Joint Comment Letter to the Board on the Proposed Changes to the Capital Assessments and Stress Testing Reports

Ms. Ann E. Misback
Secretary
Board of Governors of the Federal Reserve System
20th Street & Constitution Avenue, N.W.
Washington, DC 20551

September 8, 2020

Ladies and Gentlemen:

The American Bankers Association (ABA), the Financial Services Forum (Forum), and the Securities Industry and Financial Markets Association (SIFMA) (the Associations) appreciate the opportunity to comment on the temporary approval of information collection by the Board of Governors of the Federal Reserve System with respect to its Forms FR Y-14A/Q/M (Capital Assessments and Stress Testing Reports [Reports]) and its request for comment on the proposed extension, for three years with revision, the FR Y–14A/Q/M reports clarify the reporting of certain current expected credit losses (CECL) and capital data (Proposal).

The temporary revisions to Form Y-14A/Q/M would permit the Board to collect data pertaining to certain aspects of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) and information related to a banking organization’s participation in the Paycheck Protection Program (PPP), the Federal Reserve’s Main Street Lending Program, and other programs established by the Board in response to the COVID-19 pandemic. The Board will also require submission of FR Y–14Q, Schedule H (Wholesale) on a more frequent basis to permit more frequent assessment of the pandemic’s impact on banking organizations and the economy generally. These and other temporary revisions would extend only to reports as of December 31, 2020, unless the Board decides to extend their application.

The Associations appreciate the Board’s need for additional data to assess the economic and financial impact of the COVID-19 pandemic and the effectiveness of various measures to mitigate the resulting economic and financial market damage. The new required reporting and related management information system changes, data integrity testing, and other processes necessary to adapt to the new reporting requirements will, however, impose severe short-term burdens on key bank resources and staff. The Board has also, however, required banking organizations affected by the Proposal to resubmit and update their capital plans in the near future. The Associations therefore recommend several additional steps that would reduce these burdens without impairing the flow of essential data to the Board, including several points on which clarification would significantly improve the process.

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