Small Banks Get a Big Break

Banks with less than $250 billion in total assets may soon be seeing a relief in their federal obligations. A proposed alteration from the Federal Reserve could mean that smaller regional banks who do not conduct significant nonbank or international business would be exempted from certain parts of the “stress tests” on their economic resilience.

Issue Background

2010’s Dodd-Frank Financial Reform Bill compels any banking institution with over $50 billion in assets to undergo yearly assessments designed to measure their viability against periods of financial stress. The ultimate goal is regularly ensuring that the system is strong enough to withstand widespread economic turmoil like that seen in 2008’s Great Recession.

The tests encompass a wide variety of stressors, from overall adequacy of the organization’s capital to structural stability to whether planned capital distributions are viable in a variety of scenarios. This is a rigorous and exhaustive process that can take up significant staff time and organizational funds.

More than 30 banks across the country take this test every year, but for smaller institutions, the cost outlay can be significant — particularly for those close to the $50 billion line. In a recent statement at Yale University, Federal Reserve governor Daniel Tarullo indicated that the organization would be moving to a more risk-sensitive, customized testing model.

Model Alterations

Tarullo’s statement indicates that banks that fit the aforementioned criteria (greater than $50 and fewer than $250 billion dollars in assets, limited international or nonbank business) would be exempt from the “qualitative” portion of the stress test, which deeply investigates the organization’s risk-management systems. However, all affected banks will have to demonstrate that they can survive a potential recession with adequate capital reserves to maintain lending operations, as well as additional scrutiny around mortgage and money-laundering rules.

Systemic Importance

The Fed is also reportedly considering a separate proposal that would raise the capital requirements for banks considered “systemically important.” In short, the modifications aim to create regulatory measures that are more stringent for financial organizations of greater importance, while relaxing non-essential requirements for smaller firms.

Single Invoice and Full-Contract Factoring from Capstone

For qualified clients, Capstone provides purchase order funding, single invoice factoring and full-contract factoring for work performed under contract with credit-worthy accounts. We have highly experienced professionals on staff to facilitate the purchase of work in progress and progress billing-related accounts receivable. Please visit our homepage or contact us directly for more information.