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Better Markets Issues Comment Letter on Proposed Amendments to Capital Planning and Stress Testing Requirements

On November 11, 2020, Better Markets filed a comment letter on a proposed rule from the Federal Reserve which would amend the capital planning and stress testing requirements for certain large banks. This proposal is nominally designed to conform the capital planning and stress testing requirements with other changes to the prudential requirements applicable to larger banks recently made by the Board and other regulators. However, there are aspects of the proposal which would themselves increase systemic risk.

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