Page |1        International Association of Risk and Compliance                      Professionals (IARCP)      1200 G Str...
Page |2_____________________________________________________________International Association of Risk and Compliance Profe...
Page |3_____________________________________________________________International Association of Risk and Compliance Profe...
Page |4_____________________________________________________________International Association of Risk and Compliance Profe...
Page |5_____________________________________________________________International Association of Risk and Compliance Profe...
Page |6_____________________________________________________________International Association of Risk and Compliance Profe...
Page |7_____________________________________________________________International Association of Risk and Compliance Profe...
Page |8_____________________________________________________________International Association of Risk and Compliance Profe...
Page |9_____________________________________________________________International Association of Risk and Compliance Profe...
P a g e | 10Welcome to the Top 10 list._____________________________________________________________International Associat...
P a g e | 11Agencies Finalize Large Bank Stress TestingGuidanceThe Federal Reserve Board, the Office of theComptroller of ...
P a g e | 12The policy implications oftransmission channels betweenthe financial system and the real economyPolicymakers h...
P a g e | 13We continue tosee that SolvencyII is “future rule”…Joint Consultation Paper on theproposed response to the Eur...
P a g e | 14Press Releases                       Board of Governors of the Federal Reserve System                         ...
P a g e | 15The guidance outlines general principles for a satisfactory stress testingframework and describes various stre...
P a g e | 16SUMMARY: The Board, FDIC and OCC, (collectively, the “agencies”)are issuing this guidance, which outlines high...
P a g e | 17The 2007- 2009 financial crisis further underscored the need for bankingorganizations to incorporate stress te...
P a g e | 18In light of these recent rulemaking efforts on stress testing, the guidanceprovides banking organizations with...
P a g e | 19- with respect to the Board, these banking organizations would have  included state member banks, bank holding...
P a g e | 20threshold should use reasonable judgment and consider, in conjunctionwith their primary federal supervisor as ...
P a g e | 21SLHCs on July 21, 2011, after the agencies published the proposedguidance for public comment but before the en...
P a g e | 22Notably, the final guidance was framed broadly to inform a bankingorganization’s use of stress testing in over...
P a g e | 23in order to underscore the importance of governance and controls as a keyelement in a banking organization’s s...
P a g e | 24The agencies have considered these comments, but do not believe thefinal guidance is the appropriate place for...
P a g e | 25condition.Aside from the inclusion of a fifth principle as described above, theagencies have otherwise adopted...
P a g e | 26minimum regulatory capital ratio or suffering severe liquidity constraintsmaking it unable to meet its obligat...
P a g e | 27organization’s risk management practices, as well as its capital andliquidity adequacy.The guidance sets forth...
P a g e | 28In response to comments received on the planning horizon for stresstests, the agencies clarified that while ca...
P a g e | 29Importantly, strong governance provides critical review of elements of thestress testing framework, especially...
P a g e | 30directors should not be expected to be involved directly in moreoperational aspects of the framework.The agenc...
P a g e | 31collection unless the information collection displays a currently validOMB control number.While the guidance i...
P a g e | 32The burden of information collections associated with mandatory stresstests will be accounted for in the respe...
P a g e | 33stressful events and circumstances can suffer acute threats to theirfinancial condition and viability.The Fede...
P a g e | 34The guidance outlines broad principles for a satisfactory stress testingframework and describes the manner in ...
P a g e | 35In this manner, stress testing can assist in highlighting unidentified orunder-assessed risk concentrations an...
P a g e | 36testing frameworks, and use those policies at least annually to assess theeffectiveness of their frameworks.Su...
P a g e | 37This section describes general principles that a banking organizationshould apply in implementing such a frame...
P a g e | 38An effective stress testing framework should be applied at various levelsin the banking organization, such as ...
P a g e | 39adversely affected by shocks to economic activity at the state or local levelthan by a severe national recessi...
P a g e | 40Banking organizations should, therefore, use multiple stress testingactivities and approaches (consistent with...
P a g e | 41Furthermore, almost all stress tests, including well-developedquantitative tests supported by high-quality dat...
P a g e | 42For example, a banking organization should not assume that if it hassuffered no or minimal losses in a certain...
P a g e | 43In addition to conducting formal, routine stress tests, a bankingorganization should have the flexibility to c...
P a g e | 44Stress test measures should be tailored to the type of test and theparticular level at which the test is appli...
P a g e | 45A banking organization should review the results of its various stress testswith the strengths and limitations...
P a g e | 46The extent and sophistication of a banking organization’s governanceover its stress testing framework should a...
P a g e | 47Scenario analysis refers to a type of stress testing in which a bankingorganization applies historical or hypo...
P a g e | 48Additionally, a banking organization should consider the best manner totry to capture combinations of stressfu...
P a g e | 49Care should be taken not to make assumptions that relationships frombenign or mildly adverse times will hold d...
P a g e | 50For example, a banking organization may choose to calculate a range ofchanges to a structured security’s overa...
P a g e | 51banking organization as a whole, particularly with regard to capital andliquidity.As is the case with scenario...
P a g e | 52Selection of scenario variables is important for enterprise-wide tests,because these variables generally serve...
P a g e | 53Reverse stress testing is a tool that allows a banking organization toassume a known adverse outcome, such as ...
P a g e | 54illiquidity, but also on those that seem most imminent given the currentenvironment.Focusing on the most promi...
P a g e | 55of the time horizon considered by a given stress test, they may still havesubstantial residual risks or proble...
P a g e | 56Stress testing can aid capital contingency planning by helpingmanagement identify exposures or risks in advanc...
P a g e | 57potential planned capital actions (such as dividends or share repurchases)that would affect the banking organi...
Monday May 21 2012 - Top 10 risk and compliance management related news stories and world events that (for better or for w...
Monday May 21 2012 - Top 10 risk and compliance management related news stories and world events that (for better or for w...
Monday May 21 2012 - Top 10 risk and compliance management related news stories and world events that (for better or for w...
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Monday May 21 2012 - Top 10 risk and compliance management related news stories and world events that (for better or for w...
Monday May 21 2012 - Top 10 risk and compliance management related news stories and world events that (for better or for w...
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Monday May 21 2012 - Top 10 risk and compliance management related news stories and world events that (for better or for w...
Monday May 21 2012 - Top 10 risk and compliance management related news stories and world events that (for better or for w...
Monday May 21 2012 - Top 10 risk and compliance management related news stories and world events that (for better or for w...
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Monday May 21 2012 - Top 10 risk and compliance management related news stories and world events that (for better or for worse) shaped the week's agenda, and what is next

  1. 1. Page |1 International Association of Risk and Compliance Professionals (IARCP) 1200 G Street NW Suite 800 Washington, DC 20005-6705 USA Tel: 202-449-9750 www.risk-compliance-association.com Top 10 risk and compliance management related news storiesand world events that (for better or for worse) shaped the weeks agenda, and what is next George Lekatis President of the IARCPDear Member,This week was full of stress (tests).In the States, the Federal Reserve Board, the Office of the Comptroller ofthe Currency, and the Federal Deposit Insurance Corporation issued finalsupervisory guidance regarding stress-testing practices at bankingorganizations with total consolidated assets of more than $10 billion.In Europe, the European Banking Authority (EBA) published two sets ofGuidelines on Stressed Value-At-Risk (Stressed VaR) and on theIncremental Default and Migration Risk Charge (IRC) modellingapproaches employed by credit institutions using the Internal ModelApproach (IMA).These Guidelines are seen as an important means of addressingweaknesses in the regulatory capital framework and in the riskmanagement of financial institutions.I studied both papers during and between flights, and I feel like I needanother stress test (a medical one).I have also read the (very interesting) public financial disclosure report ofBarack Obama, and we will start from just that:_____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  2. 2. Page |2_____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  3. 3. Page |3_____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  4. 4. Page |4_____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  5. 5. Page |5_____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  6. 6. Page |6_____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  7. 7. Page |7_____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  8. 8. Page |8_____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  9. 9. Page |9_____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  10. 10. P a g e | 10Welcome to the Top 10 list._____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  11. 11. P a g e | 11Agencies Finalize Large Bank Stress TestingGuidanceThe Federal Reserve Board, the Office of theComptroller of the Currency, and the Federal Deposit InsuranceCorporation on Monday issued final supervisory guidance regardingstress-testing practices at banking organizations with total consolidatedassets of more than $10 billion.Guidelines on Stressed Value-At-Risk(Stressed VaR) and on the IncrementalDefault and Migration Risk Charge (IRC)16 May 2012The EBA published today two sets of Guidelines on StressedValue-At-Risk (Stressed VaR) and on the Incremental Default andMigration Risk Charge (IRC) modelling approaches employed by creditinstitutions using the Internal Model Approach (IMA).Models and tools formacroprudential analysisBCBS Working Papers No 21, May 2012The Basel Committees Research Task Force Transmission Channelproject aimed at generating new research on various aspects of the creditchannel linkages in the monetary transmission mechanism._____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  12. 12. P a g e | 12The policy implications oftransmission channels betweenthe financial system and the real economyPolicymakers have strengthened existing micro-prudential tools, such asbank-specific capital and liquidity requirements, and introduced newmacro-prudential tools, such as countercyclical capital requirements,capital surcharges for systemically-important financial institutions, andloan-to-value caps to promote financial stability.NIST Forensic Measurement ChallengeMay 14, 2012Recently, NIST announced the availability of $2.5 millionfor funding criminal justice applications that use newscientific discoveries.Thirty-six proposals were received, and the judges foundit difficult to narrow the choices.Remarks by Assistant Secretary for EconomicPolicy Jan Eberly before the American Instituteof Certified Accountants (AICPA)Visiting important web sites_____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  13. 13. P a g e | 13We continue tosee that SolvencyII is “future rule”…Joint Consultation Paper on theproposed response to the EuropeanCommission’s Call for Advice on theFundamental Review of FinancialConglomerates Directive14 May 2012Market entry criteria revised forbanking sector in Hong KongThe Banking Ordinance (Amendment of Seventh Schedule) Notice 2012,which seeks to update certain market entry criteria for the banking sectorin Hong Kong, will be gazetted on Friday, 18 May 2012._____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  14. 14. P a g e | 14Press Releases Board of Governors of the Federal Reserve System Federal Deposit Insurance Corporation Office of the Comptroller of the CurrencyFor Immediate Release May 14, 2012Agencies Finalize Large Bank Stress Testing GuidanceThe Federal Reserve Board, the Office of the Comptroller of theCurrency, and the Federal Deposit Insurance Corporation on Mondayissued final supervisory guidance regarding stress-testing practices atbanking organizations with total consolidated assets of more than $10billion.The guidance highlights the importance of stress testing at bankingorganizations as an ongoing risk management practice that supports abanking organizations forward-looking assessment of its risks and betterequips it to address a range of adverse outcomes.The recent financial crisis underscored the need for bankingorganizations to incorporate stress testing into their risk managementpractices, demonstrating that banking organizations unprepared forparticularly adverse events and circumstances can suffer acute threats totheir financial condition and viability.This guidance builds upon previously issued supervisory guidance thatdiscusses the uses and merits of stress testing in specific areas of riskmanagement._____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  15. 15. P a g e | 15The guidance outlines general principles for a satisfactory stress testingframework and describes various stress testing approaches and howstress testing should be used at various levels within an organization.The guidance also discusses the importance of stress testing in capitaland liquidity planning and the importance of strong internal governanceand controls as part of an effective stress-testing framework.The guidance does not implement the stress testing requirements in theDodd-Frank Wall Street Reform and Consumer Protection Act(Dodd-Frank Act) or in the Federal Reserve Boards capital plan rule thatapply to certain companies, as those requirements have been or are beingimplemented through separate proposals by the respective agencies.However, the agencies expect that banking organizations with totalconsolidated assets of more than $10 billion would follow the principlesset forth in the guidance--as well as other relevant supervisoryguidance--when conducting stress testing in accordance with theDodd-Frank Act, the capital plan rule, and other statutory or regulatoryrequirements.DEPARTMENT OF THE TREASURYOffice of the Comptroller of the CurrencyFEDERAL RESERVE SYSTEMFEDERAL DEPOSIT INSURANCE CORPORATIONSupervisory Guidance on Stress Testing for BankingOrganizations with More Than $10 Billion In TotalConsolidated AssetsAGENCIES: Board of Governors of the Federal Reserve System(“Board” or “Federal Reserve”); Federal Deposit Insurance Corporation(“FDIC”); Office of the Comptroller of the Currency, Treasury (“OCC”).ACTION: Final supervisory guidance._____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  16. 16. P a g e | 16SUMMARY: The Board, FDIC and OCC, (collectively, the “agencies”)are issuing this guidance, which outlines high-level principles for stresstesting practices, applicable to all Federal Reserve-supervised,FDIC-supervised, and OCC-supervised banking organizations with morethan $10 billion in total consolidated assets.The guidance highlights the importance of stress testing as an ongoingrisk management practice that supports a banking organization’sforward-looking assessment of its risks and better equips the organizationto address a range of adverse outcomes.DATES: This guidance will become effective on July 23, 2012.I. BackgroundOn June 15, 2011, the agencies requested public comment on jointproposed guidance on the use of stress testing as an ongoing riskmanagement practice by banking organizations with more than $10billion in total consolidated assets (the proposed guidance).The public comment period on the proposed guidance closed on July 29,2011.The agencies are adopting the guidance in final form with certainmodifications that are discussed below (the final guidance).As described below, this guidance does not apply to bankingorganizations with consolidated assets of $10 billion or less.All banking organizations should have the capacity to understand theirrisks and the potential impact of stressful events and circumstances ontheir financial condition.The agencies have previously highlighted the use of stress testing as ameans to better understand the range of a banking organization’spotential risk exposures._____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  17. 17. P a g e | 17The 2007- 2009 financial crisis further underscored the need for bankingorganizations to incorporate stress testing into their risk management, asbanking organizations unprepared for stressful events and circumstancescan suffer acute threats to their financial condition and viability.The final guidance is intended to be consistent with sound industrypractices and with international supervisory standards.Building upon previously issued supervisory guidance that discusses theuses and merits of stress testing in specific areas of risk management, thefinal guidance provides principles that a banking organization shouldfollow when conducting its stress testing activities.The guidance outlines broad principles for a satisfactory stress testingframework and describes the manner in which stress testing should beemployed as an integral component of risk management that is applicableat various levels of aggregation within a banking organization and thatcontributes to capital and liquidity planning.While the guidance is not intended to provide detailed instructions forconducting stress testing for any particular risk or business area, theguidance describes several types of stress testing activities and how theymay be most appropriately used by banking organizations subject to thisguidance.The final guidance does not implement the stress testing requirementsimposed by the Dodd-Frank Wall Street Reform and ConsumerProtection Act (Dodd-Frank Act) on financial companies regulated by theOCC, FDIC, or Board with total consolidated assets of more than $10billion or by the Board’s capital plan rule on U.S. bank holding companieswith total consolidated assets equal to or greater than $50 billion.The Dodd-Frank Act’s stress testing requirements are beingimplemented through separate notices of proposed rulemaking by therespective agencies.The Board issued the final capital plan rule on November 22, 2011._____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  18. 18. P a g e | 18In light of these recent rulemaking efforts on stress testing, the guidanceprovides banking organizations with principles for conducting theirstress testing activities to, among other things, ensure that those activitiesare adequately integrated into overall risk management.The agencies expect such companies would follow the principles set forthin the guidance – as well as other relevant supervisory guidance – whenconducting stress testing in accordance with statutory or regulatoryrequirements.II. Discussion of Comments on the Proposed GuidanceThe agencies received 17 comment letters on the proposed guidance.Commenters included financial trade associations, bank holdingcompanies, financial advisory firms, and individuals. Commentersgenerally expressed support for the proposed guidance.However, several commenters recommended changes to, or clarificationof, certain provisions of the proposed guidance, as discussed below.In response to these comments, the agencies have clarified the principlesset forth in the guidance and modified the proposed guidance in certainrespects as described in this section.A. Scope of applicationThe proposed guidance would have applied to all banking organizationssupervised by the agencies with more than $10 billion in totalconsolidated assets.Specifically,- with respect to the OCC, these banking organizations would have included national banking associations and federal branches and agencies;_____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  19. 19. P a g e | 19- with respect to the Board, these banking organizations would have included state member banks, bank holding companies, and all other institutions for which the Board is the primary federal supervisor;- with respect to the FDIC, these banking organizations would have included state nonmember banks and all other institutions for which the FDIC is the primary federal supervisor.The proposed guidance indicated that a banking organization shoulddevelop and implement its stress testing framework in a mannercommensurate with its size, complexity, business activities, and overallrisk profile.Some commenters supported the total consolidated asset threshold (i.e.,more than $10 billion), but others noted the importance and value ofstress testing for smaller banking organizations.Consistent with the proposed guidance, no supervised bankingorganization with $10 billion or less in total consolidated assets is subjectto this final guidance.The agencies believe that $10 billion is the appropriate threshold for theguidance based on the general complexity of firms above this size.However, the agencies note that previously issued supervisory guidanceapplicable to all supervised institutions discusses the use of stress testingas a tool in certain aspects of risk management—such as for commercialreal estate concentrations, liquidity risk management, and interest-raterisk management.The agencies received two comments suggesting that the $10 billion totalconsolidated asset threshold be measured over a four quarter period inorder to minimize the likelihood that temporary asset fluctuations wouldtrigger application of the guidance.The agencies do not establish an asset calculation methodology in thefinal guidance; however, banking organizations with assets near the_____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  20. 20. P a g e | 20threshold should use reasonable judgment and consider, in conjunctionwith their primary federal supervisor as appropriate, whether they shouldconsider preparing to follow the guidance.Three commenters expressed concern that foreign banking organizations(FBOs) are required to follow stress testing guidelines established bytheir home country supervisors and suggested that the agencies giveconsideration to those requirements.When developing the guidance, the agencies sought to ensure that itwould not introduce inconsistencies with internationally agreedsupervisory standards.The agencies recognize that an FBO’s U.S. operations are part of theFBO’s global enterprise subject to requirements of its home country.The agencies provided sufficient flexibility in the proposed guidance sothat the guidance could apply to various types of organizations.In this final guidance, the agencies clarify that certain aspects of theguidance may not apply to U.S. branches and agencies of FBOs (such asthe portions related to capital stress testing) or may apply differently(such as portions related to governance and controls).Supervisors will take these issues into consideration when evaluating theability of U.S. offices of FBOs to meet the principles in the guidance.Two commenters expressed concern regarding the application of theproposed guidance to savings and loan holding companies (SLHCs).They suggested that the Board issue separate guidance for SLHCs, asthese institutions would face a different set of stress testing assumptionsand scenarios than banking organizations.The Board believes that the guidance is instructive to SLHCs to the samedegree it is for bank holding companies.The Federal Reserve became the primary federal supervisor for_____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  21. 21. P a g e | 21SLHCs on July 21, 2011, after the agencies published the proposedguidance for public comment but before the end of the comment period.While the Board recognizes that certain differences do exist betweenbank holding companies and SLHCs, the Board believes the guidancecontains flexibility adequate to accommodate the variations in size,complexity, business activities, and overall risk profile of all bankingorganizations that meet the asset threshold.Thus, the guidance anticipates that each banking organization,including each SLHC, would implement stress testing in a mannerconsistent with its own business and risk profile.Similarly, one commenter advocated that the OCC propose separateguidance on stress testing specifically tailored to savings associations.The OCC became the primary federal supervisor for federal savingsassociations on July 21, 2011.While the OCC recognizes that certain differences do exist betweennational banks and federal savings associations, the OCC notes that thefinal guidance contains flexibility adequate to accommodate thevariations in size, complexity, business activities, and overall riskprofile of all banking organizations that meet the asset threshold.Thus, it is also expected that each federal savings association wouldimplement the guidance consistent with its own business and risk profile.Several commenters requested clarification on the linkage between thestress testing guidance and the stress testing requirements in theDodd-Frank Act.In devising the guidance, the agencies endeavored to ensure that theproposed and final guidance is consistent with the stress testingrequirements under the Dodd-Frank Act and believe that the principlesset forth in the final guidance are useful when conducting the stress testsrequired under the Act._____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  22. 22. P a g e | 22Notably, the final guidance was framed broadly to inform a bankingorganization’s use of stress testing in overall risk management, not juststress tests required under the Dodd-Frank Act.Dodd-Frank stress tests would generally be considered part of anorganization’s overall stress testing framework as described in thestress testing guidance.B. Stress Testing PrinciplesAs noted above, the proposed guidance identified and included adiscussion of four key principles for a banking organization’s stresstesting framework and related stress test results, namely that:(1) A banking organization’s stress testing framework should includeactivities and exercises that are tailored to and sufficiently capture thebanking organization’s exposures, activities, and risks;(2) An effective stress testing framework employs multiple conceptuallysound stress testing activities and approaches;(3) An effective stress testing framework is forward-looking and flexible;and(4) Stress test results should be clear, actionable, well supported, andinform decision-making.In the final guidance, the agencies have incorporated a fifth principlespecifying that an organization’s stress testing framework should includestrong governance and effective internal controls.The elements of the fifth principle had been set forth in section VI of theproposed guidance, and the fifth principle does not expand on this aspectof the proposed guidance.Rather, the agencies reorganized this discussion into a fifth principle_____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  23. 23. P a g e | 23in order to underscore the importance of governance and controls as a keyelement in a banking organization’s stress testing framework.As noted above, commenters were supportive of the principles-basedapproach and the notion that a banking organization’s stress testingframework should be implemented in a manner commensurate withfactors such as the complexity and size of the organization.With more specific regard to the proposed principles, commenterssuggested that the final guidance address the standardization of stresstesting through the inclusion of common coefficients, models, orbenchmarks.These commenters expressed concerns that banking organizations wouldimplement the principles inconsistently and that standardization wouldhelp regulators conduct comparative analyses across firms.Another commenter suggested that the agencies prescribe more detailedand integrated stress testing between different entities or business unitswithin an organization.The agencies did not modify the guidance in response to thesecomments.A key aspect of the guidance is to provide organizations flexibility on howthey design their individual stress testing frameworks.Thus, each banking organization should design a specific stress testingframework to capture risks relevant to the organization.The agencies believe that prescribing standardized stress tests in thisguidance would have its own inherent limitations and may notappropriately cover a banking organization’s material risks and activities.In addition, commenters suggested that the agencies mandate publicrelease of stress testing results through the guidance._____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  24. 24. P a g e | 24The agencies have considered these comments, but do not believe thefinal guidance is the appropriate place for such a requirement given itsbroader focus on banking organizations’ overall stress testingframeworks.The agencies note, however, that banking organizations may be requiredto disclose information about their stress tests pursuant to other statutory,regulatory, or supervisory requirements.A few commenters stated that a banking organization should explain andjustify the stress testing methodologies it utilizes to its primary federalsupervisor.The agencies note that supervisors will examine firms’ stress testingmethodologies through the supervisory process.One commenter noted that the guidance should explicitly indicate thatliabilities should be part of a banking organization’s stress testingactivities; the agencies intended that stress testing activities would takean organization’s liabilities into account and have clarified this in the finalguidance.Three commenters suggested that operational risk be specificallyreferenced in the guidance.In response, the agencies have clarified in the final guidance thatoperational risk should be among the risks considered by anorganization’s stress testing framework.Another commenter expressed concern that the frequency of stresstesting and communication of results might eventually desensitize seniormanagement to them.The agencies believe that regular review of stress test results is useful –both during periods of economic downturn and benign periods – andhave clarified that such review can help a banking organization track overtime the impact of ongoing business activities, changes in exposures,varying economic conditions, and market movements on its financial _____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  25. 25. P a g e | 25condition.Aside from the inclusion of a fifth principle as described above, theagencies have otherwise adopted the proposed principles in the finalguidance with only minor additional refinements.C. Stress testing approaches and applicationsThe proposed guidance described certain stress testing approaches andapplications – scenario analysis, sensitivity analysis, enterprise-widetesting, and reverse stress testing – that a banking organization couldconsider using within its stress testing framework, as appropriate.The proposed guidance provided that each banking organization shouldapply these approaches and applications commensurate with its size,complexity, and business profile, and may not need to incorporate all ofthe details described in the guidance.Some commenters questioned the appropriate number and types of stresstest approaches an organization should utilize.The agencies do not believe that specifying a number or particular typesof approaches – including the number of scenarios – is appropriate in theguidance given the wide range of stress testing activities that differentbanking organizations may undertake.A banking organization should choose the approaches that appropriatelyconsider the unique characteristics of that particular organization and therelevant risks it faces.The agencies expect that stress testing methodologies will evolve overtime as banking organizations develop approaches that best capture theirindividual risk profiles.In addition, the proposed guidance described reverse stress testing as atool that would allow a banking organization to assume a known adverseoutcome, such as suffering a credit loss that causes it to breach a_____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  26. 26. P a g e | 26minimum regulatory capital ratio or suffering severe liquidity constraintsmaking it unable to meet its obligations, and then deduce the types ofevents that could lead to such an outcome.This type of stress testing may help a banking organization to considerscenarios beyond its normal business expectations and see the impact ofsevere systemic effects on the banking organization.It also would allow a banking organization to challenge commonassumptions about its performance and expected mitigation strategies.Three commenters expressed doubts regarding the effectiveness ofreverse stress testing, as the approach could produce results ofquestionable value and captures unlikely, “extreme” scenarios.The agencies reiterate the value of reverse stress testing, as it helps abanking organization evaluate the combined effect of several types ofextreme events and circumstances that might threaten the survival of thebanking organization, even if in isolation each of the effects might bemanageable.Another commenter expressed concern that the results of severe scenariosused for reverse stress testing would directly lead to a supervisoryrequirement to raise capital if the results of the approach wereunfavorable to the organization.In addition, some commenters sought clarification that results would notbe used by regulators to criticize banking organizations.As stated in the proposed guidance, a given stress test result will notnecessarily lead to immediate action by a firm, and in some cases stresstest results – including those from reverse stress tests – are most useful forthe additional information they provide.In terms of supervisory responses to an organization’s stress testingactivities, the agencies expect to consider a banking organization’s stresstest results and the appropriateness of its overall stress testing framework,along with all other relevant information, in assessing a banking _____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  27. 27. P a g e | 27organization’s risk management practices, as well as its capital andliquidity adequacy.The guidance sets forth supervisory expectations for prudent riskmanagement practices and a firms decision not to follow the principlesin this guidance will be examined as part of the supervisory process andmay be cited as evidence of unsafe and unsound practices.D. Stress testing for assessing adequacy of capital and liquidityGiven the importance of capital and liquidity to a banking organization’sviability, stress testing should be applied to these two areas on a regularbasis.Stress testing for capital and liquidity adequacy should be conducted incoordination with a banking organization’s overall business strategy andannual planning cycles.Results should be refreshed in the event of major strategic decisions, orother changes that can materially impact capital or liquidity.An effective stress testing framework should explore the potential forcapital and liquidity problems to arise at the same time or exacerbate oneanother.A banking organization’s liquidity stress analysis should exploresituations in which the banking organization may be operating with acapital position that exceeds regulatory minimums, but is nonethelessviewed within the financial markets or by its counterparties as being ofquestionable viability.For its capital and liquidity stress tests, a banking organizationshould articulate clearly its objectives for a post-stress outcome, forinstance to remain a viable financial market participant that is able tomeet its existing and prospective obligations and commitments._____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  28. 28. P a g e | 28In response to comments received on the planning horizon for stresstests, the agencies clarified that while capital stress tests should generallybe conducted with a horizon of at least two years, organizations shouldrecognize that the effects of certain stress conditions could extend beyondthat horizon.The agencies have also clarified, in response to comments, thatconsolidated stress tests should account for the fact that certain legalentities within the consolidated organization are required to meetregulatory capital requirements.A commenter requested clarification on whether capital and liquiditystress testing should be evaluated in unified or separate stress tests.The proposed guidance did not specify the precise manner in whichcapital and liquidity stress tests should be performed.The final guidance notes that assessing the potential interaction of capitaland liquidity can be challenging and may not be possible within a singlestress test, so a banking organization should explore several avenues toassess that interaction.In any case, the agencies believe that stress testing for both liquidity andcapital adequacy should be an integral part of a banking organization’sstress testing framework.E. Governance and controlsAs noted under the new fifth principle of the final guidance, a bankingorganization’s stress testing framework will be effective only if it issubject to strong governance and controls to ensure that the frameworkfunctions as intended.Strong governance and controls also help ensure that the frameworkcontains core elements, from clearly defined stress testing objectives torecommended actions._____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  29. 29. P a g e | 29Importantly, strong governance provides critical review of elements of thestress testing framework, especially regarding key assumptions,uncertainties, and limitations.A banking organization should ensure that the stress testing framework isnot isolated within a banking organization’s risk management function,but is firmly integrated into business lines, capital and asset-liabilitycommittees, and other decision-making bodies.As part of their overall responsibilities, a banking organization’s boardand senior management should establish a comprehensive, integratedand effective stress testing framework that fits into the broader riskmanagement of the banking organization.Stress testing results should be used to inform the board about alignmentof the banking organization’s risk profile with the board’s chosen riskappetite, as well as inform operating and strategic decisions.Stress testing results should be considered directly by the board andsenior management for decisions relating to capital and liquidityadequacy.Senior management, in consultation with the board, should ensure thatthe stress testing framework includes a sufficient range of stress testingactivities applied at the appropriate levels of the banking organization(i.e., not just one enterprise-wide stress test).Several commenters raised concerns regarding the proposedresponsibilities of a banking organization’s board of directors withrespect to stress tests and the framework.One commenter believed that the board of directors should not review allstress test results, but rather only those that were expected to have amaterial impact on the overall organization.Another commenter expressed the belief that the board of directorsshould be involved in providing direction and oversight regarding thebanking organization’s stress testing framework, but that the board of_____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  30. 30. P a g e | 30directors should not be expected to be involved directly in moreoperational aspects of the framework.The agencies have modified the final guidance to clarify that seniormanagement, not the board of directors, should have the primaryresponsibility for stress testing implementation and technical design.However, the agencies emphasize that a banking organization’s board ofdirectors should be provided with information from senior managementon stress testing developments (including the process to design tests anddevelop scenarios) and on stress testing results (including from individualtests, where material).As a general matter, the board of directors is also responsible formonitoring effectiveness of the overall framework, and using the resultsto inform their decision making process.In addition, the final guidance specifies that senior management should,in consultation with the board of directors, review stress testing activitiesand results with an appropriately critical eye to ensure that there isobjective review and that the stress testing framework includes asufficient range of stress testing activities applied at the appropriate levelsof the banking organization.Finally, in response to comments, the agencies have clarified that abanking organization’s minimum annual review and assessment of theeffectiveness of their stress testing framework should ensure that stresstesting coverage is comprehensive, tests are relevant and current,methodologies are sound, and results are properly considered.IV. Administrative Law MattersA. Paperwork Reduction Act AnalysisIn accordance with the Paperwork Reduction Act (“PRA”) of 1995 theagencies reviewed the final guidance. The agencies may not conduct orsponsor, and an organization is not required to respond to, an information_____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  31. 31. P a g e | 31collection unless the information collection displays a currently validOMB control number.While the guidance is not being adopted as a rule, the agenciesdetermined that certain aspects of the guidance may constitute acollection of information and, therefore, believed it was helpful to publisha burden estimate with the guidance.In particular, the aspects of the guidance that may constitute aninformation collection are the provisions that state a bankingorganization should(i) Have a stress testing framework that includes clearly definedobjectives, well-designed scenarios tailored to the banking organization’sbusiness and risks, well-documented assumptions, conceptually soundmethodologies to assess potential impact on the banking organization’sfinancial condition, informative management reports, and recommendedactions based on stress test results; and(ii) Have policies and procedures for a stress testing framework.The agencies estimated that the above-described information collectionsincluded in the guidance would take respondents, on average, 260 hourseach year.The frequency of information collection is estimated to be annual.Respondents are banking organizations with more than $10 billion in totalconsolidated assets, as defined in the guidance.The agencies received three comment letters regarding the paperworkburden of the guidance, stating that implementation will require amultiple of the 260 estimated hours.The agencies emphasize that the guidance does not implement the stresstesting requirements imposed by the Dodd-Frank Act or the Board’scapital plan rule, and does not otherwise impose mandatory stress testingrequirements._____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  32. 32. P a g e | 32The burden of information collections associated with mandatory stresstests will be accounted for in the respective rules that implement thoserequirements.In addition, the agencies believe that in some respects, the informationcollection elements of this guidance augment certain expectations thatalready are in place relative to certain existing supervisory guidance.The burden estimates for this guidance take into consideration only thosecollections of information, such as documentation of policies andprocedures and relevant reports, that are specific to this guidance.Based on these factors, the agencies believe the burden estimatesincluded in the proposed guidance continue to be appropriate.V. Final supervisory guidanceThe text of the final supervisory guidance is as follows:Office of the Comptroller of the CurrencyFederal Reserve SystemFederal Deposit Insurance CorporationGuidance on Stress Testing for Banking Organizations withTotal Consolidated Assets of More Than $10 BillionI. IntroductionAll banking organizations should have the capacity to understand fullytheir risks and the potential impact of stressful events and circumstanceson their financial condition.The U.S. federal banking agencies have previously highlighted the use ofstress testing as a means to better understand the range of a bankingorganization’s potential risk exposures.The 2007-2009 financial crisis underscored the need for bankingorganizations to incorporate stress testing into their risk managementpractices, demonstrating that banking organizations unprepared for_____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  33. 33. P a g e | 33stressful events and circumstances can suffer acute threats to theirfinancial condition and viability.The Federal Reserve, the Office of the Comptroller of the Currency, andthe Federal Deposit Insurance Corporation (collectively, the “agencies”)are issuing this guidance to emphasize the importance of stress testing asan ongoing risk management practice that supports bankingorganizations’ forward-looking assessment of risks and better equipsthem to address a range of adverse outcomes.This joint guidance is applicable to all institutions supervised by theagencies with more than $10 billion in total consolidated assets.Specifically, with respect to the OCC, these banking organizationsinclude national banking associations, federal savings associations, andfederal branches and agencies; with respect to the Board, these bankingorganizations include state member banks, bank holding companies,savings and loan holding companies, and all other institutions for whichthe Federal Reserve is the primary federal supervisor; with respect to theFDIC, these banking organizations include state nonmember banks,state savings associations and insured branches of foreign banks.The guidance does not apply to any supervised institution below thedesignated asset threshold.Certain other existing supervisory guidance that applies to all supervisedinstitutions discusses the use of stress testing as a tool in certain aspectsof risk management, such as for commercial real estate concentrations,liquidity risk management, and interest-rate risk management.However, no institution at or below $10 billion in total consolidated assetsis subject to this final guidance.Building upon previously issued supervisory guidance that discusses theuses and merits of stress testing in specific areas of risk management, thisguidance provides broad principles a banking organization should followin conducting its stress testing activities, such as ensuring that thoseactivities fit into the organization’s overall risk management program. _____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  34. 34. P a g e | 34The guidance outlines broad principles for a satisfactory stress testingframework and describes the manner in which stress testing should beemployed as an integral component of risk management that is applicableat various levels of aggregation within a banking organization, as well asfor contributing to capital and liquidity planning.While the guidance is not intended to provide detailed instructions forconducting stress testing for any particular risk or business area, thedocument describes several types of stress testing activities and how theymay be most appropriately used by banking organizations.II. Overview of Stress Testing FrameworkFor purposes of this guidance, stress testing refers to exercises used toconduct a forward looking assessment of the potential impact of variousadverse events and circumstances on a banking organization.Stress testing occurs at various levels of aggregation, including on anenterprise-wide basis.As outlined in section IV, there are several approaches and applicationsfor stress testing and a banking organization should consider the use ofeach in its stress testing framework.An effective stress testing framework provides a comprehensive,integrated, and forward looking set of activities for a bankingorganization to employ along with other practices in order to assist in theidentification and measurement of its material risks and vulnerabilities,including those that may manifest themselves during stressful economicor financial environments, or arise from firm-specific adverse events.Such a framework should supplement other quantitative riskmanagement practices, such as those that rely primarily on statisticalestimates of risk or loss estimates based on historical data, as well asqualitative practices._____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  35. 35. P a g e | 35In this manner, stress testing can assist in highlighting unidentified orunder-assessed risk concentrations and interrelationships and theirpotential impact on the banking organization during times of stress.A banking organization should develop and implement its stress testingframework in a manner commensurate with its size, complexity, businessactivities, and overall risk profile.Its stress testing framework should include clearly defined objectives,well-designed scenarios tailored to the banking organization’s businessand risks, well-documented assumptions, sound methodologies to assesspotential impact on the banking organization’s financial condition,informative management reports, ongoing and effective review of stresstesting processes, and recommended actions based on stress test results.Stress testing should incorporate the use of high-quality data andappropriate assumptions about the performance of the institution understress to ensure that the outputs are credible and can be used to supportdecision-making.Importantly, a banking organization should have a sound governance andcontrol infrastructure with objective, critical review to ensure the stresstesting framework is functioning as intended.A stress testing framework should allow a banking organization toconduct consistent, repeatable exercises that focus on its materialexposures, activities, risks, and strategies, and also conduct ad hocscenarios as needed.The framework should consider the impact of both firm specific andsystemic stress events and circumstances that are based on historicalexperience as well as on hypothetical occurrences that could have anadverse impact on a banking organization’s operations and financialcondition.Banking organizations subject to this guidance should develop policieson reviewing and assessing the effectiveness of their stress_____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  36. 36. P a g e | 36testing frameworks, and use those policies at least annually to assess theeffectiveness of their frameworks.Such assessments should help to ensure that stress testing coverage iscomprehensive, tests are relevant and current, methodologies are sound,and results are properly considered.III. General Stress Testing PrinciplesA banking organization should develop and implement an effective stresstesting framework as part of its broader risk management and governanceprocesses.The framework should include several activities and exercises, and notjust rely on any single test or type of test, since every stress test haslimitations and relies on certain assumptions.The uses of a banking organization’s stress testing framework shouldinclude, but are not limited to,- augmenting risk identification and measurement;- estimating business line revenues and losses and informing business line strategies;- identifying vulnerabilities, assessing the potential impact from those vulnerabilities, and identifying appropriate actions;- assessing capital adequacy and enhancing capital planning; assessing liquidity adequacy and informing contingency funding plans;- contributing to strategic planning;- enabling senior management to better integrate strategy, risk management, and capital and liquidity planning decisions; and assisting with recovery and resolution planning._____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  37. 37. P a g e | 37This section describes general principles that a banking organizationshould apply in implementing such a framework.Principle 1:A banking organization’s stress testing framework should includeactivities and exercises that are tailored to and sufficiently capture thebanking organization’s exposures, activities, and risks.An effective stress testing framework covers a banking organization’s fullset of material exposures, activities, and risks, whether on or off thebalance sheet, based on effective enterprise-wide risk identification andassessment.Risks addressed in a firm’s stress testing framework may include (but arenot limited to) credit, market, operational, interest-rate, liquidity,country, and strategic risk.The framework should also address non-contractual sources of risks,such as those related to a banking organization’s reputation.Appropriate coverage is important as stress testing results could give afalse sense of comfort if certain portfolios, exposures, liabilities, orbusiness line activities are not included.Stress testing exercises should be part of a banking organization’s regularrisk identification and measurement activities.For example, in assessing credit risk a banking organization shouldevaluate the potential impact of adverse outcomes, such as an economicdownturn or declining asset values, on the condition of its borrowers andcounterparties, and on the value of any supporting collateral.As another example, in assessing interest-rate risk, banking organizationsshould analyze the effects of significant interest rate shocks or otheryield-curve movements._____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  38. 38. P a g e | 38An effective stress testing framework should be applied at various levelsin the banking organization, such as business line, portfolio, and risktype, as well as on an enterprise-wide basis.In many cases, stress testing may be more effective at business line andportfolio levels, as a higher level of aggregation may cloud orunderestimate the potential impact of adverse outcomes on a bankingorganization’s financial condition.In some cases, stress testing can also be applied to individual exposuresor instruments.Each stress test should be tailored to the relevant level of aggregation,capturing critical risk drivers, internal and external influences, and otherkey considerations at the relevant level.Stress testing should capture the interplay among different exposures,activities, and risks and their combined effects.While stress testing several types of risks or business lines simultaneouslymay prove operationally challenging, a banking organization should aimto identify common risk drivers across risk types and business lines thatcan adversely affect its financial condition.Accordingly, stress tests should provide a banking organization with theability to identify potential concentrations – including those that may notbe readily observable during benign periods and whose sensitivity to acommon set of factors is apparent only during times of stress – and toassess the impact of identified concentrations of exposures, activities, andrisks within and across portfolios and business lines and on theorganization as a whole.Stress testing should be tailored to the banking organization’sidiosyncrasies and specific business mix and include all major businesslines and significant individual counterparties.For example, a banking organization that is geographically concentratedmay determine that a certain segment of its business may be more_____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  39. 39. P a g e | 39adversely affected by shocks to economic activity at the state or local levelthan by a severe national recession.On the other hand, if the banking organization has significant globaloperations, it should consider scenarios that have an internationalcomponent and stress conditions that could affect the different aspects ofits operations in different ways, as well as conditions that could adverselyaffect all of its operations at the same time.A banking organization should use its stress testing framework todetermine whether exposures, activities, and risks under normal andstressed conditions are aligned with the banking organization’s riskappetite.A banking organization can use stress testing to help inform decisionsabout its strategic direction and/or risk appetite by better understandingthe risks from its exposures or of engaging in certain business practices.For example, if a banking organization pursues a business strategy for anew or modified product, and the banking organization does not havelong-standing experience with that product or lacks extensive data,the banking organization can use stress testing to identify the product’spotential downsides and unanticipated risks.Scenarios used in a banking organization’s stress tests should be relevantto the direction and strategy set by its board of directors, as well assufficiently severe to be credible to internal and external stakeholders.Principle 2:An effective stress testing framework employs multiple conceptuallysound stress testing activities and approaches.All measures of risk, including stress tests, have an element of uncertaintydue to assumptions, limitations, and other factors associated with usingpast performance measures and forward-looking estimates._____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  40. 40. P a g e | 40Banking organizations should, therefore, use multiple stress testingactivities and approaches (consistent with section IV), and ensure thateach is conceptually sound.Stress tests usually vary in design and complexity, including the numberof factors employed and the degree of stress applied.A banking organization should ensure that the complexity of any giventest does not undermine its integrity, usefulness, or clarity.In some cases, relatively simple tests can be very useful and informative.Additionally, effective stress testing relies on high-quality input data andinformation to produce credible outcomes.A banking organization should ensure that it has readily available dataand other information for the types of stress tests it uses, including keyvariables that drive performance.In addition, a banking organization should have appropriatemanagement information systems (MIS) and data processes that enable itto collect, sort, aggregate, and update data and other informationefficiently and reliably within business lines and across the bankingorganization for use in stress testing.If certain data and information are not current or not available, or ifproxies are used, a banking organization should analyze the stress testoutputs with an understanding of those data limitations.A banking organization should also document the assumptions used inits stress tests and note the degree of uncertainty that may beincorporated into the tools used for stress testing.In some cases, it may be appropriate to present and analyze test resultsnot just in terms of point estimates, but also including the potentialmargin of error or statistical uncertainty around the estimates._____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  41. 41. P a g e | 41Furthermore, almost all stress tests, including well-developedquantitative tests supported by high-quality data, employ a certainamount of expert or business judgment, and the role and impact of suchjudgment should be clearly documented.In some cases, when credible data are lacking and more quantitative testsare operationally challenging or in the early stages of development, abanking organization may choose to employ more qualitatively basedtests, provided that the tests are properly documented and theirassumptions are transparent.Regardless of the type of stress tests used, a banking organization shouldunderstand and clearly document all assumptions, uncertainties, andlimitations, and provide that information to users of the stress testingresults.Principle 3:An effective stress testing framework is forward-looking and flexible.A stress testing framework should be sufficiently dynamic and flexible toincorporate changes in a banking organization’s on- andoff-balance-sheet activities, portfolio composition, asset quality,operating environment, business strategy, and other risks that may ariseover time from firm-specific events, macroeconomic and financial marketdevelopments, or some combination of these events.A banking organization should also ensure that its MIS are capable ofincorporating relatively rapid changes in exposures, activities, and risks.While stress testing should utilize available historical information, abanking organization should look beyond assumptions based only onhistorical data and challenge conventional assumptions.A banking organization should ensure that it is not constrained by pastexperience and that it considers multiple scenarios, even scenarios thathave not occurred in the recent past or during the banking organization’shistory._____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  42. 42. P a g e | 42For example, a banking organization should not assume that if it hassuffered no or minimal losses in a certain business line or product thatsuch a pattern will continue.Structural changes in customer, product, and financial markets canpresent unprecedented situations for a banking organization.A banking organization with any type of significant concentration can beparticularly vulnerable to rapid changes in economic and financialconditions and should try to identify and better understand the impact ofthose vulnerabilities in advance.For example, the risks related to residential mortgages wereunderestimated for a number of years leading up to the 2007-2009financial crisis by a large number of banking organizations, and thoserisks eventually affected the banking organizations in a variety of ways.Effective stress testing can help a banking organization identify any suchconcentrations and help understand the potential impact of several keyaspects of the business being exposed to common drivers.Stress testing should be conducted over various relevant time horizons toadequately capture both conditions that may materialize in the near termand adverse situations that take longer to develop.For example, when a banking organization stress tests a portfolio formarket and credit risks simultaneously, it should consider that certaincredit risk losses may take longer to materialize than market risk losses,and also that the severity and speed of mark-to-market losses may createsignificant vulnerabilities for the firm, even if a more fundamentalanalysis of how realized losses may play out over time seems to show lessthreatening results.A banking organization should carefully consider the incremental andcumulative effects of stress conditions, particularly with respect topotential interactions among exposures, activities, and risks and possiblesecond-order or “knock-on” effects._____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  43. 43. P a g e | 43In addition to conducting formal, routine stress tests, a bankingorganization should have the flexibility to conduct new or ad hoc stresstests in a timely manner to address rapidly emerging risks.These less routine tests usually can be conducted in a short amount oftime and may be simpler and less extensive than a banking organization’smore formal, regular tests.However, for its ad hoc tests a banking organization should still have thecapacity to bring together approximated information on risks, exposures,and activities and assess their impact.More broadly, a banking organization should continue updating andmaintaining its stress testing framework in light of new risks, betterunderstanding of the banking organization’s exposures and activities,new stress testing techniques, and any changes in its operating structureand environment.A banking organization’s stress testing development should be iterative,with ongoing adjustments and refinements to better calibrate the tests toprovide current and relevant information.Banking organizations should document the ongoing development oftheir stress testing practices.Principle 4:Stress test results should be clear, actionable, well supported, and informdecision-making.Stress testing should incorporate measures that adequately and effectivelyconvey results of the impact of adverse outcomes.Such measures may include, for example, changes to asset values,accounting and economic profit and loss, revenue streams, liquiditylevels, cash flows, regulatory capital, risk-weighted assets, the loan lossallowance, internal capital estimates, levels of problem assets, breaches incovenants or key trigger levels, or other relevant measures. _____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  44. 44. P a g e | 44Stress test measures should be tailored to the type of test and theparticular level at which the test is applied (for example, at the businessline or risk level). Some stress tests may require using a range of measuresto evaluate the full impact of certain events, such as a severe systemicevent.In addition, all stress test results should be accompanied by descriptiveand qualitative information (such as key assumptions and limitations) toallow users to interpret the exercises in context.The analysis and the process should be well documented so that stresstesting processes can be replicated if need be.A banking organization should regularly communicate stress test resultsto appropriate levels within the banking organization to foster dialoguearound stress testing, keep the board of directors, management, and staffapprised, and to inform stress testing approaches, results, and decisionsin other areas of the banking organization.A banking organization should maintain an internal summary of testresults to document at a high level the range of its stress testing activitiesand outcomes, as well as proposed follow-up actions.Regular review of stress test results can be an important part of a bankingorganization’s ability over time to track the impact of ongoing businessactivities, changes in exposures, varying economic conditions, andmarket movements on its financial condition.In addition, management should review stress testing activities on aregular basis to determine, among other things, the validity of theassumptions, the severity of tests, the robustness of the estimates, theperformance of any underlying models, and the stability andreasonableness of the results.Stress test results should inform analysis and decision-making related tobusiness strategies, limits, risk profile, and other aspects of riskmanagement, consistent with the banking organization’s established riskappetite._____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  45. 45. P a g e | 45A banking organization should review the results of its various stress testswith the strengths and limitations of each test in mind (consistent withPrinciple 2), determines which results should be given greater or lesserweight, analyze the combined impact of its tests, and then evaluatepotential courses of action based on that analysis.A banking organization may decide to maintain its current course basedon test results; indeed, the results of highly severe stress tests need notalways indicate that immediate action has to be taken.Wherever possible, benchmarking or other comparative analysis shouldbe used to evaluate the stress testing results relative to other tools andmeasures – both internal and external to the banking organization – toprovide proper context and a check on results.Principle 5:An organization’s stress testing framework should include stronggovernance and effective internal controls.Similar to other aspects of its risk management, a banking organization’sstress testing framework will be effective only if it is subject to stronggovernance and effective internal controls to ensure the framework isfunctioning as intended. Strong governance and effective internalcontrols help ensure that the framework contains core elements, fromclearly defined stress testing objectives to recommended actions.Importantly, strong governance provides critical review of elements of thestress testing framework, especially regarding key assumptions,uncertainties, and limitations.A banking organization should ensure that the stress testing framework isnot isolated within a banking organization’s risk management function,but is firmly integrated into business lines, capital and asset-liabilitycommittees, and other decision making bodies.Along those lines, the board of directors and senior management shouldplay key roles in ensuring strong governance and controls._____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  46. 46. P a g e | 46The extent and sophistication of a banking organization’s governanceover its stress testing framework should align with the extent andsophistication of that framework.Additional details regarding governance and controls of an organization’sstress testing framework are outlined in section VI.IV. Stress Testing Approaches and ApplicationsThis section discusses some general types of stress testing approachesand applications.For any type of stress test, banking organizations should indicate thespecific purpose and the focus of the test.Defining the scope of a given stress test is also important, whether itapplies at the portfolio, business line, risk type, or enterprise-wide level,or even just for an individual exposure or counterparty.Based on the purpose and scope of the test, different stress testingtechniques are most useful.Thus, a banking organization should employ several approaches andapplications; these might include scenario analysis, sensitivity analysis,enterprise-wide stress testing, and reverse stress testing.Consistent with Principle 1, banking organizations should apply thesecommensurate with their size, complexity, and business profile, and maynot need to incorporate all of the details described below.Consistent with Principle 3, banking organizations should also recognizethat stress testing approaches will evolve over time and they shouldupdate their practices as needed.Scenario Analysis_____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  47. 47. P a g e | 47Scenario analysis refers to a type of stress testing in which a bankingorganization applies historical or hypothetical scenarios to assess theimpact of various events and circumstances, including extreme ones.Scenarios usually involve some kind of coherent, logical narrative or“story” as to why certain events and circumstances can occur and inwhich combination and order, such as a severe recession, failure of amajor counterparty, loss of major clients, natural or man-made disaster,localized economic downturn, disruptions in funding or capital markets,or a sudden change in interest rates brought about by unfavorableinflation developments.Scenario analysis can be applied at various levels of the bankingorganization, such as within individual business lines to help identifyfactors that could harm those business lines most.Stress scenarios should reflect a banking organization’s uniquevulnerabilities to factors that affect its exposures, activities, and risks.For example, if a banking organization is concentrated in a particular lineof business, such as commercial real estate or residential mortgagelending, it would be appropriate to explore the impact of a downturn inthose particular market segments.Similarly, a banking organization with lending concentrations to oil andgas companies should include scenarios related to the energy sector.Other relevant factors to be considered in scenario analysis relate tooperational, reputational and legal risks to a banking organization, suchas significant events of fraud or litigation, or a situation when a bankingorganization feels compelled to provide support to an affiliate or provideother types of non-contractual support to avoid reputational damage.Scenarios should be internally consistent and portray realistic outcomesbased on underlying relationships among variables, and should includeonly those mitigating developments that are consistent with the scenario._____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  48. 48. P a g e | 48Additionally, a banking organization should consider the best manner totry to capture combinations of stressful events and circumstances,including second-order and “knock-on” effects.Ultimately, a banking organization should select and design multiplescenarios that are relevant to its profile and make intuitive sense, useenough scenarios to explore the range of potential outcomes, and ensurethat the scenarios continue to be timely and relevant.A banking organization may apply scenario analysis within the context ofits existing risk measurement tools (e.g., the impact of a severe decline inmarket prices on a banking organization’s value-at-risk (VaR) measure)or use it as an alternative, supplemental measure.For instance, a banking organization may use scenario analysis tomeasure the impact of a severe financial market disturbance and comparethose results to what is produced by its VaR or other measures.This type of scenario analysis should account for known shortcomings ofother risk measurement practices.For example, market risk VaR models generally assume liquid marketswith known prices.Scenario analysis could shed light on the effects of a breakdown inliquidity and of valuation difficulties.One of the key challenges with scenario analysis is to translate a scenariointo balance sheet impact, changes in risk measures, potential losses, orother measures of adverse financial impact, which would vary dependingon the test design and the type of scenario used.For some aspects of scenario analysis, banking organizations may useeconometric or similar types of analysis to estimate a relationshipbetween some underlying factors or drivers and risk estimates or lossprojections based on a given data set, and then extrapolate to see theimpact of more severe inputs._____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  49. 49. P a g e | 49Care should be taken not to make assumptions that relationships frombenign or mildly adverse times will hold during more severe times or thatestimating such relationships is relatively straightforward.For example, linear relationships between risk drivers and losses maybecome nonlinear during times of stress.In addition, organizations should recognize that there can be multiplepermutations of outcomes from just a few key risk drivers.Sensitivity AnalysisSensitivity analysis refers to a banking organization’s assessment of itsexposures, activities, and risks when certain variables, parameters, andinputs are “stressed” or “shocked.”A key goal of sensitivity analysis is to test the impact of assumptions onoutcomes.Generally, sensitivity analysis differs from scenario analysis in that itinvolves changing variables, parameters, or inputs without an explicitunderlying reason or narrative, in order to explore what occurs under arange of inputs and at extreme or highly adverse levels.In this type of analysis a banking organization may realize, for example,that a given relationship is much more difficult to estimate at extremelevels.A banking organization may apply sensitivity analysis at various levels ofaggregation to estimate the impact from a change in one or more keyvariables.The results may help a banking organization better understand the rangeof outcomes from some of its models, such as developing a distribution ofoutput based on a variety of extreme inputs._____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  50. 50. P a g e | 50For example, a banking organization may choose to calculate a range ofchanges to a structured security’s overall value using a range of differentassumptions about the performance and linkage of underlying cash flows.Sensitivity analysis should be conducted periodically due to potentialchanges in a banking organization’s exposures, activities, operatingenvironment, or the relationship of variables to one another.Sensitivity analysis can also help to assess a combined impact on abanking organization of several variables, parameters, factors, or drivers.For example, a banking organization could better understand the impacton its credit losses from a combined increase in default rates and adecrease in collateral values.A banking organization could also explore the impact of highly adversecapitalization rates, declines in net operating income, and reductions incollateral when evaluating its risks from commercial real estateexposures.Sensitivity analysis can be especially useful because it is not necessarilyaccompanied by a particular narrative or scenario; that is, sensitivityanalysis can provide banking organizations more flexibility to explore theimpact of potential stresses that they may not be able to capture indesigned scenarios.Furthermore, banking organizations may decide to conduct sensitivityanalysis of their scenarios, i.e., choosing different levels or paths ofvariables to understand the sensitivities of choices made during scenariodesign.For instance, banking organizations may decide to apply a few differentinterest-rate paths for a given scenario.Enterprise-Wide Stress TestingEnterprise-wide stress testing is an application of stress testing thatinvolves assessing the impact of certain specified scenarios on the_____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  51. 51. P a g e | 51banking organization as a whole, particularly with regard to capital andliquidity.As is the case with scenario analysis more generally, enterprise widestress testing involves robust scenario design and effective translation ofscenarios into measures of impact.Enterprise-wide stress tests can help a banking organization in its effortsto assess the impact of its full set of risks under adverse events andcircumstances, but should be supplemented with other stress tests andother risk measurement tools given inherent limitations in capturing allrisks and all adverse outcomes in one test.Scenario design for enterprise-wide stress testing involves developingscenarios that affect the banking organization as a whole that stem frommacroeconomic, market-wide, and/or firm-specific events.These scenarios should incorporate the potential simultaneousoccurrence of both firm-specific and macroeconomic and market-wideevents, considering system-wide interactions and feedback effects.For example, price shocks may lead to significant portfolio losses, risingfunding gaps, a ratings downgrade, and diminished access to funding.In general, it is a good practice to consult with a large set of individualswithin the banking organization – in various business lines, research andrisk areas – to gain a wide perspective on how enterprise wide scenariosshould be designed and to ensure that the scenarios capture the relevantaspects of the banking organization’s business and risks.Banking organizations should also conduct scenarios of varying severityto gauge the relative impact.At least some scenarios should be of sufficient severity to challenge theviability of the banking organization, and should include instantaneousmarket shocks and stressful periods of extended duration (e.g., not just aone or two-quarter shock after which conditions return to normal)._____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  52. 52. P a g e | 52Selection of scenario variables is important for enterprise-wide tests,because these variables generally serve as the link between the overallnarrative of the scenario and tangible impact on the banking organizationas a whole.For instance, in aiming to capture the combined impact of a severerecession and a financial market downturn, a banking organization maychoose a set of variables such as changes in gross domestic product(GDP), unemployment rate, interest rates, stock market levels, or homeprice levels.However, particularly when assessing the impact on the whole bankingorganization, using a large number of variables can make a test morecumbersome and complicated – so a banking organization may alsobenefit from simpler scenarios or from those with fewer variables.Banking organizations should balance the comprehensiveness ofcontributing variables and tractability of the exercise.As with scenario analysis generally, translating scenarios into tangibleeffects on the banking organization as a whole presents certainchallenges.A banking organization should identify appropriate and meaningfulmechanisms for translating scenarios into relevant internal riskparameters that provide a firm-wide view of risks and understanding ofhow these risks are translated into loss estimates.Not all business areas are equally affected by a given scenario, andproblems in one business area can have effects on other units.However, for an enterprise-wide test, assumptions across business linesand risk areas should remain constant for the chosen scenario, since theobjective is to see how the banking organization as a whole will beaffected by a common scenario.Reverse Stress Testing_____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  53. 53. P a g e | 53Reverse stress testing is a tool that allows a banking organization toassume a known adverse outcome, such as suffering a credit loss thatbreaches regulatory capital ratios or suffering severe liquidity constraintsthat render it unable to meet its obligations, and then deduce the types ofevents that could lead to such an outcome.This type of stress testing may help a banking organization to considerscenarios beyond its normal business expectations and see the impact ofsevere systemic effects on the banking organization.It also allows a banking organization to challenge common assumptionsabout its performance and expected mitigation strategies.Reverse stress testing helps to explore so-called “break the bank”situations, allowing a banking organization to set aside the issue ofestimating the likelihood of severe events and to focus more on whatkinds of events could threaten the viability of the banking organization.This type of stress testing also helps a banking organization evaluate thecombined effect of several types of extreme events and circumstances thatmight threaten the survival of the banking organization, even if inisolation each of the effects might be manageable.For instance, reverse stress testing may help a banking organizationrecognize that a certain level of unemployment would have a severeimpact on credit losses, that a market disturbance could create additionallosses and result in rising funding costs, and that a firm-specific case offraud would cause even further losses and reputational impact that couldthreaten a banking organization’s viability.In some cases, reverse stress tests could reveal to a banking organizationthat “breaking the bank” is not as remote an outcome as originallythought.Given the numerous potential threats to a banking organization’sviability, the organization should ensure that it focuses first on thosescenarios that have the largest firm-wide impact, such as insolvency or_____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  54. 54. P a g e | 54illiquidity, but also on those that seem most imminent given the currentenvironment.Focusing on the most prominent vulnerabilities helps a bankingorganization prioritize its choice of scenarios for reverse stress testing.However, a banking organization should also consider a wider range ofpossible scenarios that could jeopardize the viability of the bankingorganization, exploring what could represent potential blind spots.Reverse stress testing can highlight previously unacknowledged sourcesof risk that could be mitigated through enhanced risk management.V. Stress Testing for Assessing the Adequacy of Capital andLiquidityThere are many uses of stress testing within banking organizations.Prominent among these are stress tests designed to assess the adequacyof capital and liquidity.Given the importance of capital and liquidity to a banking organization’sviability, stress testing should be applied in these two areas in particular,including an evaluation of the interaction between capital and liquidityand the potential for both to become impaired at the same time.Depletions and shortages of capital or liquidity can cause a bankingorganization to no longer perform effectively as a financial intermediary,be viewed by its counterparties as no longer viable, become insolvent, ordiminish its capacity to meet legal and financial obligations.A banking organization’s capital and liquidity stress testing shouldconsider how losses, earnings, cash flows, capital, and liquidity would beaffected in an environment in which multiple risks manifest themselves atthe same time, for example, an increase in credit losses during an adverseinterest-rate environment.Additionally, banking organizations should recognize that at the end_____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  55. 55. P a g e | 55of the time horizon considered by a given stress test, they may still havesubstantial residual risks or problem exposures that may continue topressure capital and liquidity resources.Stress testing for capital and liquidity adequacy should be conducted incoordination with a banking organization’s overall strategy and annualplanning cycles.Results should be refreshed in the event of major strategic decisions, orother decisions that can materially impact capital or liquidity.Banking organizations should conduct stress testing for capital andliquidity adequacy periodically.Capital Stress TestingCapital stress testing results can serve as a useful tool to support abanking organization’s capital planning and corporate governance.They may help a banking organization better understand itsvulnerabilities and evaluate the impact of adverse outcomes on its capitalposition and ensure that the banking organization holds adequate capitalgiven its business model, including the complexity of its activities and itsrisk profile.Capital stress testing complements a banking organization’s regulatorycapital analysis by providing a forward-looking assessment of capitaladequacy, usually with a forecast horizon of at least two years (with therecognition that the effects of certain stress conditions could extendbeyond two years for some stress tests), and highlighting the potentialadverse effects on capital levels and ratios from risks not fully capturedin regulatory capital requirements.It should also be used to help a banking organization assess the qualityand composition of capital and its ability to absorb losses._____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  56. 56. P a g e | 56Stress testing can aid capital contingency planning by helpingmanagement identify exposures or risks in advance that would need to bereduced and actions that could be taken to bolster capital levels orotherwise maintain capital adequacy, as well as actions that in times ofstress might not be possible – such as raising capital.Capital stress testing should include exercises that analyze the potentialfor changes in earnings, losses, reserves, and other potential effects oncapital under a variety of stressful circumstances.Such testing should also capture any potential change in risk-weightedassets, the ability of capital to absorb losses, and any resulting impact onthe banking organization’s capital ratios.It should include all relevant risk types and other factors that have apotential to affect capital adequacy, whether directly or indirectly,including firm-specific ones.A banking organization should also explore the potential for possiblebalance sheet expansion to put pressure on capital ratios and considerrisk mitigation and capital preservation options, other than simplyshrinking the balance sheet.Capital stress testing should assess the potential impact of a bankingorganization’s material subsidiaries suffering capital problems on theirown – such as being unable to meet local country capital requirements –even if the consolidated banking organization is not encounteringproblems.Where material relative to the banking organizations capital,counterparty exposures should also be included in capital stress testing.Enterprise-wide stress testing, as described in section IV, should be anintegral part of a banking organization’s capital stress testing.Such enterprise-wide testing should include proforma estimates of notonly potential losses and resources available to absorb losses, but also_____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com
  57. 57. P a g e | 57potential planned capital actions (such as dividends or share repurchases)that would affect the banking organization’s capital position, includingregulatory and other capital ratios.There should also be consideration of the impact on the bankingorganization’s allowance for loan and lease losses and other relevantfinancial metrics.Even with very effective enterprise-wide tests, banking organizationsshould use capital stress testing in conjunction with other internalapproaches (in addition to regulatory measures) for assessing capitaladequacy, such as those that rely primarily on statistical estimates of riskor loss estimates based on historical data.Liquidity stress testingA banking organization should also conduct stress testing for liquidityadequacy.Through such stress testing a banking organization can work to identifyvulnerabilities related to liquidity adequacy in light of both firm-specificand market-wide stress events and circumstances.Effective stress testing helps a banking organization identify and quantifythe depth, source, and degree of potential liquidity and funding strain andto analyze possible impacts on its cash flows, liquidity position,profitability, and other aspects of its financial condition over various timehorizons.For example, stress testing can be used to explore potential fundingshortfalls, shortages in liquid assets, the inability to issue debt, exposureto possible deposit outflows, volatility in short-term brokered deposits,sensitivity of funding to a ratings downgrade, and the impact of reducedcollateral values on borrowing capacity at the Federal Home Loan Banks,the Federal Reserve discount window, or other secured wholesale fundingsources.Liquidity stress testing should explore the potential impact of adverse_____________________________________________________________International Association of Risk and Compliance Professionals (IARCP) www.risk-compliance-association.com

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