Comprehensive Capital Analysis and Review 2017 Assessment Framework and Results

CCAR_AssessmentFrameworkAndResults_201706.pdf

Reporting and Recordkeeping Requirements Associated with Regulation Y (Capital Plans)

Comprehensive Capital Analysis and Review 2017 Assessment Framework and Results

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Comprehensive Capital Analysis
and Review 2017:
Assessment Framework and Results
June 2017

BOARD

OF

GOVERNORS

OF THE

FEDERAL RESERVE SYSTEM

Comprehensive Capital Analysis
and Review 2017:
Assessment Framework and Results
June 2017

BOARD

OF

GOVERNORS

OF THE

FEDERAL RESERVE SYSTEM

This and other Federal Reserve Board reports and publications are available online at
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iii

Preface

The Federal Reserve promotes a safe, sound, and
stable banking and financial system that supports the
growth and stability of the U.S. economy through its
supervision of bank holding companies (BHCs),
U.S. intermediate holding companies (IHCs), savings
and loan holding companies, state member banks,
and nonbank financial institutions that the Financial
Stability Oversight Council has determined shall be
supervised by the Board of Governors of the Federal
Reserve System (Board).1
The Federal Reserve has established frameworks and
programs for the supervision of the largest financial
institutions to achieve its supervisory objectives,
incorporating the lessons learned from the financial
crisis and in the period since. As part of these supervisory frameworks and programs, the Federal
Reserve annually assesses whether financial firms
with $50 billion or more in total consolidated assets
are sufficiently capitalized to absorb losses during
stressful conditions, while meeting obligations to
creditors and counterparties and continuing to be
able to lend to households and businesses. The Federal Reserve’s expectations for capital planning practices are tailored to the size, scope of operations,
activities, and systemic importance of a particular
firm. In particular, the Federal Reserve has significantly heightened expectations for BHCs and IHCs
supervised by the Large Institution Supervision
Coordinating Committee (LISCC) firms and “large
and complex firms.”2
This annual assessment includes two related
programs:
• The Comprehensive Capital Analysis and Review
(CCAR) consists of a quantitative assessment for
1

2

Information on the Federal Reserve’s regulation and supervision function, including more detail on stress testing and capital
planning assessment, is available on the Federal Reserve’s website at www.federalreserve.gov/supervisionreg.htm.
“Large and complex firms” are BHCs or U.S. IHCs that
(1) have average total consolidated assets of $250 billion or
more, or (2) have average total nonbank assets of $75 billion or
more, and (3) are not LISCC firms.

all BHCs with $50 billion or more in total consolidated assets and a qualitative assessment for BHCs
that are LISCC or large and complex firms. The
quantitative assessment evaluates a firm’s capital
adequacy and planned capital distributions, such
as any dividend payments and common stock
repurchases. The Federal Reserve assesses whether
firms have sufficient capital to continue operating
and lending to creditworthy households and businesses throughout times of economic and financial
market stress, even after making all planned capital
distributions. CCAR also includes a qualitative
assessment of capital planning practices at the
largest and most complex firms. As part of the
qualitative assessment, the Federal Reserve evaluates the reliability of each firm’s analyses and
other processes for capital planning, focusing on
the areas that are most critical to sound capital
planning—namely, how a firm identifies, measures,
and determines capital needs for its material
risks—and a firm’s controls and governance
around those practices. The Federal Reserve
recently tailored its rules to remove “large and
noncomplex firms” from the qualitative assessment
process.3 At the conclusion of the process, the Federal Reserve either does not object or objects to a
firm’s capital plan. If the Federal Reserve objects
to a firm’s capital plan, the firm may only make
capital distributions that the Federal Reserve has
not objected to in writing.
• Dodd-Frank Act supervisory stress testing is a
forward-looking quantitative evaluation of the
impact of stressful economic and financial market
conditions on BHCs’ capital. The supervisory
stress test serves to inform the Federal Reserve,
BHCs, and the general public of how institutions’
capital ratios might change under a hypothetical
set of stressful economic conditions developed by
3

“Large and noncomplex firms” are BHCs or U.S. IHCs that
(1) have average total consolidated assets of $50 billion or
more, but less than $250 billion, (2) have average total nonbank
assets of less than $75 billion, and (3) are not U.S. global systemically important banks.

iv

4

CCAR 2017: Assessment Framework and Results

the Federal Reserve.4 The supervisory stress test
results, after incorporating firms’ planned capital

actions, are also used for the quantitative assessment in CCAR.

In addition to an annual supervisory stress test conducted by
the Federal Reserve, each participating institution is required to
conduct annual company-run stress tests under the same super-

visory scenarios and conduct a mid-cycle stress test under
company-developed scenarios.

v

Contents

Executive Summary

................................................................................................................ 1

Overview of Aggregate Results .................................................................................................... 3

Requirements in CCAR 2017

.............................................................................................. 7

Quantitative Assessment Framework and Summary of Results .............................. 9
Assessment Framework .............................................................................................................. 9
Summary of Quantitative Results ............................................................................................... 10

Qualitative Assessment Framework, Process, and Summary of
Results ........................................................................................................................................ 19
Overview of Qualitative Assessment Framework ......................................................................... 19
The Qualitative Assessment Process .......................................................................................... 19
Qualitative Assessment Results ................................................................................................. 21

Process and Requirements after CCAR 2017 ............................................................... 25
Execution of Capital Plan and Consequences of a Federal Reserve Objection to a Plan ................ 25
Resubmissions ......................................................................................................................... 25

Appendix A: Disclosure Tables

......................................................................................... 27

1

Executive Summary

Large financial institutions have more than doubled
their capital levels since the financial crisis, in part
because of supervisory programs like CCAR. (For
more information on recent trends in capital levels,
see box 1.) Capital is central to a firm’s ability to
absorb losses and continue operating and lending to
creditworthy businesses and consumers. The crisis
illustrated that confidence in the capitalization and
overall financial strength of a financial institution
can erode rapidly in the face of changes in current or
expected economic and financial conditions. More
importantly, the crisis revealed that sudden actual or
expected erosions of capital can lead to loss of investor and counterparty confidence in the financial
strength of a systemically important financial institution, which may not only imperil that institution’s
viability, but also harm the broader financial system.
For this reason, the Federal Reserve has made assessments of capital planning and post-stress analysis of
capital adequacy a cornerstone of its supervision of
the largest financial institutions.
The Federal Reserve’s annual CCAR exercise is an
intensive assessment of the capital adequacy and
capital planning practices of large U.S. financial
institutions. Prior to this year, all firms involved in
the assessment could receive an objection to their
capital plans based on either quantitative or qualitative grounds. As noted, the Board recently amended
its rules to remove large and noncomplex firms from
the qualitative assessment of CCAR effective for this
year’s exercise. Large and noncomplex firms are still
required to demonstrate an ability to meet their
minimum capital requirements under stress as part of
CCAR’s quantitative assessment and will continue
to be subject to regular supervisory assessments that
examine their capital planning practices.5 BHCs that
5

The large and noncomplex firms subject only to a quantitative
objection in CCAR 2017 are: Ally Financial Inc.; American
Express Company; BancWest Corporation; BB&T Corporation; BBVA Compass Bancshares, Inc.; BMO Financial Corp.;
CIT Group Inc.; Citizens Financial Group, Inc.; Comerica
Incorporated; Discover Financial Services; Fifth Third Bancorp; Huntington Bancshares Incorporated; KeyCorp; M&T

are LISCC or large and complex firms continue to
be subject to both the qualitative and quantitative
assessment process of CCAR.6
The quantitative assessment helps to ensure that
firms maintain sufficient capital to continue operations throughout times of economic and financial
market stress. The horizontal nature of the assessment offers insights into the condition of the U.S.
financial system, including whether firms are sufficiently resilient to continue to lend to households
and businesses under such adverse conditions. The
CCAR process can also act as a counterweight to
pressures that a firm may face to use capital distributions to signal financial strength, even when facing a
deteriorating or highly stressful environment.
The qualitative assessment seeks to ensure that firms
have strong practices for assessing their capital needs
that are supported by: effective firmwide identification, measurement, and management of their material risks; strong internal controls; and effective oversight by senior management and boards of directors.
By focusing on the key elements of capital planning,
the qualitative assessment helps promote better risk
management and greater resiliency at the firms. Each

6

Bank Corporation; MUFG Americas Holdings Corporation;
Northern Trust Corporation; Regions Financial Corporation;
Santander Holdings USA, Inc.; SunTrust Banks, Inc.; and
Zions Bancorporation.
The LISCC and large and complex firms participating in
CCAR 2017 are: Bank of America Corporation; The Bank of
New York Mellon Corporation; Capital One Financial Corporation; Citigroup Inc.; The Goldman Sachs Group, Inc.; HSBC
North America Holdings Inc.; JPMorgan Chase & Co.; Morgan Stanley; The PNC Financial Services Group, Inc.; State
Street Corporation; TD Group US Holdings LLC; U.S. Bancorp; and Wells Fargo & Company. Certain LISCC or large and
complex firms that recently formed U.S. IHCs did not participate in CCAR 2017. The firms, however, were required under
the capital plan rule to submit a capital plan to the Federal
Reserve that was subject to a confidential review process. These
firms are Barclays US LLC; Credit Suisse Holdings (USA),
Inc.; Deutsche Bank USA Corporation; RBC USA Holdco
Corporation; and UBS Americas Holdings LLC. Deutsche
Bank Trust Corporation is a subsidiary of a newly formed IHC,
which has participated in CCAR in previous years and will be
subject to the quantitative assessment in CCAR.

2

CCAR 2017: Assessment Framework and Results

Box 1. Overview of Trends in Capital Levels
Figure A provides the aggregate ratio of common
equity capital to risk-weighted assets for the firms in
CCAR from 2009 through the fourth quarter of
2016.1 This ratio has more than doubled from
5.5 percent in the first quarter of 2009 to 12.5 percent in the fourth quarter of 2016. That gain reflects
a total increase of more than $750 billion in common
equity capital from the beginning of 2009 among
these firms, bringing their total common equity capital to over $1.2 trillion in the fourth quarter of 2016.
The decline in the common equity ratio in the first
quarter of 2015 resulted from the incorporation of
risk-weighted assets calculated under the standardized approach under the capital rules that the Board
adopted in 2013, which had a one-time effect of
reducing all risk-based capital ratios. However, the
aggregate common equity capital ratio of the 34
firms increased by around 65 basis points between
the first quarter of 2015 and the fourth quarter of
2015. Previously, risk-weighted assets were calculated under a prior version of the capital rules.

Figure A. Aggregate common equity capital ratio of
CCAR 2017 Firms
14

12

10

8

6

The Federal Reserve’s evaluation of a firm’s common equity
capital was initially measured using a tier 1 common capital ratio
but now is evaluated using a common equity tier 1 capital ratio,
which was introduced into the regulatory capital framework with
the implementation of Basel III. From 2009 through 2013, tier 1
common was used to measure common equity capital for all
firms. In 2014, both tier 1 common capital (for non-advanced
approaches firms) and common equity tier 1 capital (for
advanced approaches firms) were used. From 2015 to present,
common equity tier 1 capital was used for all firms. Under both
measures, firms have significantly increased their capital position
since 2009. Not all of the 34 firms participating in CCAR 2017
reported data for all periods since 2009.

firm must support its capital planning decisions with
a forward-looking, comprehensive analysis that takes
into account the firm’s unique risk profile and activities as well as the effect of highly stressful operating
environments on its financial condition.

2016:Q1

2015:Q1

2014:Q1

2013:Q1

2012:Q1

2011:Q1

2010:Q1

4

Basel I risk-weighted assets
Basel III risk-weighted assets

2009:Q1

In the aggregate, the 34 firms participating in CCAR
2017 have estimated that their common equity will
remain near current levels between the third quarter
of 2017 and the second quarter of 2018, based on
their planned capital actions and net income projections under their baseline scenario.

1

Percent

Source: FR Y-9C.

These 34 firms hold more than 75 percent of the
total assets of all U.S. financial companies.2 The
financial crisis revealed that both the level and quality of capital contribute to a firm’s ability to continue
operating under adverse conditions. In part through
programs like CCAR, the quantity and quality of
capital held by these firms has improved, increasing
the resilience of the banking sector and strengthening the financial system more broadly.
2

To calculate total assets of U.S. financial companies, this figure
uses information from all firms that file the FR Y-9C, including
domestic BHCs, IHCs, savings and loan holding companies and
securities holding companies.

nance, and internal controls processes. Information
gathered through the qualitative assessment also
serves as an input into evaluations of a firm’s capital
adequacy and overall financial condition.
This report provides

The results of the qualitative assessment serve as
inputs into other aspects of the Federal Reserve’s
supervisory program for the largest U.S. financial
institutions and factor into supervisory assessments
of each firm’s risk management, corporate gover-

• background on the CCAR requirements;
• descriptions of the assessment framework and
summary of results for the quantitative
assessment;

June 2017

• newly enhanced descriptions of the assessment
framework, process, historical deficiencies, and
summary of results for the qualitative assessment; and,
• information about the process and requirements of
CCAR 2017, including the consequences for objections to a capital plan, the execution of planned
capital distributions, the process for resubmitting a
capital plan, and feedback provided by the Federal
Reserve on a firm’s capital plan.

Overview of Aggregate Results
Quantitative Assessment
In the supervisory post-stress capital assessment, the
Federal Reserve estimates that the aggregate common equity tier 1 ratio for the firms participating in
CCAR 2017 would decline in the severely adverse
scenario from 12.5 percent in the fourth quarter of
2016 (the starting point for the exercise) to 7.2 percent at its minimum point over the planning horizon.
This post-stress common equity tier 1 ratio is
1.7 percentage points higher than the firms’ aggregate common equity tier 1 ratio in the first quarter of
2009. (See table 1 and 2 for more on the aggregate
post-stress capital ratios for the firms that participated in CCAR 2017.)

3

Qualitative Assessment
The Federal Reserve observes that, on balance, most
of the 13 firms participating in the CCAR 2017
qualitative assessment have continued to strengthen
their capital planning practices since last year. However, these firms continue to have areas of weaknesses that fall short of meeting supervisory expectations for capital planning. The Federal Reserve has
allowed time for firms to work toward full achievement of our capital planning expectations and as
such, expects firms to continue to make steady progress. (For further information, see the Qualitative
Assessment Framework, Process, and Summary of
Results section.)

Capital Plan Decisions
The Federal Reserve did not object to any of the
capital plans or planned capital distributions for the
firms participating in CCAR 2017. The Board of
Governors issued a conditional non-objection to
Capital One Financial Corporation (Capital One)
and is requiring the firm to address weaknesses
observed in the firm’s capital planning practices and
to resubmit a capital plan by December 28, 2017.
The Board’s decision on each firm’s capital plan is
presented in table 3.

4

CCAR 2017: Assessment Framework and Results

Table 1. Projected minimum regulatory capital ratios under the severely adverse scenario, 2017:Q1 to 2019:Q1:
34 participating firms
Percent
Projected minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

Actual
2016:Q4

12.5
13.9
16.5
9.2
n/a

Original planned capital
actions

Adjusted planned capital
actions

7.2
8.7
11.3
5.7
4.4

7.2
8.7
11.3
5.7
4.4

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies in their annual capital plans and the
minimum ratios incorporating any adjustments to capital distributions made by a bank holding company after reviewing the Federal Reserve’s stress test. The minimum capital
ratios, other than for the supplementary leverage ratio, are for the period 2017:Q1 to 2019:Q1. The minimum supplementary leverage ratio is for the period 2018:Q1 to
2019:Q1. The minimum capital ratios do not necessarily occur in the same quarter. Supplementary leverage ratio projections only include estimates for firms subject to
advanced approaches.
n/a Not applicable.
Source: Federal Reserve estimates in the severely adverse scenario.

Table 2. Projected minimum regulatory capital ratios under the adverse scenario, 2017:Q1 to 2019:Q1:
34 participating firms
Percent
Projected minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

Actual
2016:Q4

12.5
13.9
16.5
9.2
n/a

Original planned capital
actions

Adjusted planned capital
actions

9.2
10.6
12.9
6.9
5.3

9.2
10.6
12.9
6.9
5.3

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies in their annual capital plans and the
minimum ratios incorporating any adjustments to capital distributions made by a bank holding company after reviewing the Federal Reserve’s stress test. The minimum capital
ratios, other than for the supplementary leverage ratio, are for the period 2017:Q1 to 2019:Q1. The minimum supplementary leverage ratio is for the period 2018:Q1 to
2019:Q1. The minimum capital ratios do not necessarily occur in the same quarter. Supplementary leverage ratio projections only include estimates for firms subject to
advanced approaches.
n/a Not applicable.
Source: Federal Reserve estimates in the adverse scenario.

June 2017

Table 3. Summary of the Federal Reserve’s actions on capital plans in CCAR 2017
Non-objection to capital plan
Ally Financial Inc.
American Express Company
BancWest Corporation
Bank of America Corporation
The Bank of New York Mellon Corporation
BB&T Corporation
BBVA Compass Bancshares, Inc.
BMO Financial Corp.
CIT Group Inc.
Citigroup Inc.
Citizens Financial Group, Inc.
Comerica Incorporated
Deutsche Bank Trust Corporation
Discover Financial Services
Fifth Third Bancorp
The Goldman Sachs Group, Inc.
HSBC North America Holdings Inc.
Huntington Bancshares Incorporated
JPMorgan Chase & Co.
KeyCorp
M&T Bank Corporation
Morgan Stanley
MUFG Americas Holdings Corporation
Northern Trust Corporation
The PNC Financial Services Group, Inc.
Regions Financial Corporation
Santander Holdings USA, Inc.
State Street Corporation
SunTrust Banks, Inc.
TD Group US Holdings LLC
U.S. Bancorp
Wells Fargo & Company
Zions Bancorporation

Conditional non-objection to capital plan
Capital One Financial Corporation

Objection to capital plan

5

7

Requirements in CCAR 2017

In November 2011, the Board adopted a capital plan
rule requiring firms with consolidated assets of
$50 billion or more to submit annual capital plans to
the Federal Reserve for review.7 Earlier this year, the
Federal Reserve amended the capital plan rule to
remove large and noncomplex firms from the qualitative assessment of CCAR. For the CCAR 2017
exercise, the Federal Reserve issued instructions on
February 3, 2017,8 and received capital plans from
participating firms on April 5, 2017.
Under the capital plan rule, each firm must include
in its annual capital plan an assessment of the
expected uses and sources of capital over the planning horizon under expected and stressful conditions, a detailed description of the firm’s processes
for assessing capital adequacy, the firm’s capital
policy, and a discussion of any expected changes to
7

8

See 12 CFR 225.8. Asset size is measured over the previous four
calendar quarters as reported on the FR Y-9C regulatory
report. If a firm has not filed the FR Y-9C for each of the four
most recent consecutive quarters, average total consolidated
assets means the average of the company’s total consolidated
assets, as reported on the company’s FR Y-9C, for the most
recent quarter or consecutive quarters.
See Board of Governors of the Federal Reserve System, Comprehensive Capital Analysis and Review 2017 Summary Instructions for LISCC and Large and Complex Firms (Washington:
Board of Governors, February 2017), www.federalreserve.gov/
newsevents/pressreleases/files/bcreg20170203a4.pdf.

the firm’s business plan that are likely to have a
material impact on the firm’s capital adequacy or
liquidity.9
As noted, the Board adopted a revised regulatory
capital framework in 2013 to address shortcomings
in capital requirements that became apparent during
the financial crisis.10 The revisions are being phased
in from 2014 until 2018 and, generally, a firm must
meet the regulatory capital requirements for each
projected quarter of the planning horizon in CCAR
in accordance with the capital requirements that will
be in effect during that quarter.11 The bulk of the
revised regulatory capital framework, including the
supplementary leverage ratio for advanced
approaches firms, becomes fully phased-in in the
middle of the CCAR 2017 projection horizon (the
first quarter of 2018).12
9
10
11

12

See 12 CFR 225.8(e)(2).
See 78 FR 62018 (October 11, 2013); 12 CFR part 217.
Firms did not use the advanced approaches to calculate riskweighted assets in CCAR 2017. See 12 CFR 225.8(d)(10).
For purposes of CCAR 2017, an advanced approaches BHC
includes any BHC that has consolidated assets greater than or
equal to $250 billion or total consolidated on-balance sheet foreign exposure of at least $10 billion as of December 31, 2016.
See 12 CFR 217.100(b)(1). Other BHCs include any BHC that
is subject to 12 CFR 225.8 and is not an advanced
approaches BHC.

9

Quantitative Assessment Framework and
Summary of Results

Assessment Framework
In the quantitative assessment, the Federal Reserve
evaluated each firm’s ability to maintain post-stress
capital ratios above the applicable minimum regulatory capital ratios in effect during each quarter of
the planning horizon under both expected and stressful conditions, after taking the capital actions
described in the BHC baseline scenario of its capital
plan.13 The CCAR quantitative assessment is based
both on: (a) the results of the firm’s internal stress
tests and (b) post-stress capital ratios estimated by
the Federal Reserve under the supervisory scenarios
(CCAR supervisory post-stress capital analysis). The
Federal Reserve may object to the capital plan of any
firm that has not demonstrated an ability to maintain capital above each minimum regulatory capital
ratio throughout the planning horizon in the poststress capital analysis.
The CCAR supervisory post-stress capital analysis is
based on estimates of net income, total assets, and
risk-weighted assets from the Federal Reserve’s
supervisory stress test conducted under the DoddFrank Wall Street Reform and Consumer Protection
Act of 2010 (Dodd-Frank Act).14 (For a comparison
of the Dodd-Frank Act stress tests and CCAR, see
box 2.) As described in the overview of the methodology of the Dodd-Frank Act supervisory stress tests
published on June 22, 2017, for these projections, the
Federal Reserve uses data provided by all firms in the
CCAR quantitative assessment and a set of models
developed or selected by the Federal Reserve.15
13

14

15

In CCAR 2017, firms subject to the advanced approaches riskweighted assets calculations were required for the first time to
meet the minimum supplementary leverage ratio requirement of
3 percent as part of the quantitative assessment.
For more on the methodology of the Federal Reserve’s supervisory stress test, see Board of Governors of the Federal Reserve
System, Dodd-Frank Act Stress Test 2017: Supervisory Stress
Test Methodology and Results (Washington: Board of Governors, June 2017), www.federalreserve.gov/newsevents/
pressreleases/bcreg20170622a.htm.
For CCAR 2017, in addition to the models developed and data
collected by the Federal Reserve, the Federal Reserve used pro-

The supervisory projections are conducted under
three hypothetical macroeconomic and financial
market scenarios developed by the Federal Reserve:
the baseline, adverse, and severely adverse supervisory stress scenarios.16 While the same supervisory
scenarios applied to all firms, a subset of firms was
also subject to additional components in the severely
adverse and adverse scenarios: the global market
shock and counterparty default scenario components.17 Firms were required to conduct stress tests
using the same supervisory scenarios, at least one
stress scenario developed by the firm (the BHC stress
scenario), and a baseline scenario developed by the
firm (BHC baseline scenario).18
As noted, the Federal Reserve incorporates a firm’s
planned capital actions under its baseline scenario,
including any capital actions associated with business

16

17

18

prietary models and data licensed from certain third-party providers. These providers are identified in appendix B, “Models to
Project Net Income and Stressed Capital” of Board of Governors of the Federal Reserve System, Dodd-Frank Act Stress Test
2017: Supervisory Stress Test Methodology and Results (Washington: Board of Governors, June 2017), www.federalreserve
.gov/newsevents/pressreleases/bcreg20170622a.htm, (see
page 61, footnote 43).
Firms use these scenarios in conducting their company-run
stress tests pursuant to the Board’s rules implementing section 165(i)(2) of the Dodd-Frank Act (Dodd-Frank Act stress
test rules). See 12 USC 5365(i)(2); 12 CFR part 252, subpart F.
The six BHCs that were subject to the global market shock are
Bank of America Corporation; Citigroup Inc.; The Goldman
Sachs Group, Inc.; JPMorgan Chase & Co.; Morgan Stanley;
and Wells Fargo & Company. See 12 CFR 252.54(b)(2). The
eight BHCs that were subject to the counterparty default component are Bank of America Corporation; The Bank of New
York Mellon Corporation; Citigroup Inc.; The Goldman Sachs
Group, Inc.; JPMorgan Chase & Co.; Morgan Stanley; State
Street Corporation; and Wells Fargo & Company. See 12 CFR
252.54(b)(2). See Board of Governors of the Federal Reserve
System, 2017 Supervisory Scenarios for Annual Stress Tests
Required under the Dodd-Frank Act Stress Testing Rules and the
Capital Plan Rule (Washington: Board of Governors, February 3, 2017), www.federalreserve.gov/newsevents/pressreleases/
files/bcreg20170203a5.pdf.
The Federal Reserve expects a firm that uses the supervisory
baseline scenario as its BHC baseline scenario to explain why
the supervisory baseline scenario is an appropriate representation of the firm’s view of the most likely outlook for the risk
factors salient to the firm.

10

CCAR 2017: Assessment Framework and Results

Box 2. Differences between the Dodd-Frank Act Supervisory Stress Tests
and the CCAR Post-stress Capital Analysis
While the Dodd-Frank Act supervisory stress tests
and the CCAR supervisory post-stress capital analysis incorporate the same projections of net income,
total assets, and risk-weighted assets, the two processes use different capital action assumptions to
project post-stress capital levels and ratios.
Capital Action Assumptions for the Dodd-Frank
Act Supervisory Stress Tests
To project post-stress capital ratios for the DoddFrank Act supervisory stress tests, the Federal
Reserve uses a standardized set of capital action
assumptions that are specified in the Dodd-Frank
Act stress test rules.1 Generally:
• Common stock dividend payments are assumed
to continue at the same level as the previous
year.
• Scheduled dividend, interest, or principal payments on any other capital instrument eligible for
inclusion in the numerator of a regulatory capital
ratio are assumed to be paid.
• Repurchases of such capital instruments are
assumed to be zero.
1

To make the results of its supervisory stress test comparable to
the company-run stress tests, the Federal Reserve uses the
same capital action assumptions as those required for the
company-run stress tests, as outlined in the Dodd-Frank Act
stress test rules. See 12 CFR 252.56(b).

plan changes, in projecting the firm’s post-stress
capital ratios. Thus, the firms are assumed to maintain the level of dividends, share repurchases, and
other capital distributions they in fact plan to
execute over the planning horizon despite the hypothetical severe deterioration in the economic and
financial environment. In an actual downturn, firms
may reduce capital distributions under stressful conditions. However, the goal of the CCAR post-stress
capital analysis is to provide a rigorous test of a
firm’s financial condition even if the economy deteriorated and the firm continued to make its planned
capital distributions—as many companies continued
to do well into the financial crisis.
The Federal Reserve provides each firm with a onetime opportunity to adjust its planned capital distributions after the firm receives the Federal Reserve’s
preliminary estimates of the firm’s post-stress capital
ratios. To undertake this adjustment, the Federal

The capital action assumptions do not include issuances of new common stock or preferred stock,
except for common stock issuance associated with
expensed employee compensation or in connection
with a planned merger or acquisition.2 The projection of post-stress capital ratios includes capital
actions and other changes in the balance sheet
associated with any business plan changes under a
given scenario.
Capital Actions for CCAR
For the CCAR post-stress capital analysis, the Federal Reserve uses a firm’s planned capital actions
under its BHC baseline scenario, including both proposed capital issuances and proposed capital distributions, and incorporates related business plan
changes.
As a result, post-stress capital ratios projected for
the Dodd-Frank Act supervisory stress tests can differ significantly from those for the CCAR post-stress
capital analysis. For example, if a firm increases its
dividend, or repurchases of common equity in its
planned capital actions, the firm’s post-stress capital
ratios projected for the CCAR capital analysis could
be lower than those projected for the Dodd-Frank
Act supervisory stress tests.

2

See 12 CFR 252.56(b).

Reserve considered only reductions in capital distributions, including decreasing planned common stock
dividends and/or reducing planned repurchases or
redemptions of other regulatory capital instruments,
relative to those initially submitted by a firm in its
April 2017 capital plan. These adjusted capital
actions, where applicable, were then incorporated
into the Federal Reserve’s projections to calculate
adjusted post-stress capital levels and ratios. The
Federal Reserve discloses post-stress results with a
firm’s original capital actions and any adjusted capital actions.

Summary of Quantitative Results
The Federal Reserve did not object to any firms’
planned capital distributions on quantitative
grounds.

June 2017

Results of Quantitative Assessment
As noted above, no firm was objected to on quantitative grounds in CCAR 2017. Table 4 and 5 contain
minimum post-stress common equity tier 1 ratios for
each of the firms under the supervisory severely
adverse and adverse scenarios. The middle column of
the table incorporates the original planned capital
distributions included in the capital plans submitted
by the firms in April 2017. The ratios reported in the
right-hand column incorporate any adjusted capital
distributions submitted by a firm after receiving the
Federal Reserve’s preliminary CCAR post-stress
capital analysis.
Table 6.A and 6.B report minimum capital ratios
under the supervisory severely adverse scenario
based on both the original and adjusted planned
capital actions, where applicable. The ratios based on
adjusted capital actions are only reported for those
firms that submitted adjusted capital actions. The
results in table 6.A are for firms subject to the
advanced approaches, and the results in 6.B are for
firms that are not subject to the advanced
approaches.

11

In the supervisory severely adverse scenario, American Express Company was projected to have at least
one minimum post-stress capital ratio lower than
minimum required regulatory capital ratios based on
its original planned capital actions. American
Express Company fell below the minimum required
total capital ratio post-stress. (See the applicable
minimum capital ratios for advanced approaches
firms provided in table 6.A and the applicable minimum capital ratios for other firms provided in
table 6.B.) However, American Express was able to
maintain its post-stress regulatory capital ratios
above minimum requirements in the severely adverse
scenario after submitting adjusted capital actions.
Table 7.A and 7.B report minimum capital ratios in
the supervisory adverse scenario based on both the
original and adjusted planned capital actions, where
applicable. The minimum capital ratios were generally higher in the supervisory adverse scenario than
in the supervisory severely adverse scenario.

12

CCAR 2017: Assessment Framework and Results

Table 4. Projected minimum common equity tier 1 ratio in the severely adverse scenario, 2017:Q1 to 2019:Q1
Bank holding company
Ally Financial Inc.
American Express Company
BancWest Corporation
Bank of America Corporation
The Bank of New York Mellon Corporation
BB&T Corporation
BBVA Compass Bancshares, Inc.
BMO Financial Corp.
Capital One Financial Corporation
CIT Group Inc.
Citigroup Inc.
Citizens Financial Group, Inc.
Comerica Incorporated
Deutsche Bank Trust Corporation
Discover Financial Services
Fifth Third Bancorp
The Goldman Sachs Group, Inc.
HSBC North America Holdings Inc.
Huntington Bancshares Incorporated
JPMorgan Chase & Co.
KeyCorp
M&T Bank Corporation
Morgan Stanley
MUFG Americas Holdings Corporation
Northern Trust Corporation
The PNC Financial Services Group, Inc.
Regions Financial Corporation
Santander Holdings USA, Inc.
State Street Corporation
SunTrust Banks, Inc.
TD Group US Holdings LLC
U.S. Bancorp
Wells Fargo & Company
Zions Bancorporation

Stressed ratio with original
planned capital actions
5.2
5.0
6.1
6.8
9.1
6.3
7.4
8.0
5.6
5.4
8.0
6.5
7.5
58.0
6.9
6.3
6.0
8.9
6.0
6.9
5.5
6.2
7.9
11.5
9.1
6.3
6.0
12.8
6.0
5.4
11.3
6.3
7.4
6.6

Stressed ratio with adjusted
planned capital actions

5.3

5.9

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies in their annual capital plans and the
minimum ratios incorporating any adjustments to capital distributions made by a bank holding company after reviewing the Federal Reserve’s stress test. The minimum capital
ratios are for the period 2017:Q1 to 2019:Q1 and do not necessarily occur in the same quarter.
Source: Federal Reserve estimates in the severely adverse scenario.

June 2017

13

Table 5. Projected minimum common equity tier 1 ratio in the adverse scenario, 2017:Q1 to 2019:Q1
Bank holding company
Ally Financial Inc.
American Express Company
BancWest Corporation
Bank of America Corporation
The Bank of New York Mellon Corporation
BB&T Corporation
BBVA Compass Bancshares, Inc.
BMO Financial Corp.
Capital One Financial Corporation
CIT Group Inc.
Citigroup Inc.
Citizens Financial Group, Inc.
Comerica Incorporated
Deutsche Bank Trust Corporation
Discover Financial Services
Fifth Third Bancorp
The Goldman Sachs Group, Inc.
HSBC North America Holdings Inc.
Huntington Bancshares Incorporated
JPMorgan Chase & Co.
KeyCorp
M&T Bank Corporation
Morgan Stanley
MUFG Americas Holdings Corporation
Northern Trust Corporation
The PNC Financial Services Group, Inc.
Regions Financial Corporation
Santander Holdings USA, Inc.
State Street Corporation
SunTrust Banks, Inc.
TD Group US Holdings LLC
U.S. Bancorp
Wells Fargo & Company
Zions Bancorporation

Stressed ratio with original
planned capital actions
7.4
7.5
8.9
9.0
9.5
7.9
9.9
10.4
7.8
8.1
10.1
8.6
8.8
58.5
9.1
8.2
8.3
9.5
7.6
8.7
7.3
8.0
11.3
13.4
9.9
7.5
7.9
14.3
7.3
7.0
13.2
7.7
9.1
9.2

Stressed ratio with adjusted
planned capital actions

7.8

8.1

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies in their annual capital plans and the
minimum ratios incorporating any adjustments to capital distributions made by a bank holding company after reviewing the Federal Reserve’s stress test. The minimum capital
ratios are for the period 2017:Q1 to 2019:Q1 and do not necessarily occur in the same quarter.
Source: Federal Reserve estimates in the adverse scenario.

14

CCAR 2017: Assessment Framework and Results

Table 6.A. Projected minimum regulatory capital ratios in the severely adverse scenario, 2017:Q1 to 2019:Q1: Advanced
approaches firms

Bank holding company

American Express Company
Bank of America Corporation
The Bank of New York Mellon
Corporation
Capital One Financial Corporation
Citigroup Inc.
The Goldman Sachs Group, Inc.
HSBC North America Holdings Inc.
JPMorgan Chase & Co.
Morgan Stanley
Northern Trust Corporation
The PNC Financial Services
Group, Inc.
State Street Corporation
TD Group US Holdings LLC
U.S. Bancorp
Wells Fargo & Company

Capital
actions

Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted

Common equity tier 1
capital ratio (%)

Tier 1
capital ratio (%)

Total capital
ratio (%)

Tier 1 leverage ratio (%)

Supplementary leverage
ratio (%)

Actual
2016:Q4

Projected
minimum

Actual
2016:Q4

Projected
minimum

Actual
2016:Q4

Projected
minimum

Actual
2016:Q4

Projected
minimum

Actual
2016:Q4

Projected
minimum

12.3
12.3
12.1

5.0
5.3
6.8

13.5
13.5
13.6

6.1
6.4
8.4

15.2
15.2
16.3

7.8
8.1
11.0

11.6
11.6
8.9

5.3
5.5
5.4

4.5
4.8
4.3

12.3

9.1

14.5

11.6

15.2

12.6

6.6

5.2

10.1
10.1
14.9

5.6
5.9
8.0

11.6
11.6
15.8

7.1
7.4
9.5

14.3
14.3
19.1

9.9
10.1
12.8

9.9
9.9
10.1

6.2
6.4
6.1

14.5

6.0

16.6

8.2

19.8

10.9

9.4

4.5

17.9

8.9

20.1

11.6

25.3

15.2

9.6

5.2

12.5

6.9

14.2

8.4

16.4

10.8

8.4

5.0

17.8

7.9

20.0

10.3

23.2

13.4

8.4

4.2

11.8

9.1

12.9

10.2

14.5

12.3

8.0

6.2

10.6

6.3

12.0

7.6

14.3

9.6

10.1

6.4

11.6

6.0

14.7

9.1

16.0

10.2

6.5

4.0*

13.6

11.3

13.7

11.3

14.8

12.6

7.8

6.4

9.4

6.3

11.0

7.9

13.2

10.2

9.0

6.5

11.1

7.4

12.8

9.0

16.1

12.1

8.9

6.3

n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a

4.8
5.4
5.6
4.5
3.1
4.0
3.9
3.2
5.3
5.4
3.6
5.8
5.2
5.3

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies in their annual capital plans and the
minimum ratios incorporating any adjustments to capital distributions made by a bank holding company after reviewing the Federal Reserve’s stress test. The minimum capital
ratios, other than for the supplementary leverage ratio, are for the period 2017:Q1 to 2019:Q1. The minimum supplementary leverage ratio is for the period 2018:Q1 to
2019:Q1. The minimum capital ratios do not necessarily occur in the same quarter.
* Actual value above 4.0 percent minimum, presented as 4.0 percent because of rounding.
n/a Not applicable.
Source: Federal Reserve estimates in the severely adverse scenario.

Required minimum capital ratios in CCAR 2017 for advanced approaches firms (Percent)
Regulatory ratio
Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

Minimum
4.5
6.0
8.0
4.0
3.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board’s revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed. Bank holding companies
subject to the advanced approaches are required to maintain a supplementary leverage ratio above 3 percent for quarters corresponding to 2018:Q1 to 2019:Q1. See 12 CFR
225.8(c)(3) and 12 CFR 225.8(d)(8).

June 2017

15

Table 6.B. Projected minimum regulatory capital ratios in the severely adverse scenario, 2017:Q1 to 2019:Q1: Other firms

Bank holding company

Ally Financial Inc.
BancWest Corporation
BB&T Corporation
BBVA Compass Bancshares, Inc.
BMO Financial Corp.
CIT Group Inc.
Citizens Financial Group, Inc.
Comerica Incorporated
Deutsche Bank Trust Corporation
Discover Financial Services
Fifth Third Bancorp
Huntington Bancshares Incorporated
KeyCorp
M&T Bank Corporation
MUFG Americas Holdings Corporation
Regions Financial Corporation
Santander Holdings USA, Inc.
SunTrust Banks, Inc.
Zions Bancorporation

Capital
actions

Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted

Common equity tier 1
capital ratio (%)

Tier 1
capital ratio (%)

Total capital
ratio (%)

Tier 1 leverage ratio (%)

Actual
2016:Q4

Projected
minimum

Actual
2016:Q4

Projected
minimum

Actual
2016:Q4

Projected
minimum

Actual
2016:Q4

Projected
minimum

9.4

5.2

10.9

6.9

12.6

8.8

9.5

5.9

13.1

6.1

13.4

6.6

15.3

8.7

11.1

5.5

10.2

6.3

12.0

7.9

14.1

11.0

10.0

6.6

11.5

7.4

11.9

7.7

14.3

10.1

9.5

6.1

12.5

8.0

12.8

8.7

15.7

11.7

9.5

6.4

14.0

5.4

14.0

6.8

14.8

8.1

13.9

5.6

11.2

6.5

11.4

6.9

14.0

9.5

9.9

6.0

11.1

7.5

11.1

7.5

13.3

9.5

10.2

6.7

64.4

58.0

64.4

58.0

64.7

59.0

14.6

13.0

13.2

6.9

13.9

7.5

15.5

9.3

12.3

6.6

10.4

6.3

11.5

7.2

15.0

10.3

9.9

6.2

9.6

6.0

10.9

7.3

13.1

9.7

8.7

5.8

9.5

5.5

10.9

6.5

12.9

8.7

9.9

5.9

10.7

6.2

11.9

7.3

14.1

9.8

10.0

6.1

14.8

11.5

14.8

11.5

16.4

12.6

9.9

7.6

11.2

6.0

12.0

7.4

14.2

9.5

10.2

6.3

14.5

12.8

16.1

13.7

18.0

15.2

12.5

10.6

9.6

5.4

10.3

6.8

12.3

9.2

9.2

6.1

12.1

6.6

13.5

7.7

15.2

9.8

11.1

6.3

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies in their annual capital plans and the
minimum ratios incorporating any adjustments to capital distributions made by a bank holding company after reviewing the Federal Reserve’s stress test. The minimum capital
ratios, other than for the supplementary leverage ratio, are for the period 2017:Q1 to 2019:Q1. The minimum supplementary leverage ratio is for the period 2018:Q1 to
2019:Q1. The minimum capital ratios do not necessarily occur in the same quarter.
Source: Federal Reserve estimates in the severely adverse scenario.

Required minimum capital ratios in CCAR 2017 for other firms (Percent)
Regulatory ratio
Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio

Minimum
4.5
6.0
8.0
4.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board’s revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.

16

CCAR 2017: Assessment Framework and Results

Table 7.A. Projected minimum regulatory capital ratios in the adverse scenario, 2017:Q1 to 2019:Q1: Advanced approaches
firms

Bank holding company

American Express Company
Bank of America Corporation
The Bank of New York Mellon
Corporation
Capital One Financial Corporation
Citigroup Inc.
The Goldman Sachs Group, Inc.
HSBC North America Holdings Inc.
JPMorgan Chase & Co.
Morgan Stanley
Northern Trust Corporation
The PNC Financial Services
Group, Inc.
State Street Corporation
TD Group US Holdings LLC
U.S. Bancorp
Wells Fargo & Company

Capital
actions

Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted

Common equity tier 1
capital ratio (%)

Tier 1
capital ratio (%)

Total capital
ratio (%)

Tier 1 leverage ratio (%)

Supplementary leverage
ratio (%)

Actual
2016:Q4

Projected
minimum

Actual
2016:Q4

Projected
minimum

Actual
2016:Q4

Projected
minimum

Actual
2016:Q4

Projected
minimum

Actual
2016:Q4

Projected
minimum

12.3
12.3
12.1

7.5
7.8
9.0

13.5
13.5
13.6

8.6
8.9
10.6

15.2
15.2
16.3

10.3
10.6
12.7

11.6
11.6
8.9

7.3
7.6
6.9

6.3
6.5
5.4

12.3

9.5

14.5

12.0

15.2

12.9

6.6

5.3

10.1
10.1
14.9

7.8
8.1
10.1

11.6
11.6
15.8

9.2
9.5
11.5

14.3
14.3
19.1

11.6
11.9
14.4

9.9
9.9
10.1

7.9
8.1
7.3

14.5

8.3

16.6

10.4

19.8

12.9

9.4

5.7

17.9

9.5

20.1

12.1

25.3

15.2

9.6

5.5

12.5

8.7

14.2

10.2

16.4

12.2

8.4

5.9

17.8

11.3

20.0

13.6

23.2

16.2

8.4

5.5

11.8

9.9

12.9

11.0

14.5

12.8

8.0

6.6

10.6

7.5

12.0

8.8

14.3

10.4

10.1

7.4

11.6

7.3

14.7

10.4

16.0

11.3

6.5

4.5

13.6

13.2

13.7

13.2

14.8

14.2

7.8

7.4

9.4

7.7

11.0

9.3

13.2

11.3

9.0

7.6

11.1

9.1

12.8

10.7

16.1

13.4

8.9

7.3

n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a

4.9
6.8
7.0
5.5
3.9
4.2
4.6
4.2
5.6
6.2
4.1
6.8
6.1
6.3

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies in their annual capital plans and the
minimum ratios incorporating any adjustments to capital distributions made by a bank holding company after reviewing the Federal Reserve’s stress test. The minimum capital
ratios, other than for the supplementary leverage ratio, are for the period 2017:Q1 to 2019:Q1. The minimum supplementary leverage ratio is for the period 2018:Q1 to
2019:Q1. The minimum capital ratios do not necessarily occur in the same quarter.
n/a Not applicable.
Source: Federal Reserve estimates in the adverse scenario.

Required minimum capital ratios in CCAR 2017 for advanced approaches firms (Percent)
Regulatory ratio
Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

Minimum
4.5
6.0
8.0
4.0
3.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board’s revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed. Bank holding companies
subject to the advanced approaches are required to maintain a supplementary leverage ratio above 3 percent for quarters corresponding to 2018:Q1 to 2019:Q1. See 12 CFR
225.8(c)(3) and 12 CFR 225.8(d)(8).

June 2017

17

Table 7.B. Projected minimum regulatory capital ratios in the adverse scenario, 2017:Q1 to 2019:Q1: Other firms

Bank holding company

Ally Financial Inc.
BancWest Corporation
BB&T Corporation
BBVA Compass Bancshares, Inc.
BMO Financial Corp.
CIT Group Inc.
Citizens Financial Group, Inc.
Comerica Incorporated
Deutsche Bank Trust Corporation
Discover Financial Services
Fifth Third Bancorp
Huntington Bancshares Incorporated
KeyCorp
M&T Bank Corporation
MUFG Americas Holdings Corporation
Regions Financial Corporation
Santander Holdings USA, Inc.
SunTrust Banks, Inc.
Zions Bancorporation

Capital
actions

Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted
Original
Adjusted

Common equity tier 1
capital ratio (%)

Tier 1
capital ratio (%)

Total capital
ratio (%)

Tier 1 leverage ratio (%)

Actual
2016:Q4

Projected
minimum

Actual
2016:Q4

Projected
minimum

Actual
2016:Q4

Projected
minimum

Actual
2016:Q4

Projected
minimum

9.4

7.4

10.9

8.9

12.6

10.9

9.5

7.7

13.1

8.9

13.4

9.4

15.3

11.5

11.1

7.7

10.2

7.9

12.0

9.5

14.1

12.1

10.0

7.8

11.5

9.9

11.9

10.2

14.3

12.3

9.5

7.9

12.5

10.4

12.8

11.0

15.7

13.6

9.5

8.0

14.0

8.1

14.0

9.5

14.8

10.8

13.9

7.8

11.2

8.6

11.4

9.0

14.0

11.4

9.9

7.7

11.1

8.8

11.1

8.8

13.3

10.5

10.2

7.9

64.4

58.5

64.4

58.5

64.7

59.2

14.6

12.9

13.2

9.1

13.9

9.7

15.5

11.2

12.3

8.5

10.4

8.2

11.5

9.1

15.0

11.7

9.9

7.7

9.6

7.6

10.9

8.9

13.1

11.0

8.7

6.9

9.5

7.3

10.9

8.4

12.9

10.2

9.9

7.5

10.7

8.0

11.9

9.1

14.1

11.2

10.0

7.4

14.8

13.4

14.8

13.4

16.4

14.1

9.9

8.8

11.2

7.9

12.0

9.4

14.2

11.2

10.2

7.8

14.5

14.3

16.1

15.9

18.0

17.7

12.5

12.2

9.6

7.0

10.3

8.4

12.3

10.4

9.2

7.4

12.1

9.2

13.5

10.2

15.2

12.0

11.1

8.2

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies in their annual capital plans and the
minimum ratios incorporating any adjustments to capital distributions made by a bank holding company after reviewing the Federal Reserve’s stress test. The minimum capital
ratios, other than for the supplementary leverage ratio, are for the period 2017:Q1 to 2019:Q1. The minimum supplementary leverage ratio is for the period 2018:Q1 to
2019:Q1. The minimum capital ratios do not necessarily occur in the same quarter.
Source: Federal Reserve estimates in the adverse scenario.

Required minimum capital ratios in CCAR 2017 for other firms (Percent)
Regulatory ratio
Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio

Minimum
4.5
6.0
8.0
4.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board’s revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.

19

Qualitative Assessment Framework, Process,
and Summary of Results

Overview of Qualitative Assessment
Framework
In addition to the quantitative assessment of each
firm’s capital adequacy discussed above, the Federal
Reserve conducted a full review of the capital plans
submitted by the LISCC and large and complex
firms to assess the strength of each firm’s capital
planning practices.
In the qualitative assessment, supervisors focus on
the firms’ analyses and practices used to determine
the amount and composition of capital needed to
continue to lend to households and businesses
throughout a period of severe stress. In doing so, the
Federal Reserve evaluates the comprehensiveness and
reasonableness of a firm’s capital plan; the reasonableness of the assumptions and analysis underlying
the plan, including the extent to which it captures
and addresses potential risks stemming from firmwide activities; and the robustness of the firm’s capital planning process.19 Where applicable, the assessment leverages existing supervisory information
about each firm, such as supervisory findings and
information from examinations conducted throughout the year.
Effective capital planning appropriately accounts for
firmwide risks and is subject to effective oversight.
The Federal Reserve’s qualitative assessment of capital plans focuses on the extent to which each firm’s
analyses supporting its capital plan appropriately
captures the specific risks and vulnerabilities faced
by the firm under stress. Specifically, the Federal
Reserve evaluates how each firm identifies, measures,
and determines capital needs for its material risks
under both expected and stressful conditions and
whether the analyses and practices used provide a
reasonable basis for its board of directors to make
sound capital planning decisions.

Guidance published in December 2015 provides
supervisory expectations for capital planning for
firms that are subject to the CCAR qualitative
assessment.20 The letter explains that the Federal
Reserve’s expectations for capital planning processes
are tailored based on the size, scope of operations,
activities, and systemic importance of the firm. In
particular, the Federal Reserve has significantly
heightened expectations for LISCC firms and
expects them to have the most sophisticated, comprehensive, and robust capital planning processes.

The Qualitative Assessment Process
For LISCC and large and complex firms, the qualitative assessment of the annual CCAR exercise is the
culmination of three supervisory activities that
evaluate whether firms have sound practices and
analyses for determining their capital needs on a
forward-looking basis:
1. assessment of the underlying analyses and support for firms’ annual capital plan submissions,
2. monitoring of firms’ remediation of outstanding
supervisory findings related to capital planning, and
3. execution of targeted horizontal exams pertaining to capital planning throughout the year.21
As explained in more detail below, these three evaluations are conducted at different times throughout a
given year and together allow the Federal Reserve to
gain a comprehensive view into six areas critical to
sound capital planning: (1) governance, (2) risk management, (3) internal controls, (4) capital policies,
(5) scenario design, and (6) projection methodolo20

21

19

12 CFR 225.8(f)(1).

See SR letter 15-18, “Federal Reserve Assessment of Capital
Planning and Positions for LISCC Firms and Large and Complex Firms,” December 18, 2015, www.federalreserve.gov/
supervisionreg/srletters/sr1518.htm.
Horizontal examinations are assessments of a common area or
practice (such as internal audit) across multiple firms by a coordinated team of examiners.

20

CCAR 2017: Assessment Framework and Results

gies.22 See box 3 for explanations of these areas and
examples of past deficiencies.

Assessment of Capital Plan Submissions
In April of each year as a part of the CCAR exercise, firms submit to the Federal Reserve capital
plans that include detailed descriptions of the firms’
capital planning practices and underlying analyses,
including descriptions of their internal processes for
assessing capital adequacy and their policies governing capital actions. Those plans are then assessed by
subject matter experts from across the Federal
Reserve System over a three-month period. The
assessment is also informed by related supervisory
work conducted throughout the year.
Two groups of supervisors—dedicated supervisory
teams (DSTs) and horizontal evaluation teams
(HETs)—conduct an initial assessment of each
firm’s capital plan submission. DSTs, which are composed of Federal Reserve staff that focus on a single
firm, assess the adequacy of firms’ capital planning
practices related to governance, risk management,
internal controls, and scenario design. HETs are
composed of Federal Reserve staff that are not
assigned to a specific financial institution for purposes of the CCAR annual exercise but instead focus
on the examination of practices across multiple
firms. Some HETs assess the reasonableness of
firms’ stressed loss, revenue, and expense estimation
approaches and the governance and controls around
those approaches. Others, such as the capital planning review team, work closely with DSTs to provide
a horizontal assessment across the DSTs’ areas of
focus.
The DST and HET assessments consider whether a
firm’s capital planning practices allow it to reliably
estimate its capital needs on a forward-looking basis,
given dynamic changes that can occur to a firm’s risk
profile. These assessments are based on previously
articulated supervisory guidance and expectations.
The horizontal element of the exercise assists the
Federal Reserve in consistently applying its supervisory expectations to its assessment of each firm’s
capital planning practices.
After this initial assessment, the DSTs and HETs rate
each firm’s practices in each of the six areas noted
above. These ratings, which indicate the extent to
which a firm’s capital planning practices meet previ22

Ibid.

ously communicated supervisory expectations, are
used to determine the nature and severity of supervisory feedback. The initial supervisory assessments
are subject to review by a committee comprising
senior staff from across the Federal Reserve System
that seek to confirm that
• evaluations are aligned with the supervisory expectations communicated to the industry;
• evaluations are well supported and are consistently
applied across firms accounting for their size and
complexity; and
• assessments, as reflected in the ratings, are appropriately calibrated to the materiality of the supervisory concern.
This committee also ranks firms based on the ratings
for each assessment area, with consideration of the
firms’ individual risk profiles. The rankings assist the
Federal Reserve in distinguishing the relative
strength of each firm’s capital planning practices
and facilitating the consistent application of supervisory guidance across firms. However, the qualitative
assessment of a firm’s capital plan is based on an
absolute assessment of an individual firm’s capital
planning practices relative to the Federal Reserve’s
expectations as set forth in SR letter 15-18 and not
on comparative rankings. As such, a low ranking is
not, in and of itself, a reason for an objection to a
capital plan.
The DSTs formulate a recommendation to object or
not object to a firm’s capital plan based on the combined assessment, after extensive review by the
national committee. The LISCC’s Operating Committee, which comprises senior staff from across the
Federal Reserve System, then reviews and presents
its own recommendation for each LISCC firm to the
director of the Board’s Division of Supervision and
Regulation.23 Reserve Banks responsible for the
supervision of large and complex firms that are not
LISCC firms make recommendations with regard to
those firms, after review by a separate committee of
senior staff. The director makes the final recommendations, with supervisory findings, to the Board of
Governors, who makes the final decision whether to
object to a firm’s capital plan.

23

See SR letter 15-7. “Governance Structure of the Large Institution Supervision Coordinating Committee (LISCC) Supervisory Program,” April 17, 2015, www.federalreserve.gov/
supervisionreg/srletters/sr1507.htm.

June 2017

Objections on qualitative grounds can arise for reasons including, but not limited to
• unresolved material supervisory issues;
• inappropriate assumptions and analyses underlying a firm’s capital plan; or
• inadequate governance and internal controls, risk
management and risk identification in support of
a firm’s capital planning practices.24

Communication of Feedback
Soon after the completion of the CCAR exercise,
whether a firm’s capital plan is objected to or not,
the Federal Reserve sends a letter to each firm,
detailing weaknesses in the firm’s capital planning
analyses and processes and any actions these firms
must take to remediate those weaknesses. Each firm
is required to submit a plan detailing how it will
address the identified weaknesses, and supervisors
then assess whether those plans are likely to address
those weaknesses in a reasonable period of time. The
Federal Reserve then communicates its evaluation of
the action plans to the firm. In this way, the feedback letters serve as a guide for firms and supervisors to develop a common understanding of how
supervisory concerns will be remediated.

Monitoring Outstanding Findings
DSTs and HETs monitor each firm’s progress in
remediating outstanding supervisory findings consistent with the firm’s remediation plan. Any resulting
concerns are communicated to firms on an ongoing
basis so that changes, if needed, can be made by the
firm before the next CCAR exercise. The annual process is meant to give firms regular feedback so they
know the issues they face—before, during, and after
the CCAR qualitative assessment—and can make
improvements throughout the year.

Horizontal Examinations
Horizontal examinations are assessments of a common area or practice (such as internal audit) across
multiple firms by a coordinated team of examiners.
24

For further information on the qualitative grounds upon which
capital plans may be objected, see “Box 2. Considerations for
Capital Plan Qualitative Assessments” of Board of Governors
of the Federal Reserve System, Comprehensive Capital Analysis
and Review 2016: Assessment Framework and Results (Washington: Board of Governors, June 2016), 9, www.federalreserve
.gov/newsevents/pressreleases/files/bcreg20160629a1.pdf.

21

Throughout the year, the Federal Reserve conducts
horizontal examinations aimed at assessing whether
firms have sound capital planning practices in place
to enable them to reliably determine their capital
needs under expected and stressful conditions. The
focus of a given year’s capital planning horizontal
examinations are determined in the fall of each year,
and findings from the exams serve as key inputs for
the annual CCAR qualitative assessment.
Horizontal examinations conducted since CCAR
2016 have included firms’ internal audit coverage of
capital planning processes, the models and other
approaches used to determine counterparty credit
exposure under stress, pricing models used to estimate stressed trading losses, and approaches used to
rate the credit risk of obligors and facilities for
wholesale loans.

Qualitative Assessment Results
The Federal Reserve did not object to any firm’s
capital plan on qualitative grounds.
The Federal Reserve issued a conditional nonobjection to Capital One’s capital plan. The firm
must submit a capital plan addressing weaknesses
identified in its capital planning practices by December 28, 2017.

Qualitative Assessment Results
The qualitative assessment conducted as part of
CCAR 2017 found that many firms continued to
improve their capital planning practices, both in
terms of the estimation methods used to conduct
their stress tests and the risk measurement and management, internal controls, and governance supporting the firms’ capital planning practices. Strong practices in these areas are critical to ensuring the integrity of the inputs into assessing capital adequacy and
making decisions about capital distributions.
Most of the largest firms have made progress since
CCAR 2016, though some firms continue to fall
short of meeting supervisory expectations. This
group of firms has made progress addressing many
of their past capital planning weaknesses, including
those relating to the way they identify and assess
capital needs for their unique risks. These firms are
making decisions based on more reliable post-stress
capital assessments, which should strengthen their
overall safety and soundness.

22

CCAR 2017: Assessment Framework and Results

Box 3. The Importance of Capital Planning and Examples of Historical
Deficiencies
Capital is central to a firm’s ability to absorb unexpected losses and continue to lend to creditworthy
businesses and consumers in times of stress. Firms
must have in place sound capital planning practices
that allow them to reliably determine their expected
capital needs under stress on a forward-looking
basis. This allows firms’ boards of directors to make
informed decisions about capital actions. The practices that are important for sound capital planning
are also foundational to a firm’s broader risk identification, measurement, and management frameworks.
The emphasis on strong capital planning practices is
a direct response to many of the critical shortcomings
that were exposed by the financial crisis and hindered
firms’ ability to effectively manage risk in the face of
financial stress. For example, during and immediately
following the crisis, a number of firms had significant
problems identifying and measuring their risks, which
undermined their ability to determine their capital
needs. Some of the firms were unable to aggregate
their total exposure to their major counterparties and
lacked ready access to basic information about the
location and value of the collateral they held.
As noted earlier, the Federal Reserve focuses on six
key areas for capital planning when assessing a
firm’s capital planning processes: governance, risk
management, internal controls, capital policies, scenario design, and projection methodologies. This
box discusses why each area is essential to capital
planning and gives examples of historical deficiencies at firms. The deficiencies described in these
examples, standing alone, did not result in a qualitative objection. Firms receiving qualitative objections
in past CCAR cycles generally had multiple deficiencies in one or more areas of capital planning.
1. Governance
Strong governance in capital planning requires a
firm’s senior management to design and oversee its
capital planning process and its board of directors to
periodically review and approve that process. In
doing so, senior management must make informed
recommendations to the board of directors regarding
a firm’s capital planning and capital adequacy. The
recommendations should have sound analytical support and take into account the expectations of key
stakeholders, including shareholders, rating agencies, counterparties, depositors, creditors, and
supervisors. In order to make these recommendations, senior management must design and oversee
the firm’s capital planning process—including its use
of models and other estimation approaches—as well
as an independent review framework that identifies
weaknesses within the capital planning process.
It is the responsibility of the board of directors to
ensure that a firm’s capital plan is consistent with

the firm’s strategic direction and its risk appetite. A
common element of deficient capital plans has often
included failure on the part of management to
ensure that the analyses underlying the firm’s capital
plan was reliable or to accurately communicate the
firm’s full capital planning practices—including weaknesses therein—to the firm’s board of directors.
Example: A firm was found to have deficient governance over capital planning because its senior management failed to inform its board of directors of
potential uncertainties and gaps in significant areas
of the firm’s capital planning practices. In addition,
the firm provided information to its board of directors
and the Federal Reserve that incorrectly noted the
remediation of a previously identified supervisory
issue related to capital planning that, in fact, had not
been remediated. This action raised significant concerns about management’s oversight of the firm’s
capital planning process and, in turn, the reliability of
the grounds upon which the firm made capital
decisions.
2. Risk Management
A firm’s risk management infrastructure should identify, measure, and assess its material risks, including
specifically how they may evolve under stress, and
provide a strong foundation for capital planning. A
firm’s risk identification process should include a
comprehensive assessment of risks stemming from
its unique business activities and associated exposures. The risk identification process should be
dynamic and comprehensive, and drive the firm’s
capital adequacy analysis. Sound risk measurement
processes inform a firm’s senior management and
board of directors about the size and risk characteristics of exposures faced by the firm under both normal and stressful operating conditions, thereby
allowing the firm’s leadership to make wellsupported decisions about capital needs under
stress.
Example: A firm’s risk identification process was
found to be inadequate for capital planning purposes because it was not integrated with the process used to develop the firm’s capital plan. While
the firm had a process to identify its material risks,
these risks were not included consistently in the
firm’s stress scenarios or represented in its revenue
and loss estimation approaches. As a result, material risks identified by the firm were not factored into
the determination of its capital needs under stress.
3. Internal Controls
A firm’s internal control framework supports its entire
capital planning process. A sound internal control
framework should have (a) policies and procedures
(continued on next page)

June 2017

Box 3. The Importance of Capital Planning and Examples of Historical
Deficiencies (continued)
that support consistent and repeatable processes,
(b) validation of estimation methods for suitability,
(c) reliable data and information systems, and (d) an
internal audit function that oversees the entire capital planning process. This internal audit function
should also ensure that appropriate independent
review is occurring at all key levels within the capital
planning process. A sound internal control framework helps ensure that all aspects of the capital
planning process are functioning as designed and
result in sound assessments of the firm’s capital
needs.

including both a narrative of the situation and paths
of economic variables that relate to the scenario.
Well-designed scenarios should incorporate appropriately stressful conditions and events that could
adversely affect a firm’s capital adequacy. Firmspecific scenarios should reflect the specific vulnerabilities of the firm and directly link to the firm’s riskidentification process and associated risk assessment. Scenario design is essential to testing the
range of potential outcomes a firm could face in
stress and contributes to informed capital planning
processes.

Example: A firm’s internal controls were found to be
inadequate because the process for estimating total
losses was highly manual, without appropriate controls. This made it difficult to compile and verify final
results, and led to fundamental errors in the firm’s
capital plan. This weak control environment rendered the firm’s capital plan unreliable and led to its
board of directors making capital distribution decisions based on incorrect information.

Example: A firm’s risk identification process was
found to be inadequate because of its failure to capture unique risks arising from a portfolio material to
its business. The firm was overly reliant upon events
from the financial crisis in designing its stress scenarios, despite material changes in its risk profile
and business mix since that time. As a result, this
process resulted in a stress scenario that was not
particularly stressful or applicable to the firm in its
current state and, therefore, did not provide a useful
means of determining capital adequacy.

4. Capital Policy
A capital policy is a firm’s written description of the
principles and guidelines used for capital planning,
issuance, usage, and distributions. The capital policy
should reflect a number of factors, including the
firm’s business strategy, risk appetite, organizational
structure, governance structure, post-stress capital
goals, and real-time targeted capital levels. It should
also establish the actions the firm will take in the
event of breaching a post-stress capital goal, realtime targeted capital level, or early warning metric. A
sound capital policy underpins the creation of poststress capital goals that are aligned with a firm’s risk
appetite and risk profile. It is also critical to a firm’s
ability to appropriately manage its capital adequacy
under normal circumstances and continue to be able
to lend during times of stress. Prior to the crisis,
most firms did not have forward-looking capital policies to guide their response to deteriorating financial
conditions.
Example: A firm was found to have a deficient capital policy because the policy lacked detail in critical
areas. The policy did not establish capital limits that
were supported by forward-looking analysis of the
firm’s risks or considered the capital the firm needed
to maintain the confidence of its counterparties. The
capital policy also did not set forth the actions the
firm could take to improve its capital position. These
weaknesses inhibited the firm’s senior management
and board of directors from proactively addressing
capital shortfalls.
5. Scenario Design
Scenario design entails creating a hypothetical economic environment over a specific period of time,

6. Projection Methodologies
Forward-looking capital planning requires a firm to
make projections of its future capital needs. In doing
so, a firm should estimate losses, revenues,
expenses, and capital using a sound method that
relates macroeconomic and other risk factors to its
projections. The firm should be able to identify the
manner in which key variables, factors, and events
in a scenario affect losses, revenue, expenses, and
capital over the planning horizon. Sound projection
methodologies allow a firm’s senior management
and board of directors to make appropriate,
informed decisions regarding the firm’s capitalization. Deficient projection methodologies may also be
evidence of weak internal controls, such as model
risk management.
Example: A firm’s capital plan was found to be deficient because the models used to estimate losses
for one of the firm’s most material portfolios did not
sufficiently capture relevant risk drivers, were based
on unsupported assumptions, and used very limited
data. The resulting models were not sensitive to the
firm’s risk characteristics and scenario conditions.
These weaknesses raised significant concerns
about the conceptual soundness of these methodologies and the loss estimates resulting from them.
As a result, management of the firm was unable to
provide reliable loss projections on a major portfolio
to its board of directors, and the board of directors
was unable to make informed decisions about capital adequacy at the firm.

23

24

CCAR 2017: Assessment Framework and Results

However, some of these firms continue to fall short
of supervisory expectations in the following areas:
• identification of risks associated with firms’ products and services that may materialize under
stressed conditions, particularly risks stemming
from the introduction of new products or changes
in underwriting standards;
• use of loss estimation approaches that may be
appropriate to use under expected conditions but
are not suitable for stress testing, as they may
materially underestimate losses in stressful conditions when the relationships between risk drivers
and losses diverge from the relationships under
expected conditions; and
• controls around data accuracy, model risk management, and internal audit, which are foundational
areas of capital planning.

Reasons for Conditional Non-objection
The Board of Governors did not object to Capital
One’s capital plan. However, Capital One exhibited
material weaknesses in its capital planning practices,

which warrant further near-term attention. Notable
weaknesses were identified in the oversight and
execution of the firm’s capital planning practices,
which undermined the reliability of the firm’s
forward-looking assessment of its capital adequacy
under stress. Specifically, the firm’s capital plan did
not appropriately take into account the potential
impact of the risks in one of its most material businesses. Further, the firm’s internal controls functions,
including independent risk management, did not
identify these material weaknesses in the firm’s capital planning practices. Therefore, senior management
was not in a position to provide the firm’s board of
directors with a reliable assessment upon which to
determine the reasonableness of the capital plan.
As a condition of not objecting to Capital One’s
capital plan, the Board of Governors is requiring the
firm to address the weaknesses noted above and
resubmit its capital plan by December 28, 2017. If
Capital One does not satisfactorily address the identified weaknesses in its capital planning practices by
that time, the Board of Governors would expect to
object to the resubmitted capital plan and may
restrict the firm’s capital distributions.

25

Process and Requirements after CCAR 2017

Execution of Capital Plan and
Consequences of a Federal Reserve
Objection to a Plan
The Federal Reserve evaluates planned capital
actions for the full nine-quarter planning horizon to
better understand each firm’s longer-term capital
management strategy and to assess post-stress capital
levels over the full planning horizon.25 While the
nine-quarter planning horizon reflected in the 2017
capital plans extends through the beginning of 2019,
the Federal Reserve’s decision to object or not object
to firms’ planned capital actions is carried out annually and applies only to the four quarters following
the disclosure of results. Therefore, the Federal
Reserve’s decisions with regard to planned capital
distributions in CCAR 2017 will apply from the
beginning of the third quarter of 2017 through the
end of the second quarter of 2018.26
When the Federal Reserve objects to a firm’s capital
plan, the firm may not make any capital distribution
unless expressly permitted by the Federal Reserve.27
For those firms that did not receive an objection to
their capital plans, the capital plan rule provides that
a firm generally must request prior approval of a
capital distribution if the dollar amount of the capital distribution will exceed the amount described in
the capital plan for which a non-objection was issued
(gross distribution limit).28

In addition, a firm generally must request the
Board’s non-objection for capital distributions
included in the firm’s capital plan if the firm has
issued less capital of a given class of regulatory capital instrument (net of distributions) than the firm
had included in its capital plan, measured cumulatively, beginning with the third quarter of the planning horizon (the third quarter of 2017).29 For
example, a firm that planned to issue common stock
in the fourth quarter of 2017, but issued less stock
than included in its capital plan, would be prohibited
from making planned common dividends, share
repurchases, or both in that quarter and subsequent
quarters unless and until it offsets the excess net distributions. A firm’s consistent failure to issue the
regulatory capital included in its plan may be indicative of shortcomings in the firm’s capital planning
process and may negatively influence the Federal
Reserve’s assessment of the firm’s capital plans in
future years.

Resubmissions
If a firm’s capital plan was objected to, it may resubmit its plan in advance of the next CCAR exercise,
but it is not required to do so.30 The Federal Reserve
can require a firm to resubmit its capital plan following CCAR for a number of reasons, including if
there has been or will likely be a material change in
the firm’s risk profile, financial condition, or corpo29

25

26

27
28

See Board of Governors of the Federal Reserve System, Comprehensive Capital Analysis and Review 2017 Summary Instructionsfor LISCC and Large and Complex Firms (Washington:
Board of Governors, February 2017), www.federalreserve.gov/
newsevents/pressreleases/files/bcreg20170203a4.pdf.
The capital distributions for the three “out quarters” (the third
and fourth quarters of 2018 and the first quarter of 2019) in
CCAR 2017 will be addressed in CCAR 2018.
See 12 CFR 225.8(f)(2)(iv).
A firm is not required to provide prior notice and seek approval
for distributions involving issuances of instruments that would
qualify for inclusion in the numerator of regulatory capital
ratios that were not included in the firm’s capital plan. See
12 CFR 225.8(g)(1).

30

The classes of regulatory capital instruments are common
equity tier 1, additional tier 1, and tier 2 capital instruments, as
defined in 12 CFR 217.2. Firms are not required to provide
prior notice and seek approval for distributions included in
their capital plans that are scheduled payments on additional
tier 1 or tier 2 capital. In addition, firms are not required to
provide prior notice and seek approval where the shortfall in
capital issuance (net of distributions) is due to employeedirected capital issuances related to an employee stock ownership plan, a planned merger or acquisition that is no longer
expected to be consummated or for which the consideration
paid was lower than the projected price in the capital plan, or if
aggregate excess net distributions are less than 1 percent of the
firm’s tier 1 capital. See 12 CFR 225.8(g)(3)(iii).
See 12 CFR 225.8(e)(4)(ii).

26

CCAR 2017: Assessment Framework and Results

rate structure; the firm’s stress scenarios are no longer appropriate for the firm’s business models or
portfolios; or changes in the macroeconomic outlook
that could materially affect the firm’s risk profile and
financial condition require the use of updated scenarios.31 As detailed in the capital plan rule, a firm

must update and resubmit its capital plan if it determines there has been or will be a material change in
the firm’s risk profile (including a material change in
its business strategy or any material risk exposures),
financial condition, or corporate structure since the
firm adopted the capital plan.32

31

32

See 12 CFR 225.8(e)(4)(i)(B).

See 12 CFR 225.8(e)(4)(i)(A).

27

Appendix A: Disclosure Tables

These tables provide projections that represent hypothetical estimates involving an economic outcome
that is more adverse than expected. These estimates
are not forecasts of capital ratios. The tables include
the minimum ratios assuming the capital actions
originally submitted in April 2017 by the firms in
their annual capital plans and, where applicable,

reflect any adjustments to capital distributions made
by firms after reviewing the Federal Reserve’s stress
test projections. The minimum capital ratios are for
the period from the first quarter of 2017 to the first
quarter of 2019 and do not necessarily occur in the
same quarter.

28

CCAR 2017: Assessment Framework and Results

Table 1.A. Ally Financial Inc.
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Severely adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio

Actual
2016:Q4

Original planned capital
actions

9.4
10.9
12.6
9.5

Adjusted planned capital
actions

5.2
6.9
8.8
5.9

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios are for the period 2017:Q1 to 2019:Q1 and do not necessarily occur in the same
quarter.

Required minimum capital ratios for firms not subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0

4.5
6.0
8.0
4.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.

June 2017

29

Table 1.B. Ally Financial Inc.
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio

Actual
2016:Q4

Original planned capital
actions

9.4
10.9
12.6
9.5

Adjusted planned capital
actions

7.4
8.9
10.9
7.7

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios are for the period 2017:Q1 to 2019:Q1 and do not necessarily occur in the same
quarter.

Required minimum capital ratios for firms not subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0

4.5
6.0
8.0
4.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.

30

CCAR 2017: Assessment Framework and Results

Table 2.A. American Express Company
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Severely adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

Actual
2016:Q4

Original planned capital
actions

Adjusted planned capital
actions

5.0
6.1
7.8
5.3
4.5

5.3
6.4
8.1
5.5
4.8

12.3
13.5
15.2
11.6
n/a

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios, other than for the supplementary leverage ratio, are for the period 2017:Q1 to
2019:Q1. The minimum supplementary leverage ratio is for the period 2018:Q1 to 2019:Q1. The minimum capital ratios do not necessarily occur in the same quarter.
n/a Not applicable.

Required minimum capital ratios for firms subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0
n/a

4.5
6.0
8.0
4.0
3.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.
n/a Not applicable.

June 2017

31

Table 2.B. American Express Company
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

Actual
2016:Q4

Original planned capital
actions

Adjusted planned capital
actions

7.5
8.6
10.3
7.3
6.3

7.8
8.9
10.6
7.6
6.5

12.3
13.5
15.2
11.6
n/a

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios, other than for the supplementary leverage ratio, are for the period 2017:Q1 to
2019:Q1. The minimum supplementary leverage ratio is for the period 2018:Q1 to 2019:Q1. The minimum capital ratios do not necessarily occur in the same quarter.
n/a Not applicable.

Required minimum capital ratios for firms subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0
n/a

4.5
6.0
8.0
4.0
3.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.
n/a Not applicable.

32

CCAR 2017: Assessment Framework and Results

Table 3.A. BancWest Corporation
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Severely adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio

Actual
2016:Q4

Original planned capital
actions

13.1
13.4
15.3
11.1

Adjusted planned capital
actions

6.1
6.6
8.7
5.5

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios are for the period 2017:Q1 to 2019:Q1 and do not necessarily occur in the same
quarter.

Required minimum capital ratios for firms not subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0

4.5
6.0
8.0
4.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.

June 2017

33

Table 3.B. BancWest Corporation
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio

Actual
2016:Q4

Original planned capital
actions

13.1
13.4
15.3
11.1

Adjusted planned capital
actions

8.9
9.4
11.5
7.7

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios are for the period 2017:Q1 to 2019:Q1 and do not necessarily occur in the same
quarter.

Required minimum capital ratios for firms not subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0

4.5
6.0
8.0
4.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.

34

CCAR 2017: Assessment Framework and Results

Table 4.A. Bank of America Corporation
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Severely adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

Actual
2016:Q4

Original planned capital
actions

12.1
13.6
16.3
8.9
n/a

Adjusted planned capital
actions

6.8
8.4
11.0
5.4
4.3

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios, other than for the supplementary leverage ratio, are for the period 2017:Q1 to
2019:Q1. The minimum supplementary leverage ratio is for the period 2018:Q1 to 2019:Q1. The minimum capital ratios do not necessarily occur in the same quarter.
n/a Not applicable.

Required minimum capital ratios for firms subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0
n/a

4.5
6.0
8.0
4.0
3.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.
n/a Not applicable.

June 2017

35

Table 4.B. Bank of America Corporation
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

Actual
2016:Q4

Original planned capital
actions

12.1
13.6
16.3
8.9
n/a

Adjusted planned capital
actions

9.0
10.6
12.7
6.9
5.4

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios, other than for the supplementary leverage ratio, are for the period 2017:Q1 to
2019:Q1. The minimum supplementary leverage ratio is for the period 2018:Q1 to 2019:Q1. The minimum capital ratios do not necessarily occur in the same quarter.
n/a Not applicable.

Required minimum capital ratios for firms subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0
n/a

4.5
6.0
8.0
4.0
3.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.
n/a Not applicable.

36

CCAR 2017: Assessment Framework and Results

Table 5.A. The Bank of New York Mellon Corporation
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Severely adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

Actual
2016:Q4

Original planned capital
actions

12.3
14.5
15.2
6.6
n/a

Adjusted planned capital
actions

9.1
11.6
12.6
5.2
4.8

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios, other than for the supplementary leverage ratio, are for the period 2017:Q1 to
2019:Q1. The minimum supplementary leverage ratio is for the period 2018:Q1 to 2019:Q1. The minimum capital ratios do not necessarily occur in the same quarter.
n/a Not applicable.

Required minimum capital ratios for firms subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0
n/a

4.5
6.0
8.0
4.0
3.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.
n/a Not applicable.

June 2017

37

Table 5.B. The Bank of New York Mellon Corporation
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

Actual
2016:Q4

Original planned capital
actions

12.3
14.5
15.2
6.6
n/a

Adjusted planned capital
actions

9.5
12.0
12.9
5.3
4.9

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios, other than for the supplementary leverage ratio, are for the period 2017:Q1 to
2019:Q1. The minimum supplementary leverage ratio is for the period 2018:Q1 to 2019:Q1. The minimum capital ratios do not necessarily occur in the same quarter.
n/a Not applicable.

Required minimum capital ratios for firms subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0
n/a

4.5
6.0
8.0
4.0
3.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.
n/a Not applicable.

38

CCAR 2017: Assessment Framework and Results

Table 6.A. BB&T Corporation
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Severely adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio

Actual
2016:Q4

Original planned capital
actions

10.2
12.0
14.1
10.0

Adjusted planned capital
actions

6.3
7.9
11.0
6.6

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios are for the period 2017:Q1 to 2019:Q1 and do not necessarily occur in the same
quarter.

Required minimum capital ratios for firms not subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0

4.5
6.0
8.0
4.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.

June 2017

39

Table 6.B. BB&T Corporation
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio

Actual
2016:Q4

Original planned capital
actions

10.2
12.0
14.1
10.0

Adjusted planned capital
actions

7.9
9.5
12.1
7.8

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios are for the period 2017:Q1 to 2019:Q1 and do not necessarily occur in the same
quarter.

Required minimum capital ratios for firms not subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0

4.5
6.0
8.0
4.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.

40

CCAR 2017: Assessment Framework and Results

Table 7.A. BBVA Compass Bancshares, Inc.
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Severely adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio

Actual
2016:Q4

Original planned capital
actions

11.5
11.9
14.3
9.5

Adjusted planned capital
actions

7.4
7.7
10.1
6.1

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios are for the period 2017:Q1 to 2019:Q1 and do not necessarily occur in the same
quarter.

Required minimum capital ratios for firms not subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0

4.5
6.0
8.0
4.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.

June 2017

41

Table 7.B. BBVA Compass Bancshares, Inc.
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio

Actual
2016:Q4

Original planned capital
actions

11.5
11.9
14.3
9.5

Adjusted planned capital
actions

9.9
10.2
12.3
7.9

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios are for the period 2017:Q1 to 2019:Q1 and do not necessarily occur in the same
quarter.

Required minimum capital ratios for firms not subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0

4.5
6.0
8.0
4.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.

42

CCAR 2017: Assessment Framework and Results

Table 8.A. BMO Financial Corp.
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Severely adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio

Actual
2016:Q4

Original planned capital
actions

12.5
12.8
15.7
9.5

Adjusted planned capital
actions

8.0
8.7
11.7
6.4

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios are for the period 2017:Q1 to 2019:Q1 and do not necessarily occur in the same
quarter.

Required minimum capital ratios for firms not subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0

4.5
6.0
8.0
4.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.

June 2017

43

Table 8.B. BMO Financial Corp.
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio

Actual
2016:Q4

Original planned capital
actions

12.5
12.8
15.7
9.5

Adjusted planned capital
actions

10.4
11.0
13.6
8.0

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios are for the period 2017:Q1 to 2019:Q1 and do not necessarily occur in the same
quarter.

Required minimum capital ratios for firms not subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0

4.5
6.0
8.0
4.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.

44

CCAR 2017: Assessment Framework and Results

Table 9.A. Capital One Financial Corporation
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Severely adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

Actual
2016:Q4

Original planned capital
actions

Adjusted planned capital
actions

5.6
7.1
9.9
6.2
5.4

5.9
7.4
10.1
6.4
5.6

10.1
11.6
14.3
9.9
n/a

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios, other than for the supplementary leverage ratio, are for the period 2017:Q1 to
2019:Q1. The minimum supplementary leverage ratio is for the period 2018:Q1 to 2019:Q1. The minimum capital ratios do not necessarily occur in the same quarter.
n/a Not applicable.

Required minimum capital ratios for firms subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0
n/a

4.5
6.0
8.0
4.0
3.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.
n/a Not applicable.

June 2017

45

Table 9.B. Capital One Financial Corporation
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

Actual
2016:Q4

Original planned capital
actions

Adjusted planned capital
actions

7.8
9.2
11.6
7.9
6.8

8.1
9.5
11.9
8.1
7.0

10.1
11.6
14.3
9.9
n/a

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios, other than for the supplementary leverage ratio, are for the period 2017:Q1 to
2019:Q1. The minimum supplementary leverage ratio is for the period 2018:Q1 to 2019:Q1. The minimum capital ratios do not necessarily occur in the same quarter.
n/a Not applicable.

Required minimum capital ratios for firms subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0
n/a

4.5
6.0
8.0
4.0
3.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.
n/a Not applicable.

46

CCAR 2017: Assessment Framework and Results

Table 10.A. CIT Group Inc.
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Severely adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio

Actual
2016:Q4

Original planned capital
actions

14.0
14.0
14.8
13.9

Adjusted planned capital
actions

5.4
6.8
8.1
5.6

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios are for the period 2017:Q1 to 2019:Q1 and do not necessarily occur in the same
quarter.

Required minimum capital ratios for firms not subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0

4.5
6.0
8.0
4.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.

June 2017

47

Table 10.B. CIT Group Inc.
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio

Actual
2016:Q4

Original planned capital
actions

14.0
14.0
14.8
13.9

Adjusted planned capital
actions

8.1
9.5
10.8
7.8

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios are for the period 2017:Q1 to 2019:Q1 and do not necessarily occur in the same
quarter.

Required minimum capital ratios for firms not subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0

4.5
6.0
8.0
4.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.

48

CCAR 2017: Assessment Framework and Results

Table 11.A. Citigroup Inc.
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Severely adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

Actual
2016:Q4

Original planned capital
actions

14.9
15.8
19.1
10.1
n/a

Adjusted planned capital
actions

8.0
9.5
12.8
6.1
4.5

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios, other than for the supplementary leverage ratio, are for the period 2017:Q1 to
2019:Q1. The minimum supplementary leverage ratio is for the period 2018:Q1 to 2019:Q1. The minimum capital ratios do not necessarily occur in the same quarter.
n/a Not applicable.

Required minimum capital ratios for firms subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0
n/a

4.5
6.0
8.0
4.0
3.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.
n/a Not applicable.

June 2017

49

Table 11.B. Citigroup Inc.
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

Actual
2016:Q4

Original planned capital
actions

14.9
15.8
19.1
10.1
n/a

Adjusted planned capital
actions

10.1
11.5
14.4
7.3
5.5

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios, other than for the supplementary leverage ratio, are for the period 2017:Q1 to
2019:Q1. The minimum supplementary leverage ratio is for the period 2018:Q1 to 2019:Q1. The minimum capital ratios do not necessarily occur in the same quarter.
n/a Not applicable.

Required minimum capital ratios for firms subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0
n/a

4.5
6.0
8.0
4.0
3.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.
n/a Not applicable.

50

CCAR 2017: Assessment Framework and Results

Table 12.A. Citizens Financial Group, Inc.
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Severely adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio

Actual
2016:Q4

Original planned capital
actions

11.2
11.4
14.0
9.9

Adjusted planned capital
actions

6.5
6.9
9.5
6.0

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios are for the period 2017:Q1 to 2019:Q1 and do not necessarily occur in the same
quarter.

Required minimum capital ratios for firms not subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0

4.5
6.0
8.0
4.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.

June 2017

51

Table 12.B. Citizens Financial Group, Inc.
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio

Actual
2016:Q4

Original planned capital
actions

11.2
11.4
14.0
9.9

Adjusted planned capital
actions

8.6
9.0
11.4
7.7

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios are for the period 2017:Q1 to 2019:Q1 and do not necessarily occur in the same
quarter.

Required minimum capital ratios for firms not subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0

4.5
6.0
8.0
4.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.

52

CCAR 2017: Assessment Framework and Results

Table 13.A. Comerica Incorporated
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Severely adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio

Actual
2016:Q4

Original planned capital
actions

11.1
11.1
13.3
10.2

Adjusted planned capital
actions

7.5
7.5
9.5
6.7

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios are for the period 2017:Q1 to 2019:Q1 and do not necessarily occur in the same
quarter.

Required minimum capital ratios for firms not subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0

4.5
6.0
8.0
4.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.

June 2017

53

Table 13.B. Comerica Incorporated
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio

Actual
2016:Q4

Original planned capital
actions

11.1
11.1
13.3
10.2

Adjusted planned capital
actions

8.8
8.8
10.5
7.9

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios are for the period 2017:Q1 to 2019:Q1 and do not necessarily occur in the same
quarter.

Required minimum capital ratios for firms not subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0

4.5
6.0
8.0
4.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.

54

CCAR 2017: Assessment Framework and Results

Table 14.A. Deutsche Bank Trust Corporation
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Severely adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio

Actual
2016:Q4

Original planned capital
actions

64.4
64.4
64.7
14.6

Adjusted planned capital
actions

58.0
58.0
59.0
13.0

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios are for the period 2017:Q1 to 2019:Q1 and do not necessarily occur in the same
quarter.

Required minimum capital ratios for firms not subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0

4.5
6.0
8.0
4.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.

June 2017

55

Table 14.B. Deutsche Bank Trust Corporation
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio

Actual
2016:Q4

Original planned capital
actions

64.4
64.4
64.7
14.6

Adjusted planned capital
actions

58.5
58.5
59.2
12.9

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios are for the period 2017:Q1 to 2019:Q1 and do not necessarily occur in the same
quarter.

Required minimum capital ratios for firms not subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0

4.5
6.0
8.0
4.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.

56

CCAR 2017: Assessment Framework and Results

Table 15.A. Discover Financial Services
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Severely adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio

Actual
2016:Q4

Original planned capital
actions

13.2
13.9
15.5
12.3

Adjusted planned capital
actions

6.9
7.5
9.3
6.6

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios are for the period 2017:Q1 to 2019:Q1 and do not necessarily occur in the same
quarter.

Required minimum capital ratios for firms not subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0

4.5
6.0
8.0
4.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.

June 2017

57

Table 15.B. Discover Financial Services
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio

Actual
2016:Q4

Original planned capital
actions

13.2
13.9
15.5
12.3

Adjusted planned capital
actions

9.1
9.7
11.2
8.5

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios are for the period 2017:Q1 to 2019:Q1 and do not necessarily occur in the same
quarter.

Required minimum capital ratios for firms not subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0

4.5
6.0
8.0
4.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.

58

CCAR 2017: Assessment Framework and Results

Table 16.A. Fifth Third Bancorp
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Severely adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio

Actual
2016:Q4

Original planned capital
actions

10.4
11.5
15.0
9.9

Adjusted planned capital
actions

6.3
7.2
10.3
6.2

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios are for the period 2017:Q1 to 2019:Q1 and do not necessarily occur in the same
quarter.

Required minimum capital ratios for firms not subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0

4.5
6.0
8.0
4.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.

June 2017

59

Table 16.B. Fifth Third Bancorp
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio

Actual
2016:Q4

Original planned capital
actions

10.4
11.5
15.0
9.9

Adjusted planned capital
actions

8.2
9.1
11.7
7.7

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios are for the period 2017:Q1 to 2019:Q1 and do not necessarily occur in the same
quarter.

Required minimum capital ratios for firms not subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0

4.5
6.0
8.0
4.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.

60

CCAR 2017: Assessment Framework and Results

Table 17.A. The Goldman Sachs Group, Inc.
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Severely adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

Actual
2016:Q4

Original planned capital
actions

14.5
16.6
19.8
9.4
n/a

Adjusted planned capital
actions

6.0
8.2
10.9
4.5
3.1

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios, other than for the supplementary leverage ratio, are for the period 2017:Q1 to
2019:Q1. The minimum supplementary leverage ratio is for the period 2018:Q1 to 2019:Q1. The minimum capital ratios do not necessarily occur in the same quarter.
n/a Not applicable.

Required minimum capital ratios for firms subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0
n/a

4.5
6.0
8.0
4.0
3.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.
n/a Not applicable.

June 2017

61

Table 17.B. The Goldman Sachs Group, Inc.
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

Actual
2016:Q4

Original planned capital
actions

14.5
16.6
19.8
9.4
n/a

Adjusted planned capital
actions

8.3
10.4
12.9
5.7
3.9

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios, other than for the supplementary leverage ratio, are for the period 2017:Q1 to
2019:Q1. The minimum supplementary leverage ratio is for the period 2018:Q1 to 2019:Q1. The minimum capital ratios do not necessarily occur in the same quarter.
n/a Not applicable.

Required minimum capital ratios for firms subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0
n/a

4.5
6.0
8.0
4.0
3.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.
n/a Not applicable.

62

CCAR 2017: Assessment Framework and Results

Table 18.A. HSBC North America Holdings Inc.
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Severely adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

Actual
2016:Q4

Original planned capital
actions

17.9
20.1
25.3
9.6
n/a

Adjusted planned capital
actions

8.9
11.6
15.2
5.2
4.0

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios, other than for the supplementary leverage ratio, are for the period 2017:Q1 to
2019:Q1. The minimum supplementary leverage ratio is for the period 2018:Q1 to 2019:Q1. The minimum capital ratios do not necessarily occur in the same quarter.
n/a Not applicable.

Required minimum capital ratios for firms subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0
n/a

4.5
6.0
8.0
4.0
3.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.
n/a Not applicable.

June 2017

63

Table 18.B. HSBC North America Holdings Inc.
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

Actual
2016:Q4

Original planned capital
actions

17.9
20.1
25.3
9.6
n/a

Adjusted planned capital
actions

9.5
12.1
15.2
5.5
4.2

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios, other than for the supplementary leverage ratio, are for the period 2017:Q1 to
2019:Q1. The minimum supplementary leverage ratio is for the period 2018:Q1 to 2019:Q1. The minimum capital ratios do not necessarily occur in the same quarter.
n/a Not applicable.

Required minimum capital ratios for firms subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0
n/a

4.5
6.0
8.0
4.0
3.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.
n/a Not applicable.

64

CCAR 2017: Assessment Framework and Results

Table 19.A. Huntington Bancshares Incorporated
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Severely adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio

Actual
2016:Q4

Original planned capital
actions

9.6
10.9
13.1
8.7

Adjusted planned capital
actions

6.0
7.3
9.7
5.8

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios are for the period 2017:Q1 to 2019:Q1 and do not necessarily occur in the same
quarter.

Required minimum capital ratios for firms not subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0

4.5
6.0
8.0
4.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.

June 2017

65

Table 19.B. Huntington Bancshares Incorporated
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio

Actual
2016:Q4

Original planned capital
actions

9.6
10.9
13.1
8.7

Adjusted planned capital
actions

7.6
8.9
11.0
6.9

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios are for the period 2017:Q1 to 2019:Q1 and do not necessarily occur in the same
quarter.

Required minimum capital ratios for firms not subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0

4.5
6.0
8.0
4.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.

66

CCAR 2017: Assessment Framework and Results

Table 20.A. JPMorgan Chase & Co.
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Severely adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

Actual
2016:Q4

Original planned capital
actions

12.5
14.2
16.4
8.4
n/a

Adjusted planned capital
actions

6.9
8.4
10.8
5.0
3.9

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios, other than for the supplementary leverage ratio, are for the period 2017:Q1 to
2019:Q1. The minimum supplementary leverage ratio is for the period 2018:Q1 to 2019:Q1. The minimum capital ratios do not necessarily occur in the same quarter.
n/a Not applicable.

Required minimum capital ratios for firms subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0
n/a

4.5
6.0
8.0
4.0
3.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.
n/a Not applicable.

June 2017

67

Table 20.B. JPMorgan Chase & Co.
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

Actual
2016:Q4

Original planned capital
actions

12.5
14.2
16.4
8.4
n/a

Adjusted planned capital
actions

8.7
10.2
12.2
5.9
4.6

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios, other than for the supplementary leverage ratio, are for the period 2017:Q1 to
2019:Q1. The minimum supplementary leverage ratio is for the period 2018:Q1 to 2019:Q1. The minimum capital ratios do not necessarily occur in the same quarter.
n/a Not applicable.

Required minimum capital ratios for firms subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0
n/a

4.5
6.0
8.0
4.0
3.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.
n/a Not applicable.

68

CCAR 2017: Assessment Framework and Results

Table 21.A. KeyCorp
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Severely adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio

Actual
2016:Q4

Original planned capital
actions

9.5
10.9
12.9
9.9

Adjusted planned capital
actions

5.5
6.5
8.7
5.9

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios are for the period 2017:Q1 to 2019:Q1 and do not necessarily occur in the same
quarter.

Required minimum capital ratios for firms not subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0

4.5
6.0
8.0
4.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.

June 2017

69

Table 21.B. KeyCorp
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio

Actual
2016:Q4

Original planned capital
actions

9.5
10.9
12.9
9.9

Adjusted planned capital
actions

7.3
8.4
10.2
7.5

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios are for the period 2017:Q1 to 2019:Q1 and do not necessarily occur in the same
quarter.

Required minimum capital ratios for firms not subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0

4.5
6.0
8.0
4.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.

70

CCAR 2017: Assessment Framework and Results

Table 22.A. M&T Bank Corporation
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Severely adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio

Actual
2016:Q4

Original planned capital
actions

10.7
11.9
14.1
10.0

Adjusted planned capital
actions

6.2
7.3
9.8
6.1

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios are for the period 2017:Q1 to 2019:Q1 and do not necessarily occur in the same
quarter.

Required minimum capital ratios for firms not subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0

4.5
6.0
8.0
4.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.

June 2017

71

Table 22.B. M&T Bank Corporation
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio

Actual
2016:Q4

Original planned capital
actions

10.7
11.9
14.1
10.0

Adjusted planned capital
actions

8.0
9.1
11.2
7.4

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios are for the period 2017:Q1 to 2019:Q1 and do not necessarily occur in the same
quarter.

Required minimum capital ratios for firms not subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0

4.5
6.0
8.0
4.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.

72

CCAR 2017: Assessment Framework and Results

Table 23.A. Morgan Stanley
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Severely adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

Actual
2016:Q4

Original planned capital
actions

17.8
20.0
23.2
8.4
n/a

Adjusted planned capital
actions

7.9
10.3
13.4
4.2
3.2

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios, other than for the supplementary leverage ratio, are for the period 2017:Q1 to
2019:Q1. The minimum supplementary leverage ratio is for the period 2018:Q1 to 2019:Q1. The minimum capital ratios do not necessarily occur in the same quarter.
n/a Not applicable.

Required minimum capital ratios for firms subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0
n/a

4.5
6.0
8.0
4.0
3.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.
n/a Not applicable.

June 2017

73

Table 23.B. Morgan Stanley
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

Actual
2016:Q4

Original planned capital
actions

17.8
20.0
23.2
8.4
n/a

Adjusted planned capital
actions

11.3
13.6
16.2
5.5
4.2

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios, other than for the supplementary leverage ratio, are for the period 2017:Q1 to
2019:Q1. The minimum supplementary leverage ratio is for the period 2018:Q1 to 2019:Q1. The minimum capital ratios do not necessarily occur in the same quarter.
n/a Not applicable.

Required minimum capital ratios for firms subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0
n/a

4.5
6.0
8.0
4.0
3.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.
n/a Not applicable.

74

CCAR 2017: Assessment Framework and Results

Table 24.A. MUFG Americas Holdings Corporation
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Severely adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio

Actual
2016:Q4

Original planned capital
actions

14.8
14.8
16.4
9.9

Adjusted planned capital
actions

11.5
11.5
12.6
7.6

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios are for the period 2017:Q1 to 2019:Q1 and do not necessarily occur in the same
quarter.

Required minimum capital ratios for firms not subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0

4.5
6.0
8.0
4.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.

June 2017

75

Table 24.B. MUFG Americas Holdings Corporation
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio

Actual
2016:Q4

Original planned capital
actions

14.8
14.8
16.4
9.9

Adjusted planned capital
actions

13.4
13.4
14.1
8.8

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios are for the period 2017:Q1 to 2019:Q1 and do not necessarily occur in the same
quarter.

Required minimum capital ratios for firms not subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0

4.5
6.0
8.0
4.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.

76

CCAR 2017: Assessment Framework and Results

Table 25.A. Northern Trust Corporation
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Severely adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

Actual
2016:Q4

Original planned capital
actions

11.8
12.9
14.5
8.0
n/a

Adjusted planned capital
actions

9.1
10.2
12.3
6.2
5.3

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios, other than for the supplementary leverage ratio, are for the period 2017:Q1 to
2019:Q1. The minimum supplementary leverage ratio is for the period 2018:Q1 to 2019:Q1. The minimum capital ratios do not necessarily occur in the same quarter.
n/a Not applicable.

Required minimum capital ratios for firms subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0
n/a

4.5
6.0
8.0
4.0
3.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.
n/a Not applicable.

June 2017

77

Table 25.B. Northern Trust Corporation
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

Actual
2016:Q4

Original planned capital
actions

11.8
12.9
14.5
8.0
n/a

Adjusted planned capital
actions

9.9
11.0
12.8
6.6
5.6

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios, other than for the supplementary leverage ratio, are for the period 2017:Q1 to
2019:Q1. The minimum supplementary leverage ratio is for the period 2018:Q1 to 2019:Q1. The minimum capital ratios do not necessarily occur in the same quarter.
n/a Not applicable.

Required minimum capital ratios for firms subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0
n/a

4.5
6.0
8.0
4.0
3.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.
n/a Not applicable.

78

CCAR 2017: Assessment Framework and Results

Table 26.A. The PNC Financial Services Group, Inc.
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Severely adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

Actual
2016:Q4

Original planned capital
actions

10.6
12.0
14.3
10.1
n/a

Adjusted planned capital
actions

6.3
7.6
9.6
6.4
5.4

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios, other than for the supplementary leverage ratio, are for the period 2017:Q1 to
2019:Q1. The minimum supplementary leverage ratio is for the period 2018:Q1 to 2019:Q1. The minimum capital ratios do not necessarily occur in the same quarter.
n/a Not applicable.

Required minimum capital ratios for firms subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0
n/a

4.5
6.0
8.0
4.0
3.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.
n/a Not applicable.

June 2017

79

Table 26.B. The PNC Financial Services Group, Inc.
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

Actual
2016:Q4

Original planned capital
actions

10.6
12.0
14.3
10.1
n/a

Adjusted planned capital
actions

7.5
8.8
10.4
7.4
6.2

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios, other than for the supplementary leverage ratio, are for the period 2017:Q1 to
2019:Q1. The minimum supplementary leverage ratio is for the period 2018:Q1 to 2019:Q1. The minimum capital ratios do not necessarily occur in the same quarter.
n/a Not applicable.

Required minimum capital ratios for firms subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0
n/a

4.5
6.0
8.0
4.0
3.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.
n/a Not applicable.

80

CCAR 2017: Assessment Framework and Results

Table 27.A. Regions Financial Corporation
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Severely adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio

Actual
2016:Q4

Original planned capital
actions

11.2
12.0
14.2
10.2

Adjusted planned capital
actions

6.0
7.4
9.5
6.3

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios are for the period 2017:Q1 to 2019:Q1 and do not necessarily occur in the same
quarter.

Required minimum capital ratios for firms not subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0

4.5
6.0
8.0
4.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.

June 2017

81

Table 27.B. Regions Financial Corporation
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio

Actual
2016:Q4

Original planned capital
actions

11.2
12.0
14.2
10.2

Adjusted planned capital
actions

7.9
9.4
11.2
7.8

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios are for the period 2017:Q1 to 2019:Q1 and do not necessarily occur in the same
quarter.

Required minimum capital ratios for firms not subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0

4.5
6.0
8.0
4.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.

82

CCAR 2017: Assessment Framework and Results

Table 28.A. Santander Holdings USA, Inc.
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Severely adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio

Actual
2016:Q4

Original planned capital
actions

14.5
16.1
18.0
12.5

Adjusted planned capital
actions

12.8
13.7
15.2
10.6

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios are for the period 2017:Q1 to 2019:Q1 and do not necessarily occur in the same
quarter.

Required minimum capital ratios for firms not subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0

4.5
6.0
8.0
4.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.

June 2017

83

Table 28.B. Santander Holdings USA, Inc.
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio

Actual
2016:Q4

Original planned capital
actions

14.5
16.1
18.0
12.5

Adjusted planned capital
actions

14.3
15.9
17.7
12.2

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios are for the period 2017:Q1 to 2019:Q1 and do not necessarily occur in the same
quarter.

Required minimum capital ratios for firms not subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0

4.5
6.0
8.0
4.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.

84

CCAR 2017: Assessment Framework and Results

Table 29.A. State Street Corporation
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Severely adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

Actual
2016:Q4

Original planned capital
actions

11.6
14.7
16.0
6.5
n/a

Adjusted planned capital
actions

6.0
9.1
10.2
4.0
3.6

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios, other than for the supplementary leverage ratio, are for the period 2017:Q1 to
2019:Q1. The minimum supplementary leverage ratio is for the period 2018:Q1 to 2019:Q1. The minimum capital ratios do not necessarily occur in the same quarter.
n/a Not applicable.

Required minimum capital ratios for firms subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0
n/a

4.5
6.0
8.0
4.0
3.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.
n/a Not applicable.

June 2017

85

Table 29.B. State Street Corporation
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

Actual
2016:Q4

Original planned capital
actions

11.6
14.7
16.0
6.5
n/a

Adjusted planned capital
actions

7.3
10.4
11.3
4.5
4.1

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios, other than for the supplementary leverage ratio, are for the period 2017:Q1 to
2019:Q1. The minimum supplementary leverage ratio is for the period 2018:Q1 to 2019:Q1. The minimum capital ratios do not necessarily occur in the same quarter.
n/a Not applicable.

Required minimum capital ratios for firms subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0
n/a

4.5
6.0
8.0
4.0
3.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.
n/a Not applicable.

86

CCAR 2017: Assessment Framework and Results

Table 30.A. SunTrust Banks, Inc.
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Severely adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio

Actual
2016:Q4

Original planned capital
actions

9.6
10.3
12.3
9.2

Adjusted planned capital
actions

5.4
6.8
9.2
6.1

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios are for the period 2017:Q1 to 2019:Q1 and do not necessarily occur in the same
quarter.

Required minimum capital ratios for firms not subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0

4.5
6.0
8.0
4.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.

June 2017

87

Table 30.B. SunTrust Banks, Inc.
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio

Actual
2016:Q4

Original planned capital
actions

9.6
10.3
12.3
9.2

Adjusted planned capital
actions

7.0
8.4
10.4
7.4

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios are for the period 2017:Q1 to 2019:Q1 and do not necessarily occur in the same
quarter.

Required minimum capital ratios for firms not subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0

4.5
6.0
8.0
4.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.

88

CCAR 2017: Assessment Framework and Results

Table 31.A. TD Group US Holdings LLC
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Severely adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

Actual
2016:Q4

Original planned capital
actions

13.6
13.7
14.8
7.8
n/a

Adjusted planned capital
actions

11.3
11.3
12.6
6.4
5.8

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios, other than for the supplementary leverage ratio, are for the period 2017:Q1 to
2019:Q1. The minimum supplementary leverage ratio is for the period 2018:Q1 to 2019:Q1. The minimum capital ratios do not necessarily occur in the same quarter.
n/a Not applicable.

Required minimum capital ratios for firms subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0
n/a

4.5
6.0
8.0
4.0
3.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.
n/a Not applicable.

June 2017

89

Table 31.B. TD Group US Holdings LLC
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

Actual
2016:Q4

Original planned capital
actions

13.6
13.7
14.8
7.8
n/a

Adjusted planned capital
actions

13.2
13.2
14.2
7.4
6.8

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios, other than for the supplementary leverage ratio, are for the period 2017:Q1 to
2019:Q1. The minimum supplementary leverage ratio is for the period 2018:Q1 to 2019:Q1. The minimum capital ratios do not necessarily occur in the same quarter.
n/a Not applicable.

Required minimum capital ratios for firms subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0
n/a

4.5
6.0
8.0
4.0
3.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.
n/a Not applicable.

90

CCAR 2017: Assessment Framework and Results

Table 32.A. U.S. Bancorp
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Severely adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

Actual
2016:Q4

Original planned capital
actions

9.4
11.0
13.2
9.0
n/a

Adjusted planned capital
actions

6.3
7.9
10.2
6.5
5.2

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios, other than for the supplementary leverage ratio, are for the period 2017:Q1 to
2019:Q1. The minimum supplementary leverage ratio is for the period 2018:Q1 to 2019:Q1. The minimum capital ratios do not necessarily occur in the same quarter.
n/a Not applicable.

Required minimum capital ratios for firms subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0
n/a

4.5
6.0
8.0
4.0
3.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.
n/a Not applicable.

June 2017

91

Table 32.B. U.S. Bancorp
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

Actual
2016:Q4

Original planned capital
actions

9.4
11.0
13.2
9.0
n/a

Adjusted planned capital
actions

7.7
9.3
11.3
7.6
6.1

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios, other than for the supplementary leverage ratio, are for the period 2017:Q1 to
2019:Q1. The minimum supplementary leverage ratio is for the period 2018:Q1 to 2019:Q1. The minimum capital ratios do not necessarily occur in the same quarter.
n/a Not applicable.

Required minimum capital ratios for firms subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0
n/a

4.5
6.0
8.0
4.0
3.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.
n/a Not applicable.

92

CCAR 2017: Assessment Framework and Results

Table 33.A. Wells Fargo & Company
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Severely adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

Actual
2016:Q4

Original planned capital
actions

11.1
12.8
16.1
8.9
n/a

Adjusted planned capital
actions

7.4
9.0
12.1
6.3
5.3

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios, other than for the supplementary leverage ratio, are for the period 2017:Q1 to
2019:Q1. The minimum supplementary leverage ratio is for the period 2018:Q1 to 2019:Q1. The minimum capital ratios do not necessarily occur in the same quarter.
n/a Not applicable.

Required minimum capital ratios for firms subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0
n/a

4.5
6.0
8.0
4.0
3.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.
n/a Not applicable.

June 2017

93

Table 33.B. Wells Fargo & Company
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

Actual
2016:Q4

Original planned capital
actions

11.1
12.8
16.1
8.9
n/a

Adjusted planned capital
actions

9.1
10.7
13.4
7.3
6.3

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios, other than for the supplementary leverage ratio, are for the period 2017:Q1 to
2019:Q1. The minimum supplementary leverage ratio is for the period 2018:Q1 to 2019:Q1. The minimum capital ratios do not necessarily occur in the same quarter.
n/a Not applicable.

Required minimum capital ratios for firms subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio
Supplementary leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0
n/a

4.5
6.0
8.0
4.0
3.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.
n/a Not applicable.

94

CCAR 2017: Assessment Framework and Results

Table 34.A. Zions Bancorporation
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Severely adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio

Actual
2016:Q4

Original planned capital
actions

12.1
13.5
15.2
11.1

Adjusted planned capital
actions

6.6
7.7
9.8
6.3

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios are for the period 2017:Q1 to 2019:Q1 and do not necessarily occur in the same
quarter.

Required minimum capital ratios for firms not subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0

4.5
6.0
8.0
4.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.

June 2017

95

Table 34.B. Zions Bancorporation
Actual and minimum projected regulatory capital ratios, actual 2016:Q4 and projected
2017:Q1–2019:Q1
Federal Reserve estimates: Adverse scenario
Actual 2016:Q4 and projected capital ratios through 2019:Q1
Percent
Minimum stressed ratios
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio

Actual
2016:Q4

Original planned capital
actions

12.1
13.5
15.2
11.1

Adjusted planned capital
actions

9.2
10.2
12.0
8.2

Note: These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital
ratios. The tables include the minimum ratios assuming the capital actions originally submitted in April 2017 by the bank holding companies (BHCs) in their annual capital plans
and the minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve’s stress test projections and original planned
capital distributions for those BHCs that did not make adjustments. The minimum capital ratios are for the period 2017:Q1 to 2019:Q1 and do not necessarily occur in the same
quarter.

Required minimum capital ratios for firms not subject to the advanced approaches capital framework in CCAR 2017
Percent
Minimum ratio
Regulatory ratio

Common equity tier 1 capital ratio
Tier 1 risk-based capital ratio
Total risk-based capital ratio
Tier 1 leverage ratio

2017

2018–19

4.5
6.0
8.0
4.0

4.5
6.0
8.0
4.0

Note: All ratios are calculated in accordance with the transition arrangements provided in the Board's revised capital framework, issued in July 2013. Per recent technical
amendments to the stress test and capital plan rules, the use of the advanced approaches risk-weighted asset calculations is indefinitely delayed.

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