One side effect of the Fed stress tests is that they have forced banks to invest more in technology, such as analytics and data aggregation tools, and infrastructure related to enterprise risk management. Indeed, overall the Fed stress tests have spurred a massive change in the way the industry looks at enterprise risk management, says Adam Girling, a manager at Ernst & Young.
"It has been a colossal effort," he notes. "Banks have put a lot of specific infrastructure in place to deal with CCAR. But despite the pain, I think most people have found that this has been a useful exercise, especially for the management and the board level. It's forced the industry to invest in more robust stress-testing infrastructure, and firms have really learned something about their risk profile and capital adequacy."
Girling adds that the banking industry is far from done, however, when it comes to the evolving way it looks at risk and capital adequacy. Banks have invested in the infrastructure needed to deal with the requirements of the stress tests, he says, "but now they're looking hard at better systems, data controls and how to improve the efficiency and effectiveness of this process. Also, the vendor landscape is starting to catch up [to the stress test requirements], there is more availability of tools that have come on the market."
Further, though banks have been building the framework to do this over the past several years, they now must actually put that structure to work, notes Accenture's Klein. "It's not just about building the capabilities but figuring out how to use them. The processes have been set up and now banks are working on how to operationalize them."
Small Bank Stress
Perhaps the biggest change this year in the stress test process is the requirement that midtier banks be subjected to the tests. Even though banks in the $10 billion to $50 billion range won't be subjected to as intensive a process as the nation's largest banks are, there are still similar expectations that banks of this size will deliver the data the Fed is seeking, adds Ernst & Young's Girling.
"Even though their requirements may be a little less, there is still a significant investment needed to put the infrastructure in place, and not all of them will have it in place from day one," he says. "We'll probably see a few more years of investment as banks get up to speed."
Primatics' Sant says one fear is that many of the banks in this asset range will not be suitably prepared for the stress tests. Though they won't be subjected to as robust reporting requirements as the larger banks, many still won't be ready since they don't normally take into consideration how they might be affected by large, macroeconomic scenarios. On the other hand, Sant also notes that many smaller banks are far better capitalized than larger banks and not as systemically important to the national economy, meaning it could also be less likely they will fail the stress tests.
One thing that is likely to occur for banks of this size, however, is an increased investment in their risk management departments, Sant says. "Everyone will have to increase their fixed cost of compliance and that will squeeze some banks," he says.
The American Bankers Association, while supportive of the idea of stress testing as a tool for banks to understand and manage risk, believes the Federal Reserve needs to adopt a more flexible testing approach for banks with less than $50 billion in assets. In an April 2013 comment letter to the Fed written by the ABA's senior counsel, Hugh Carey, the industry group said the Fed must "clearly communicate expectations commensurate with an institution's size, complexity and familiarity with stress testing for smaller banks.
"Banks with $50 billion or more in assets previously participated in one or more of the Supervisory Capital Assessment Program (SCAP), comprehensive Capital Analysis and Review (CCAR) or Capital Plan Review (CapPR)," Carey writes. "Smaller banks have not participated in these processes and are not familiar with the agencies' expectations. As a result, these institutions do not know how best to comply with the proposed procedures." Further, the ABA recommends that the implementation date for smaller banks be extended to 2014, and that banks with a smaller geographic footprint be allowed to develop their own scenarios.
[Risk Management Must Be Priority For All Banks, Not Just The Biggest]
Like the ABA, the Financial Services Roundtable's Pawlenty agrees that these smaller institutions should not be subjected to the same rigor as big banks, but overall supports the idea of smaller banks being subjected to the stress tests. Pawlenty believes it is important to ensure that "banks of all sizes are sound" and that smaller banks can likely benefit and learn something about their market capitalization from the tests.
"Small banks can fail, too, and in some cases they have," he adds.
Another advocate for the concept that stress testing banks in the $10 billion to $50 billion range is ultimately a good thing for the national economy is Reetu Kholsa, a director at Pegasystems, which provides business process management and customer relationship management solutions. "If you take all the midtier banks and compile them together, the sum of all their parts is a big bank," she adds.
Kholsa also believes that being subjected to the stress tests will ultimately be good for banks of this size because it will force them to invest in better technology. Further, she suggests that being stress tested may actually provide a competitive advantage for these banks and make them more attractive to consumers because the fact that they have undergone and passed Fed capital requirement tests "brings credibility to the marketplace."