Banks grapple with Fed’s double deadline on stress-test plans
Supervisor consulting simultaneously on next year’s test scenario and broader model changes
US banks face a tight turnaround to respond to a double consultation by the Federal Reserve on the future of its stress-testing regime. Comments on the draft 2026 scenario are due by December 1 this year, while the broader proposal on model transparency and scenario design closes on January 22, 2026.
The overlap adds a sense of urgency, and two sources say that some firms may end up combining feedback on both, particularly where the broader proposals about scenario design intersect with questions
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