Section 165(i)(2) of Dodd-Frank requires banking organizations
with more than $10 billion in total assets to conduct annual stress
tests. It also mandates that the FRB, FDIC and OCC (together, the
"Federal Agencies") adopt rules that (i) define the term
''stress test''; (ii) establish methodologies for
stress testing at least three different sets of conditions,
including baseline, adverse and severely adverse; (iii) establish
the form and content of reports to the appropriate Federal
Agencies; and (iv) require public disclosure of stress test
results. In furtherance of Dodd-Frank requirements, the Federal
Agencies adopted final rules regarding annual company-run stress
tests ("Final Rules") for Medium-Size Banks in October
2012. After issuing those Final Rules, the Federal Agencies then
sought comment on proposed supervisory guidance that would
supplement the Final Rules. The Federal Agencies also discussed
expectations for stress test practices and offered
