macro variables in the stress test scenarios it
provides, it expects the companies to
evaluate the paths of local-level macro
variables as needed for their internal models,
and ensure internal consistency between
these variables and their aggregate, macroeconomic counterparts. The Board will
provide the macroeconomic scenario
component of the stress test scenarios for a
period that spans a minimum of 13 quarters.
The scenario horizon reflects the supervisory
stress test approach that the Board plans to
use. Under the stress test rules, the Board
will assess the effect of different scenarios on
the consolidated capital of each company
over a forward-looking planning horizon of at
least nine quarters.
3.2 Market Shock Component
a. The market shock component of the
adverse and severely adverse scenarios will
only apply to companies with significant
trading activity and their subsidiaries.11 The
11 Currently, companies with significant trading
activity include any bank holding company or
intermediate holding company that (1) has
aggregate trading assets and liabilities of $50 billion
or more, or aggregate trading assets and liabilities
equal to 10 percent or more of total consolidated
assets, and (2) is not a large and noncomplex firm.
The Board may also subject a state member bank
subsidiary of any such bank holding company to
the market shock component. The set of companies
subject to the market shock component could
change over time as the size, scope, and complexity
of financial company’s trading activities evolve.
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component consists of large moves in market
prices and rates that would be expected to
generate losses. Market shocks differ from
macroeconomic scenarios in a number of
ways, both in their design and application.
For instance, market shocks that might
typically be observed over an extended
period (e.g., 6 months) are assumed to be an
instantaneous event which immediately
affects the market value of the companies’
trading assets and liabilities. In addition,
under the stress test rules, the as-of date for
market shocks will differ from the quarterend, and the Board will provide the as-of
date for market shocks no later than February
1 of each year. Finally, as described in
section 4, the market shock includes a much
larger set of risk factors than the set of
economic and financial variables included in
macroeconomic scenarios. Broadly, these risk
factors include shocks to financial market
variables that affect asset prices, such as a
credit spread or the yield on a bond, and, in
some cases, the value of the position itself
(e.g., the market value of private equity
positions).
b. The Board envisions that the market
shocks will include shocks to a broad range
of risk factors that are similar in granularity
to those risk factors trading companies use
internally to produce profit and loss
estimates, under stressful market scenarios,
for all asset classes that are considered
trading assets, including equities, credit,
interest rates, foreign exchange rates, and
commodities. Examples of risk factors
include, but are not limited to:
i. Equity indices of all developed markets,
and of developing and emerging market
nations to which companies with significant
trading activity may have exposure, along
with term structures of implied volatilities;
ii. Cross-currency FX rates of all major and
many minor currencies, along term structures
of implied volatilities;
iii. Term structures of government rates
(e.g., U.S. Treasuries), interbank rates (e.g.,
swap rates) and other key rates (e.g.,
commercial paper) for all developed markets
and for developing and emerging market
nations to which companies may have
exposure;
iv. Term structures of implied volatilities
that are key inputs to the pricing of interest
rate derivatives;
v. Term structures of futures prices for
energy products including crude oil
(differentiated by country of origin), natural
gas, and power;
vi. Term structures of futures prices for
metals and agricultural commodities;
vii. ‘‘Value-drivers’’ (credit spreads or
instrument prices themselves) for creditsensitive product segments including:
Corporate bonds, credit default swaps, and
collateralized debt obligations by risk; nonagency residential mortgage-backed securities
and commercial mortgage-backed securities
by risk and vintage; sovereign debt; and,
municipal bonds; and
viii. Shocks to the values of private equity
positions.
4. Approach for Formulating the
Macroeconomic Assumptions for Scenarios
a. This section describes the Board’s
approach for formulating macroeconomic
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assumptions for each scenario. The
methodologies for formulating this part of
each scenario differ by scenario, so these
methodologies for the baseline, severely
adverse, and the adverse scenarios are
described separately in each of the following
subsections.
b. In general, the baseline scenario will
reflect the most recently available consensus
views of the macroeconomic outlook
expressed by professional forecasters,
government agencies, and other public-sector
organizations as of the beginning of the
annual stress-test cycle. The severely adverse
scenario will consist of a set of economic and
financial conditions that reflect the
conditions of post-war U.S. recessions. The
adverse scenario will consist of a set of
economic and financial conditions that are
more adverse than those associated with the
baseline scenario but less severe than those
associated with the severely adverse
scenario.
c. Each of these scenarios is described
further in sections below as follows: Baseline
(subsection 4.1), severely adverse (subsection
4.2), and adverse (subsection 4.3).
4.1 Approach for Formulating
Macroeconomic Assumptions in the Baseline
Scenario
a. The stress test rules define the baseline
scenario as a set of conditions that affect the
U.S. economy or the financial condition of a
banking organization, and that reflect the
consensus views of the economic and
financial outlook. Projections under a
baseline scenario are used to evaluate how
companies would perform in more likely
economic and financial conditions. The
baseline serves also as a point of comparison
to the severely adverse and adverse
scenarios, giving some sense of how much of
the company’s capital decline could be
ascribed to the scenario as opposed to the
company’s capital adequacy under expected
conditions.
b. The baseline scenario will be developed
around a macroeconomic projection that
captures the prevailing views of privatesector forecasters (e.g. Blue Chip Consensus
Forecasts and the Survey of Professional
Forecasters), government agencies, and other
public-sector organizations (e.g., the
International Monetary Fund and the
Organization for Economic Co-operation and
Development) near the beginning of the
annual stress-test cycle. The baseline
scenario is designed to represent a consensus
expectation of certain economic variables
over the time period of the tests and it is not
the Board’s internal forecast for those
economic variables. For example, the
baseline path of short-term interest rates is
constructed from consensus forecasts and
may differ from that implied by the FOMC’s
Summary of Economic Projections.
c. For some scenario variables—such as
U.S. real GDP growth, the unemployment
rate, and the consumer price index—there
will be a large number of different forecasts
available to project the paths of these
variables in the baseline scenario. For others,
a more limited number of forecasts will be
available. If available forecasts diverge
notably, the baseline scenario will reflect an
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assessment of the forecast that is deemed to
be most plausible. In setting the paths of
variables in the baseline scenario, particular
care will be taken to ensure that, together, the
paths present a coherent and plausible
outlook for the U.S. and global economy,
given the economic climate in which they are
formulated.
4.2 Approach for Formulating the
Macroeconomic Assumptions in the Severely
Adverse Scenario
The stress test rules define a severely
adverse scenario as a set of conditions that
affect the U.S. economy or the financial
condition of a financial company and that
overall are more severe than those associated
with the adverse scenario. The financial
company will be required to publicly
disclose a summary of the results of its stress
test under the severely adverse scenario, and
the Board intends to publicly disclose the
results of its analysis of the financial
company under the adverse scenario and the
severely adverse scenario.
4.2.1 General Approach: The Recession
Approach
a. The Board intends to use a recession
approach to develop the severely adverse
scenario. In the recession approach, the
Board will specify the future paths of
variables to reflect conditions that
characterize post-war U.S. recessions,
generating either a typical or specific
recreation of a post-war U.S. recession. The
Board chose this approach because it has
observed that the conditions that typically
occur in recessions—such as increasing
unemployment, declining asset prices, and
contracting loan demand—can put significant
stress on companies’ balance sheets. This
stress can occur through a variety of
channels, including higher loss provisions
due to increased delinquencies and defaults;
losses on trading positions through sharp
moves in market prices; and lower bank
income through reduced loan originations.
For these reasons, the Board believes that the
paths of economic and financial variables in
the severely adverse scenario should, at a
minimum, resemble the paths of those
variables observed during a recession.
b. This approach requires consideration of
the type of recession to feature. All post-war
U.S. recessions have not been identical:
Some recessions have been associated with
very elevated interest rates, some have been
associated with sizable asset price declines,
and some have been relatively more global.
The most common features of recessions,
however, are increases in the unemployment
rate and contractions in aggregate incomes
and economic activity. For this and the
following reasons, the Board intends to use
the unemployment rate as the primary basis
for specifying the severely adverse scenario.
First, the unemployment rate is likely the
most representative single summary indicator
of adverse economic conditions. Second, in
comparison to GDP, labor market data have
traditionally featured more prominently than
GDP in the set of indicators that the National
Bureau of Economic Research reviews to
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inform its recession dates.12 Third and
finally, the growth rate of potential output
can cause the size of the decline in GDP to
vary between recessions. While changes in
the unemployment rate can also vary over
time due to demographic factors, this seems
to have more limited implications over time
relative to changes in potential output
growth. The unemployment rate used in the
severely adverse scenario will reflect an
unemployment rate that has been observed in
severe post-war U.S. recessions, measuring
severity by the absolute level of and relative
increase in the unemployment rate.13
c. The Board believes that the severely
adverse scenario should also reflect a
housing recession. The house prices path set
in the severely adverse scenario will reflect
developments that have been observed in
post-war U.S. housing recessions, measuring
severity by the absolute level of and relative
decrease in the house prices.
d. The Board will specify the paths of most
other macroeconomic variables based on the
paths of unemployment, income, house
prices, and activity. Some of these other
variables, however, have taken wildly
divergent paths in previous recessions (e.g.,
foreign GDP), requiring the Board to use its
informed judgment in selecting appropriate
paths for these variables. In general, the path
for these other variables will be based on
their underlying structure at the time that the
scenario is designed (e.g., economic or
financial-system vulnerabilities in other
countries).
e. The Board considered alternative
methods for scenario design of the severely
adverse scenario, including a probabilistic
approach. The probabilistic approach
constructs a baseline forecast from a largescale macroeconomic model and identifies a
scenario that would have a specific
probabilistic likelihood given the baseline
forecast. The Board believes that, at this time,
the recession approach is better suited for
developing the severely adverse scenario
than a probabilistic approach because it
guarantees a recession of some specified
severity. In contrast, the probabilistic
approach requires the choice of an extreme
tail outcome—relative to baseline—to
characterize the severely adverse scenario
(e.g., a 5 percent or a 1 percent tail outcome).
In practice, this choice is difficult as adverse
economic outcomes are typically thought of
in terms of how variables evolve in an
absolute sense rather than how far away they
lie in the probability space away from the
baseline. In this sense, a scenario featuring a
recession may be somewhat clearer and more
straightforward to communicate. Finally, the
12 More recently, a monthly measure of GDP has
been added to the list of indicators.
13 Even though all recessions feature increases in
the unemployment rate and contractions in incomes
and economic activity, the size of this change has
varied over post-war U.S. recessions. Table 1 of this
appendix documents the variability in the depth of
post-war U.S. recessions. Some recessions—labeled
mild in Table 1—have been relatively modest with
GDP edging down just slightly and the
unemployment rate moving up about a percentage
point. Other recessions—labeled severe in Table 1—
have been much harsher with GDP dropping 33⁄4
percent and the unemployment rate moving up a
total of about 4 percentage points.
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probabilistic approach relies on estimates of
uncertainty around the baseline scenario and
such estimates are in practice modeldependent.
4.2.2 Setting the Unemployment Rate
Under the Severely Adverse Scenario
a. The Board anticipates that the severely
adverse scenario will feature an
unemployment rate that increases between 3
to 5 percentage points from its initial level
over the course of 6 to 8 calendar quarters.14
The initial level will be set based on the
conditions at the time that the scenario is
designed. However, if a 3 to 5 percentage
point increase in the unemployment rate
does not raise the level of the unemployment
rate to at least 10 percent—the average level
to which it has increased in the most recent
three severe recessions—the path of the
unemployment rate in most cases will be
specified so as to raise the unemployment
rate to at least 10 percent.
b. This methodology is intended to
generate scenarios that feature stressful
outcomes but do not induce greater
procyclicality in the financial system and
macroeconomy. When the economy is in the
early stages of a recovery, the unemployment
rate in a baseline scenario generally trends
downward, resulting in a larger difference
between the path of the unemployment rate
in the severely adverse scenario and the
baseline scenario and a severely adverse
scenario that is relatively more intense.
Conversely, in a sustained strong
expansion—when the unemployment rate
may be below the level consistent with full
employment—the unemployment in a
baseline scenario generally trends upward,
resulting in a smaller difference between the
path of the unemployment rate in the
severely adverse scenario and the baseline
scenario and a severely adverse scenario that
is relatively less intense. Historically, a 3 to
5 percentage point increase in
unemployment rate is reflective of stressful
conditions. As illustrated in Table 1 of this
appendix, over the last half-century, the U.S.
economy has experienced four severe postwar recessions. In all four of these recessions
the unemployment rate increased 3 to 5
percentage points and in the three most
recent of these recessions the unemployment
rate reached a level between 9 percent and
11 percent.
c. Under this method, if the initial
unemployment rate were low—as it would be
after a sustained long expansion—the
unemployment rate in the scenario would
increase to a level as high as what has been
seen in past severe recessions. However, if
the initial unemployment rate were already
high—as would be the case in the early stages
of a recovery—the unemployment rate would
exhibit a change as large as what has been
seen in past severe recessions.
d. The Board believes that the typical
increase in the unemployment rate in the
14 Six to eight quarters is the average number of
quarters for which a severe recession lasts plus the
average number of subsequent quarters over which
the unemployment rate continues to rise. The
variable length of the timeframe reflects the
different paths to the peak unemployment rate
depending on the severity of the scenario.
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severely adverse scenario will be about 4
percentage points. However, the Board will
calibrate the increase in unemployment
based on its views of the status of cyclical
systemic risk. The Board intends to set the
unemployment rate at the higher end of the
range if the Board believed that cyclical
systemic risks were high (as it would be after
a sustained long expansion), and to the lower
end of the range if cyclical systemic risks
were low (as it would be in the earlier stages
of a recovery). This may result in a scenario
that is slightly more intense than normal if
the Board believed that cyclical systemic
risks were increasing in a period of robust
expansion.15 Conversely, it will allow the
Board to specify a scenario that is slightly
less intense than normal in an environment
where systemic risks appeared subdued, such
as in the early stages of an expansion. Indeed,
the Board expects that, in general, it will
adopt a change in the unemployment rate of
less than 4 percentage points when the
unemployment rate at the start of the
scenarios is elevated but the labor market is
judged to be strengthening and higher-thanusual credit losses stemming from previously
elevated unemployment rates were either
already realized—or are in the process of
being realized—and thus removed from
banks’ balance sheets.16 However, even at the
lower end of the range of unemployment-rate
increases, the scenario will still feature an
increase in the unemployment rate similar to
what has been seen in about half of the
severe recessions of the last 50 years.
e. As indicated previously, if a 3 to 5
percentage point increase in the
unemployment rate does not raise the level
of the unemployment rate to 10 percent—the
average level to which it has increased in the
most recent three severe recessions—the path
of the unemployment rate will be specified
so as to raise the unemployment rate to 10
percent. Setting a floor for the unemployment
rate at 10 percent recognizes the fact that not
only do cyclical systemic risks build up at
financial intermediaries during robust
expansions but that these risks are also easily
obscured by the buoyant environment.
f. In setting the increase in the
unemployment rate, the Board will consider
the extent to which analysis by economists,
supervisors, and financial market experts
finds cyclical systemic risks to be elevated
(but difficult to be captured more precisely
in one of the scenario’s other variables). In
addition, the Board—in light of impending
shocks to the economy and financial
system—will also take into consideration the
extent to which a scenario of some increased
severity might be necessary for the results of
15 Note, however, that the severity of the scenario
would not exceed an implausible level: even at the
upper end of the range of unemployment-rate
increases, the path of the unemployment rate would
still be consistent with severe post-war U.S.
recessions.
16 Evidence of a strengthening labor market could
include a declining unemployment rate, steadily
expanding nonfarm payroll employment, or
improving labor force participation. Evidence that
credit losses are being realized could include
elevated charge-offs on loans and leases, loan-loss
provisions in excess of gross charge-offs, or losses
being realized in securities portfolios that include
securities that are subject to credit risk.
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the stress test and the associated supervisory
actions to sustain confidence in financial
institutions.
g. While the approach to specifying the
severely adverse scenario is designed to
avoid adding sources of procyclicality to the
financial system, it is not designed to
explicitly offset any existing procyclical
tendencies in the financial system. The
purpose of the stress test scenarios is to make
sure that the companies are properly
capitalized to withstand severe economic and
financial conditions, not to serve as an
explicit countercyclical offset to the financial
system.
h. In developing the approach to the
unemployment rate, the Board also
considered a method that would increase the
unemployment rate to some fairly elevated
fixed level over the course of 6 to 8 quarters.
This will result in scenarios being more
severe in robust expansions (when the
unemployment rate is low) and less severe in
the early stages of a recovery (when the
unemployment rate is high) and so would not
result in pro-cyclicality. Depending on the
initial level of the unemployment rate, this
approach could lead to only a very modest
increase in the unemployment rate—or even
a decline. As a result, this approach—while
not procyclical—could result in scenarios not
featuring stressful macroeconomic outcomes.
4.2.3 Setting the Other Variables in the
Severely Adverse Scenario
a. Generally, all other variables in the
severely adverse scenario will be specified to
be consistent with the increase in the
unemployment rate. The approach for
specifying the paths of these variables in the
scenario will be a combination of (1) how
economic models suggest that these variables
should evolve given the path of the
unemployment rate, (2) how these variables
have typically evolved in past U.S.
recessions, and (3) and evaluation of these
and other factors.
b. Economic models—such as mediumscale macroeconomic models—should be
able to generate plausible paths consistent
with the unemployment rate for a number of
scenario variables, such as real GDP growth,
CPI inflation and short-term interest rates,
which have relatively stable (direct or
indirect) relationships with the
unemployment rate (e.g., Okun’s Law, the
Phillips Curve, and interest rate feedback
rules). For some other variables, specifying
their paths will require a case-by-case
consideration.
c. Declining house prices, which are an
important source of stress to a company’s
balance sheet, are not a steadfast feature of
recessions, and the historical relationship of
house prices with the unemployment rate is
not strong. Simply adopting their typical
path in a severe recession would likely
underestimate risks stemming from the
housing sector. In specifying the path for
nominal house prices, the Board will
consider the ratio of the nominal house price
index (HPI) to nominal, per capita,
disposable income (DPI). The Board believes
that the typical decline in the HPI–DPI ratio
will be at a minimum 25 percent from its
starting value, or enough to bring the ratio
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down to its Great Recession trough. As
illustrated in Table 2 of this appendix,
housing recessions have on average featured
HPI–DPI ratio declines of about 25 percent
and the HPI–DPI ratio fell to its Great
Recession trough.17
d. In addition, judgment is necessary in
projecting the path of a scenario’s
international variables. Recessions that occur
simultaneously across countries are an
important source of stress to the balance
sheets of companies with notable
international exposures but are not an
invariable feature of the international
economy. As a result, simply adopting the
typical path of international variables in a
severe U.S. recession would likely
underestimate the risks stemming from the
international economy. Consequently, an
approach that uses both judgment and
economic models informs the path of
international variables.
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4.2.4 Adding Salient Risks to the Severely
Adverse Scenario
a. The severely adverse scenario will be
developed to reflect specific risks to the
economic and financial outlook that are
especially salient but will feature minimally
in the scenario if the Board were only to use
approaches that looked to past recessions or
relied on historical relationships between
variables.
b. There are some important instances
when it will be appropriate to augment the
recession approach with salient risks. For
example, if an asset price were especially
elevated and thus potentially vulnerable to
an abrupt and potentially destabilizing
decline, it would be appropriate to include
such a decline in the scenario even if such
a large drop were not typical in a severe
recession. Likewise, if economic
developments abroad were particularly
unfavorable, assuming a weakening in
international conditions larger than what
typically occurs in severe U.S. recessions
would likely also be appropriate.
c. Clearly, while the recession component
of the severely adverse scenario is within
some predictable range, the salient risk
aspect of the scenario is far less so, and
therefore, needs an annual assessment. Each
year, the Board will identify the risks to the
financial system and the domestic and
international economic outlooks that appear
more elevated than usual, using its internal
analysis and supervisory information and in
consultation with the Federal Deposit
Insurance Corporation (FDIC) and the Office
of the Comptroller of the Currency (OCC).
Using the same information, the Board will
then calibrate the paths of the
17 The house-price retrenchments that occurred
over the periods 1980–1985, 1989–1996, 2006–2011
(as detailed in Table 2 of this appendix) are referred
to in this document as housing recessions. The
date-ranges of housing recessions are based on the
timing of house-price retrenchments. These dates
were also associated with sustained declines in real
residential investment, although, the precise
timings of housing recessions would likely be
slightly different were they to be classified based on
real residential investment in addition to house
prices. The ratios described in Table 2 are
calculated based on nominal HPI and HPI–DPI
ratios indexed to 100 in 2000:Q1.
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macroeconomic and financial variables in the
scenario to reflect these risks.
d. Detecting risks that have the potential to
weaken the banking sector is particularly
difficult when economic conditions are
buoyant, as a boom can obscure the
weaknesses present in the system. In
sustained robust expansions, therefore, the
selection of salient risks to augment the
scenario will err on the side of including
risks of uncertain significance.
e. The Board will factor in particular risks
to the domestic and international
macroeconomic outlook identified by its
economists, bank supervisors, and financial
market experts and make appropriate
adjustments to the paths of specific economic
variables. These adjustments will not be
reflected in the general severity of the
recession and, thus, all macroeconomic
variables; rather, the adjustments will apply
to a subset of variables to reflect comovements in these variables that are
historically less typical. The Board plans to
discuss the motivation for the adjustments
that it makes to variables to highlight
systemic risks in the narrative describing the
scenarios.18
4.3 Approach for Formulating
Macroeconomic Assumptions in the Adverse
Scenario
a. The adverse scenario can be developed
in a number of different ways, and the
selected approach will depend on a number
of factors, including how the Board intends
to use the results of the adverse scenario.19
Generally, the Board believes that the
companies should consider multiple adverse
scenarios for their internal capital planning
purposes, and likewise, it is appropriate that
the Board consider more than one adverse
scenario to assess a company’s ability to
withstand stress. Accordingly, the Board
does not identify a single approach for
specifying the adverse scenario. Rather, the
adverse scenario will be formulated
according to one of the possibilities listed
below. The Board may vary the approach it
uses for the adverse scenario each year so
that the results of the scenario provide the
most value to supervisors, in light of current
condition of the economy and the financial
services industry.
b. The simplest method to specify the
adverse scenario is to develop a less severe
version of the severely adverse scenario. For
example, the adverse scenario could be
formulated such that the deviations of the
paths of the variables relative to the baseline
18 The means of effecting an adjustment to the
severely adverse scenario to address salient
systemic risks differs from the means used to adjust
the unemployment rate. For example, in adjusting
the scenario for an increased unemployment rate,
the Board would modify all variables such that the
future paths of the variables are similar to how
these variables have moved historically. In contrast,
to address salient risks, the Board may only modify
a small number of variables in the scenario and, as
such, their future paths in the scenario would be
somewhat more atypical, albeit not implausible,
given existing risks.
19 For example, in the context of CCAR, the Board
currently uses the adverse scenario as one
consideration in evaluating a firm’s capital
adequacy.
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were simply one-half of or two-thirds of the
deviations of the paths of the variables
relative to the baseline in the severely
adverse scenario. A priori, specifying the
adverse scenario in this way may appear
unlikely to provide the greatest possible
informational value to supervisors—given
that it is just a less severe version of the
severely adverse scenario. However, to the
extent that the effect of macroeconomic
variables on company loss positions and
incomes are nonlinear, there could be
potential value from this approach.
c. Another method to specify the adverse
scenario is to capture risks in the adverse
scenario that the Board believes should be
understood better or should be monitored,
but does not believe should be included in
the severely adverse scenario, perhaps
because these risks would render the
scenario implausibly severe. For instance, the
adverse scenario could feature sizable
increases in oil or natural gas prices or shifts
in the yield curve that are atypical in a
recession. The adverse scenario might also
feature less acute, but still consequential,
adverse outcomes, such as a disruptive
slowdown in growth from emerging-market
economies.
d. Under the Board’s stress test rules,
covered companies are required to develop
their own scenarios for mid-cycle companyrun stress tests.20 A particular combination of
risks included in these scenarios may inform
the design of the adverse scenario for annual
stress tests. In this same vein, another
possibility would be to use modified versions
of the circumstances that companies describe
in their living wills as being able to cause
their failures.
e. It might also be informative to
periodically use a stable adverse scenario, at
least for a few consecutive years. Even if the
scenario used for the stress test does not
change over the credit cycle, if companies
tighten and relax lending standards over the
cycle, their loss rates under the adverse
scenario—and indirectly the projected
changes to capital—would decrease and
increase, respectively. A consistent scenario
would allow the direct observation of how
capital fluctuates to reflect growing cyclical
risks.
f. The Board may consider specifying the
adverse scenario using the probabilistic
approach described in section 4.2.1 (that is,
with a specified lower probability of
occurring than the severely adverse scenario
but a greater probability of occurring than the
baseline scenario). The approach has some
intuitive appeal despite its shortcomings. For
example, using this approach for the adverse
scenario could allow the Board to explore an
alternative approach to develop stress testing
scenarios and their effect on a company’s net
income and capital.
g. Finally, the Board could design the
adverse scenario based on a menu of
historical experiences—such as, a moderate
recession (e.g., the 1990–1991 recession); a
stagflation event (e.g., stagflation during
1974); an emerging markets crisis (e.g., the
Asian currency crisis of 1997–1998); an oil
price shock (e.g., the shock during the run up
20 12
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to the 1990–1991 recession); or high inflation
shock (e.g., the inflation pressures of 1977–
1979). The Board believes these are
important stresses that should be understood;
however, there may be notable benefits from
formulating the adverse scenario following
other approaches—specifically, those
described previously in this section—and
consequently the Board does not believe that
the adverse scenario should be limited to
historical episodes only.
h. With the exception of cases in which the
probabilistic approach is used to generate the
adverse scenario, the adverse scenario will at
a minimum contain a mild to moderate
recession. This is because most of the value
from investigating the implications of the
risks described above is likely to be obtained
from considering them in the context of
balance sheets of companies that are under
some stress.
5. Approach for Formulating the Market
Shock Component
a. This section discusses the approach the
Board proposes to adopt for developing the
market shock component of the adverse and
severely adverse scenarios appropriate for
companies with significant trading activities.
The design and specification of the market
shock component differs from that of the
macroeconomic scenarios because profits and
losses from trading are measured in mark-tomarket terms, while revenues and losses from
traditional banking are generally measured
using the accrual method. As noted above,
another critical difference is the timeevolution of the market shock component.
The market shock component consists of an
instantaneous ‘‘shock’’ to a large number of
risk factors that determine the mark-tomarket value of trading positions, while the
macroeconomic scenarios supply a projected
path of economic variables that affect
traditional banking activities over the entire
planning period.
b. The development of the market shock
component that are detailed in this section
are as follows: baseline (subsection 5.1),
severely adverse (subsection 5.2), and
adverse (subsection 5.3).
5.1 Approach for Formulating the Market
Shock Component Under the Baseline
Scenario
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By definition, market shocks are large,
previously unanticipated moves in asset
prices and rates. Because asset prices should,
broadly speaking, reflect consensus opinions
about the future evolution of the economy,
large price movements, as envisioned in the
market shock, should not occur along the
baseline path. As a result, the market shock
will not be included in the baseline scenario.
5.2 Approach for Formulating the Market
Shock Component Under the Severely
Adverse Scenario
This section addresses possible approaches
to designing the market shock component in
the severely adverse scenario, including
important considerations for scenario design,
possible approaches to designing scenarios,
and a development strategy for implementing
the preferred approach.
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5.2.1 Design Considerations for Market
Shocks
a. The general market practice for stressing
a trading portfolio is to specify market shocks
either in terms of extreme moves in
observable, broad market indicators and risk
factors or directly as large changes to the
mark-to-market values of financial
instruments. These moves can be specified
either in relative terms or absolute terms.
Supplying values of risk factors after a
‘‘shock’’ is roughly equivalent to the
macroeconomic scenarios, which supply
values for a set of economic and financial
variables; however, trading stress testing
differs from macroeconomic stress testing in
several critical ways.
b. In the past, the Board used one of two
approaches to specify market shocks. During
SCAP and CCAR in 2011, the Board used a
very general approach to market shocks and
required companies to stress their trading
positions using changes in market prices and
rates experienced during the second half of
2008, without specifying risk factor shocks.
This broad guidance resulted in
inconsistency across companies both in
terms of the severity and the application of
shocks. In certain areas companies were
permitted to use their own experience during
the second half of 2008 to define shocks. This
resulted in significant variation in shock
severity across companies.
c. To enhance the consistency and
comparability in market shocks for the stress
tests in 2012 and 2013, the Board provided
to each trading company more than 35,000
specific risk factor shocks, primarily based
on market moves in the second half of 2008.
While the number of risk factors used in
companies’ pricing and stress-testing models
still typically exceed that provided in the
Board’s scenarios, the greater specificity
resulted in more consistency in the scenario
across companies. The benefit of the
comprehensiveness of risk factor shocks is at
least partly offset by potential difficulty in
creating shocks that are coherent and
internally consistent, particularly as the
framework for developing market shocks
deviates from historical events.
d. Also importantly, the ultimate losses
associated with a given market shock will
depend on a company’s trading positions,
which can make it difficult to rank order, ex
ante, the severity of the scenarios. In certain
instances, market shocks that include large
market moves may not be particularly
stressful for a given company. Aligning the
market shock with the macroeconomic
scenario for consistency may result in certain
companies actually benefiting from risk
factor moves of larger magnitude in the
market scenario if the companies are hedging
against salient risks to other parts of their
business. Thus, the severity of market shocks
must be calibrated to take into account how
a complex set of risks, such as directional
risks and basis risks, interacts with each
other, given the companies’ trading positions
at the time of stress. For instance, a large
depreciation in a foreign currency would
benefit companies with net short positions in
the currency while hurting those with net
long positions. In addition, longer maturity
positions may move differently from shorter
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maturity positions, adding further
complexity.
e. The instantaneous nature of market
shocks and the immediate recognition of
mark-to-market losses add another element to
the design of market shocks, and to
determining the appropriate severity of
shocks. For instance, in previous stress tests,
the Board assumed that market moves that
occurred over the six-month period in late
2008 would occur instantaneously. The
design of the market shocks must factor in
appropriate assumptions around the period
of time during which market events will
unfold and any associated market responses.
5.2.2 Approaches to Market Shock Design
a. As an additional component of the
adverse and severely adverse scenarios, the
Board plans to use a standardized set of
market shocks that apply to all companies
with significant trading activity. The market
shocks could be based on a single historical
episode, multiple historical periods,
hypothetical (but plausible) events, or some
combination of historical episodes and
hypothetical events (hybrid approach).
Depending on the type of hypothetical
events, a scenario based on such events may
result in changes in risk factors that were not
previously observed. In the supervisory
scenarios for 2012 and 2013, the shocks were
largely based on relative moves in asset
prices and rates during the second half of
2008, but also included some additional
considerations to factor in the widening of
spreads for European sovereigns and
financial companies based on actual
observation during the latter part of 2011.
b. For the market shock component in the
severely adverse scenario, the Board plans to
use the hybrid approach to develop shocks.
The hybrid approach allows the Board to
maintain certain core elements of consistency
in market shocks each year while providing
flexibility to add hypothetical elements based
on market conditions at the time of the stress
tests. In addition, this approach will help
ensure internal consistency in the scenario
because of its basis in historical episodes;
however, combining the historical episode
and hypothetical events may require small
adjustments to ensure mutual consistency of
the joint moves. In general, the hybrid
approach provides considerable flexibility in
developing scenarios that are relevant each
year, and by introducing variations in the
scenario, the approach will also reduce the
ability of companies with significant trading
activity to modify or shift their portfolios to
minimize expected losses in the severely
adverse market shock.
c. The Board has considered a number of
alternative approaches for the design of
market shocks. For example, the Board
explored an option of providing tailored
market shocks for each trading company,
using information on the companies’
portfolio gathered through ongoing
supervision, or other means. By specifically
targeting known or potential vulnerabilities
in a company’s trading position, the tailored
approach will be useful in assessing each
company’s capital adequacy as it relates to
the company’s idiosyncratic risk. However,
the Board does not believe this approach to
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be well-suited for the stress tests required by
regulation. Consistency and comparability
are key features of annual supervisory stress
tests and annual company-run stress tests
required in the stress test rules. It would be
difficult to use the information on the
companies’ portfolio to design a common set
of shocks that are universally stressful for all
covered companies. As a result, this
approach will be better suited to more
customized, tailored stress tests that are part
of the company’s internal capital planning
process or to other supervisory efforts outside
of the stress tests conducted under the capital
rule and the stress test rules.
5.2.3 Development of the Market Shock
a. Consistent with the approach described
above, the market shock component for the
severely adverse scenario will incorporate
key elements of market developments during
the second half of 2008, but also incorporate
observations from other periods or price and
rate movements in certain markets that the
Board deems to be plausible though such
movements may not have been observed
historically. Over time the Board also expects
to rely less on market events of the second
half of 2008 and more on hypothetical events
or other historical episodes to develop the
market shock.
b. The developments in the credit markets
during the second half of 2008 were
unprecedented, providing a reasonable basis
for market shocks in the severely adverse
scenario. During this period, key risk factors
in virtually all asset classes experienced
extremely large shocks; the collective breadth
and intensity of the moves have no parallels
in modern financial history and, on that
basis, it seems likely that this episode will
continue to be the most relevant historical
scenario, although experience during other
historical episodes may also guide the
severity of the market shock component of
the severely adverse scenario. Moreover, the
risk factor moves during this episode are
directly consistent with the ‘‘recession’’
approach that underlies the macroeconomic
assumptions. However, market shocks based
only on historical events could become stale
and less relevant over time as the company’s
positions change, particularly if more salient
features are not added each year.
c. While the market shocks based on the
second half of 2008 are of unparalleled
magnitude, the shocks may become less
relevant over time as the companies’ trading
positions change. In addition, more recent
events could highlight the companies’
vulnerability to certain market events. For
example, in 2011, Eurozone credit spreads in
the sovereign and financial sectors surpassed
those observed during the second half of
2008, necessitating the modification of the
severely adverse market shock in 2012 and
2013 to reflect a salient source of stress to
trading positions. As a result, it is important
to incorporate both historical and
hypothetical outcomes into market shocks for
the severely adverse scenario. For the time
being, the development of market shocks in
the severely adverse scenario will begin with
the risk factor movements in a particular
historical period, such as the second half of
2008. The Board will then consider
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hypothetical but plausible outcomes, based
on financial stability reports, supervisory
information, and internal and external
assessments of market risks and potential
flash points. The hypothetical outcomes
could originate from major geopolitical,
economic, or financial market events with
potentially significant impacts on market risk
factors. The severity of these hypothetical
moves will likely be guided by similar
historical events, assumptions embedded in
the companies’ internal stress tests or market
participants, and other available information.
d. Once broad market scenarios are agreed
upon, specific risk factor groups will be
targeted as the source of the trading stress.
For example, a scenario involving the failure
of a large, interconnected globally active
financial institution could begin with a sharp
increase in credit default swap spreads and
a precipitous decline in asset prices across
multiple markets, as investors become more
risk averse and market liquidity evaporates.
These broad market movements will be
extrapolated to the granular level for all risk
factors by examining transmission channels
and the historical relationships between
variables, though in some cases, the
movement in particular risk factors may be
amplified based on theoretical relationships,
market observations, or the saliency to
company trading books. If there is a
disagreement between the risk factor
movements in the historical event used in the
scenario and the hypothetical event, the
Board will reconcile the differences by
assessing a priori expectation based on
financial and economic theory and the
importance of the risk factors to the trading
positions of the covered companies.
5.3 Approach for Formulating the Market
Shock Under the Adverse Scenario
a. The market shock component included
in the adverse scenario will feature risk factor
movements that are generally less significant
than the market shock component of the
severely adverse scenario. However, the
adverse market shock may also feature risk
factor shocks that are substantively different
from those included in the severely adverse
scenario, in order to provide useful
information to supervisors. As in the case of
the macroeconomic scenario, the market
shock component in the adverse scenario can
be developed in a number of different ways.
b. The adverse scenario could be
differentiated from the severely adverse
scenario by the absolute size of the shock, the
scenario design process (e.g., historical
events versus hypothetical events), or some
other criteria. The Board expects that as the
market shock component of the adverse
scenario may differ qualitatively from the
market shock component of the severely
adverse scenario, the results of adverse
scenarios may be useful in identifying a
particularly vulnerable area in a trading
company’s positions.
c. There are several possibilities for the
adverse scenario and the Board may use a
different approach each year to better explore
the vulnerabilities of companies with
significant trading activity. One approach is
to use a scenario based on some combination
of historical events. This approach is similar
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to the one used for the market shock in 2012,
where the market shock component was
largely based on the second half of 2008, but
also included a number of risk factor shocks
that reflected the significant widening of
spreads for European sovereigns and
financials in late 2011. This approach will
provide some consistency each year and
provide an internally consistent scenario
with minimal implementation burden.
Having a relatively consistent adverse
scenario may be useful as it potentially
serves as a benchmark against the results of
the severely adverse scenario and can be
compared to past stress tests.
d. Another approach is to have an adverse
scenario that is identical to the severely
adverse scenario, except that the shocks are
smaller in magnitude (e.g., 100 basis points
for adverse versus 200 basis points for
severely adverse). This ‘‘scaling approach’’
generally fits well with an intuitive
interpretation of ‘‘adverse’’ and ‘‘severely
adverse.’’ Moreover, since the nature of the
moves will be identical between the two
classes of scenarios, there will be at least
directional consistency in the risk factor
inputs between scenarios. While under this
approach the adverse scenario will be
superficially identical to the severely
adverse, the logic underlying the severely
adverse scenario may not be applicable. For
example, if the severely adverse scenario was
based on a historical scenario, the same
could not be said of the adverse scenario. It
is also remains possible, although unlikely,
that a scaled adverse scenario actually will
result in greater losses, for some companies,
than the severely adverse scenario with
similar moves of greater magnitude. For
example, if some companies are hedging
against tail outcomes then the more extreme
trading book dollar losses may not
correspond to the most extreme market
moves. The market shock component of the
adverse scenario in 2013 was largely based
on the scaling approach where a majority of
risk factor shocks were smaller in magnitude
than the severely adverse scenario, but it also
featured long-term interest rate shocks that
were not part of the severely adverse market
shock.
e. Alternatively, the market shock
component of an adverse scenario could
differ substantially from the severely adverse
scenario with respect to the sizes and nature
of the shocks. Under this approach, the
market shock component could be
constructed using some combination of
historical and hypothetical events, similar to
the severely adverse scenario. As a result, the
market shock component of the adverse
scenario could be viewed as an alternative to
the severely adverse scenario and, therefore,
it is possible that the adverse scenario could
have larger losses for some companies than
the severely adverse scenario.
f. Finally, the design of the adverse
scenario for annual stress tests could be
informed by the companies’ own trading
scenarios used for their BHC-designed
scenarios in CCAR and in their mid-cycle
company-run stress tests.21
21 12
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Federal Register / Vol. 82, No. 240 / Friday, December 15, 2017 / Proposed Rules
6. Consistency Between the Macroeconomic
Scenarios and the Market Shock
a. As discussed earlier, the market shock
comprises a set of movements in a very large
number of risk factors that are realized
instantaneously. Among the risk factors
specified in the market shock are several
variables also specified in the
macroeconomic scenarios, such as short- and
long-maturity interest rates on Treasury and
corporate debt, the level and volatility of U.S.
stock prices, and exchange rates.
b. The market shock component is an addon to the macroeconomic scenarios that is
applied to a subset of companies, with no
assumed effect on other aspects of the stress
tests such as balances, revenues, or other
losses. As a result, the market shock
component may not be always directionally
consistent with the macroeconomic scenario.
Because the market shock is designed, in
part, to mimic the effects of a sudden market
dislocation, while the macroeconomic
scenarios are designed to provide a
description of the evolution of the real
economy over two or more years, assumed
economic conditions can move in
significantly different ways. In effect, the
market shock can simulate a market panic,
during which financial asset prices move
rapidly in unexpected directions, and the
macroeconomic assumptions can simulate
the severe recession that follows. Indeed, the
pattern of a financial crisis, characterized by
a short period of wild swings in asset prices
followed by a prolonged period of moribund
activity, and a subsequent severe recession is
familiar and plausible.
c. As discussed in section 4.2.4, the Board
may feature a particularly salient risk in the
macroeconomic assumptions for the severely
adverse scenario, such as a fall in an elevated
asset price. In such instances, the Board may
also seek to reflect the same risk in one of
the market shocks. For example, if the
macroeconomic scenario were to feature a
substantial decline in house prices, it may
seem plausible for the market shock to also
feature a significant decline in market values
of any securities that are closely tied to the
housing sector or residential mortgages.
d. In addition, as discussed in section 4.3,
the Board may specify the macroeconomic
assumptions in the adverse scenario in such
a way as to explore risks qualitatively
different from those in the severely adverse
scenario. Depending on the nature and type
of such risks, the Board may also seek to
reflect these risks in one of the market shocks
as appropriate.
7. Timeline for Scenario Publication
a. The Board will provide a description of
the macroeconomic scenarios by no later
than February 15. During the period
immediately preceding the publication of the
scenarios, the Board will collect and consider
information from academics, professional
forecasters, international organizations,
domestic and foreign supervisors, and other
private-sector analysts that regularly conduct
stress tests based on U.S. and global
economic and financial scenarios, including
analysts at the covered companies. In
addition, the Board will consult with the
FDIC and the OCC on the salient risks to be
considered in the scenarios. The Board
expects to conduct this process in October
and November of each year and to update the
scenarios based on incoming macroeconomic
data releases and other information through
the end of January.
b. The Board expects to provide a broad
overview of the market shock component
along with the macroeconomic scenarios.
The Board will publish the market shock
templates by no later than March 1 of each
year, and intends to publish the market shock
earlier in the stress test and capital plan
cycles to allow companies more time to
conduct their stress tests.
TABLE 1 TO APPENDIX A OF PART 252—CLASSIFICATION OF U.S. RECESSIONS
Duration
(quarters)
Peak
Trough
Severity
1957Q3 ....................................................
1960Q2 ....................................................
1969Q4 ....................................................
1973Q4 ....................................................
1980Q1 ....................................................
1981Q3 ....................................................
1990Q3 ....................................................
2001Q1 ....................................................
2007Q4 ....................................................
Average ...................................................
Average ...................................................
Average ...................................................
1958Q2 ..........
1961Q1 ..........
1970Q4 ..........
1975Q1 ..........
1980Q3 ..........
1982Q4 ..........
1991Q1 ..........
2001Q4 ..........
2009Q2 ..........
........................
........................
........................
Severe ...........
Moderate ........
Moderate ........
Severe ...........
Moderate ........
Severe ...........
Mild ................
Mild ................
Severe ...........
Severe ...........
Moderate ........
Mild ................
4
4
5
6
3
6
3
4
7
6
4
3
Decline in real
GDP
Change in the
unemployment
rate during the
recession
Total change
in the
unemployment
rate (incl.
after the
recession)
¥3.6
¥1.0
¥0.2
¥3.1
¥2.2
¥2.8
¥1.3
0.2
¥4.3
¥3.5
¥1.1
¥0.6
3.2
1.6
2.2
3.4
1.4
3.3
0.9
1.3
4.5
3.7
1.8
1.1
3.2
1.8
2.4
4.1
1.4
3.3
1.9
2.0
5.1
3.9
1.8
1.9
(Medium) ....
(Medium) ....
(Medium) ....
(Long) .........
(Short) .........
(Long) .........
(Short) .........
(Medium) ....
(Long) .........
.....................
.....................
.....................
Source: Bureau of Economic Analysis, National Income and Product Accounts, Comprehensive Revision on July 31, 2013.
TABLE 2 TO APPENDIX A OF PART 252—HOUSE PRICES IN HOUSING RECESSIONS
Trough
Severity
Duration
(quarters)
1980Q2 ....................................................
1989Q4 ....................................................
2005Q4 ....................................................
Average ...................................................
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Peak
1985Q2 ..........
1997Q1 ..........
2012Q1 ..........
........................
Moderate ........
Moderate ........
Severe ...........
........................
Percent
change in
NHPI
20 (long) ........
29 (long) ........
25 (long) ........
24.7 ................
Percent
change in
HPI–DPI
26.6
10.5
¥29.6
2.5
Source: CoreLogic, BEA.
Note: The date-ranges of housing recessions listed in this table are based on the timing of house-price retrenchments.
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¥15.9
¥17.0
¥41.3
¥24.7
HPI–DPI
Trough Level
(2000:Q1 =
100)
102.1
94.9
86.9
94.6
Federal Register / Vol. 82, No. 240 / Friday, December 15, 2017 / Proposed Rules
By order of the Board of Governors of the
Federal Reserve System, December 7, 2017.
Ann E. Misback,
Secretary of the Board.
[FR Doc. 2017–26858 Filed 12–14–17; 8:45 am]
BILLING CODE 6210–01–P
FEDERAL RESERVE SYSTEM
12 CFR Chapter II
[Docket No. OP–1586]
Enhanced Disclosure of the Models
Used in the Federal Reserve’s
Supervisory Stress Test
Board of Governors of the
Federal Reserve System (Board).
ACTION: Notification with request for
public comment.
AGENCY:
The Board is inviting
comment on an enhanced disclosure of
the models used in the Federal
Reserve’s supervisory stress test
conducted under the Board’s Regulation
YY pursuant to the Dodd-Frank Wall
Street Reform and Consumer Protection
Act (Dodd-Frank Act) and the Board’s
capital plan rule.
DATES: Comments must be received by
January 22, 2018.
ADDRESSES: You may submit comments,
identified by Docket No. OP–1586 by
any of the following methods:
• Agency website: https://
www.federalreserve.gov. Follow the
instructions for submitting comments at
https://www.federalreserve.gov/
generalinfo/foia/ProposedRegs.aspx.
• Federal eRulemaking Portal: https://
www.regulations.gov. Follow the
instructions for submitting comments.
• Email: regs.comments@
federalreserve.gov. Include the docket
number and RIN number in the subject
line of the message.
• Fax: (202) 452–2819 or (202) 452–
3102.
• Mail: Ann Misback, Secretary,
Board of Governors of the Federal
Reserve System, 20th Street and
Constitution Avenue NW, Washington,
DC 20551.
All public comments will be made
available on the Board’s website at
https://www.federalreserve.gov/
generalinfo/foia/ProposedRegs.aspx as
submitted, unless modified for technical
reasons. Accordingly, your comments
will not be edited to remove any
identifying or contact information.
Public comments may also be viewed
electronically or in paper form in Room
3515, 1801 K St. NW (between 18th and
19th Streets NW), Washington, DC
20006 between 9:00 a.m. and 5:00 p.m.
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SUMMARY:
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on weekdays. For security reasons, the
Board requires that visitors make an
appointment to inspect comments. You
may do so by calling (202) 452–3684.
Upon arrival, visitors will be required to
present valid government-issued photo
identification and to submit to security
screening in order to inspect and
photocopy comments.
FOR FURTHER INFORMATION CONTACT: Lisa
Ryu, Associate Director, (202) 263–4833,
Kathleen Johnson, Assistant Director,
(202) 452–3644, Robert Sarama,
Manager (202) 973–7436, Division of
Supervision and Regulation; Benjamin
W. McDonough, Assistant General
Counsel, (202) 452–2036, or Julie
Anthony, Counsel, (202) 475–6682,
Legal Division, Board of Governors of
the Federal Reserve System, 20th Street
and Constitution Avenue NW,
Washington, DC 20551. Users of
Telecommunication Device for Deaf
(TDD) only, call (202) 263–4869.
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Overview
II. Description of Enhanced Model Disclosure
A. Enhanced Description of Models
B. Modeled Loss Rates on Pools of Loans
C. Portfolios of Hypothetical Loans and
Associated Loss Rates
D. Explanatory Notes on Enhanced Model
Disclosures
III. Request for Comment
IV. Example of Enhanced Model Disclosure
A. Enhanced Description of Models
B. Modeled Loss Rates on Pools of Loans
C. Portfolios of Hypothetical Loans and
Associated Loss Rates
I. Overview
Each year the Federal Reserve
publicly discloses the results of the
supervisory stress test.1 The disclosures
include revenues, expenses, losses, pretax net income, and capital ratios that
would result under two sets of adverse
economic and financial conditions. As
part of the disclosures, the Federal
Reserve also describes the broad
framework and methodology used in the
supervisory stress test, including
information about the models used to
estimate the revenues, losses, and
capital ratios in the stress test. The
annual disclosures of both the stress test
results and supervisory model
framework and methodology represent a
significant increase in the public
transparency of large bank supervision
in the U.S.2 Indeed, prior to the first
1 See, for example, Dodd-Frank Act Stress Test
2017: Supervisory Stress Test Methodology and
Results, June 2017 and Comprehensive Capital
Analysis and Review 2017: Assessment Framework
and Results, June 2017.
2 In addition to those public disclosures, the
Federal Reserve has published detailed information
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supervisory stress test in 2009, many
analysts and institutions cautioned
against these disclosures, arguing that
releasing bank-specific loss estimates to
the public would be destabilizing.
However, experience to date has shown
the opposite to be true—disclosing these
details to the public has garnered public
and market confidence in the process.
The Federal Reserve routinely reviews
its stress testing and capital planning
programs, and during those reviews the
Federal Reserve has received feedback
regarding the transparency of the
supervisory stress test models.3 Some of
those providing feedback requested
more detail on modeling methodologies
with a focus on year-over-year changes
in the supervisory models.4 Others,
however, cautioned against disclosing
too much information about the
supervisory models because doing so
could permit firms to reverse-engineer
the stress test.
The Federal Reserve recognizes that
disclosing additional information about
supervisory models and methodologies
has significant public benefits, and is
committed to finding ways to further
increase the transparency of the
supervisory stress test. More detailed
disclosures could further enhance the
credibility of the stress test by providing
the public with information on the
fundamental soundness of the models
and their alignment with best modeling
practices. These disclosures would also
facilitate comments on the models from
the public, including academic experts.
These comments could lead to
improvements, particularly in the data
most useful to understanding the risks
of particular loan types. More detailed
disclosures could also help the public
understand and interpret the results of
the stress test, furthering the goal of
maintaining market and public
confidence in the U.S. financial system.
Finally, more detailed disclosures of
how the Federal Reserve’s models
assign losses to particular positions
about its scenario design framework and annual
letters detailing material model changes. The
Federal Reserve also hosts an annual symposium in
which supervisors and financial industry
practitioners share best practices in modeling,
model risk management, and governance.
3 During a review that began in 2015, the Federal
Reserve received feedback from senior management
at firms subject to the Board’s capital plan rule, debt
and equity market analysts, representatives from
public interest groups, and academics in the fields
of economics and finance. That review also
included an internal assessment.
4 Some of the comments in favor of additional
disclosure included requests that the Federal
Reserve provide additional information to firms
only, without making the additional disclosures
public. Doing so would be contrary to the Federal
Reserve’s established practice of not disclosing
information related to the stress test to firms if that
information is not also publicly disclosed.
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15DEP1
Agencies
[Federal Register Volume 82, Number 240 (Friday, December 15, 2017)]
[Proposed Rules]
[Pages 59533-59547]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2017-26858]
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FEDERAL RESERVE SYSTEM
12 CFR Part 252
[Regulation YY; Docket No. OP-1588]
Policy Statement on the Scenario Design Framework for Stress
Testing
AGENCY: Board of Governors of the Federal Reserve System (Board).
ACTION: Proposed rule; policy statement with request for public
comment.
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SUMMARY: The Board is requesting public comment on amendments to its
policy statement on the scenario design framework for stress testing.
The proposed amendments to the policy statement would clarify when the
Board may adopt a change in the unemployment rate in the severely
adverse scenario of less than 4 percentage points; institute a counter-
cyclical guide for the change in the house price index in the severely
adverse scenario; and provide notice that the Board plans to
incorporate wholesale funding costs for banking organizations in the
scenarios. The Board would continue to use the policy
[[Page 59534]]
statement to develop the macroeconomic scenarios and additional
scenario components that are used in the supervisory and company-run
stress tests conducted under the Board's stress test rules and the
Board's capital plan rule.
DATES: Comments must be received by January 22, 2018.
ADDRESSES: You may submit comments, identified by Docket No. OP-1588 by
any of the following methods:
Agency website: https://www.federalreserve.gov. Follow the
instructions for submitting comments at https://www.federalreserve.gov/generalinfo/foia/ProposedRegs.aspx.
Federal eRulemaking Portal: https://www.regulations.gov.
Follow the instructions for submitting comments.
Email: [email protected]. Include the
docket number and RIN number in the subject line of the message.
Fax: (202) 452-2819 or (202) 452-3102.
Mail: Ann Misback, Secretary, Board of Governors of the
Federal Reserve System, 20th Street and Constitution Avenue NW,
Washington, DC 20551.
All public comments will be made available on the Board's website
at https://www.federalreserve.gov/generalinfo/foia/ProposedRegs.aspx as
submitted, unless modified for technical reasons. Accordingly, your
comments will not be edited to remove any identifying or contact
information. Public comments may also be viewed electronically or in
paper form in Room 3515, 1801 K St. NW (between 18th and 19th Streets
NW), Washington, DC 20006 between 9:00 a.m. and 5:00 p.m. on weekdays.
For security reasons, the Board requires that visitors make an
appointment to inspect comments. You may do so by calling (202) 452-
3684. Upon arrival, visitors will be required to present valid
government-issued photo identification and to submit to security
screening in order to inspect and photocopy comments.
FOR FURTHER INFORMATION CONTACT: Lisa Ryu, Associate Director, (202)
263-4833, Joseph Cox, Supervisory Financial Analyst, (202) 452-3216, or
Aurite Werman, Financial Analyst (202) 263-4802, Division of
Supervision and Regulation; Benjamin W. McDonough, Assistant General
Counsel, (202) 452-2036, or Julie Anthony, Counsel, (202) 475-6682,
Legal Division; or William Bassett, Associate Director, (202) 736-5644,
Luca Guerrieri, Deputy Associate Director, (202) 452-2550, or Bora
Durdu, Chief, (202) 452-3755, Division of Financial Stability.
SUPPLEMENTARY INFORMATION:
I. Background
A. Supervisory Scenarios
Pursuant to the Board's stress test rules, the Board conducts
supervisory stress tests of bank holding companies and U.S.
intermediate holding companies subsidiaries of foreign banking
organizations with total consolidated assets of $50 billion or more
(covered companies) and requires covered companies to conduct semi-
annual company-run stress tests.\1\ In addition, savings and loan
holding companies, state member banks with greater than $10 billion in
total consolidated assets, and bank holding companies with assets of
more than $10 billion but less than $50 billion are required to conduct
annual company-run stress tests.\2\
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\1\ 12 CFR part 252, subparts E and F. In addition, the
supervisory stress test rules would apply to any nonbank financial
company supervised by the Board that becomes subject to these
requirements pursuant to a rule or order of the Board. Currently, no
nonbank financial companies supervised by the Board are subject to
the capital planning or stress test requirements.
\2\ 12 CFR part 252, subpart B.
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To conduct the supervisory stress tests, the Board develops three
scenarios--a baseline, adverse, and severely adverse scenario--and
projects a firm's balance sheet, risk-weighted assets, net income, and
resulting post-stress capital levels and regulatory capital ratios
under each scenario. Similarly, a firm subject to company-run stress
tests under the Board's rules uses the same adverse and severely
adverse scenarios that apply in the supervisory stress test to conduct
an annual company-run stress test. The scenarios also serve as an input
into a covered company's capital plan under the Board's capital plan
rule (12 CFR 225.8), and the Federal Reserve also uses these scenarios
to evaluate each firm's capital plan in the supervisory post-stress
capital assessment.\3\
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\3\ Bank holding companies with $50 billion or more in total
consolidated assets and U.S. intermediate holding companies of
foreign banking organizations additionally conduct mid-cycle
company-run stress tests under scenarios that they develop. See 12
CFR 252.55.
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On November 29, 2013, the Board adopted a final policy statement on
its scenario design framework for stress testing (policy statement).\4\
The policy statement outlined the characteristics of the supervisory
stress test scenarios and explained the considerations and procedures
that underlie the formulation of these scenarios. The considerations
and procedures described in the policy statement apply to the Board's
stress testing framework, including to the stress tests required under
12 CFR part 252, subparts B, E, and F, and the Board's capital plan
rule. The policy statement describes in greater detail than the stress
test rules the baseline, adverse, and severely adverse scenarios. The
policy statement also describes the Board's approach for developing
these three macroeconomic scenarios and additional components of the
stress test scenarios, which apply to a subset of covered companies.
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\4\ See 12 CFR part 252, appendix A.
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As described in the policy statement, the severely adverse scenario
is designed to reflect conditions that have characterized post-war U.S.
recessions (the ``recession approach''). Historically, recessions
typically feature increases in the unemployment rate and contractions
in aggregate incomes and economic activity. In light of the typical co-
movement of measures of economic activity during economic downturns,
such as the unemployment rate and gross domestic product, in developing
the severely adverse scenario, the Board first specifies a path for the
unemployment rate and then develops paths for other measures of
activity broadly consistent with the course of the unemployment rate.
The Board's scenario design framework includes a counter-cyclical
design element in the change in the unemployment rate in the severely
adverse scenario. The policy statement provides that the Board
anticipates the unemployment rate in the severely adverse scenario
would increase by between 3 and 5 percentage points from its initial
level. However, if a 3 to 5 percentage point increase in the
unemployment rate does not raise the level of the unemployment rate to
at least 10 percent, the path of the unemployment rate in most cases
will be specified so as to raise the unemployment rate to at least 10
percent. The policy statement also notes that the typical increase in
the unemployment rate in the severely adverse scenario will be about 4
percentage points. The policy statement provides that the Board intends
to set the unemployment rate at the higher end of the 3 to 5 percentage
point range if the Board believes that cyclical systemic risks are high
(as they would be after a sustained long expansion), and to the lower
end of the range if cyclical systemic risks are low (as they would be
in the earlier stages of a recovery).
The policy statement provides that economic variables included in
the scenarios may change over time, or that
[[Page 59535]]
the Board may augment the recession approach to account for salient
risks.\5\ The Board has not historically captured stress to funding
markets in the supervisory stress test exercise. However, it is
exploring the inclusion of such a stress in the scenarios, given the
potential impact that funding shocks could have on firms subject to the
supervisory stress test.
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\5\ For example, if scenario variables do not capture material
risks to capital, or if historical relationships between
macroeconomic variables change such that one variable is no longer
an appropriate proxy for another, the Board may add variables to a
supervisory scenario. The Board may also include additional scenario
components or additional scenarios that are designed to capture the
effects of different adverse events on revenue, losses, and capital.
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B. Review of Stress Test Exercises
The Federal Reserve routinely reviews its experience with each
year's stress testing and capital planning programs as implemented
through DFAST and CCAR. These reviews have included formal engagements
with public interest groups, meetings with academics in the fields of
economics and finance, and internal assessments.
In the course of its review of the stress test exercises, the
Federal Reserve has received feedback on the Board's framework for
designing stress scenarios. Some participants advocated developing a
structured process for strengthening scenario design over time. Other
participants were concerned that the Federal Reserve would be pressured
to reduce the severity of the scenario over time. As part of its
internal assessment of the stress test exercises, the Federal Reserve
also considered ways to further enhance the countercyclical elements,
transparency, and risk coverage of the scenario design framework.
After considering feedback received in these reviews and possible
improvements to the methodology for specifying the macroeconomic
scenarios used in the supervisory stress test and the annual company-
run stress tests, the Board is proposing to modify the policy statement
to enhance the countercyclicality and transparency of the Board's
scenario design framework and improve the risk coverage of the
scenarios.
II. Review of the Supervisory Scenarios
A. Unemployment and House Prices in the Severely Adverse Scenario
The Board investigated possible improvements to the methodology for
specifying the macroeconomic scenarios used in supervisory and company-
run stress tests. A main area of inquiry was the severity of
macroeconomic scenarios used in previous stress test exercises. As
noted, the scenario design framework was formulated to increase the
severity of the severely adverse scenario during economic expansions in
order to limit the procyclicality of the financial system by increasing
the resilience of the banking system to building risks. The review
evaluated the path of key variables in the severely adverse scenarios
since 2011, and determined that amendments to the scenario design
framework could further limit procyclicality.\6\
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\6\ For completeness, the tables present data from the 2017
severely adverse scenario, however, this data was not available at
the time of the review conducted by the Board. The data from 2017
was generally consistent with the analysis of the earlier scenarios.
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The severity of a scenario can be gauged by considering both the
maximum (or minimum) levels obtained by key variables and changes of
the variables from their starting points. Table 1 shows the peak and
change in the unemployment rate in the supervisory severely adverse
scenarios since 2011.\7\ The peak unemployment rate in the severely
adverse scenario has been falling since CCAR 2012 as the economy
improved. Beginning in 2016, the countercyclical element of the Board's
scenario design framework acted to increase scenario severity, so while
the peak level of the unemployment rate remained about the same, the
change in the unemployment rate increased. The countercyclical design
of the scenarios is also reflected in the change in real GDP, which, in
2017, declined by the largest amount since 2012.
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\7\ The change in real gross domestic product (real GDP) is also
presented as an additional gauge of severity because the path of
real GDP is formulated based on the path of the unemployment.
Table 1--Unemployment Rate and Real GDP in the Severely Adverse Scenario
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Stress test exercise Great Severe
----------------------------------------------------------------------------- recession recessions
2011 \a\ 2012 \a\ 2013 2014 2015 2016 2017 \b\ \c\
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Panel A: Developments as published in the supervisory scenarios
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Unemployment Rate:
Peak Level (pct.)............................ 11.1 12.6 12.1 11.3 10.1 10.0 10.0 10.0 9.3
Change Start-to-peak (pp.)................... 1.5 3.6 4.0 4.0 4.0 5.0 5.3 4.5 3.6
Real GDP:
Change Start-to-trough (pct.)................ -4.1 -6.9 -4.8 -4.7 -4.7 -6.2 -6.6 -4.7 -3.4
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Note:
\a\ In 2011 and 2012 the scenario was referred to as the ``supervisory stress scenario.''
\b\ Great Recession is defined as that which occurred in Q4:2007-Q2:2009.
\c\ Recessions classified as severe: 1957:Q3-1958:Q2, 1973:Q4-1975:Q1, 1981:Q3-1982:Q4, and 2007:Q4-2009:Q2.
The Board also evaluated its approach to developing the path of
house prices, which is a key scenario variable, to assess whether it
could improve the transparency of the measure and to identify a guide
that would formalize the Board's countercyclical objectives. To date,
the Board has developed the path of house prices using a judgmental
approach, and has not established a quantitative guide for the
trajectory of house prices.
As demonstrated in Panel A of table 2, the existing approach to
house prices has resulted in increasing severity over time. The
declines in the nominal house price index (nominal HPI) from the start
to the trough have increased from 21 percent (in 2012 and 2013) to
about 25-26 percent (in 2014 through 2017). The increased severity in
the decline in nominal HPI in supervisory scenarios beginning in 2014
offset the rise in observed house prices over that period, and hence
limited procyclicality.
Assessing the procyclicality of house price paths over time is
complicated by the fact that house prices--in contrast to the
unemployment rate--naturally trend upward over time. The ratio of
nominal house prices to nominal, per capita, disposable personal income
(HPI-DPI ratio, henceforth), does not exhibit an upward trend and, as
such, provides an alternative way to assess the
[[Page 59536]]
procyclicality of the scenarios' house price paths. The severity of a
scenario depends on both the change and the trough level of the HPI-DPI
ratio. Panel A of table 2 indicates that the change in the HPI-DPI
ratio increased in absolute terms in the years 2014 to 2017 compared to
the years 2012 and 2013. However, the trough of the HPI-DPI ratio
achieved in the severely adverse scenarios has generally moved up since
2012. Scenarios with higher HPI-DPI troughs may be less severe even if
they feature the same decline in the ratio.
Table 2--House Prices in the Severely Adverse Scenario
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Stress test exercise Great Housing
----------------------------------------------------------------------------- recession recessions
2011 \a\ 2012 \a\ 2013 2014 2015 2016 2017 \b\ \c\
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Panel A: Developments as published in the supervisory scenarios
Nominal HPI:
Change Start-to-trough (pct.)................ -11 -21 -21 -26 -26 -25 -25 -30 2.5
Trough Level \c\............................. 124 106 111 116 126 135 134 130 ...........
HPI-DPI Ratio:
Change Start-to-trough (pct.)................ -11 -19 -18 -27 -25 -25 -24 -41 -25
Trough Level \c\............................. 89 76 78 75 79 82 81 87 95
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Panel B: Developments as implied by the HPI-DPI Guide
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Nominal HPI:
Change Start-to-trough (pct.)................ -25 -27 -27 -24 -25 -25 -26 -30 2.5
Trough Level \c\............................. 104 98 102 119 127 134 134 130 ...........
HPI-DPI Ratio:
Change Start-to-trough (pct.)................ -25 -25 -25 -25 -25 -25 -25 -41 -25
Trough Level \d\............................. 75 70 72 76 80 82 79 87 95
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Note:
\a\ In 2011 and 2012 the scenario was referred to as the ``supervisory stress scenario.''
\b\ Great Recession is defined as that which occurred in Q4:2007-Q2:2009.
\c\ Housing recessions are defined as the following date ranges: 1980-1985, 1989-1996, and 2006-2011. The date-ranges of housing recessions are based on
the timing of house-price retrenchments. These dates were also associated with sustained declines in real residential investment, although, the
precise timings of housing recessions would likely be slightly different were they to be classified based on real residential investment in addition
to house prices.
\d\ Both the nominal HPI and HPI-DPI ratios are indexed to 100 in 2000:Q1.
Based on this analysis, the Board determined that its scenario
design framework could be strengthened by (1) enhancing the counter-
cyclicality of the scenarios when conditions at the start of the
exercise already reflected stress; and (2) improving the transparency
of the scenario design framework by developing an explicit guide for
formulating the path of house prices in the severely adverse scenario.
B. Risk Coverage in Supervisory Scenarios
The Board also has examined whether there were important dimensions
of risk that had not featured in supervisory scenarios to date. The
review suggested that a key risk dimension that had not been directly
addressed in the supervisory stress test was banking organizations'
reliance on certain types of runnable liabilities, which has been an
important source of financial stress on banking organizations, as well
a channel by which one firm's distress affects other firms. For
example, shocks to the costs of short-term wholesale funding played a
prominent role in the recent financial crisis, and had a notable effect
on firms' ability to operate as financial intermediaries. Accordingly,
the Board is exploring incorporating an increase in the cost of short-
term wholesale funding in its scenarios and stress tests.
III. Proposed Amendments to the Policy Statement
The proposal includes three modifications to the Board's scenario
design framework. First, the proposal would modify the current guide in
the policy statement for the peak unemployment rate in the severely
adverse scenario to include a description of the circumstances in which
an increase in the unemployment rate at the lower end of the 3 to 5
percentage point range suggested by the guide would be warranted.
Second, the proposal would add to the policy statement an explicit
guide for house prices in the severely adverse scenario based on the
HPI-DPI ratio that features both a minimum level and a fixed change in
the HPI-DPI ratio. Third, the proposal would provide notice that the
Board is exploring the inclusion of an increase in the cost of funds
for banking organizations as an explicit factor in the scenarios.
Finally, the policy statement would be amended to update references and
remove obsolete text.
A. Unemployment Rate in the Severely Adverse Scenario
The proposal would include more specific guidance for the change in
the unemployment rate when the stress test is conducted during a period
in which the unemployment rate is already elevated. The Board currently
calibrates the peak unemployment rate in the severely adverse scenario
as the greater of a 3 to 5 percentage point increase from the
unemployment rate at the beginning of the stress test planning horizon,
or 10 percent. This approach introduces an element of counter-
cyclicality to the scenario design process, as lower levels of the
unemployment rate at the beginning of the stress planning horizons
imply a larger increase in unemployment over the severely adverse
scenario to a level that is at least consistent with past severe
recessions.
Consistent with the current policy statement, the Board believes
that the typical increase in the unemployment rate in the severely
adverse scenario will be about 4 percentage points, and that a lower
increase may be appropriate in certain circumstances. In determining
the increase in the unemployment rate, the Board would consider the
level of unemployment at the start of the scenarios, the strength of
the labor market, and the strength of firms' balance sheets. The
proposed framework would clarify that the Board may adopt an increase
in the unemployment rate of less than 4 percentage points when the
unemployment rate at the start of the scenarios is elevated but the
labor market is judged to be strengthening and higher-than-usual credit
losses stemming from previously elevated unemployment rates were either
already realized--or are in the process of being
[[Page 59537]]
realized--and thus removed from banks' balance sheets. Evidence of a
strengthening labor market could include a declining unemployment rate,
steadily expanding nonfarm payroll employment, or improving labor force
participation. Evidence that credit losses are being realized could
include elevated charge-offs on loans and leases, loan-loss provisions
in excess of gross charge-offs, or losses being realized in securities
portfolios that include securities that are subject to credit risk.
This proposed change would keep the unemployment rate in the
macroeconomic scenario broadly similar to that in previous scenarios
except during times when a smaller change would be appropriate based on
the credit cycle. By adopting a smaller change in the unemployment rate
when the economy was recovering and losses had already been broadly
recognized by the industry, the proposal would complement the current
counter-cyclical design elements.
Question number 1: In connection with this proposal, the Federal
Reserve considered an alternative guide for the unemployment rate, in
which the path of the unemployment rate would reach the lesser of a
level 4 percentage points above its level at the beginning of the
scenario or 11 percent. On average, this alternative would increase the
severity of severely adverse scenarios but also would be more
countercyclical than the current guide. What are the advantages or
disadvantages to this alternative relative to the proposed guide?
B. House Prices in the Severely Adverse Scenario
The policy statement would also be amended to include guidance for
the path of the nominal house price index in the severely adverse
scenario. The nominal house price index is a key scenario variable, and
providing explicit guidance for its path over the planning horizon
would enhance the transparency and countercyclical design of the
scenario design framework.
The proposal would establish a quantitative guide for house prices.
The guide for house prices would be informed by the ratio of the
nominal house price index to nominal per capita disposable income (HPI-
DPI ratio). Unlike the level of house prices, the HPI-DPI ratio does
not exhibit a trend over time. Under most circumstances, the decline in
the HPI-DPI ratio in the severely adverse scenario is expected to be 25
percent from its starting value or enough to bring the ratio down to
its Great Recession trough, whichever is greater. A rule with both a
minimum change in the ratio and a level of severity that the ratio must
reach is consistent with the rule for the path of the unemployment rate
and would further the Board's countercyclical goals in scenario design.
In its analysis, the Board identified the HPI-DPI trough reached
during the Great Recession as the lowest trough attained in housing
recessions since 1976, and considered this trough an appropriate basis
for explicit guidance for the path of house prices. Setting a minimum
decline in the HPI-DPI ratio would ensure that additional economic
stress would be incorporated into the macroeconomic scenario, even if
house prices were depressed at the outset of the scenario. The Board
would typically set a minimum decline in the HPI-DPI ratio of 25
percent from its starting value. A decline of 25 percent is consistent
with the average decline in housing recessions (see table 2 in the
Policy Statement) and with the path of house prices in the supervisory
severely adverse scenarios since 2015.
Procyclicality in house prices would be limited by setting a
maximum level for the trough of the HPI-DPI ratio in the severely
adverse scenario. This would increase the severity of the decline in
house prices as house prices rise relative to disposable personal
incomes, as is the case in times of economic expansion. When the HPI-
DPI ratio rises above the level at which a 25 percent decline would
bring the ratio to its Great Recession trough, at the start of the
stress test, the change in the ratio would be greater than 25 percent
in order to bring the ratio to its Great Recession trough.\8\ This
proposal would offer a more systematic approach to specifying house
price paths than does the current approach, and would limit
procyclicality while broadly preserving the decline in the nominal HPI
featured in recent stress testing cycles.
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\8\ The Great Recession trough depends on the reference date
used for indexing. For example, with nominal HPI and HPI-DPI ratios
indexed to 100 in 2000:Q1, a decline in the HPI-DPI index of more
than 25 percent would be necessary to reach the Great Recession
trough of 87 when the HPI-DPI ratio at the start of the supervisory
scenario was 116 or greater.
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Question number 2: In connection with this proposal, the Federal
Reserve considered alternative guides for projecting house prices,
including guides based on the ratio of the nominal house price index to
an index of nominal rent prices for residential housing. What are the
advantages or disadvantages to such alternatives relative to the
proposed guide?
C. Incorporating Short-Term Wholesale Funding Costs in the Adverse and
Severely Adverse Scenarios
To date, the Board's adverse and severely adverse scenarios have
not incorporated stress to funding markets. The proposal states that
the Board may include variables or an additional components in the
scenario to capture the cost of funds, particularly wholesale funds, to
banking organizations. Including stress to funding costs in the
scenarios would account for the impact of increased costs of certain
runnable liabilities on net income and capital of banking organizations
reliant on short-term wholesale funding. The Board would not expect to
incorporate wholesale funding costs in the scenarios before 2019, and
would expect to include wholesale funding costs in the adverse scenario
before the severely adverse scenario. Accordingly, the Board would not
expect to include a stress to funding costs in the severely adverse
scenario until 2020 at the earliest.
Question number 3: What variable or combinations of variables would
best represent stress to funding costs or availability in the
supervisory scenarios?
Question number 4: What, if any, other risks should the Federal
Reserve consider capturing in the supervisory scenarios?
D. Impact Analysis
Generally, the proposed amendments would not affect the severity of
the scenarios in a manner that persists throughout the economic cycle.
The one exception is the introduction of an increase in the cost of
certain runnable liabilities. Generally, the inclusion of a stress to
wholesale funding would be expected to increase the stringency of the
stress test. The extent of the increased stringency would depend on the
implementation of the stress, such as the type of liabilities stressed,
and the duration and magnitude of the stress considered.
The proposed unemployment rate clarification would reduce the
stringency of the scenario if the economy had already experienced
stress and was recovering, and would not impact the stringency of the
scenario in other points during the economic cycle. The house price
guide would formalize an approach that was previously judgmental with
little persistent impact on the severity of the stress to house prices
in the severely adverse scenarios. However, the countercyclical element
of the guide would increase the severity of the stress to house prices
when the ratio
[[Page 59538]]
of house prices to disposable personal income was particularly elevated
at the start of the stress test.
Question number 5: The Federal Reserve is proposing changes to the
Scenario Design Policy Statement to enhance the countercyclicality,
risk coverage, and transparency of the scenario development process.
Are there other modifications not included in this proposal that could
further enhance the scenario development process?
IV. Administrative Law Matters
A. Use of Plain Language
Section 722 of the Gramm-Leach-Bliley Act (Pub. L. 106-102, 113
Stat. 1338, 1471, 12 U.S.C. 4809) requires the Federal banking agencies
to use plain language in all proposed and final rules published after
January 1, 2000. The Board has sought to present the proposed rule in a
simple and straightforward manner, and invites comment on the use of
plain language.
B. Paperwork Reduction Act
In accordance with the requirements of the Paperwork Reduction Act
of 1995 (44 U.S.C. 3506), the Board has reviewed the proposed policy
statement to assess any information collections. There are no
collections of information as defined by the Paperwork Reduction Act in
the proposal.
C. Regulatory Flexibility Act Analysis
In accordance with section 3(a) of the Regulatory Flexibility Act
(RFA), the Board is publishing an initial regulatory flexibility
analysis of the proposed policy statement. The RFA, 5 U.S.C. 601 et
seq., requires each federal agency to prepare an initial regulatory
flexibility analysis in connection with the promulgation of a proposed
rule, or certify that the proposed rule will not have a significant
economic impact on a substantial number of small entities.\9\ The RFA
requires an agency either to provide an initial regulatory flexibility
analysis with a proposed rule for which a general notice of proposed
rulemaking is required or to certify that the proposed rule will not
have a significant economic impact on a substantial number of small
entities. Based on its analysis and for the reasons stated below, the
Board believes that the proposed policy statement would not have a
significant economic impact on a substantial number of small entities.
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\9\ See 5 U.S.C. 603, 604 and 605.
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Under regulations issued by the Small Business Administration
(SBA), a ``small entity'' includes those firms within the ``Finance and
Insurance'' sector with asset sizes that vary from $7 million or less
in assets to $175 million or less in assets.\10\ The Board believes
that the Finance and Insurance sector constitutes a reasonable universe
of firms for these purposes because such firms generally engage in
actives that are financial in nature. Consequently, bank holding
companies, savings and loan holding companies, state member banks, or
nonbank financial companies with assets sizes of $175 million or less
are small entities for purposes of the RFA.
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\10\ 13 CFR 121.201.
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As discussed in the SUPPLEMENTARY INFORMATION, the proposed policy
statement generally would affect the scenario design framework used in
regulations that apply to covered companies, savings and loan holding
companies, and state member banks with greater than $10 billion in
total consolidated assets and bank holding companies with assets of
more than $10 billion but less than $50 billion. Companies that are
affected by the proposed policy statement therefore substantially
exceed the $175 million asset threshold at which a banking entity is
considered a ``small entity'' under SBA regulations.\11\ The proposed
policy statement would affect a nonbank financial company designated by
the Council under section 113 of the Dodd-Frank Act regardless of such
a company's asset size. Although the asset size of nonbank financial
companies may not be the determinative factor of whether such companies
may pose systemic risks and would be designated by the Council for
supervision by the Board, it is an important consideration.\12\ It is
therefore unlikely that a financial firm that is at or below the $175
million asset threshold would be designated by the Council under
section 113 of the Dodd-Frank Act because material financial distress
at such firms, or the nature, scope, size, scale, concentration,
interconnectedness, or mix of its activities, are not likely to pose a
threat to the financial stability of the United States.
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\11\ The Dodd-Frank Act provides that the Board may, on the
recommendation of the Council, increase the $50 billion asset
threshold for the application of certain of the enhanced standards.
See 12 U.S.C. 5365(a)(2)(B). However, neither the Board nor the
Council has the authority to lower such threshold.
\12\ See 76 FR 4555 (January 26, 2011).
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As noted above, because the proposed policy statement is not likely
to apply to any company with assets of $175 million or less, if adopted
in final form, it is not expected to affect any small entity for
purposes of the RFA. The Board does not believe that the proposed
policy statement duplicates, overlaps, or conflicts with any other
Federal rules. In light of the foregoing, the Board does not believe
that the proposed policy statement, if adopted in final form, would
have a significant economic impact on a substantial number of small
entities supervised. Nonetheless, the Board seeks comment on whether
the proposed policy statement would impose undue burdens on, or have
unintended consequences for, small organizations, and whether there are
ways such potential burdens or consequences could be minimized in a
manner consistent its purpose.
List of Subjects in 12 CFR Part 252
Administrative practice and procedure, Banks, Banking, Federal
Reserve System, Holding companies, Nonbank financial companies
supervised by the Board, Reporting and recordkeeping requirements,
Securities, Stress testing.
Authority and Issuance
For the reasons stated in the SUPPLEMENTARY INFORMATION, the Board
of Governors of the Federal Reserve System proposes to amend 12 CFR
part 252 as follows:
PART 252--ENHANCED PRUDENTIAL STANDARDS (Regulation YY)
0
1. The authority citation for part 252 continues to read as follows:
Authority: 12 U.S.C. 321-338a, 1467a(g), 1818, 1831p-1,
1844(b), 1844(c), 5361, 5365, 5366.
0
2. Appendix A to part 252 is revised to read as follows:
Appendix A to Part 252--Policy Statement on the Scenario Design
Framework for Stress Testing
1. Background
a. The Board has imposed stress testing requirements through its
regulations (stress test rules) implementing section 165(i) of the
Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-
Frank Act or Act) and through its capital plan rule (12 CFR 225.8).
Under the stress test rules issued under section 165(i)(1) of the
Act, the Board conducts an annual stress test (supervisory stress
tests), on a consolidated basis, of each bank holding company with
total consolidated assets of $50 billion or more, intermediate
holding company of a foreign banking organization, and nonbank
financial company that the Financial Stability Oversight Council has
designated for supervision by the Board (together, covered
companies).\1\ In addition, under the stress test rules issued under
section 165(i)(2) of the Act, covered companies must conduct stress
tests semi-annually and other financial
[[Page 59539]]
companies with total consolidated assets of more than $10 billion
and for which the Board is the primary regulatory agency must
conduct stress tests on an annual basis (together, company-run
stress tests).\2\ The Board will provide for at least three
different sets of conditions (each set, a scenario), including
baseline, adverse, and severely adverse scenarios for both
supervisory and company-run stress tests (macroeconomic
scenarios).\3\
---------------------------------------------------------------------------
\1\ 12 U.S.C. 5365(i)(1); 12 CFR part 252, subpart E.
\2\ 12 U.S.C. 5365(i)(2); 12 CFR part 252, subparts B and F.
\3\ The stress test rules define scenarios, baseline scenario,
adverse scenario, and severely adverse scenario. See 12 CFR
252.12(b), (f), (p), and (q); 12 CFR 252.42(b), (e), (n), and (o);
12 CFR 252.52(b), (e), (o), and (p).
---------------------------------------------------------------------------
b. The stress test rules provide that the Board will notify
covered companies by no later than February 15 of each year of the
scenarios it will use to conduct its annual supervisory stress tests
and provide, also by no later than February 15, covered companies
and other financial companies subject to the final rules the set of
scenarios they must use to conduct their annual company-run stress
tests.\4\ Under the stress test rules, the Board may require certain
companies to use additional components in the adverse or severely
adverse scenario or additional scenarios. For example, the Board
expects to require large banking organizations with significant
trading activities to include a trading and counterparty component
(market shock, described in the following sections) in their adverse
and severely adverse scenarios. The Board will provide any
additional components or scenario by no later than March 1 of each
year.\5\ The Board expects that the scenarios it will require the
companies to use will be the same as those the Board will use to
conduct its supervisory stress tests (together, stress test
scenarios).
---------------------------------------------------------------------------
\4\ Id.
\5\ Id.
---------------------------------------------------------------------------
c. In addition, Sec. 225.8 of the Board's Regulation Y (capital
plan rule) requires covered companies to submit annual capital
plans, including stress test results, to the Board to allow the
Board to assess whether they have robust, forward-looking capital
planning processes and have sufficient capital to continue
operations throughout times of economic and financial stress.\6\
---------------------------------------------------------------------------
\6\ See 12 CFR 225.8.
---------------------------------------------------------------------------
d. Stress tests required under the stress test rules and under
the capital plan rule require the Board and financial companies to
calculate pro-forma capital levels--rather than ``current'' or
actual levels--over a specified planning horizon under baseline and
stressful scenarios. This approach integrates key lessons of the
2007-2009 financial crisis into the Board's supervisory framework.
During the financial crisis, investor and counterparty confidence in
the capitalization of financial companies eroded rapidly in the face
of changes in the current and expected economic and financial
conditions, and this loss in market confidence imperiled companies'
ability to access funding, continue operations, serve as a credit
intermediary, and meet obligations to creditors and counterparties.
Importantly, such a loss in confidence occurred even when a
financial institution's capital ratios were in excess of regulatory
minimums. This is because the institution's capital ratios were
perceived as lagging indicators of its financial condition,
particularly when conditions were changing.
e. The stress tests required under the stress test rules and
capital plan rule are a valuable supervisory tool that provide a
forward-looking assessment of large financial companies' capital
adequacy under hypothetical economic and financial market
conditions. Currently, these stress tests primarily focus on credit
risk and market risk--that is, risk of mark-to-market losses
associated with companies' trading and counterparty positions--and
not on other types of risk, such as liquidity risk. Pressures
stemming from these sources are considered in separate supervisory
exercises. No single supervisory tool, including the stress tests,
can provide an assessment of a company's ability to withstand every
potential source of risk.
f. Selecting appropriate scenarios is an especially significant
consideration for stress tests required under the capital plan rule,
which ties the review of a company's performance under stress
scenarios to its ability to make capital distributions. More severe
scenarios, all other things being equal, generally translate into
larger projected declines in banks' capital. Thus, a company would
need more capital today to meet its minimum capital requirements in
more stressful scenarios and have the ability to continue making
capital distributions, such as common dividend payments. This
translation is far from mechanical, however; it will depend on
factors that are specific to a given company, such as underwriting
standards and the company's business model, which would also greatly
affect projected revenue, losses, and capital.
2. Overview and Scope
a. This policy statement provides more detail on the
characteristics of the stress test scenarios and explains the
considerations and procedures that underlie the approach for
formulating these scenarios. The considerations and procedures
described in this policy statement apply to the Board's stress
testing framework, including to the stress tests required under 12
CFR part 252, subparts B, E, and F, as well as the Board's capital
plan rule (12 CFR 225.8).\7\
---------------------------------------------------------------------------
\7\ 12 CFR 252.14(a), 12 CFR 252.44(a), 12 CFR 252.54(a).
---------------------------------------------------------------------------
b. Although the Board does not envision that the broad approach
used to develop scenarios will change from year to year, the stress
test scenarios will reflect changes in the outlook for economic and
financial conditions and changes to specific risks or
vulnerabilities that the Board, in consultation with the other
federal banking agencies, determines should be considered in the
annual stress tests. The stress test scenarios should not be
regarded as forecasts; rather, they are hypothetical paths of
economic variables that will be used to assess the strength and
resilience of the companies' capital in various economic and
financial environments.
c. The remainder of this policy statement is organized as
follows. Section 3 provides a broad description of the baseline,
adverse, and severely adverse scenarios and describes the types of
variables that the Board expects to include in the macroeconomic
scenarios and the market shock component of the stress test
scenarios applicable to companies with significant trading activity.
Section 4 describes the Board's approach for developing the
macroeconomic scenarios, and section 5 describes the approach for
the market shocks. Section 6 describes the relationship between the
macroeconomic scenario and the market shock components. Section 7
provides a timeline for the formulation and publication of the
macroeconomic assumptions and market shocks.
3. Content of the Stress Test Scenarios
a. The Board will publish a minimum of three different
scenarios, including baseline, adverse, and severely adverse
conditions, for use in stress tests required in the stress test
rules.\8\ In general, the Board anticipates that it will not issue
additional scenarios. Specific circumstances or vulnerabilities that
in any given year the Board determines require particular vigilance
to ensure the resilience of the banking sector will be captured in
either the adverse or severely adverse scenarios. A greater number
of scenarios could be needed in some years--for example, because the
Board identifies a large number of unrelated and uncorrelated but
nonetheless significant risks.
---------------------------------------------------------------------------
\8\ 12 CFR 252.14(b), 12 CFR 252.44(b), 12 CFR 252.54(b).
---------------------------------------------------------------------------
b. While the Board generally expects to use the same scenarios
for all companies subject to the final rule, it may require a subset
of companies--depending on a company's financial condition, size,
complexity, risk profile, scope of operations, or activities, or
risks to the U.S. economy--to include additional scenario components
or additional scenarios that are designed to capture different
effects of adverse events on revenue, losses, and capital. One
example of such components is the market shock that applies only to
companies with significant trading activity. Additional components
or scenarios may also include other stress factors that may not
necessarily be directly correlated to macroeconomic or financial
assumptions but nevertheless can materially affect companies' risks,
such as the unexpected default of a major counterparty.
c. Early in each stress testing cycle, the Board plans to
publish the macroeconomic scenarios along with a brief narrative
summary that provides a description of the economic situation
underlying the scenario and explains how the scenarios have changed
relative to the previous year. In addition, to assist companies in
projecting the paths of additional variables in a manner consistent
with the scenario, the narrative will also provide descriptions of
the general path of some additional variables. These descriptions
will be general--that is, they will describe developments for broad
classes of variables rather than for specific variables--and will
specify the intensity and direction of variable
[[Page 59540]]
changes but not numeric magnitudes. These descriptions should
provide guidance that will be useful to companies in specifying the
paths of the additional variables for their company-run stress
tests. Note that in practice it will not be possible for the
narrative to include descriptions on all of the additional variables
that companies may need for their company-run stress tests. In cases
where scenarios are designed to reflect particular risks and
vulnerabilities, the narrative will also explain the underlying
motivation for these features of the scenario. The Board also plans
to release a broad description of the market shock components.
3.1 Macroeconomic Scenarios
a. The macroeconomic scenarios will consist of the future paths
of a set of economic and financial variables.\9\ The economic and
financial variables included in the scenarios will likely comprise
those included in the ``2014 Supervisory Scenarios for Annual Stress
Tests Required under the Dodd-Frank Act Stress Testing Rules and the
Capital Plan Rule'' (2013 supervisory scenarios). The domestic U.S.
variables provided for in the 2013 supervisory scenarios included:
---------------------------------------------------------------------------
\9\ The future path of a variable refers to its specification
over a given time period. For example, the path of unemployment can
be described in percentage terms on a quarterly basis over the
stress testing time horizon.
---------------------------------------------------------------------------
i. Six measures of economic activity and prices: Real and
nominal gross domestic product (GDP) growth, the unemployment rate
of the civilian non-institutional population aged 16 and over, real
and nominal disposable personal income growth, and the Consumer
Price Index (CPI) inflation rate;
ii. Four measures of developments in equity and property
markets: The Core Logic National House Price Index, the National
Council for Real Estate Investment Fiduciaries Commercial Real
Estate Price Index, the Dow Jones Total Stock Market Index, and the
Chicago Board Options Exchange Market Volatility Index; and
iii. Six measures of interest rates: The rate on the three-month
Treasury bill, the yield on the 5-year Treasury bond, the yield on
the 10-year Treasury bond, the yield on a 10-year BBB corporate
security, the prime rate, and the interest rate associated with a
conforming, conventional, fixed-rate, 30-year mortgage.
b. The international variables provided for in the 2014
supervisory scenarios included, for the euro area, the United
Kingdom, developing Asia, and Japan:
i. Percent change in real GDP;
ii. Percent change in the Consumer Price Index or local
equivalent; and
iii. The U.S./foreign currency exchange rate.\10\
---------------------------------------------------------------------------
\10\ The Board may increase the range of countries or regions
included in future scenarios, as appropriate.
---------------------------------------------------------------------------
c. The economic variables included in the scenarios influence
key items affecting financial companies' net income, including pre-
provision net revenue and credit losses on loans and securities.
Moreover, these variables exhibit fairly typical trends in adverse
economic climates that can have unfavorable implications for
companies' net income and, thus, capital positions.
d. The economic variables included in the scenario may change
over time. For example, the Board may add variables to a scenario if
the international footprint of companies that are subject to the
stress testing rules changed notably over time such that the
variables already included in the scenario no longer sufficiently
capture the material risks of these companies. Alternatively,
historical relationships between macroeconomic variables could
change over time such that one variable (e.g., disposable personal
income growth) that previously provided a good proxy for another
(e.g., light vehicle sales) in modeling companies' pre-provision net
revenue or credit losses ceases to do so, resulting in the need to
create a separate path, or alternative proxy, for the other
variable. However, recognizing the amount of work required for
companies to incorporate the scenario variables into their stress
testing models, the Board expects to eliminate variables from the
scenarios only in rare instances.
e. The Board expects that the company may not use all of the
variables provided in the scenario, if those variables are not
appropriate to the company's line of business, or may add additional
variables, as appropriate. The Board expects the companies will
ensure that the paths of such additional variables are consistent
with the scenarios the Board provided. For example, the companies
may use, as part of their internal stress test models, local-level
variables, such as state-level unemployment rates or city-level
house prices. While the Board does not plan to include local-level
macro variables in the stress test scenarios it provides, it expects
the companies to evaluate the paths of local-level macro variables
as needed for their internal models, and ensure internal consistency
between these variables and their aggregate, macro-economic
counterparts. The Board will provide the macroeconomic scenario
component of the stress test scenarios for a period that spans a
minimum of 13 quarters. The scenario horizon reflects the
supervisory stress test approach that the Board plans to use. Under
the stress test rules, the Board will assess the effect of different
scenarios on the consolidated capital of each company over a
forward-looking planning horizon of at least nine quarters.
3.2 Market Shock Component
a. The market shock component of the adverse and severely
adverse scenarios will only apply to companies with significant
trading activity and their subsidiaries.\11\ The component consists
of large moves in market prices and rates that would be expected to
generate losses. Market shocks differ from macroeconomic scenarios
in a number of ways, both in their design and application. For
instance, market shocks that might typically be observed over an
extended period (e.g., 6 months) are assumed to be an instantaneous
event which immediately affects the market value of the companies'
trading assets and liabilities. In addition, under the stress test
rules, the as-of date for market shocks will differ from the
quarter-end, and the Board will provide the as-of date for market
shocks no later than February 1 of each year. Finally, as described
in section 4, the market shock includes a much larger set of risk
factors than the set of economic and financial variables included in
macroeconomic scenarios. Broadly, these risk factors include shocks
to financial market variables that affect asset prices, such as a
credit spread or the yield on a bond, and, in some cases, the value
of the position itself (e.g., the market value of private equity
positions).
---------------------------------------------------------------------------
\11\ Currently, companies with significant trading activity
include any bank holding company or intermediate holding company
that (1) has aggregate trading assets and liabilities of $50 billion
or more, or aggregate trading assets and liabilities equal to 10
percent or more of total consolidated assets, and (2) is not a large
and noncomplex firm. The Board may also subject a state member bank
subsidiary of any such bank holding company to the market shock
component. The set of companies subject to the market shock
component could change over time as the size, scope, and complexity
of financial company's trading activities evolve.
---------------------------------------------------------------------------
b. The Board envisions that the market shocks will include
shocks to a broad range of risk factors that are similar in
granularity to those risk factors trading companies use internally
to produce profit and loss estimates, under stressful market
scenarios, for all asset classes that are considered trading assets,
including equities, credit, interest rates, foreign exchange rates,
and commodities. Examples of risk factors include, but are not
limited to:
i. Equity indices of all developed markets, and of developing
and emerging market nations to which companies with significant
trading activity may have exposure, along with term structures of
implied volatilities;
ii. Cross-currency FX rates of all major and many minor
currencies, along term structures of implied volatilities;
iii. Term structures of government rates (e.g., U.S.
Treasuries), interbank rates (e.g., swap rates) and other key rates
(e.g., commercial paper) for all developed markets and for
developing and emerging market nations to which companies may have
exposure;
iv. Term structures of implied volatilities that are key inputs
to the pricing of interest rate derivatives;
v. Term structures of futures prices for energy products
including crude oil (differentiated by country of origin), natural
gas, and power;
vi. Term structures of futures prices for metals and
agricultural commodities;
vii. ``Value-drivers'' (credit spreads or instrument prices
themselves) for credit-sensitive product segments including:
Corporate bonds, credit default swaps, and collateralized debt
obligations by risk; non-agency residential mortgage-backed
securities and commercial mortgage-backed securities by risk and
vintage; sovereign debt; and, municipal bonds; and
viii. Shocks to the values of private equity positions.
4. Approach for Formulating the Macroeconomic Assumptions for Scenarios
a. This section describes the Board's approach for formulating
macroeconomic
[[Page 59541]]
assumptions for each scenario. The methodologies for formulating
this part of each scenario differ by scenario, so these
methodologies for the baseline, severely adverse, and the adverse
scenarios are described separately in each of the following
subsections.
b. In general, the baseline scenario will reflect the most
recently available consensus views of the macroeconomic outlook
expressed by professional forecasters, government agencies, and
other public-sector organizations as of the beginning of the annual
stress-test cycle. The severely adverse scenario will consist of a
set of economic and financial conditions that reflect the conditions
of post-war U.S. recessions. The adverse scenario will consist of a
set of economic and financial conditions that are more adverse than
those associated with the baseline scenario but less severe than
those associated with the severely adverse scenario.
c. Each of these scenarios is described further in sections
below as follows: Baseline (subsection 4.1), severely adverse
(subsection 4.2), and adverse (subsection 4.3).
4.1 Approach for Formulating Macroeconomic Assumptions in the
Baseline Scenario
a. The stress test rules define the baseline scenario as a set
of conditions that affect the U.S. economy or the financial
condition of a banking organization, and that reflect the consensus
views of the economic and financial outlook. Projections under a
baseline scenario are used to evaluate how companies would perform
in more likely economic and financial conditions. The baseline
serves also as a point of comparison to the severely adverse and
adverse scenarios, giving some sense of how much of the company's
capital decline could be ascribed to the scenario as opposed to the
company's capital adequacy under expected conditions.
b. The baseline scenario will be developed around a
macroeconomic projection that captures the prevailing views of
private-sector forecasters (e.g. Blue Chip Consensus Forecasts and
the Survey of Professional Forecasters), government agencies, and
other public-sector organizations (e.g., the International Monetary
Fund and the Organization for Economic Co-operation and Development)
near the beginning of the annual stress-test cycle. The baseline
scenario is designed to represent a consensus expectation of certain
economic variables over the time period of the tests and it is not
the Board's internal forecast for those economic variables. For
example, the baseline path of short-term interest rates is
constructed from consensus forecasts and may differ from that
implied by the FOMC's Summary of Economic Projections.
c. For some scenario variables--such as U.S. real GDP growth,
the unemployment rate, and the consumer price index--there will be a
large number of different forecasts available to project the paths
of these variables in the baseline scenario. For others, a more
limited number of forecasts will be available. If available
forecasts diverge notably, the baseline scenario will reflect an
assessment of the forecast that is deemed to be most plausible. In
setting the paths of variables in the baseline scenario, particular
care will be taken to ensure that, together, the paths present a
coherent and plausible outlook for the U.S. and global economy,
given the economic climate in which they are formulated.
4.2 Approach for Formulating the Macroeconomic Assumptions in the
Severely Adverse Scenario
The stress test rules define a severely adverse scenario as a
set of conditions that affect the U.S. economy or the financial
condition of a financial company and that overall are more severe
than those associated with the adverse scenario. The financial
company will be required to publicly disclose a summary of the
results of its stress test under the severely adverse scenario, and
the Board intends to publicly disclose the results of its analysis
of the financial company under the adverse scenario and the severely
adverse scenario.
4.2.1 General Approach: The Recession Approach
a. The Board intends to use a recession approach to develop the
severely adverse scenario. In the recession approach, the Board will
specify the future paths of variables to reflect conditions that
characterize post-war U.S. recessions, generating either a typical
or specific recreation of a post-war U.S. recession. The Board chose
this approach because it has observed that the conditions that
typically occur in recessions--such as increasing unemployment,
declining asset prices, and contracting loan demand--can put
significant stress on companies' balance sheets. This stress can
occur through a variety of channels, including higher loss
provisions due to increased delinquencies and defaults; losses on
trading positions through sharp moves in market prices; and lower
bank income through reduced loan originations. For these reasons,
the Board believes that the paths of economic and financial
variables in the severely adverse scenario should, at a minimum,
resemble the paths of those variables observed during a recession.
b. This approach requires consideration of the type of recession
to feature. All post-war U.S. recessions have not been identical:
Some recessions have been associated with very elevated interest
rates, some have been associated with sizable asset price declines,
and some have been relatively more global. The most common features
of recessions, however, are increases in the unemployment rate and
contractions in aggregate incomes and economic activity. For this
and the following reasons, the Board intends to use the unemployment
rate as the primary basis for specifying the severely adverse
scenario. First, the unemployment rate is likely the most
representative single summary indicator of adverse economic
conditions. Second, in comparison to GDP, labor market data have
traditionally featured more prominently than GDP in the set of
indicators that the National Bureau of Economic Research reviews to
inform its recession dates.\12\ Third and finally, the growth rate
of potential output can cause the size of the decline in GDP to vary
between recessions. While changes in the unemployment rate can also
vary over time due to demographic factors, this seems to have more
limited implications over time relative to changes in potential
output growth. The unemployment rate used in the severely adverse
scenario will reflect an unemployment rate that has been observed in
severe post-war U.S. recessions, measuring severity by the absolute
level of and relative increase in the unemployment rate.\13\
---------------------------------------------------------------------------
\12\ More recently, a monthly measure of GDP has been added to
the list of indicators.
\13\ Even though all recessions feature increases in the
unemployment rate and contractions in incomes and economic activity,
the size of this change has varied over post-war U.S. recessions.
Table 1 of this appendix documents the variability in the depth of
post-war U.S. recessions. Some recessions--labeled mild in Table 1--
have been relatively modest with GDP edging down just slightly and
the unemployment rate moving up about a percentage point. Other
recessions--labeled severe in Table 1--have been much harsher with
GDP dropping 3\3/4\ percent and the unemployment rate moving up a
total of about 4 percentage points.
---------------------------------------------------------------------------
c. The Board believes that the severely adverse scenario should
also reflect a housing recession. The house prices path set in the
severely adverse scenario will reflect developments that have been
observed in post-war U.S. housing recessions, measuring severity by
the absolute level of and relative decrease in the house prices.
d. The Board will specify the paths of most other macroeconomic
variables based on the paths of unemployment, income, house prices,
and activity. Some of these other variables, however, have taken
wildly divergent paths in previous recessions (e.g., foreign GDP),
requiring the Board to use its informed judgment in selecting
appropriate paths for these variables. In general, the path for
these other variables will be based on their underlying structure at
the time that the scenario is designed (e.g., economic or financial-
system vulnerabilities in other countries).
e. The Board considered alternative methods for scenario design
of the severely adverse scenario, including a probabilistic
approach. The probabilistic approach constructs a baseline forecast
from a large-scale macroeconomic model and identifies a scenario
that would have a specific probabilistic likelihood given the
baseline forecast. The Board believes that, at this time, the
recession approach is better suited for developing the severely
adverse scenario than a probabilistic approach because it guarantees
a recession of some specified severity. In contrast, the
probabilistic approach requires the choice of an extreme tail
outcome--relative to baseline--to characterize the severely adverse
scenario (e.g., a 5 percent or a 1 percent tail outcome). In
practice, this choice is difficult as adverse economic outcomes are
typically thought of in terms of how variables evolve in an absolute
sense rather than how far away they lie in the probability space
away from the baseline. In this sense, a scenario featuring a
recession may be somewhat clearer and more straightforward to
communicate. Finally, the
[[Page 59542]]
probabilistic approach relies on estimates of uncertainty around the
baseline scenario and such estimates are in practice model-
dependent.
4.2.2 Setting the Unemployment Rate Under the Severely Adverse
Scenario
a. The Board anticipates that the severely adverse scenario will
feature an unemployment rate that increases between 3 to 5
percentage points from its initial level over the course of 6 to 8
calendar quarters.\14\ The initial level will be set based on the
conditions at the time that the scenario is designed. However, if a
3 to 5 percentage point increase in the unemployment rate does not
raise the level of the unemployment rate to at least 10 percent--the
average level to which it has increased in the most recent three
severe recessions--the path of the unemployment rate in most cases
will be specified so as to raise the unemployment rate to at least
10 percent.
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\14\ Six to eight quarters is the average number of quarters for
which a severe recession lasts plus the average number of subsequent
quarters over which the unemployment rate continues to rise. The
variable length of the timeframe reflects the different paths to the
peak unemployment rate depending on the severity of the scenario.
---------------------------------------------------------------------------
b. This methodology is intended to generate scenarios that
feature stressful outcomes but do not induce greater procyclicality
in the financial system and macroeconomy. When the economy is in the
early stages of a recovery, the unemployment rate in a baseline
scenario generally trends downward, resulting in a larger difference
between the path of the unemployment rate in the severely adverse
scenario and the baseline scenario and a severely adverse scenario
that is relatively more intense. Conversely, in a sustained strong
expansion--when the unemployment rate may be below the level
consistent with full employment--the unemployment in a baseline
scenario generally trends upward, resulting in a smaller difference
between the path of the unemployment rate in the severely adverse
scenario and the baseline scenario and a severely adverse scenario
that is relatively less intense. Historically, a 3 to 5 percentage
point increase in unemployment rate is reflective of stressful
conditions. As illustrated in Table 1 of this appendix, over the
last half-century, the U.S. economy has experienced four severe
post-war recessions. In all four of these recessions the
unemployment rate increased 3 to 5 percentage points and in the
three most recent of these recessions the unemployment rate reached
a level between 9 percent and 11 percent.
c. Under this method, if the initial unemployment rate were
low--as it would be after a sustained long expansion--the
unemployment rate in the scenario would increase to a level as high
as what has been seen in past severe recessions. However, if the
initial unemployment rate were already high--as would be the case in
the early stages of a recovery--the unemployment rate would exhibit
a change as large as what has been seen in past severe recessions.
d. The Board believes that the typical increase in the
unemployment rate in the severely adverse scenario will be about 4
percentage points. However, the Board will calibrate the increase in
unemployment based on its views of the status of cyclical systemic
risk. The Board intends to set the unemployment rate at the higher
end of the range if the Board believed that cyclical systemic risks
were high (as it would be after a sustained long expansion), and to
the lower end of the range if cyclical systemic risks were low (as
it would be in the earlier stages of a recovery). This may result in
a scenario that is slightly more intense than normal if the Board
believed that cyclical systemic risks were increasing in a period of
robust expansion.\15\ Conversely, it will allow the Board to specify
a scenario that is slightly less intense than normal in an
environment where systemic risks appeared subdued, such as in the
early stages of an expansion. Indeed, the Board expects that, in
general, it will adopt a change in the unemployment rate of less
than 4 percentage points when the unemployment rate at the start of
the scenarios is elevated but the labor market is judged to be
strengthening and higher-than-usual credit losses stemming from
previously elevated unemployment rates were either already
realized--or are in the process of being realized--and thus removed
from banks' balance sheets.\16\ However, even at the lower end of
the range of unemployment-rate increases, the scenario will still
feature an increase in the unemployment rate similar to what has
been seen in about half of the severe recessions of the last 50
years.
---------------------------------------------------------------------------
\15\ Note, however, that the severity of the scenario would not
exceed an implausible level: even at the upper end of the range of
unemployment-rate increases, the path of the unemployment rate would
still be consistent with severe post-war U.S. recessions.
\16\ Evidence of a strengthening labor market could include a
declining unemployment rate, steadily expanding nonfarm payroll
employment, or improving labor force participation. Evidence that
credit losses are being realized could include elevated charge-offs
on loans and leases, loan-loss provisions in excess of gross charge-
offs, or losses being realized in securities portfolios that include
securities that are subject to credit risk.
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e. As indicated previously, if a 3 to 5 percentage point
increase in the unemployment rate does not raise the level of the
unemployment rate to 10 percent--the average level to which it has
increased in the most recent three severe recessions--the path of
the unemployment rate will be specified so as to raise the
unemployment rate to 10 percent. Setting a floor for the
unemployment rate at 10 percent recognizes the fact that not only do
cyclical systemic risks build up at financial intermediaries during
robust expansions but that these risks are also easily obscured by
the buoyant environment.
f. In setting the increase in the unemployment rate, the Board
will consider the extent to which analysis by economists,
supervisors, and financial market experts finds cyclical systemic
risks to be elevated (but difficult to be captured more precisely in
one of the scenario's other variables). In addition, the Board--in
light of impending shocks to the economy and financial system--will
also take into consideration the extent to which a scenario of some
increased severity might be necessary for the results of the stress
test and the associated supervisory actions to sustain confidence in
financial institutions.
g. While the approach to specifying the severely adverse
scenario is designed to avoid adding sources of procyclicality to
the financial system, it is not designed to explicitly offset any
existing procyclical tendencies in the financial system. The purpose
of the stress test scenarios is to make sure that the companies are
properly capitalized to withstand severe economic and financial
conditions, not to serve as an explicit countercyclical offset to
the financial system.
h. In developing the approach to the unemployment rate, the
Board also considered a method that would increase the unemployment
rate to some fairly elevated fixed level over the course of 6 to 8
quarters. This will result in scenarios being more severe in robust
expansions (when the unemployment rate is low) and less severe in
the early stages of a recovery (when the unemployment rate is high)
and so would not result in pro-cyclicality. Depending on the initial
level of the unemployment rate, this approach could lead to only a
very modest increase in the unemployment rate--or even a decline. As
a result, this approach--while not procyclical--could result in
scenarios not featuring stressful macroeconomic outcomes.
4.2.3 Setting the Other Variables in the Severely Adverse Scenario
a. Generally, all other variables in the severely adverse
scenario will be specified to be consistent with the increase in the
unemployment rate. The approach for specifying the paths of these
variables in the scenario will be a combination of (1) how economic
models suggest that these variables should evolve given the path of
the unemployment rate, (2) how these variables have typically
evolved in past U.S. recessions, and (3) and evaluation of these and
other factors.
b. Economic models--such as medium-scale macroeconomic models--
should be able to generate plausible paths consistent with the
unemployment rate for a number of scenario variables, such as real
GDP growth, CPI inflation and short-term interest rates, which have
relatively stable (direct or indirect) relationships with the
unemployment rate (e.g., Okun's Law, the Phillips Curve, and
interest rate feedback rules). For some other variables, specifying
their paths will require a case-by-case consideration.
c. Declining house prices, which are an important source of
stress to a company's balance sheet, are not a steadfast feature of
recessions, and the historical relationship of house prices with the
unemployment rate is not strong. Simply adopting their typical path
in a severe recession would likely underestimate risks stemming from
the housing sector. In specifying the path for nominal house prices,
the Board will consider the ratio of the nominal house price index
(HPI) to nominal, per capita, disposable income (DPI). The Board
believes that the typical decline in the HPI-DPI ratio will be at a
minimum 25 percent from its starting value, or enough to bring the
ratio
[[Page 59543]]
down to its Great Recession trough. As illustrated in Table 2 of
this appendix, housing recessions have on average featured HPI-DPI
ratio declines of about 25 percent and the HPI-DPI ratio fell to its
Great Recession trough.\17\
---------------------------------------------------------------------------
\17\ The house-price retrenchments that occurred over the
periods 1980-1985, 1989-1996, 2006-2011 (as detailed in Table 2 of
this appendix) are referred to in this document as housing
recessions. The date-ranges of housing recessions are based on the
timing of house-price retrenchments. These dates were also
associated with sustained declines in real residential investment,
although, the precise timings of housing recessions would likely be
slightly different were they to be classified based on real
residential investment in addition to house prices. The ratios
described in Table 2 are calculated based on nominal HPI and HPI-DPI
ratios indexed to 100 in 2000:Q1.
---------------------------------------------------------------------------
d. In addition, judgment is necessary in projecting the path of
a scenario's international variables. Recessions that occur
simultaneously across countries are an important source of stress to
the balance sheets of companies with notable international exposures
but are not an invariable feature of the international economy. As a
result, simply adopting the typical path of international variables
in a severe U.S. recession would likely underestimate the risks
stemming from the international economy. Consequently, an approach
that uses both judgment and economic models informs the path of
international variables.
4.2.4 Adding Salient Risks to the Severely Adverse Scenario
a. The severely adverse scenario will be developed to reflect
specific risks to the economic and financial outlook that are
especially salient but will feature minimally in the scenario if the
Board were only to use approaches that looked to past recessions or
relied on historical relationships between variables.
b. There are some important instances when it will be
appropriate to augment the recession approach with salient risks.
For example, if an asset price were especially elevated and thus
potentially vulnerable to an abrupt and potentially destabilizing
decline, it would be appropriate to include such a decline in the
scenario even if such a large drop were not typical in a severe
recession. Likewise, if economic developments abroad were
particularly unfavorable, assuming a weakening in international
conditions larger than what typically occurs in severe U.S.
recessions would likely also be appropriate.
c. Clearly, while the recession component of the severely
adverse scenario is within some predictable range, the salient risk
aspect of the scenario is far less so, and therefore, needs an
annual assessment. Each year, the Board will identify the risks to
the financial system and the domestic and international economic
outlooks that appear more elevated than usual, using its internal
analysis and supervisory information and in consultation with the
Federal Deposit Insurance Corporation (FDIC) and the Office of the
Comptroller of the Currency (OCC). Using the same information, the
Board will then calibrate the paths of the macroeconomic and
financial variables in the scenario to reflect these risks.
d. Detecting risks that have the potential to weaken the banking
sector is particularly difficult when economic conditions are
buoyant, as a boom can obscure the weaknesses present in the system.
In sustained robust expansions, therefore, the selection of salient
risks to augment the scenario will err on the side of including
risks of uncertain significance.
e. The Board will factor in particular risks to the domestic and
international macroeconomic outlook identified by its economists,
bank supervisors, and financial market experts and make appropriate
adjustments to the paths of specific economic variables. These
adjustments will not be reflected in the general severity of the
recession and, thus, all macroeconomic variables; rather, the
adjustments will apply to a subset of variables to reflect co-
movements in these variables that are historically less typical. The
Board plans to discuss the motivation for the adjustments that it
makes to variables to highlight systemic risks in the narrative
describing the scenarios.\18\
---------------------------------------------------------------------------
\18\ The means of effecting an adjustment to the severely
adverse scenario to address salient systemic risks differs from the
means used to adjust the unemployment rate. For example, in
adjusting the scenario for an increased unemployment rate, the Board
would modify all variables such that the future paths of the
variables are similar to how these variables have moved
historically. In contrast, to address salient risks, the Board may
only modify a small number of variables in the scenario and, as
such, their future paths in the scenario would be somewhat more
atypical, albeit not implausible, given existing risks.
---------------------------------------------------------------------------
4.3 Approach for Formulating Macroeconomic Assumptions in the
Adverse Scenario
a. The adverse scenario can be developed in a number of
different ways, and the selected approach will depend on a number of
factors, including how the Board intends to use the results of the
adverse scenario.\19\ Generally, the Board believes that the
companies should consider multiple adverse scenarios for their
internal capital planning purposes, and likewise, it is appropriate
that the Board consider more than one adverse scenario to assess a
company's ability to withstand stress. Accordingly, the Board does
not identify a single approach for specifying the adverse scenario.
Rather, the adverse scenario will be formulated according to one of
the possibilities listed below. The Board may vary the approach it
uses for the adverse scenario each year so that the results of the
scenario provide the most value to supervisors, in light of current
condition of the economy and the financial services industry.
---------------------------------------------------------------------------
\19\ For example, in the context of CCAR, the Board currently
uses the adverse scenario as one consideration in evaluating a
firm's capital adequacy.
---------------------------------------------------------------------------
b. The simplest method to specify the adverse scenario is to
develop a less severe version of the severely adverse scenario. For
example, the adverse scenario could be formulated such that the
deviations of the paths of the variables relative to the baseline
were simply one-half of or two-thirds of the deviations of the paths
of the variables relative to the baseline in the severely adverse
scenario. A priori, specifying the adverse scenario in this way may
appear unlikely to provide the greatest possible informational value
to supervisors--given that it is just a less severe version of the
severely adverse scenario. However, to the extent that the effect of
macroeconomic variables on company loss positions and incomes are
nonlinear, there could be potential value from this approach.
c. Another method to specify the adverse scenario is to capture
risks in the adverse scenario that the Board believes should be
understood better or should be monitored, but does not believe
should be included in the severely adverse scenario, perhaps because
these risks would render the scenario implausibly severe. For
instance, the adverse scenario could feature sizable increases in
oil or natural gas prices or shifts in the yield curve that are
atypical in a recession. The adverse scenario might also feature
less acute, but still consequential, adverse outcomes, such as a
disruptive slowdown in growth from emerging-market economies.
d. Under the Board's stress test rules, covered companies are
required to develop their own scenarios for mid-cycle company-run
stress tests.\20\ A particular combination of risks included in
these scenarios may inform the design of the adverse scenario for
annual stress tests. In this same vein, another possibility would be
to use modified versions of the circumstances that companies
describe in their living wills as being able to cause their
failures.
---------------------------------------------------------------------------
\20\ 12 CFR 252.55.
---------------------------------------------------------------------------
e. It might also be informative to periodically use a stable
adverse scenario, at least for a few consecutive years. Even if the
scenario used for the stress test does not change over the credit
cycle, if companies tighten and relax lending standards over the
cycle, their loss rates under the adverse scenario--and indirectly
the projected changes to capital--would decrease and increase,
respectively. A consistent scenario would allow the direct
observation of how capital fluctuates to reflect growing cyclical
risks.
f. The Board may consider specifying the adverse scenario using
the probabilistic approach described in section 4.2.1 (that is, with
a specified lower probability of occurring than the severely adverse
scenario but a greater probability of occurring than the baseline
scenario). The approach has some intuitive appeal despite its
shortcomings. For example, using this approach for the adverse
scenario could allow the Board to explore an alternative approach to
develop stress testing scenarios and their effect on a company's net
income and capital.
g. Finally, the Board could design the adverse scenario based on
a menu of historical experiences--such as, a moderate recession
(e.g., the 1990-1991 recession); a stagflation event (e.g.,
stagflation during 1974); an emerging markets crisis (e.g., the
Asian currency crisis of 1997-1998); an oil price shock (e.g., the
shock during the run up
[[Page 59544]]
to the 1990-1991 recession); or high inflation shock (e.g., the
inflation pressures of 1977-1979). The Board believes these are
important stresses that should be understood; however, there may be
notable benefits from formulating the adverse scenario following
other approaches--specifically, those described previously in this
section--and consequently the Board does not believe that the
adverse scenario should be limited to historical episodes only.
h. With the exception of cases in which the probabilistic
approach is used to generate the adverse scenario, the adverse
scenario will at a minimum contain a mild to moderate recession.
This is because most of the value from investigating the
implications of the risks described above is likely to be obtained
from considering them in the context of balance sheets of companies
that are under some stress.
5. Approach for Formulating the Market Shock Component
a. This section discusses the approach the Board proposes to
adopt for developing the market shock component of the adverse and
severely adverse scenarios appropriate for companies with
significant trading activities. The design and specification of the
market shock component differs from that of the macroeconomic
scenarios because profits and losses from trading are measured in
mark-to-market terms, while revenues and losses from traditional
banking are generally measured using the accrual method. As noted
above, another critical difference is the time-evolution of the
market shock component. The market shock component consists of an
instantaneous ``shock'' to a large number of risk factors that
determine the mark-to-market value of trading positions, while the
macroeconomic scenarios supply a projected path of economic
variables that affect traditional banking activities over the entire
planning period.
b. The development of the market shock component that are
detailed in this section are as follows: baseline (subsection 5.1),
severely adverse (subsection 5.2), and adverse (subsection 5.3).
5.1 Approach for Formulating the Market Shock Component Under the
Baseline Scenario
By definition, market shocks are large, previously unanticipated
moves in asset prices and rates. Because asset prices should,
broadly speaking, reflect consensus opinions about the future
evolution of the economy, large price movements, as envisioned in
the market shock, should not occur along the baseline path. As a
result, the market shock will not be included in the baseline
scenario.
5.2 Approach for Formulating the Market Shock Component Under the
Severely Adverse Scenario
This section addresses possible approaches to designing the
market shock component in the severely adverse scenario, including
important considerations for scenario design, possible approaches to
designing scenarios, and a development strategy for implementing the
preferred approach.
5.2.1 Design Considerations for Market Shocks
a. The general market practice for stressing a trading portfolio
is to specify market shocks either in terms of extreme moves in
observable, broad market indicators and risk factors or directly as
large changes to the mark-to-market values of financial instruments.
These moves can be specified either in relative terms or absolute
terms. Supplying values of risk factors after a ``shock'' is roughly
equivalent to the macroeconomic scenarios, which supply values for a
set of economic and financial variables; however, trading stress
testing differs from macroeconomic stress testing in several
critical ways.
b. In the past, the Board used one of two approaches to specify
market shocks. During SCAP and CCAR in 2011, the Board used a very
general approach to market shocks and required companies to stress
their trading positions using changes in market prices and rates
experienced during the second half of 2008, without specifying risk
factor shocks. This broad guidance resulted in inconsistency across
companies both in terms of the severity and the application of
shocks. In certain areas companies were permitted to use their own
experience during the second half of 2008 to define shocks. This
resulted in significant variation in shock severity across
companies.
c. To enhance the consistency and comparability in market shocks
for the stress tests in 2012 and 2013, the Board provided to each
trading company more than 35,000 specific risk factor shocks,
primarily based on market moves in the second half of 2008. While
the number of risk factors used in companies' pricing and stress-
testing models still typically exceed that provided in the Board's
scenarios, the greater specificity resulted in more consistency in
the scenario across companies. The benefit of the comprehensiveness
of risk factor shocks is at least partly offset by potential
difficulty in creating shocks that are coherent and internally
consistent, particularly as the framework for developing market
shocks deviates from historical events.
d. Also importantly, the ultimate losses associated with a given
market shock will depend on a company's trading positions, which can
make it difficult to rank order, ex ante, the severity of the
scenarios. In certain instances, market shocks that include large
market moves may not be particularly stressful for a given company.
Aligning the market shock with the macroeconomic scenario for
consistency may result in certain companies actually benefiting from
risk factor moves of larger magnitude in the market scenario if the
companies are hedging against salient risks to other parts of their
business. Thus, the severity of market shocks must be calibrated to
take into account how a complex set of risks, such as directional
risks and basis risks, interacts with each other, given the
companies' trading positions at the time of stress. For instance, a
large depreciation in a foreign currency would benefit companies
with net short positions in the currency while hurting those with
net long positions. In addition, longer maturity positions may move
differently from shorter maturity positions, adding further
complexity.
e. The instantaneous nature of market shocks and the immediate
recognition of mark-to-market losses add another element to the
design of market shocks, and to determining the appropriate severity
of shocks. For instance, in previous stress tests, the Board assumed
that market moves that occurred over the six-month period in late
2008 would occur instantaneously. The design of the market shocks
must factor in appropriate assumptions around the period of time
during which market events will unfold and any associated market
responses.
5.2.2 Approaches to Market Shock Design
a. As an additional component of the adverse and severely
adverse scenarios, the Board plans to use a standardized set of
market shocks that apply to all companies with significant trading
activity. The market shocks could be based on a single historical
episode, multiple historical periods, hypothetical (but plausible)
events, or some combination of historical episodes and hypothetical
events (hybrid approach). Depending on the type of hypothetical
events, a scenario based on such events may result in changes in
risk factors that were not previously observed. In the supervisory
scenarios for 2012 and 2013, the shocks were largely based on
relative moves in asset prices and rates during the second half of
2008, but also included some additional considerations to factor in
the widening of spreads for European sovereigns and financial
companies based on actual observation during the latter part of
2011.
b. For the market shock component in the severely adverse
scenario, the Board plans to use the hybrid approach to develop
shocks. The hybrid approach allows the Board to maintain certain
core elements of consistency in market shocks each year while
providing flexibility to add hypothetical elements based on market
conditions at the time of the stress tests. In addition, this
approach will help ensure internal consistency in the scenario
because of its basis in historical episodes; however, combining the
historical episode and hypothetical events may require small
adjustments to ensure mutual consistency of the joint moves. In
general, the hybrid approach provides considerable flexibility in
developing scenarios that are relevant each year, and by introducing
variations in the scenario, the approach will also reduce the
ability of companies with significant trading activity to modify or
shift their portfolios to minimize expected losses in the severely
adverse market shock.
c. The Board has considered a number of alternative approaches
for the design of market shocks. For example, the Board explored an
option of providing tailored market shocks for each trading company,
using information on the companies' portfolio gathered through
ongoing supervision, or other means. By specifically targeting known
or potential vulnerabilities in a company's trading position, the
tailored approach will be useful in assessing each company's capital
adequacy as it relates to the company's idiosyncratic risk. However,
the Board does not believe this approach to
[[Page 59545]]
be well-suited for the stress tests required by regulation.
Consistency and comparability are key features of annual supervisory
stress tests and annual company-run stress tests required in the
stress test rules. It would be difficult to use the information on
the companies' portfolio to design a common set of shocks that are
universally stressful for all covered companies. As a result, this
approach will be better suited to more customized, tailored stress
tests that are part of the company's internal capital planning
process or to other supervisory efforts outside of the stress tests
conducted under the capital rule and the stress test rules.
5.2.3 Development of the Market Shock
a. Consistent with the approach described above, the market
shock component for the severely adverse scenario will incorporate
key elements of market developments during the second half of 2008,
but also incorporate observations from other periods or price and
rate movements in certain markets that the Board deems to be
plausible though such movements may not have been observed
historically. Over time the Board also expects to rely less on
market events of the second half of 2008 and more on hypothetical
events or other historical episodes to develop the market shock.
b. The developments in the credit markets during the second half
of 2008 were unprecedented, providing a reasonable basis for market
shocks in the severely adverse scenario. During this period, key
risk factors in virtually all asset classes experienced extremely
large shocks; the collective breadth and intensity of the moves have
no parallels in modern financial history and, on that basis, it
seems likely that this episode will continue to be the most relevant
historical scenario, although experience during other historical
episodes may also guide the severity of the market shock component
of the severely adverse scenario. Moreover, the risk factor moves
during this episode are directly consistent with the ``recession''
approach that underlies the macroeconomic assumptions. However,
market shocks based only on historical events could become stale and
less relevant over time as the company's positions change,
particularly if more salient features are not added each year.
c. While the market shocks based on the second half of 2008 are
of unparalleled magnitude, the shocks may become less relevant over
time as the companies' trading positions change. In addition, more
recent events could highlight the companies' vulnerability to
certain market events. For example, in 2011, Eurozone credit spreads
in the sovereign and financial sectors surpassed those observed
during the second half of 2008, necessitating the modification of
the severely adverse market shock in 2012 and 2013 to reflect a
salient source of stress to trading positions. As a result, it is
important to incorporate both historical and hypothetical outcomes
into market shocks for the severely adverse scenario. For the time
being, the development of market shocks in the severely adverse
scenario will begin with the risk factor movements in a particular
historical period, such as the second half of 2008. The Board will
then consider hypothetical but plausible outcomes, based on
financial stability reports, supervisory information, and internal
and external assessments of market risks and potential flash points.
The hypothetical outcomes could originate from major geopolitical,
economic, or financial market events with potentially significant
impacts on market risk factors. The severity of these hypothetical
moves will likely be guided by similar historical events,
assumptions embedded in the companies' internal stress tests or
market participants, and other available information.
d. Once broad market scenarios are agreed upon, specific risk
factor groups will be targeted as the source of the trading stress.
For example, a scenario involving the failure of a large,
interconnected globally active financial institution could begin
with a sharp increase in credit default swap spreads and a
precipitous decline in asset prices across multiple markets, as
investors become more risk averse and market liquidity evaporates.
These broad market movements will be extrapolated to the granular
level for all risk factors by examining transmission channels and
the historical relationships between variables, though in some
cases, the movement in particular risk factors may be amplified
based on theoretical relationships, market observations, or the
saliency to company trading books. If there is a disagreement
between the risk factor movements in the historical event used in
the scenario and the hypothetical event, the Board will reconcile
the differences by assessing a priori expectation based on financial
and economic theory and the importance of the risk factors to the
trading positions of the covered companies.
5.3 Approach for Formulating the Market Shock Under the Adverse
Scenario
a. The market shock component included in the adverse scenario
will feature risk factor movements that are generally less
significant than the market shock component of the severely adverse
scenario. However, the adverse market shock may also feature risk
factor shocks that are substantively different from those included
in the severely adverse scenario, in order to provide useful
information to supervisors. As in the case of the macroeconomic
scenario, the market shock component in the adverse scenario can be
developed in a number of different ways.
b. The adverse scenario could be differentiated from the
severely adverse scenario by the absolute size of the shock, the
scenario design process (e.g., historical events versus hypothetical
events), or some other criteria. The Board expects that as the
market shock component of the adverse scenario may differ
qualitatively from the market shock component of the severely
adverse scenario, the results of adverse scenarios may be useful in
identifying a particularly vulnerable area in a trading company's
positions.
c. There are several possibilities for the adverse scenario and
the Board may use a different approach each year to better explore
the vulnerabilities of companies with significant trading activity.
One approach is to use a scenario based on some combination of
historical events. This approach is similar to the one used for the
market shock in 2012, where the market shock component was largely
based on the second half of 2008, but also included a number of risk
factor shocks that reflected the significant widening of spreads for
European sovereigns and financials in late 2011. This approach will
provide some consistency each year and provide an internally
consistent scenario with minimal implementation burden. Having a
relatively consistent adverse scenario may be useful as it
potentially serves as a benchmark against the results of the
severely adverse scenario and can be compared to past stress tests.
d. Another approach is to have an adverse scenario that is
identical to the severely adverse scenario, except that the shocks
are smaller in magnitude (e.g., 100 basis points for adverse versus
200 basis points for severely adverse). This ``scaling approach''
generally fits well with an intuitive interpretation of ``adverse''
and ``severely adverse.'' Moreover, since the nature of the moves
will be identical between the two classes of scenarios, there will
be at least directional consistency in the risk factor inputs
between scenarios. While under this approach the adverse scenario
will be superficially identical to the severely adverse, the logic
underlying the severely adverse scenario may not be applicable. For
example, if the severely adverse scenario was based on a historical
scenario, the same could not be said of the adverse scenario. It is
also remains possible, although unlikely, that a scaled adverse
scenario actually will result in greater losses, for some companies,
than the severely adverse scenario with similar moves of greater
magnitude. For example, if some companies are hedging against tail
outcomes then the more extreme trading book dollar losses may not
correspond to the most extreme market moves. The market shock
component of the adverse scenario in 2013 was largely based on the
scaling approach where a majority of risk factor shocks were smaller
in magnitude than the severely adverse scenario, but it also
featured long-term interest rate shocks that were not part of the
severely adverse market shock.
e. Alternatively, the market shock component of an adverse
scenario could differ substantially from the severely adverse
scenario with respect to the sizes and nature of the shocks. Under
this approach, the market shock component could be constructed using
some combination of historical and hypothetical events, similar to
the severely adverse scenario. As a result, the market shock
component of the adverse scenario could be viewed as an alternative
to the severely adverse scenario and, therefore, it is possible that
the adverse scenario could have larger losses for some companies
than the severely adverse scenario.
f. Finally, the design of the adverse scenario for annual stress
tests could be informed by the companies' own trading scenarios used
for their BHC-designed scenarios in CCAR and in their mid-cycle
company-run stress tests.\21\
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\21\ 12 CFR 252.55.
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[[Page 59546]]
6. Consistency Between the Macroeconomic Scenarios and the Market Shock
a. As discussed earlier, the market shock comprises a set of
movements in a very large number of risk factors that are realized
instantaneously. Among the risk factors specified in the market
shock are several variables also specified in the macroeconomic
scenarios, such as short- and long-maturity interest rates on
Treasury and corporate debt, the level and volatility of U.S. stock
prices, and exchange rates.
b. The market shock component is an add-on to the macroeconomic
scenarios that is applied to a subset of companies, with no assumed
effect on other aspects of the stress tests such as balances,
revenues, or other losses. As a result, the market shock component
may not be always directionally consistent with the macroeconomic
scenario. Because the market shock is designed, in part, to mimic
the effects of a sudden market dislocation, while the macroeconomic
scenarios are designed to provide a description of the evolution of
the real economy over two or more years, assumed economic conditions
can move in significantly different ways. In effect, the market
shock can simulate a market panic, during which financial asset
prices move rapidly in unexpected directions, and the macroeconomic
assumptions can simulate the severe recession that follows. Indeed,
the pattern of a financial crisis, characterized by a short period
of wild swings in asset prices followed by a prolonged period of
moribund activity, and a subsequent severe recession is familiar and
plausible.
c. As discussed in section 4.2.4, the Board may feature a
particularly salient risk in the macroeconomic assumptions for the
severely adverse scenario, such as a fall in an elevated asset
price. In such instances, the Board may also seek to reflect the
same risk in one of the market shocks. For example, if the
macroeconomic scenario were to feature a substantial decline in
house prices, it may seem plausible for the market shock to also
feature a significant decline in market values of any securities
that are closely tied to the housing sector or residential
mortgages.
d. In addition, as discussed in section 4.3, the Board may
specify the macroeconomic assumptions in the adverse scenario in
such a way as to explore risks qualitatively different from those in
the severely adverse scenario. Depending on the nature and type of
such risks, the Board may also seek to reflect these risks in one of
the market shocks as appropriate.
7. Timeline for Scenario Publication
a. The Board will provide a description of the macroeconomic
scenarios by no later than February 15. During the period
immediately preceding the publication of the scenarios, the Board
will collect and consider information from academics, professional
forecasters, international organizations, domestic and foreign
supervisors, and other private-sector analysts that regularly
conduct stress tests based on U.S. and global economic and financial
scenarios, including analysts at the covered companies. In addition,
the Board will consult with the FDIC and the OCC on the salient
risks to be considered in the scenarios. The Board expects to
conduct this process in October and November of each year and to
update the scenarios based on incoming macroeconomic data releases
and other information through the end of January.
b. The Board expects to provide a broad overview of the market
shock component along with the macroeconomic scenarios. The Board
will publish the market shock templates by no later than March 1 of
each year, and intends to publish the market shock earlier in the
stress test and capital plan cycles to allow companies more time to
conduct their stress tests.
Table 1 to Appendix A of Part 252--Classification of U.S. Recessions
--------------------------------------------------------------------------------------------------------------------------------------------------------
Total change
Change in the in the
Decline in unemployment unemployment
Peak Trough Severity Duration (quarters) real GDP rate during rate (incl.
the recession after the
recession)
--------------------------------------------------------------------------------------------------------------------------------------------------------
1957Q3.......................... 1958Q2................ Severe................ 4 (Medium)............ -3.6 3.2 3.2
1960Q2.......................... 1961Q1................ Moderate.............. 4 (Medium)............ -1.0 1.6 1.8
1969Q4.......................... 1970Q4................ Moderate.............. 5 (Medium)............ -0.2 2.2 2.4
1973Q4.......................... 1975Q1................ Severe................ 6 (Long).............. -3.1 3.4 4.1
1980Q1.......................... 1980Q3................ Moderate.............. 3 (Short)............. -2.2 1.4 1.4
1981Q3.......................... 1982Q4................ Severe................ 6 (Long).............. -2.8 3.3 3.3
1990Q3.......................... 1991Q1................ Mild.................. 3 (Short)............. -1.3 0.9 1.9
2001Q1.......................... 2001Q4................ Mild.................. 4 (Medium)............ 0.2 1.3 2.0
2007Q4.......................... 2009Q2................ Severe................ 7 (Long).............. -4.3 4.5 5.1
Average......................... ...................... Severe................ 6..................... -3.5 3.7 3.9
Average......................... ...................... Moderate.............. 4..................... -1.1 1.8 1.8
Average......................... ...................... Mild.................. 3..................... -0.6 1.1 1.9
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Source: Bureau of Economic Analysis, National Income and Product Accounts, Comprehensive Revision on July 31, 2013.
Table 2 to Appendix A of Part 252--House Prices in Housing Recessions
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HPI-DPI Trough
Percent change Percent change Level
Peak Trough Severity Duration (quarters) in NHPI in HPI-DPI (2000:Q1 =
100)
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1980Q2.......................... 1985Q2................ Moderate.............. 20 (long)............. 26.6 -15.9 102.1
1989Q4.......................... 1997Q1................ Moderate.............. 29 (long)............. 10.5 -17.0 94.9
2005Q4.......................... 2012Q1................ Severe................ 25 (long)............. -29.6 -41.3 86.9
Average......................... ...................... ...................... 24.7.................. 2.5 -24.7 94.6
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Source: CoreLogic, BEA.
Note: The date-ranges of housing recessions listed in this table are based on the timing of house-price retrenchments.
[[Page 59547]]
By order of the Board of Governors of the Federal Reserve
System, December 7, 2017.
Ann E. Misback,
Secretary of the Board.
[FR Doc. 2017-26858 Filed 12-14-17; 8:45 am]
BILLING CODE 6210-01-P