A POV on Bank Stress Testing – CCAR & DFAST..

The recession of 2007 to 2009 was still the most painful since the Depression. At its depths, $15 trillion in household wealth had disappeared, ravaging the pensions and college funds of Americans who had thought their money was in good hands. Nearly 9 million workers lost jobs; 9 million people slipped below the poverty line; 5 million homeowners lost homes.”
― Timothy F. Geithner, Former Secretary of the US Treasury – “Reflections on Financial crises – 2014”

A Quick Introduction to Macroeconomic Stress Testing..

The concept of stress testing in banking is not entirely new. It has been practiced for years in global banks across specific business functions that deal with risk. The goal of these internal tests has been to assess firm wide capital adequacy in periods of economic stress. However,the 2008 financial crisis clearly exposed how unprepared the Bank Holding Companies (BHCs) were to systemic risk brought on as a result of severe macroeconomic distress. Thus the current raft of regulator driven stress tests are motivated from the taxpayer funded bailouts in 2008. Back then banks were neither adequately capitalized to cope with stressed economic conditions nor were their market,credit risk losses across portfolios sustainable.

In 2007, SCAP (Supervisory Capital Access Program) was enacted as a stress testing framework in the US that only 19 leading financial institutions (Banks, Insurers etc) had to adhere to. The exercise was not only focused on the quantity of capital available but also the quality- Tier 1 common capital – with the institution. The emphasis on Tier 1 Common Capital is important as it provided an institution with a higher absorption capacity with minimizing losses to higher capital tiers.  Tier 1 Common Capital can also be managed better during economic stress by adjusting dividends, share buybacks and related activities.

Though it was a one off, the SCAP was a stringent and rigorous test. The Fed performed SCAP audits on the results of all the 19 BHC’s – some of whom failed the test.

Following this in 2010, the Dodd Frank Act was enacted by the Obama Administration.The Dodd Frank Act also introduced it’s own stress test – DFAST (Dodd-Frank Act Stress Testing). DFAST requires BHCs with assets of $10 billion & above to run annual stress tests and to make the results public. The goal of these stress tests is multifold but they are conducted primarily to assure the public, the regulators that BHCs have adequately capitalized their portfolios. BHC’s are required to present detailed capital plans to the Fed.

The SCAP’s successor, CCAR (Comprehensive Capital Adequacy Review) was also enacted around that time. Depending on the overall risk profile of the institution, the CCAR mandates several qualitative & quantitative metrics that BHCs need to report on and make public for several stressed macroeconomic scenarios.


Comprehensive Capital Analysis and Review (CCAR) is a regulatory framework introduced by the Federal Reserve in order to assess, regulate, and supervise large banks and financial institutions – collectively referred to in the framework as Bank Holding Companies (BHCs).
– (WikiPedia)

  • Every year, an increasing number of Tier 2 banks come under the CCAR mandate. CCAR basically requires specific BHCs to develop a set of internal macroeconomic scenarios or use those developed by the regulators. Regulators would then get the individual results of these scenario runs from firms across a nine quarter time horizon. Regulators also develop their own systemic stress tests to verify if a given BHC can withstand negative economic scenarios and continue to operate their lending operations. CCAR coverage primarily includes retail banking operations, auto & home lending, trading, counter party credit risk, AFS (Available For Sale)/HTM (Hold To Maturity) securities etc. The CCAR covers all major kinds of risk – market, credit, liquidity and OpsRisk.
CCAR kicked off global moves by regulators to enforce the same of banks in their respective jurisdictions. The EU requires EBA stress testing. The UK is an example of a country that requires its own stress testing – the Prudential Regulatory Authority. The same evolution of the firm wide stress testing has been followed by other regulators over the world, for example, in Europe with the EBA stress testing. Emerging markets such as India and China are also following this trend. Every year, more and more BHCs are increasingly subject to CCAR reporting mandates.

Similarities & Differences between CCAR and DFAST..

To restate – the CCAR is an annual exercise by the Federal Reserve to assess whether the largest bank holding companies operating in the United States have sufficient capital to continue operations throughout times of economic and financial stress and that they have robust, forward-looking capital-planning processes that account for their unique risks.  As part of this exercise, the Federal Reserve evaluates institutions’ capital adequacy, internal capital adequacy assessment processes, and their individual plans to make capital distributions, such as dividend payments or stock repurchases. Dodd-Frank Act stress testing (DFAST)-an exercise similar to CCAR- is a forward-looking stress test conducted by the Federal Reserve for smaller financial institutions. It is supervised by the Federal Reserve to help assess whether institutions have sufficient capital to absorb losses and support operations during adverse economic conditions.

As part of CCAR reporting guidelines, the BHC’s have to explicitly call out

  1. their sources of capital given their risk profile & breadth of operations,
  2. the internal policies & controls for measuring capital adequacy &
  3. any upcoming business decisions (share buybacks, dividends etc) that may impact their capital adequacy plans.

While both CCAR and DFAST look very similar from a high level  – they both mandate that banks  conduct stress tests – they do differ in the details. DFAST is applicable to banks that have assets between 10-50 billion $. During the planning horizon phase, CCAR allows the BHCs to use their own capital action assessments while DFAST enforces a standardized set of capital actions.The DFAST scenarios represent baseline, adverse and severely adverse scenarios. The DFAST is supervised by the Fed, the OCC (Office of the Comptroller of Currency) and the FDIC.

                                                Summary of DFAST and CCAR (Source: E&Y) 

As can be seen from the above table, while DFAST is complementary to CCAR, both efforts are distinct testing exercises that rely on similar processes, data, supervisory exercises, and requirements. The Federal Reserve coordinates these processes to reduce duplicative requirements and to minimize regulatory burden. CCAR results are reported twice on an annual basis and BHCs are required to also incorporate Basel III capital ratios in their reports with Tier 1 capital ratios calculated using existing rules. DFAST is reported up annually and it does include Basel III reporting.

In a Nutshell…

In CCAR (and DFAST), the Fed is essentially asking the BHC’s the following questions –

(1) For your defined risk profile, please define a process of understanding and mapping the key stakeholders to carry out this process.

(2) Please ensure that you use clean internal data to compute your exposures in the event of economic stress. The entire process of data sourcing, cleaning, computation, analytics & reporting needs to be auditable.

(3) What macroeconomic stress scenarios did you develop in working with key lines of business ? What are the key historical assumptions in developing these? What are the key what-if scenarios that you have developed based on the stressed scenarios? The scenarios need to be auditable as well.

(4) We are then going to run our own macroeconomic numbers & run our own scenarios using our own exposure generators on your raw data.

(5) We want to see how close both sets of numbers are.

Both CCAR and DFAST scenarios are expressed in stressed macroeconomic factors and financial indicators. The regulators typically provide these figures on a quarterly basis a few reporting periods in advance.

What are some examples of these scenarios?
  • Measures of Index Turbulence – E.g. In a certain quarter, regulators might establish that the S&P 500 would go down 30%; Decrease in key indices like home, commercial property & other asset prices.
  • Measures of  Economic Activity – E.g. US unemployment rate spikes, higher interest rates, increased inflation. What if unemployment ran to 14%? What does that do to my mortgage portfolio – the default rates increase and this is what it looks like.
  • Measures of Interest Rate Turbulence –  E.g. US treasury yields, Interest rates on US mortgages etc.

Based on this information, banks would then assess the impact of these economic scenarios as reflected in market and credit losses to their portfolios. This would help them estimate how their capital base would behave in this situation. These internal CCAR metrics are then sent over to the regulators. Every Bank has their own models based on their understanding which the Fed needs to review as well for completeness and quality.

The Fed uses the CCAR and DFAST results to evaluate capital adequacy, the quality of the capital adequacy assessment process and then evaluates the BHC’s plans to make capital distributions using dividends & share repurchases etc in the context of the results. The BHC’s boards of directors are required to approve and sign off on these plans.

What do CCAR & DFAST entail of Banks?

Well, six important things as the above illustration captures –

    1. CCAR is fundamentally very different from other umbrella risk types in that it has a strong external component in terms of reporting on internal bank data to the regulatory authorities. CCAR reporting is done by sending over internal bank Book of Record Transaction (BORT) data from their lending systems (with hundreds of manual adjustments) to the regulators for them to run their models to assess capital adequacy.  Currently , most banks do some model reporting internally which are based on canned CCAR algos in tools like SAS/Spark computed for a few macroeconomic stress scenarios.
    2. Both CCAR and DFAST stress the same business processes, data resources and governance mechanisms. They are both a significant ask on the BHCs from the standpoint of planning, execution and governance. BHCs have found them daunting with the new D-SIB’s that enter the mandate are faced with implementing these programs that need significant organizational and IT spend.
    3. Both CCAR and DFAST challenge the banks on data collection, quality, lineage and reporting. The Fed requires that data needs to be accurate, comprehensive and clean. Data Quality is the single biggest challenge to stress test compliance. Banks need to work on a range of BORT (Book of Record Transaction Systems) like Core Banking, Lending Portfolios, Position data and any other data needed to accurate reflect the business. There is also a reconciliation process that is typically used to reconcile risk data with the GL (General Ledger). For instance if a BHC’s lending portfolio is $4 billion based on the raw summary data. Once reconciliation is performed – it seems to be around $3 billion after adjustments. The regulator runs the aforesaid macroeconomic scenarios at $4 billion and the exposures are naturally off.
    4. Contrary to popular perception -the heavy lifting from is typically not in creating and running the exposure calculations for stress testing. The creation of these is relatively straightforward. Banks historically have had their own analytics groups produce these macroeconomic models. They also already have 10s of libraries in place that can be modified to create supervisory scenarios for CCAR/DFAST- the baseline, adverse & severely adverse. The critical difference with stress testing is that silo-ed models and scenarios need be unified along with the data.
    5. Model development in Banks usually follows a well defined lifecycle.Most of Liquidity Assessment and Liquidity Groups within Banks currently have a good base of quants with a clean separation of job duties. For instance, while one group produces scenarios, others work on exposures that feed into liquidity engines to calculate liquidity. The teams running these liquidity assessments are good candidates to run the CCAR/DFAST models as well. The calculators themselves will need to be rewritten for Big Data using something like SAS/ Spark.
    6. Transparency must be demonstrated down to the source data level. And banks need to be able to document all capital classification and computation rules to a sufficient degree to meet regulatory requirements during the auditing and review process.

The Technology Implications of  CCAR/DFAST..

It can clearly be seen that regulatory stress testing derives inputs from virtually every banking function. Then it should come as no surprise that  it follows that from a technology point of view there are several implications :

    • CCAR and DFAST impact a range of systems, processes and controls. The challenges that most Banks have in integrating front office trading desk data (Position data, pricing data and reporting) with back-office systems –  risk & finance are making the job of accurately reporting on stress numbers all the more difficult. These are causing most BHC’s to resort to manual data operations, analytics and complicated reconciliation process across the front, mid and back offices.
    • Not just from a computation & reporting library standardization, banks need to be able to perform common data storage for data from a range of BORT systems.
    • Banks also need to standardize on data taxonomies across all of these systems.
    • To that end, Banks need to stop creating more silos data across Risk and Finance functions; as I have often advocated in this blog – a move to a Data Lake enabled architecture is appropriate as a way of eliminating silos and the problem of unclean data which is sure to invite regulatory sanction.
    • Banks need to focus on Data Cleanliness by setting appropriate governance and audit-ability policies
    • Move to a paradigm of bringing compute to large datasets instead of the other way around
    • Move towards in memory analytics to transform, aggregate and analyze data in real time across many dimensions to obtain an understanding of the banks risk profile at any given point in time

A Reference Architecture for CCAR and DFAST..

 I recommend readers review the below post on FRTB Architecture as it contains core architectural and IT themes that are broadly applicable to CCAR and DFAST as well.

A Reference Architecture for the FRTB (Fundamental Review of the Trading Book)

Conclusion..

As can be seen from the above, both CCAR & DFAST require a holistic approach across the value chain (model development, data sourcing, reporting) across Risk, Finance and Treasury functions.  Further Regulators are increasingly demanding an automated process across risk & capital calculations under various scenarios using accurate and consistent data. The need of the hour for BHCs is to move to a common model for data storage, stress modeling and testing. Doing this can only ensure that the metrics and outputs of capital adequacy can be produced accurately and in a timely manner, thus satisfying the regulatory mandate.

References –

[1] Federal Reserve CCAR Summary Instructions 2016

https://www.federalreserve.gov/newsevents/press/bcreg/bcreg20160128a1.pdf

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