Regional banks in the United States nearing $100 billion in total consolidated assets should already be preparing for the Comprehensive Capital Analysis and Review (CCAR), rather than waiting for the regulatory clock to start ticking.
Crossing the $100 billion threshold places institutions under Category IV supervision, as per the Federal Reserve’s (Fed) enhanced prudential standards, triggering participation in supervisory stress testing and expanded capital planning requirements.
For many mid-sized banks, the transition from traditional risk management frameworks to the highly structured CCAR ecosystem—encompassing stress testing, capital planning, regulatory reporting and governance—is a multi-year transformation effort.