What is the Fed testing? — Since the 2007-2009 financial crisis, the central bank has used these simulations to gauge whether large lenders can survive a severe economic downturn. This year, 32 banks face a hypothetical scenario featuring a global recession and heightened stress in commercial and residential real estate. Lenders with significant trading operations face an additional gauntlet: a global market shock and the sudden default of their largest counterparty.
Why the pause in capital changes? — The industry has long pushed back against the process, labeling the Fed’s internal models as subjective and overly opaque. The tension escalated in 2024 when banks sued the central bank to force greater transparency. In response, the Fed has proposed allowing lenders to review and comment on the confidential models and scenarios used in the tests. Fed Vice Chair for Supervision Michelle Bowman noted that freezing capital requirements allows the agency to incorporate this feedback and correct existing deficiencies before resuming standard adjustments.

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