Troubled Asset Relief Program: Bank Stress Test Offers Lessons as Regulators Take Further Actions to Strengthen Supervisory Oversight
Released: 2010-09-29T00:00:00

Letter

Background

Despite efforts undertaken by TARP to bolster capital of the largest financial institutions, market conditions in the beginning of 2009 were deteriorating and public confidence in the ability of financial institutions to withstand losses and to continue lending were further declining. On February 10, 2009, Treasury announced the Financial Stability Plan, which outlined measures to address the financial crisis and restore confidence in the U.S. financial and housing markets. The goals of the plan were to (1) restart the flow of credit to consumers and businesses, (2) strengthen financial institutions, and (3) provide aid to homeowners and small businesses. Under SCAP, the stress test would assess the ability of the largest 19 BHCs to absorb losses if economic conditions deteriorated further in a hypothetical “more adverse” scenario, characterized by a sharper and more protracted decline in gross domestic product (GDP) growth, a steeper drop in home prices, and a larger rise in the unemployment rate than in a baseline consensus scenario. BHCs that were found not to meet the SCAP capital buffer requirement under the “more adverse” scenario would need to provide a satisfactory capital plan to address any shortfall by raising funds, privately if possible. CAP, which was a key part of the plan, would provide backup capital to financial institutions unable to raise funds from private investors. Any of the 19 BHCs that participated in the stress test and had a capital shortfall could apply for capital from CAP immediately if necessary. The timeline in figure 1 provides some highlights of key developments in the implementation of SCAP.

In a joint statement issued on February 10, 2009, Treasury, along with the Federal Reserve, FDIC, and OCC (collectively referred to as the SCAP regulators), committed to design and implement the stress test. According to a Treasury official, the department generally did not participate in the design or implementation of SCAP, but was kept informed by the Federal Reserve during the stress test. The SCAP regulators developed economic assumptions to estimate the potential impact of further losses on BHCs’ capital under two scenarios. The baseline scenario reflected the consensus view about the depth and duration of the recession, and the more adverse scenario reflected a plausible but deeper and longer recession than the consensus view. Regulators then calculated how much capital, if any, was required for each BHC to achieve the required SCAP buffer at the end of 2010 under the more adverse scenario.

The SCAP assessment examined tier 1 capital and tier 1 common capital, and the BHCs were required to raise capital to meet any identified capital shortfall (either tier 1 capital or tier 1 common capital). Tier 1 risk-based capital is considered core capital—the most stable and readily available for supporting a bank’s operations and includes elements such as common stock and noncumulative perpetual preferred stock. SCAP’s focus on tier 1 common capital, a subset of tier 1 capital, reflects the recent regulatory push for BHCs to hold a higher quality of capital. The focus on common equity reflected both the long held view by bank supervisors that common equity should be the dominant component of tier 1 capital and increased market scrutiny of common equity ratios, driven in part by deterioration in common equity during the financial crisis. Common equity offers protection to more senior parts of the capital structure because it is the first to absorb losses in the capital structure. Common equity also gives a BHC greater permanent loss absorption capacity and greater ability to conserve resources under stress by changing the amount and timing of dividends and other distributions.

To protect against risks, financial regulators set minimum standards for the capital that firms are to hold. However, SCAP set a one-time minimum capital buffer target for BHCs to hold to protect against losses and preprovision net revenue (PPNR) that were worse than anticipated during the 2009 to 2010 period. For the purposes of SCAP, the one-time target capital adequacy ratios are at least 6 percent of risk-weighted assets in tier 1 capital and at least 4 percent in tier 1 common capital projected as of December 31, 2010. For the purposes of the projection, the regulators assumed that BHCs would suffer the estimated losses and earned revenues in 2009 and 2010 in the more adverse scenario. SCAP regulators conducted the stress test strictly on the BHCs’ assets as of December 31, 2008, and—with the exception of off-balance sheet positions subject to Financial Accounting Statements No. 166 and 167, which assumed in the analysis to come on balance sheet as of January 1, 2010—did not take int account any changes in the composition of their balance sheets over the year time frame.

Stress testing is one of many risk management tools used by both BHCs and regulators. Complex financial institutions need management information systems that can help firms to identify, assess, and manage a full range of risks across the whole organization arising from both internal and external sources and from assets and obligations that are found both on and off the BHC’s balance sheet. This approach is intended to help ensure that a firmwide approach to managing risk has been viewed as being crucial for responding to rapid and unanticipated changes in financial markets. Risk management also depends on an effective corporate governance system that addresses risk across the institution and also within specific areas, such as subprime mortgage lending. The board of directors, senior management, audit committee, internal auditors, external auditors, and others play important roles in effectively operating a risk management system. The different roles of each of these groups represent critical checks and balances in the overall risk management system. However, the management information systems at many financial institutions have been called into question since the financial crisis began in 2007. Identified shortcomings, such as lack of firmwide stress testing, have led banking organizations and their regulators to reassess capital requirements, risk management practices, and other aspects of bank regulation and supervision.

Stress testing has been used throughout the financial industry for more than 10 years, but has recently evolved as a risk management tool in response to the urgency of the financial crisis. The main evolution is towards the use of comprehensive firmwide stress testing as an integral and critical part of firms’ internal capital adequacy assessment processes. In the case of SCAP, the intent of the stress test was to help ensure that the capital held by a BHC is sufficient to withstand a plausible adverse economic environment over the 2-year time frame ending December 31, 2010. The Basel Committee on Banking Supervision (Basel Committee) issued a document in May 2009 outlining several principles for sound stress testing practices and supervision. The Basel Committee document endorses stress testing by banks as a part of their internal risk management to assess the following: Credit risk. The potential for financial losses resulting from the failure of a borrower or counterparty to perform on an obligation.

Market risk. The potential for financial losses due to an increase or decrease in the value of an asset or liability resulting from broad price movements; for example, in interest rates, commodity prices, stock prices, or the relative value of currencies (foreign exchange).

Liquidity risk. The potential for financial losses due to an institution’s failure to meet its obligations because it cannot liquidate assets or obtain adequate funding.

Operational risk. The potential for unexpected financial losses due to a wide variety of institutional factors including inadequate information systems, operational problems, breaches in internal controls, or fraud.

Legal risk. The potential for financial losses due to breaches of law or regulation that may result in heavy penalties or other costs.

Compliance risk. The potential for loss arising from violations of laws or regulations or nonconformance with internal policies or ethical standards.

Strategic risk. The potential for loss arising from adverse business decisions or improper implementation of decisions.

Reputational risk. The potential for loss arising from negative publicity regarding an institution’s business practices.

SCAP Process Generally Viewed as Promoting Coordination, Transparency, and Capital Adequacy

According to SCAP regulators and many market participants we interviewed, the process used to design and implement SCAP was effective in promoting coordination and transparency among the regulators and participating BHCs, but some SCAP participants we interviewed expressed concerns about the process. The majority of supervisory and bank industry officials we interviewed stated that they were satisfied with how SCAP was implemented, especially considering the stress test’s unprecedented nature, limited time frame, and the uncertainty in the economy. SCAP established a process for (1) coordinating and communicating among the regulators and with the BHCs and (2) promoting transparency of the stress test to the public. In addition, according to regulators, the process resulted in a methodology that yielded credible results and by design helped to assure that the BHCs would be sufficiently capitalized to weather a more adverse economic downturn.

SCAP Process Included Coordination and Communication among the Federal Bank Regulators and with the BHCs

Robust coordination and communication are essential to programs like SCAP when bringing together regulatory staff from multiple agencies and disciplines to effectively analyze complex financial institutions and understand the interactions among multiple layers of risk. Moreover, supervisory guidance emphasizes the importance of coordination and communication among regulators to both effectively assess banks and conduct coordinated supervisory reviews across a group of peer institutions, referred to as “horizontal examinations.”

The regulators implemented each phase of SCAP in a coordinated interagency fashion. Also, while some disagreed, most regulators and market participants we interviewed were satisfied with the level of coordination and communication. They also thought that the SCAP process could serve as a model for future supervisory efforts. The regulators executed the SCAP process in three broad phases: In the first phase, the Analytical Group, comprising interagency economists and supervisors, generated two sets of economic conditions— a baseline scenario and a more adverse scenario with a worse-than- expected economic outcome—and then used these scenarios to aid in estimating industrywide indicative loan loss rates. To develop these scenarios, the Analytical Group used three primary indicators of economic health: the U.S. GDP, housing prices in 10 key U.S. cities, and the annual average U.S. unemployment rate. The baseline scenario reflected the consensus view of the course for the economy as of February 2009, according to well-known professional economic forecasters. The Federal Reserve developed the more adverse scenario from the baseline scenario by taking into account the historical accuracy of the forecasts for unemployment and the GDP and the uncertainty of the economic outlook at that time by professional forecasters. The Federal Reserve also used regulators’ judgment about the appropriate severity of assumed additional stresses against which BHCs would be required to hold a capital buffer, given that the economy was already in a recession at the initiation of SCAP.

In the second phase, several Supervisory Analytical and Advisory Teams— comprising interagency senior examiners, economists, accountants, lawyers, financial analysts, and other professionals from the SCAP regulators—collected, verified, and analyzed each BHC’s estimates for losses, PPNR, and allowance for loan and lease losses (ALLL). The teams also collected additional data to evaluate the BHC’s estimates, and to allow supervisors to develop their own independent estimates of losses for loans, trading assets, counterparty credit risk, and securities and PPNR for each BHC.

In the third phase, the Capital Assessment Group, comprising interagency staff, served as the informal decision-making body for SCAP. The Capital Assessment Group developed a framework for combing the Supervisory Analytical and Advisory Teams’ estimates with other independent supervisory estimates of loan losses and resources available to absorb these losses. They evaluated the estimates by comparing across BHCs and by aggregating over the 19 BHCs to check for consistency with the specified macroeconomic scenarios to calculate the amount, if any, of additional capital needed for each BHC to achieve the SCAP buffer target capital ratios as of December 31, 2010, in the more adverse economic environment. Lastly, the Capital Assessment Group set two deadlines: (1) June 8, 2009, for BHCs requiring capital to develop and submit a capital plan to the Federal Reserve on how they would meet their SCAP capital shortfall and (2) November 9, 2009, for these BHCs to raise the required capital.

A key component of this process was the involvement of multidisciplinary interagency teams that leveraged the skills and experiences of staff from different disciplines and agencies. The Federal Reserve, OCC, and FDIC had representatives on each SCAP team (the Analytical Group, Supervisory Analytical and Advisory Teams, and the Capital Assessment Group). For example, OCC officials said that they contributed to the development of quantitative models required for the implementation of SCAP and offered their own models for use in assessing the loss rates of certain portfolios. In addition, each of the SCAP regulators tapped expertise within their organization for specific disciplines, such as accounting, custodial banking, macroeconomics, commercial and industry loan loss modeling, and consumer risk modeling. According to the FDIC, the broad involvement of experts from across the agencies helped validate loss assumptions and also helped improve confidence in the results. Further, these officials noted that the SCAP process was enhanced because productive debate became a common event as team members from different regulatory agencies and disciplines brought their own perspectives and ideas to the process. For example, some SCAP staff argued for a more moderate treatment of securities in BHCs’ available for sale portfolios, which would have been consistent with generally accepted accounting principles under a new change in accounting standards. They maintained that the modified accounting standard for declines in market value (and discounting the impact of liquidity premia) that had been implemented after the stress test was announced and before the numbers had been finalized was in some ways more reflective of the realized credit loss expectations for the affected securities. After significant discussion, the regulators decided to allow for the accounting change in the baseline loss estimates, but not in the more adverse scenario estimates. They believed that under the more adverse scenario there was a heightened possibility of increased liquidity demands on banks and that many distressed securities would need to be liquidated at distressed levels. Consequently, for securities found to be other than temporarily impaired in the more adverse scenario, they assumed the firm would have to realize all unrealized losses (i.e., write down the value of the security to market value as of year end 2008). Similarly, some staff argued against adopting other changes in accounting standards that were expected to impact BHCs’ balance sheets, including their capital adequacy. Primary among these was the inclusion of previously off-balance sheet items. As noted above, ultimately, the more conservative approach prevailed and the expected inclusion of these assets was addressed in SCAP.

To facilitate coordination, the Federal Reserve instituted a voting system to resolve any contentious issues, but in practice differences among regulators were generally resolved through consensus. When SCAP regulators met, the Federal Reserve led the discussions and solicited input from other regulators. For example, officials from OCC and FDIC both told us that they felt that they were adequately involved in tailoring the aggregate loss estimates to each BHC as part of the determination of each BHC’s SCAP capital requirement. SCAP regulators were also involved in drafting the design and results documents, which were publicly released by the Federal Reserve.

Representatives from most of the BHCs were satisfied with the SCAP regulators’ coordination and communication. Many of the BHC officials stated that they were generally impressed with the onsite SCAP teams and said that these teams improved the BHCs’ coordination and communication with the regulators. BHC officials said that they usually received answers to their questions in a timely manner, either during conference calls held three times a week, through the distribution of answers to frequently asked questions, or from onsite SCAP examiners. Collecting and aggregating data were among the most difficult and time- consuming tasks for BHCs, but most of them stated that the nature of the SCAP’s requests were clear. At the conclusion of SCAP, the regulators presented the results to each of the institutions showing the final numbers that they planned to publish.

Market Participants Generally Agreed that the SCAP Process Was Transparent

The SCAP process included steps to promote transparency, such as the release of key program information to SCAP BHCs and the public. According to SCAP regulators, BHCs, and credit rating agency officials we interviewed, the release of the results provided specific information on the financial health and viability of the 19 largest BHCs regarding their ability to withstand additional losses during a time of significant uncertainty. Many experts have said that the lack of transparency about potential losses from certain assets contributed significantly to the instability in financial markets during the current crisis. Such officials also stated that publicly releasing the methodology and results of the stress test helped strengthen market confidence. Further, many market observers have commented that the Federal Reserve’s unprecedented disclosure of sensitive supervisory information for each BHC helped European bank regulators decide to publicly release detailed results of their own stress tests in July 2010.

Not all SCAP participants agreed that the SCAP process was fully transparent. For example, some participants questioned the transparency of certain assumptions used in developing the stress test. According to BHC officials and one regulator, the Federal Reserve could have shared more detailed information about SCAP loss assumptions and calculations with BHCs. According to several BHC officials, the Federal Reserve did not fully explain the methodology for estimating losses but expected BHC officials to fully document and provide supporting data for all of their assumptions. Without knowing the details of the methodology, according to some BHC officials, they could not efficiently provide all relevant information to SCAP examiners.

SCAP Was Designed to Help Ensure That BHCs Were Adequately Capitalized Under the More Adverse Economic Scenario

SCAP regulators aimed to ensure that SCAP sufficiently stressed BHCs’ risk exposures and potential PPNR under the more adverse scenario. To accomplish this, the regulators made what they viewed to be conservative assumptions and decisions in the following areas. First, the regulators decided to stress only assets that were on the BHCs’ balance sheets as of December 31, 2008, (i.e., a static approach) without accounting for new business activity. According to BHC officials, new loans were thought to have generally been of better quality than legacy loans because BHCs had significantly tightened their underwriting standards since the onset of the financial crisis. As a result, BHCs would have been less likely to charge- off these loans within the SCAP time period ending December 31, 2010, resulting in the potential for greater reported revenue estimates for the period. By excluding earnings from new business, risk-weighted assets were understated, charge-off rates were overstated, and projected capital levels were understated.

Second, SCAP regulators generally did not allow the BHCs to cut expenses to address the anticipated drop in revenues under the more adverse scenario. However, some BHC officials told us that they would likely cut expenses, including initiating rounds of layoffs, if the economy performed in accordance with the more adverse economic scenario, especially if they were not generating any new business. Federal Reserve officials noted that BHCs were given credit in the stress test for cost cuts made in the first quarter of 2009.

Third, some BHCs were required to assume an increase in their ALLL as of the end of 2010, if necessary, to ensure adequate reserves relative to their year end 2010 portfolio. Some BHC officials believed that this requirement resulted in the BHCs having to raise additional capital because the required ALLL increases were subtracted from the revenue estimates in calculating the resources available to absorb losses. This meant that some BHCs judged to have insufficient year end 2010 reserve adequacy had to account for this shortcoming in the calculation of capital needed to meet the SCAP targeted capital requirements as of the end of 2010 while maintaining a sufficient ALLL for 2011 losses under the more adverse economic scenario. According to some BHCs, the size of the 2010 ALLL was severe given the extent of losses are already included in the 2009 and 2010 loss estimates and effectively stressed BHCs for a third year.

Finally, according to many BHC officials and others, the calculations used to derive the loan loss rates and other assumptions to stress the BHCs were conservative (i.e., more severe). For example, the total loan loss rate estimated by the SCAP regulators was 9.1 percent, which was greater than the historical 2-year loan loss rates at all commercial banks from 1921 until 2008, including the worst levels seen during the Great Depression (see figure 2). However, the macroeconomic assumptions of the more adverse scenario, which we will discuss later in the report, did not meet the definition of a depression. Specifically, a 25 percent unemployment rate coupled with economic contraction is indicative of a depression. In contrast, the more adverse scenario estimated approximately a 10 percent unemployment rate with some economic growth in late 2010.

SCAP regulators also estimated ranges for loan loss rates within specific loan categories using the baseline and more adverse scenarios as guides. They used a variety of methods to tailor loan losses to each BHC, including an analysis of past BHC losses and quantitative models, and sought empirical support from BHCs regarding the risk level of their portfolios. However, some BHCs told us that the Federal Reserve made substantial efforts to help ensure conformity with the indicative loan loss rates while incorporating BHC-specific information where possible and reliable. Table 1 compares the different indicative loan loss rate ranges under the more adverse scenario for each asset category with actual losses in 2009 for SCAP BHCs and the banking industry. Some BHCs stated that the resulting loan loss rates were indicative of an economy worse off than that represented by the more adverse macroeconomic assumptions, although they recognized the need for the more conservative approach.

However, nearly all agreed that the loan loss rates were a more important indication of the stringency of SCAP than the assumptions.

After the public release of the SCAP methodology in April 2009, many observers commented that the macroeconomic assumptions for a more adverse economic downturn were not severe enough given the economic conditions at that time. In defining a more adverse economic scenario, the SCAP regulators made assumptions about the path of the economy using three broad macroeconomic indicators—changes in real GDP, the unemployment rate, and home prices—during the 2-year SCAP period ending December 2010. The actual performances of GDP and home prices have performed better than assumed under the more adverse scenario. However, the actual unemployment rate has more closely tracked the more adverse scenario (see figure 3). Further, as noted earlier, some regulatory and BHC officials have indicated that the loan loss rates that the regulators subsequently developed were more severe than one would have expected under the macroeconomic assumptions. While our analysis of actual and SCAP estimated indicative loan losses (see table 1) is generally consistent with this view, these estimates were developed at a time of significant uncertainty about the direction of the economy and the financial markets, as well as an unprecedented deterioration in the U.S. housing markets.

While SCAP Increased Capital Levels and Improved Confidence in the Banking System, BHCs Could Face Ongoing Challenges

SCAP largely met its goals of increasing the level and quality of capital held by the 19 largest BHCs and, more broadly, of strengthening market confidence in the banking system. The stress test identified 10 of the 19 BHCs as needing to raise a total of about $75 billion in additional capital. The Federal Reserve encouraged the BHCs to raise common equity via private sources—for example, through new common equity issuances, conversion of existing preferred equity to common equity, and sales of businesses or portfolios of assets. Nine of the 10 BHCs were able to raise the required SCAP amount of new common equity in the private markets by the November 9, 2009, deadline (see table 2). Some of these BHCs also raised capital internally from other sources. GMAC LLC (GMAC) was the only BHC that was not able to raise sufficient private capital by the November 9, 2009, deadline. On December 30, 2009, Treasury provided GMAC with a capital investment of $3.8 billion to help fulfill its SCAP capital buffer requirement, drawing funds from TARP’s Automotive Industry Financing Program. A unique and additional element of the estimated losses for GMAC included the unknown impact of possible bankruptcy filings by General Motors Corporation (GM) and Chrysler LLC (Chrysler). Thus, a conservative estimate of GMAC’s capital buffer was developed in response to this possibility. The Federal Reserve, in consultation with Treasury, subsequently reduced GMAC’s SCAP required capital buffer by $1.8 billion—$5.6 billion to $3.8 billion—primarily to reflect the lower-than-estimated actual losses from the bankruptcy proceedings of GM and Chrysler. GMAC was the only company to have its original capital buffer requirement reduced.

Capital adequacy generally improved across all 19 SCAP BHCs during 2009. As shown in table 3, the largest gains were in tier 1 common capital, which increased by about 51 percent in the aggregate across the 19 BHCs, rising from $412.5 billion on December 31, 2008, to $621.9 billion by December 31, 2009. On an aggregate basis, the tier 1 common capital ratio at BHCs increased from 5.3 percent to 8.3 percent of risk-weighted assets (compared with the SCAP threshold of 4 percent at the end of 2010). The tier 1 risk-based capital ratio also grew from 10.7 percent to 11.3 percent of risk-weighted assets (compared with the SCAP threshold of 6 percent at the end of 2010). While these ratios were helped to some extent by reductions in risk-weighted assets, which fell 4.3 percent from $7.815 trillion on December 31, 2008, to $7.481 trillion on December 31, 2009, the primary driver of the increases was the increase in total tier 1 common capital.

The quality of capital—measured as that portion of capital made up of tier 1 common equity—also increased across most of the BHCs in 2009. The tier 1 common capital ratio increased at 17 of the 19 BHCs between the end of 2008 and the end of 2009 (see table 4). Citigroup Inc. (Citigroup) and The Goldman Sachs Group, Inc. (Goldman Sachs) had the largest increases in tier 1 common capital ratios—747 and 450 basis points, respectively. However, GMAC’s tier 1 common capital ratio declined by 155 basis points in this period to 4.85 percent. MetLife, Inc. was the only other BHC to see a drop in its tier 1 common capital ratio, which fell by 33 basis points to 8.17 percent and still more than double the 4 percent target. Based on the SCAP results document, the 2008 balances in the table include the impact of certain mergers and acquisitions, such as Bank of America Corporation’s (Bank of America) purchase of Merrill Lynch & Co. Inc. Further, the increase in capital levels reflects the capital that was raised as a result of SCAP.

As previously stated by interviewees, the unprecedented public release of the stress test results helped to restore investors’ confidence in the financial markets. Some officials from participating BHCs and credit rating agencies also viewed the BHCs’ ability to raise the capital required by the stress test as further evidence of SCAP’s success in increasing market confidence and reducing uncertainty. But some expressed concerns that the timing of the announcement of SCAP on February 10, 2009—nearly 3 months before the results were released on May 7, 2009—may have intensified market uncertainty about the financial health of the BHCs.

A broad set of market indicators also suggest that the public release of SCAP results may have helped reduce uncertainty in the financial markets and increased market confidence. For example, banks’ renewed ability to raise private capital reflects improvements in perceptions of the financial condition of banks. Specifically, banks and thrifts raised significant amounts of common equity in 2008, totaling $56 billion. Banks and thrifts raised $63 billion in common equity in the second quarter of 2009 (see figure 4). The substantial increase in second quarter issuance of common equity occurred after the stress test results were released on May 7, 2009, and was dominated by several SCAP institutions.

Similarly, stock market prices since the release of the stress test results in May 2009 through October 2009 improved substantially in the overall banking sector and among the 18 public BHCs that participated in SCAP (see figure 5). The initial increase since May 2009 also suggests that SCAP may have helped bolster investor and public confidence. However, equity markets are generally volatile and react to a multitude of events.

Credit default swap spreads, another measure of confidence in the banking sector, also improved. A credit default swap is an agreement in which a buyer pays a periodic fee to a seller in exchange for protection from certain credit events such as bankruptcy, failure to pay debt obligations, or a restructuring related to a specific debt issuer or issues known as the reference entity. Therefore, the credit default swap spread, or market price, is a measure of the credit risk of the reference entity, with a higher spread indicating a greater amount of credit risk. When the markets’ perception of the reference entity’s credit risk deteriorates or improves, the spread generally will widen or tighten, respectively. Following the SCAP results release in May 2009, the credit default swap spreads continued to see improvements (see figure 6). While many forces interact to influence investors’ actions, these declining spreads suggest that the market’s perception of the risk of banking sector defaults was falling. Further, the redemption of TARP investments by some banking institutions demonstrated that regulators believed these firms could continue to serve as a source of financial and managerial strength, as well as fulfill their roles as intermediaries that facilitate lending, while both reducing reliance on government funding and maintaining adequate capital levels. This positive view of the regulators may also have helped increase market confidence in the banking system (see appendix II for details on the status of TARP investments in the institutions participating in SCAP).

The 19 Tested BHCs Experienced Better Performance Than a Pro Rata Estimate under the More Adverse Scenario

As of the end of 2009, while the SCAP BHCs generally had not experienced the level of losses that were estimated on a pro rata basis under the stress test’s more adverse economic scenario, concerns remain that some banks could absorb potentially significant losses in certain asset categories that would erode capital levels. Collectively, the BHCs’ total loan losses of $141.2 billion were approximately 38 percent less than the GAO-calculated $229.4 billion in pro rata losses under the more adverse scenario for 2009 (see table 5). The BHCs also experienced significant gains in securities and trading and counterparty credit risk portfolios compared with estimated pro rata losses under SCAP. Total resources other than capital to absorb losses (resources) were relatively close to the pro rata amount, exceeding it by 4 percent.

In tracking BHCs’ losses and resources against the SCAP estimates, we compared the actual results with those estimated under the more adverse scenario. We used the 2-year estimates of the more adverse scenario from the SCAP results and annualized those amounts by dividing them in half (the “straight line” method) to get pro rata loss estimates for 2009 because the SCAP regulators did not develop estimates on a quarterly or annual basis. A key limitation of this approach is that it assumes equal distribution of losses, revenues, expenses, and changes to reserves over time, although these items were unlikely to be distributed evenly over the 2-year period. Another important consideration is that actual results were not intended and should not be expected to align with the SCAP projections. Actual economic performance in 2009 differed from the SCAP macroeconomic variable inputs, which were based on a scenario that was more adverse than was anticipated or than occurred, and other forces in the business and regulatory environment could have influenced the timing and level of losses. Appendix I contains additional details on our methodology, including our data sources and calculations, for tracking BHCs’ financial performance data.

Losses Varied by Individual BHCs

Although the 19 BHCs’ actual combined losses were less than the 2009 pro rata loss estimates for the more adverse scenario, the loss rates varied significantly by individual BHCs. For example, most of the BHCs had consumer and commercial loan losses that were below the pro rata loss estimates, but three BHCs—GMAC, Citigroup, and SunTrust Banks Inc. (SunTrust)—exceeded these estimates in at least one portfolio (see figure 7). GMAC was the only one with 2009 loan losses on certain portfolios that exceeded SCAP’s full 2-year estimate. Specifically, GMAC exceeded the SCAP 2-year estimated losses in the first-lien, second/junior lien, and commercial real estate portfolios and the 1-year pro rata losses in the “Other” portfolio; Citigroup exceeded the 1-year pro rata estimated losses in the commercial and industrial loan portfolio; and SunTrust exceeded the 1-year estimated losses in the first-lien and credit card portfolios. Appendix III provides detailed data on the individual performance of each of the BHCs.

GMAC faced particular challenges in the first year of the assessment period and posed some risk to the federal government, a majority equity stakeholder. GMAC’s loan losses in its first-lien portfolio were $2.4 billion, compared with the $2 billion projected for the full 2-year period. In the second/junior lien portfolio, GMAC saw losses of $1.6 billion, compared with the $1.1 billion estimated losses for the 2 years. GMAC experienced losses of $710 million in its commercial real estate portfolio, compared with $600 million projected for the full 2-year period. Further, in its “Other” portfolio (which is comprised of auto leases and consumer auto loans), GMAC’s losses were $2.1 billion, exceeding the 1-year pro rata $2 billion loss estimate. With a tier 1 common capital ratio of 4.85 percent— just more than the SCAP threshold of 4 percent—at the end of 2009, GMAC has a relatively small buffer in the face of potential losses.

GMAC’s position should be placed in context, however, because it is relatively unique among the SCAP participants. It was the only nonpublicly traded participant, and the federal government owns a majority equity stake in the company as a result of capital investments made through the Automotive Industry Financing Program under TARP. Further, GMAC’s core business line—financing for automobiles—is dependent on the success of efforts to restructure, stabilize, and grow General Motors Company and Chrysler Group LLC. Finally, the Federal Reserve told us that because GMAC only recently became a BHC and had not previously been subject to banking regulations, it would take some time before GMAC was fully assimilated into a regulated banking environment. To improve its future operating performance and better position itself to become a public company in the future, GMAC officials stated that the company posted large losses in the fourth quarter of 2009 as result of accelerating its recognition of lifetime losses on loans. In addition, the company has been restructuring its operations and recently sold off some nonperforming assets. However, the credit rating agencies we met with generally believed that there could still be further losses at GMAC, although the agencies were less certain about the pace and level of those losses. Two of the agencies identified GMAC’s Residential Capital, LLC mortgage operation as the key source of potential continued losses.

BHCs Are Generally Not Experiencing the Level of Securities and Trading Losses That Were Estimated under the Pro Rata More Adverse Scenario, and Some Have Recorded Gains

Given that market conditions have generally improved, the BHCs’ investments in securities and trading account assets performed considerably better in 2009 than had been estimated under the pro rata more adverse scenario. The SCAP assessment of the securities portfolio consisted of an evaluation for possible impairment of the portfolio’s assets, including Treasury securities, government agency securities, sovereign debt, and private sector securities. In the aggregate, the securities portfolio has experienced a gain of $3.5 billion in 2009, compared with a pro rata estimated loss of $17.6 billion under the stress test’s more adverse scenario. As figure 8 shows, 5 of the 19 BHCs recorded securities losses in 2009, 13 recorded gains, and 1 (Morgan Stanley) recorded no gain or loss. Losses were projected at 17 of the BHCs under the pro rata more adverse scenario, and SCAP regulators did not consider the remaining 2 BHCs (American Express Company and Morgan Stanley) to be applicable for this category. In the securities portfolio, The Bank of New York Mellon Corporation had losses greater than estimated under SCAP for the full 2-year period. The variances could be due to a number of factors, including the extent to which a BHC decides to deleverage, how their positions react to changing market values, and other factors.

To estimate trading and counterparty losses, SCAP regulators assumed that these investments would be subject to the change in value of a proportional level as experienced in the last half of 2008. The trading portfolio shows an even greater difference between the 1-year pro rata estimates and the actual performance—a gain of $56.9 billion in 2009 rather than the pro rata $49.7 billion estimated loss under the more adverse scenario (see table 5). The stress test only calculated trading and counterparty credit loss estimates for the five BHCs with trading assets that exceeded $100 billion. All five had trading gains as opposed to losses, based on the publicly available data from the Y-9C. These gains were the result of a number of particular circumstances. First, the extreme spreads and risk premium resulting from the lack of liquidity during the financial crisis—especially in the second half of 2008—reversed in 2009, improving the pricing of many risky trading assets that remained on BHCs’ balance sheets. Because the trading portfolio is valued at fair value, it had been written down for the declines in value that occurred throughout 2008 and the first quarter of 2009 and saw significant gains when the market rebounded through the remainder of 2009. Second, the crisis led to the failure or absorption of several large investment banks, reducing the number of competitors and, according to our analysis of Thomson Reuters Datastream, increased market share and pricing power for the remaining firms. Finally, the Federal Reserve’s low overnight bank lending rates (near 0 percent) have prevailed for a long period and have facilitated a favorable trading environment for BHCs. This enabled BHCs to fund longer-term, higher yielding assets in their trading portfolios with discounted wholesale funding (see figure 9).

Potential Losses in Consumer and Commercial Credit Continue to Pose a Challenge

Potentially large losses in consumer and commercial loans continue to challenge SCAP BHCs, and addressing these challenges depends on a variety of factors, including, among other things, the effectiveness of federal efforts to reduce foreclosures in the residential mortgage market. The BHCs absorbed nearly $400 billion in losses in the 18 months ending December 31, 2008. As they continue to experience the effects of the recent financial crisis, estimating precisely how much more they could lose is difficult. In March 2010, officials from two credit rating agencies indicated that 50 percent or more of the losses the banking industry was expected to incur during the current financial crisis could still be realized if the economy were to suffer further stresses.

Data for the 19 BHCs show a rapid rise in the percentage of nonperforming loans over the course of 2009 (see figure 10). Specifically, total nonperforming loans grew from 1 percent in the first quarter of 2007 to 6.6 percent in the fourth quarter of 2009 for SCAP BHCs. In particular, increases in total nonperforming loans were driven by significant growth in nonperforming first-lien mortgages and commercial real estate loans. Standard & Poor’s Corporation noted that many nonperforming loans may ultimately have to be charged-off, exposing the BHCs to further potential losses. According to the credit rating agencies that we interviewed, federal housing policy to aid homeowners who are facing foreclosures, as well as time lags in the commercial real estate markets, will likely continue to affect the number of nonperforming loans for the remainder of the SCAP time frame (December 2010).

The Economic and Regulatory Environment Could Impact BHCs’ Net Revenues and Loss Reserves

The total amount of resources other than capital to absorb losses (resources) has tracked the amount GAO prorated under the stress test’s more adverse scenario. Resources measure how much cushion the BHCs have to cover loans losses. As shown previously in table 5, the aggregate actual results through the end of 2009 for resources showed a total of $188.4 billion, or 4 percent more than GAO’s pro rata estimated $181.5 billion in the stress test’s more adverse scenario. Eleven of the 19 BHCs tracked greater than the pro rata estimated amount in 2009, while the remaining 8 tracked less than the estimate (see figure 11). GMAC and MetLife, Inc. had negative resources in 2009, although only GMAC was projected to have negative resources over the full 2-year period.

Our calculation considers increases in ALLL during 2009 to be a drain on resources in order to mirror the regulators’ calculation for the full 2-year projection. However, the ALLL may ultimately be used as a resource in 2010, causing available resources to be higher than they currently appear in our tracking. PPNR is based on numerous factors, including interest income, trading revenues, and expenses. The future course of this resource will be affected by factors such as the performance of the general economy, the BHCs’ business strategies, and regulatory changes, including the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank Act) and the Credit Card Accountability, Responsibility, and Disclosure Act of 2009. Such regulatory changes could impose additional costs or reduce future profitability, either of which would impact future PPNR.

SCAP Provided Lessons That Could Help Regulators Strengthen Supervisory Oversight and BHCs Improve Risk Management Practices

The SCAP stress test provided lessons in a number of areas that can be incorporated in the bank supervision process and used to improve BHCs’ risk management practices. First, the transparency that was part of SCAP helped bolster market confidence, but the Federal Reserve has not yet developed a plan that incorporates transparency into the supervisory process. Second, the SCAP experience highlighted that BHCs’ stress tests in the past were not sufficiently comprehensive and we found that regulators’ oversight of these tests has been generally weak. Third, we identified opportunities to enhance both the process and data inputs for conducting stress testing in the future. Finally, SCAP demonstrated the importance of robust coordination and communication among the different regulators as an integral part of any effective supervisory process. By incorporating these lessons going forward, regulators will be able to enhance their ability to efficiently and effectively oversee the risk- taking in the banking industry.

SCAP’s Transparency Helped Bolster Market Confidence, but the Federal Reserve Has Yet to Implement a Plan to Incorporate Greater Transparency into the Supervisory Process

As stated earlier and as agreed generally by market participants, the public release of the SCAP design and results helped restore confidence in the financial system during a period of severe turmoil. Some agency officials stated that their experience in implementing SCAP suggested that greater transparency would also be beneficial in the supervisory process. In recent statements, the chairman and a governor of the Federal Reserve have both stated that, while protecting the confidentiality of firm-specific proprietary information is imperative, greater transparency about the methods and conclusions of future stress tests could benefit from greater scrutiny by the public. The Federal Reserve governor also noted that feedback from the public could help to improve the methodologies and assumptions used in the supervisory process. In addition, they noted that more transparency about the central bank’s activities overall would ultimately enhance market discipline and that the Federal Reserve is looking at ways to enhance its disclosure policies.

Consistent with the goal of greater transparency, we previously recommended that the Federal Reserve consider periodically disclosing to the public the aggregate performance of the 19 BHCs against the SCAP estimates for the 2-year forecast period. Subsequently, the chairman and a governor of the Federal Reserve have publicly disclosed 2009 aggregate information about the performance of the 19 BHCs based on the Federal Reserve’s internal tracking. As the 2-year SCAP period comes to a close at the end of 2010, completing a final analysis that compares the performance of BHCs with the estimated performance under the more adverse economic scenario would be useful; however, at the time of the review, Federal Reserve officials told us that they have not decided whether to conduct and publicly release any type of analysis. Given that the chairman and a governor of the Federal Reserve have already publicly disclosed some aggregate BHC performance against the more adverse scenario for 2009, providing the 2-year results would provide the public with consistent and reliable information from the chief architect of the stress test that could be used to further establish the importance of understanding such tests and consider lessons learned about the rigor of the stress test estimates.

Increasing transparency in the bank supervisory process is a more controversial issue to address. Supervisory officials from OCC (including the then Comptroller) and the Federal Reserve question the extent to which greater transparency would improve day-to-day bank supervision. And, some BHCs we interviewed also were against public disclosure of future stress tests results. They noted that SCAP was a one-time stress test conducted under unique circumstances. Specifically, during the financial crisis, Treasury had provided a capital backstop for BHCs that were unable to raise funds privately. They expressed concern that public disclosure of certain unfavorable information about individual banks in a normal market environment could cause depositors to withdraw funds en masse creating a “run” on the bank. In addition, banks that appear weaker than their peers could be placed at a competitive disadvantage and may encourage them to offer more aggressive rates and terms for new depositors, thereby increasing their riskiness and further affecting their financial stability. While these concerns are valid and deserve further consideration, they have to be weighed against the potential benefits of greater transparency about the financial health of financial institutions and the banking system in general to investors, creditors, and counterparties.

The Dodd-Frank Act takes significant steps toward greater transparency. For example, the act requires the Federal Reserve to perform annual stress tests on systematically significant institutions and publicly release a summary of results. Also, the act requires each of the systematically significant institutions to publicly report the summary of internal stress tests semiannually. Given comments by its senior leadership, the Federal Reserve is willing to engage in a constructive dialogue about creating a plan for greater transparency that could benefit the entire financial sector. The other federal bank regulators—FDIC, OCC, and the Office of the Thrift Supervision—are also critical stakeholders in developing such a plan. While Federal Reserve officials have discussed possible options for increasing transparency, the regulators have yet to engage in a formal dialogue about these issues and have not formalized a plan for the public disclosure of regulatory banking information or developed a plan for integrating public disclosures into the ongoing supervisory process. Without a plan for reconciling these divergent views and for incorporating steps to enhance transparency into the supervisory process and practices, including the public disclosure of certain information, bank regulators may miss a significant opportunity to enhance market discipline by providing investors, creditors, and counterparties with information such as bank asset valuations.

Limited Use and Weak Oversight of BHCs’ Stress Tests Prior to SCAP Highlights the Need for More Rigorous Testing and Better Monitoring of Tests

SCAP highlighted that the development and utilization of BHCs’ stress tests were limited. Further, BHC officials noted that they failed to adequately stress test for the effects of a severe economic downturn scenario and did not test on a firmwide basis or test frequently enough. We also found that the regulator’s oversight of these tests were weak, reinforcing the need for more rigorous and firmwide stress testing, better risk governance processes by BHCs, and more vigorous oversight of BHCs’ stress tests by regulators. Going forward, as stress tests become a fundamental part of oversights of individual banks and the financial system, more specific guidance needs to be developed for examiners. BHCs and regulators stated that they are taking steps to address these shortcomings.

BHCs Generally Did Not Perform Firmwide Stress Tests Prior to SCAP

Prior to SCAP, many BHCs generally performed stress tests on individual portfolios, such as commercial real estate or proprietary trading, rather than on a firmwide basis. SCAP led some institutions to look at their businesses in the aggregate to determine how losses would affect the holding company’s capital base rather than individual portfolios’ capital levels. As a result, some BHC officials indicated that they had begun making detailed assessments of their capital adequacy and risk management processes and are making improvements. Officials from one BHC noted that before SCAP their financial and risk control teams had run separate stress tests, but had not communicate or coordinate with each other about their stress testing activities. Officials from another BHC noted that their senior management and board of directors were not actively involved in the oversight of the stress testing process. These officials said that since participating in SCAP, they have improved in these areas by institutionalizing the internal communication and coordination procedures between the financial risk and control teams, and by increasing communication with senior management and board of directors about the need for active involvement in risk management oversight, respectively. These improvements can enhance the quality of the stress testing process. Moreover, officials of BHCs that were involved in ongoing bank mergers during the SCAP process credited SCAP with speeding up of the conversion process of the two institutions’ financial systems since the BHCs’ staff had to work together to be able to quickly provide, among other things, the aggregate asset valuations and losses of the combined firm’s balance sheets to the regulators.

BHC officials also stated that their stress tests would take a firmwide view, that is, taking into account all business units and risks within the holding company structure and would include updates of the economic inputs used to determine potential losses and capital needs in adverse scenarios. One BHC noted that it had developed several severe stress scenarios for liquidity because the recent financial crisis had shown that liquidity could deteriorate more quickly than capital, endangering a company’s prospects for survival. This danger became evident in the failures of major financial institutions during the recent financial crisis— for example, IndyMac Bank, Lehman Brothers, and Bear Stearns.

BHCs Did Not Sufficiently Stress Their Portfolios for Unexpected Losses Prior to SCAP

Officials from many SCAP BHCs and the Federal Reserve noted that internal bank stress test models generally did not use macroeconomic assumptions and loss rates inputs as conservative as those used in the SCAP stress test. According to Federal Reserve officials, using the SCAP macroeconomic assumptions, most of the 19 BHCs that took part in SCAP initially determined that they would not need additional capital to weather the more adverse scenario. However, the SCAP test results subsequently showed that more than half of them (10 of 19) did need to raise capital to meet the SCAP capital buffer requirements. Some BHCs indicated that future stress tests would be more comprehensive than SCAP. BHCs can tailor their stress test assumptions to match their specific business models, while SCAP generally used a one-size-fits-all assumptions approach. For example, some BHCs noted that they use macroeconomic inputs (such as disability claims, prolonged stagflation, or consumer confidence) that were not found in the SCAP stress test.

Although the Federal Reserve has required BHCs to conduct stress tests since 1998, officials from several BHCs noted that their institutions had not conducted rigorous stress tests in the years prior to SCAP, a statement that is consistent with regulatory findings during the same period. To some degree, this lack of rigorous testing reflected the relatively good economic times that preceded the financial crisis. According to one credit rating agency and a BHC, stress test assumptions generally tend to be more optimistic in good economic times and more pessimistic in bad economic times. In addition, one BHC noted that it had conducted stress tests on and off for about 20 years, but usually only as the economy deteriorated. To address this issue, many BHC officials said that they have incorporated or are planning to incorporate more conservative inputs into their stress test models and are conducting more rigorous, firmwide stress testing more frequently.

Regulators Required Stress Tests Prior to SCAP, but Oversight Was Limited

Although regulators’ guidelines have required for over 10 years that financial institutions use stress tests to assess their capacity to withstand losses, we found that regulators’ oversight of these tests had been limited. Horizontal examinations by the regulators from 2006 through 2008 identified multiple weaknesses in institutions’ risk management systems, including deficiencies in stress testing. Areas of weaknesses found during examination included that the BHCs’ stress testing of their balance sheets lacked severity, were not performed frequently enough, and were not done on a firmwide basis. Also, it was found that BHCs’ risk governance process lacked the active and effective involvement of BHC senior management and board of directors. The SCAP stress test and the financial crisis revealed the same shortcomings in BHCs’ risk management and stress testing practices.

However, we previously found that regulators did not always effectively address these weaknesses or in some cases fully appreciate their magnitude. Specifically, regulators did not take measures to push forcefully for institutions to better understand and manage risks in a timely and effective manner. In addition, according to our discussions with some SCAP participants, oversight of these tests through routine examinations was limited in scope and tended to be discretionary. For example, regulators would review firms’ internal bank stress tests of counterparty risk and would make some suggestions, but reviews of these tests were done at the discretion of the individual supervisory team and were not consistently performed across teams. Even though BHCs have for many years performed stress tests to one degree or another, they have not been required to report the results of their testing to the Federal Reserve unless it specifically requested the information.

The Federal Reserve recently issued a letter to the largest banking organizations outlining its view on good practices with respect to the use of stress testing in the context of internal capital adequacy assessment practices (ICAAP). For example, some areas highlighted in the letter include how frequent a stress test should be performed, the minimum time frame that the test should cover, documentation of the process, involvement of senior management and board of directors, and types of scenarios and risks to include in such tests. Some BHC officials believed that stress testing would become an integral part of future risk management practices and noted that SCAP helped them see how bank examiners would want them to stress their portfolios in the future. In anticipation of future action by regulators, many BHCs were designing at least part of their stress tests along the lines of SCAP. However, a few BHC officials hoped that future stress tests would not be performed in the same manner as SCAP, with the largest institutions tested simultaneously in a largely public setting, but rather as part of the confidential supervisory review process.

Regulatory Oversight Is to Focus on More Rigorous Stress Testing, but Examiners Need More Specific Guidance

Federal Reserve officials stated that going forward, stress tests will become a fundamental part of the agency’s oversight of individual banks and the financial system. As a result of SCAP, Federal Reserve officials stated that they are placing greater emphasis on the BHCs’ internal capital adequacy planning through their ICAAP. This initiative is intended to improve the measurement of firmwide risk and the incorporation of all risks into firms’ capital planning assessment and planning processes. In addition to enhanced supervisory focus on these practices across BHCs, stress testing is also a key component of the Basel II capital framework (Pillar 2). Under Pillar 2, supervisory review is intended to help ensure that banks have adequate capital to support all risks and to encourage that banks develop and use better risk management practices. All BHCs, including those adopting Basel II, must have a rigorous process of assessing capital adequacy that includes strong board and senior management oversight, comprehensive assessment of risks, rigorous stress testing and scenario analyses, validation programs, and independent review and oversight. In addition, Pillar 2 requires supervisors to review and evaluate banks’ internal capital adequacy assessments and monitor compliance with regulatory capital requirements. The Federal Reserve wants the large banks to conduct this work for themselves and report their findings to their senior management and boards of directors. According to Federal Reserve officials, for BHCs to satisfy the totality of expectations for ICAAP it may take 18 to 24 months, partly because the BHCs are taking actions to enhance practices where needed—including with respect to the use of stress testing and scenario analyses in internal capital assessments—and the Federal Reserve then needs to evaluate these actions across a relatively large number of BHCs.

In addition, the Federal Reserve is finalizing guidance for examiners to assess the capital adequacy process, including stress testing, for BHCs. Examiners are expected to evaluate how BHCs’ stress tests inform the process for identifying and measuring risk and decisions about capital adequacy. Federal Reserve officials stated that examiners are expected to look closely at BHCs’ internal stress test methodologies and results. In a letter to BHCs, the Federal Reserve also emphasized that institutions should look at time frames of 2 or more years and considers losses firmwide. It also suggested that BHCs develop their own stress test scenarios and then review these scenarios and the results for appropriate rigor and quantification of risk.

While these are positive steps, examiners do not have specific criteria for assessing the quality of these tests. For example, the Federal Reserve has not established criteria for assessing the severity of the assumptions used to stress BHCs’ balance sheets. The Federal Reserve officials stated that they intend to have technical teams determine the type of criteria that will be needed to evaluate these assumptions, but they are in the early planning stages. Development of such criteria will be particularly helpful in ensuring the effective implementation of the stress test requirements under the Dodd-Frank Act. Without specific criteria, Federal Reserve examiners will not be able to ensure the rigor of BHCs’ stress tests—an important part of the capital adequacy planning. Furthermore, the absence of such guidance could lead to variations in the intensity of these assessments by individual examiners and across regional districts.

Risk Identification and Assessment Infrastructure Needs to be Upgraded to Improve Oversight

Following SCAP, regulatory and BHC officials we met with identified opportunities to enhance both the process and data inputs for conducting stress testing in the future. This would include processes for obtaining, analyzing, and sharing data and capabilities for data modeling and forecasting, which potentially could increase the Federal Reserve’s abilities to assess risks in the banking system. According to the Federal Reserve, an essential component of this new system will be a quantitative surveillance mechanism for large, complex financial institutions that will combine a more firmwide and multidisciplinary approach for bank supervision. This quantitative surveillance mechanism will use supervisory information, firm-specific data analysis, and market-based indicators to identify developing strains and imbalances that may affect multiple institutions, as well as emerging risks within specific institutions. This effort by the Federal Reserve may also improve other areas of supervision which rely on data and quantitative analysis, such as assessing the process used by BHC’s to determine their capital adequacy, forecasting revenue, and assessing and measuring risk, which is critical to supervising large, complex banks. Officials at the Federal Reserve told us that examiners should be analyzing BHC performances versus their stress test projections to provide insight into the agency’s loss forecasting approach. Moreover, Federal Reserve officials stated that they are always looking to increase their analytical capabilities, and they have recently implemented a new governance structure to address some of their management information infrastructure challenges. However, not enough time has passed to determine the extent to which such measures will improve banking supervision.

In addition, some other deficiencies were found in the data reported to the Federal Reserve by BHCs using the Y-9C, as well as the Federal Reserve’s ability to analyze the risk of losses pertaining to certain portfolios that were identified during the SCAP stress test. This led the Federal Reserve to develop a more robust risk identification and assessment infrastructure including internally developed models or purchased analytical software and tools from data vendors. Going forward, such models and analytics would facilitate improved risk identification and assessment capabilities and oversight, including the oversight of systemic risk. Moreover, a risk identification and assessment system that can gauge risk in the banking sector by collecting data on a timelier basis is necessary to better ensure the safety and soundness of the banking industry. Specific areas in which data collection and risk identification and assessment could be enhanced include mortgage default modeling to include more analysis of nontraditional mortgage products, counterparty level exposures, country and currency exposures, and commodity exposures. An example of where the Federal Reserve used SCAP to significantly upgrade its ability to assess risks across large BHCs is the development of a system that allowed BHCs to submit their securities positions and market values at a fixed date and apply price shocks. This process was enhanced during SCAP to facilitate the stress analysis of securities portfolios held by SCAP BHCs. This system allowed the Federal Reserve to analyze approximately 100,000 securities in a relatively short time period. The Federal Reserve intends to continue using this database to receive and analyze updated positions from BHCs.

With other portfolios, the Federal Reserve contracted with outside data and analytical systems providers. For multifamily loan portfolios, nonfarm loans, and nonresidential loans with a maturity beyond 2 years, all of which are subsets of commercial and industrial loans or commercial real estate portfolios, the Federal Reserve used internal models and purchased an outside vendor service that allowed it to estimate losses for these portfolios. For the remaining commercial portfolios, the Federal Reserve used different existing models found at both the Federal Reserve and Federal Reserve district banks and new models developed to meet the needs of SCAP. When analyzing BHCs’ mortgage portfolios, the consumer loans Supervisory Analytical and Advisory Team provided templates to the BHCs to collect granular data for such analysis, allowing the system to separate BHCs’ mortgage portfolios into much more granular tranches than would be possible using data from regulatory filings. The Federal Reserve further used data from various sources, including a large comprehensive loan-level database of most mortgages that have been securitized in the United States to assist in developing its own loss estimates to benchmark against the BHCs’ proprietary estimates.

These examples point to enhancements in the ability to assess risks to individual firms and across the banking sector that resulted from the SCAP stress test. The Federal Reserve has made clear that it views many of these innovations in its ability to assess and model risks and potential losses as permanent additions to its toolkit, and has also recognized the need for more timely and granular information to improve its supervision of BHCs and other institutions. However, the extent to which these models and tools will be distributed across the Federal Reserve district banks and other federal banking regulators is unclear. In addition, as the stress test applied to trading positions was limited to those BHCs that held trading positions of at least $100 billion as of February 20, 2009, the Federal Reserve has not indicated that it will roll out its new system to BHCs with smaller trading positions. The Federal Reserve has taken steps to maintain and enhance the tools and data used during SCAP. Further, improving the Federal Reserve’s financial data collection and supervisory tools will require additional resources, training for bank examiners, coordination in the dissemination of new infrastructure across all U.S. financial regulators, and, according to a Federal Reserve governor, would benefit from relief from the Paperwork Reduction Act of 1980 as well.

The Federal Reserve lacks a complete plan on how it will achieve permanent improvements in its risk identification and assessment infrastructure, but according to officials, such a plan is in development. The Federal Reserve has finalized a plan that describes a governance structure for overseeing large, complex financial organizations. The plan defines the roles and responsibilities of various committees and teams within the Federal Reserve that will carry out its supervisory responsibilities over these organizations. However, further planning is needed to incorporate lessons learned from SCAP for addressing data and modeling gaps that existed prior to the crisis and a structure for disseminating improvements to risk identification and assessment. Specifically, this plan will also be critical to addressing improvements to data and modeling infrastructure in supervising not only large financial holding companies but also smaller institutions. A fully developed plan would also consider how to disseminate data, models, and other infrastructure to the entire Federal Reserve System and bank regulatory agencies, as well as the newly established Financial Stability Oversight Council and Treasury’s Office of Financial Research. Without such a plan, the agency runs the risk of not optimizing its oversight responsibilities, especially in light of its new duties as the systemic risk regulator under the Dodd-Frank Act.

More Coordination and Communication across Regulators Is Critical for Understanding Risks to Individual Institutions and Financial Markets

Another critical lesson from SCAP was the need for robust coordination and communication among the regulators in examining large, complex financial institutions. Officials from the regulatory agencies and BHCs stated that the degree of cooperation among the SCAP regulators was unprecedented and improved the understanding of the risks facing the individual BHCs and the financial market. Such coordination and communication will become increasingly important as banking regulators increase their oversight role. Even with recent major reform to the financial regulatory structure, multiple regulatory agencies continue to oversee the banking industry, and regulators will need to prioritize efforts to promote coordination and communication among staff from these agencies so that emerging problematic issues affecting the financial industry are identified in a timely manner and effectively addressed.

Going forward, based on our discussions with various SCAP participants and statements by Federal Reserve officials, including the chairman, the regulators’ experience with SCAP is anticipated to lead to the expanded use of horizontal examinations and multidisciplinary staff that will require extensive interagency coordination. Horizontal examinations may involve multiple regulators and underscore the importance of effective coordination and communication.

Currently, regulators are conducting horizontal examinations of internal processes that evaluate the capital adequacy at the 28 largest U.S. BHCs. Their focus is on the use of stress testing and scenario analyses in ICAAP, as well as how shortcomings in fundamental risk management practices and governance and oversight by the board of directors for these processes could impair firms’ abilities to estimate their capital needs. Regulators recently completed the initial phase of horizontal examinations of incentive compensation practices at 25 large U.S. BHCs. As part of this review, each organization was required to submit an analysis of shortcomings or “gaps” in its existing practices relative to the principles contained in the proposed supervisory guidance issued by the Federal Reserve in the fall of 2009 as well as plans—including timetables—for addressing any weaknesses in the firm’s incentive compensation arrangements and related risk-management and corporate governance practices. In May 2010, regulators provided the banking organizations feedback on the firms’ analyses and plans. These organizations recently submitted revised plans to the Federal Reserve for addressing areas of deficiencies in their incentive compensation programs. In a June 2010 press release, the Federal Reserve noted that to monitor and encourage improvements in compensation practices by banking organizations, its staff will prepare a report after 2010 on trends and developments in such practices at banking organizations.

Our prior work has found that coordination and communication among regulatory agencies is an ongoing challenge. For example, in 2007, OCC onsite examiners, as well as officials in headquarters, told us that coordination issues hampered the Federal Reserve’s horizontal examinations. Also, in 2007, a bank told us that it had initially received conflicting information from the Federal Reserve, its consolidated supervisor, and the OCC, its primary bank supervisor, regarding a key policy interpretation. Officials from the bank also noted that when the Federal Reserve collected information, it did not coordinate with OCC, the primary bank examiner of the lead bank, resulting in unnecessary duplication. We noted that to improve oversight in the future, regulators will need to work closely together to expedite examinations and avoid such duplications.

Since the SCAP stress test was concluded, the following examples highlight ongoing challenges in coordination and communication: Officials from OCC and FDIC indicated that they were not always involved in important discussions and decisions. For example, they were not involved in the decision to reduce GMAC’s SCAP capital requirement, even though they were significantly involved in establishing the original capital requirement. Also, FDIC noted that it was excluded from such decision even though it is the primary federal bank regulator for GMAC’s retail bank (Ally Bank).

The Federal Reserve held an internal meeting to discuss lessons learned from SCAP, but has yet to reach out to the other SCAP regulators. The OCC and FDIC told us that they had not met with the Federal Reserve as a group to evaluate the SCAP process and document lessons learned. As a result, the FDIC and OCC did not have an opportunity to share their views on what aspects of SCAP worked and did not work, as well as any potential improvements that can be incorporated into future horizontal reviews or other coordinated efforts.

In the recent horizontal examinations, both FDIC and OCC noted that the interagency process for collaboration—especially in the initial design stages—was not as effective as it was for SCAP. OCC commented that more collaboration up front would have been preferable. Also, FDIC stated that the Federal Reserve did not include it in meetings to formulate aggregate findings for the horizontal examination of incentive compensation programs, and it experienced difficulties in obtaining aggregate findings from the Federal Reserve. The Federal Reserve commented that the FDIC was involved in the development of findings for those organizations that control an FDIC-supervised subsidiary bank and that FDIC has since been provided information on the findings across the full range of organizations included in the horizontal review, the majority of which do not control an FDIC-supervised subsidiary bank.

These continued challenges in ensuring effective coordination and communication underscore the need for sustained commitment and effort by the regulators to ensure the inclusion of all relevant agencies in key discussions and decisions regarding the design, implementation, and results of multiagency horizontal examinations. As the SCAP process has shown, active participation by all relevant regulators can strengthen approaches used by examiners in performing their supervisory activities. Without continuous coordination and communication, the regulators will miss opportunities to leverage perspectives and experiences that could further strengthen the supervision of financial institutions, especially during horizontal examinations of financial institutions.

Conclusions

Publicly reporting a comparison of the actual performance of the SCAP BHCs and the estimated performance under a more adverse scenario provides insights into the financial strength of the nation’s largest BHCs. Senior Federal Reserve officials have publicly disclosed select aggregate information about the performance of the 19 BHCs consistent with the recommendation in our June 2009 report. Specifically, we recommended that the Federal Reserve consider periodically disclosing to the public the performance of the 19 BHCs against the SCAP estimates during the 2-year period. However, the Federal Reserve has yet to commit to completing a final analysis that compares the BHCs’ actual performance with the estimated performance under SCAP’s more adverse economic scenario for the entire 2-year period and making this analysis public. Such an analysis is important for the market and BHCs to assess the rigor of the stress test methodology. Publicly releasing the results also would allow the public to gauge the health of the BHCs that participated in SCAP, which is a strong proxy for the entire U.S. banking industry. And public disclosure of this analysis could act as a catalyst for a public discussion of the value of effective bank risk management and enhance confidence in the regulatory supervision of financial institutions.

The public release of the stress test methodology and results helped improve market confidence in the largest BHCs during the recent financial crisis and provided an unprecedented window into bank supervision process. Subsequently, the Chairman of the Federal Reserve and a Federal Reserve governor have publicly stated that greater transparency should be built into the supervisory process and that feedback from the public could help increase the integrity of the supervisory process. Increased transparency can also augment the information that is available to investors and counterparties of the institutions tested and enhance market discipline. Despite these statements, the Federal Reserve and other bank regulators have yet to start a formal dialogue about this issue, nor have they developed a plan for integrating public disclosures into the ongoing supervisory process. Such a plan could detail the types of information that would benefit the markets if it were publicly released; the planned methodology for the stress tests, including assumptions; the frequency with which information would be made public; and the various means of disseminating the information. Taking into account the need to protect proprietary information and other market-sensitive information would be an important part of such a plan. While regulators will undoubtedly face challenges in determining how best to overcome skepticism about the potential effects on the financial markets of disclosing sensitive information on the financial health of banks, the Dodd-Frank Act requires that the Federal Reserve and certain banks publicly release a summary of results from periodic stress tests. Without a plan for enhancing the transparency of supervisory processes and practices, bank regulators may miss a significant opportunity to further strengthen market discipline and confidence in the banking industry by providing investors, creditors, and counterparties with useful information.

The SCAP stress test shed light on areas for further improvement in the regulators’ bank supervision processes, including oversight of risk management practices at BHCs. Prior to SCAP, regulatory oversight of stress tests performed by the BHCs themselves was ineffective. Specifically, although regulators required stress tests, the guidelines for conducting them were more than a decade old, and the individual banks were responsible for designing and executing them. The Federal Reserve’s reviews of the internal stress tests were done at the discretion of the BHCs’ individual supervisory teams and were not consistently performed. Further, even though BHCs performed stress tests, they were not required to report the results of their stress testing to the Federal Reserve without a specific request from regulators. Post-SCAP, however, the Federal Reserve has stated that stress testing will now be a fundamental part of their oversight of individual banks. The Federal Reserve expects to play a more prominent role in reviewing assumptions, results, and providing input into the BHCs’ risk management practices. While the Federal Reserve has begun to take steps to augment its oversight, currently Federal Reserve examiners lack specific criteria for assessing the severity of BHCs’ stress tests. Without specific criteria, Federal Reserve examiners will not be able to ensure the rigor of BHCs’ stress tests. Furthermore, the absence of such criteria could lead to variations in the intensity of these assessments by individual examiners and across regional districts.

The experience with SCAP also showed that regulators needed relevant and detailed data to improve oversight of individual banks and to identify and assess risks. As the Federal Reserve and the other regulators conduct more horizontal reviews, they will need a robust plan for quantitatively assessing the risk in the banking sector. Collecting timely data for the annual stress testing and other supervisory actions will be critical in order to better ensure the safety and soundness of the banking industry. The Federal Reserve has finalized a plan that describes a governance structure for overseeing large, complex financial organizations. However, further planning is needed to incorporate lessons learned from SCAP for addressing data and modeling gaps and a structure for disseminating improvements to risk identification and assessment. Further, efforts to improve the risk identification and assessment infrastructure will need to be effectively coordinated with other regulators and the newly established Financial Stability Oversight Council and Treasury’s Office of Financial Research in order to ensure an effective systemwide risk assessment. Without fully developing a plan that can identify BHCs’ risks in time to take appropriate supervisory action, the Federal Reserve may not be well- positioned to anticipate and minimize future banking problems and ensure the soundness of the banking system.

Despite the positive coordination and communication experience of the SCAP stress test, developments since the completion of SCAP have renewed questions about the effectiveness of regulators’ efforts to strengthen their coordination and communication. For example, on important issues, such as finalizing GMAC’s SCAP capital amount, the Federal Reserve chose not to seek the views of other knowledgeable bank regulators. While the Dodd-Frank Act creates formal mechanisms that require coordination and communication among regulators, the experiences from SCAP point to the need for a sustained commitment by each of the banking regulators to enhance coordination and communication. In particular, ensuring inclusion of relevant agencies in key discussions and decisions regarding the design, implementation, and results of multiagency horizontal examinations will be critical. If regulators do not consistently coordinate and communicate effectively during horizontal examinations, they run the risk of missing opportunities to leverage perspectives and experiences that could further strengthen bank supervision.

Recommendations

To gain a better understanding of SCAP and inform the use of similar stress tests in the future, we recommend that the Chairman of the Federal Reserve direct the Division of Banking Supervision and Regulation to: Compare the performance of the 19 largest BHCs against the more adverse scenario projections following the completion of the 2-year period covered in the SCAP stress test ending December 31, 2010, and disclose the results of the analysis to the public.

To leverage the lessons learned from SCAP to the benefit of other regulated bank and thrift institutions, we recommend that the Chairman of the Federal Reserve in consultation with the heads of the FDIC and OCC take the following actions: Follow through on the Federal Reserve’s commitment to improve the transparency of bank supervision by developing a plan that reconciles the divergent views on transparency and allows for increased transparency in the regular supervisory process. Such a plan should, at a minimum, outline steps for releasing supervisory methodologies and analytical results for stress testing.

Develop more specific criteria to include in its guidance to examiners for assessing the quality of stress tests and how these tests inform BHCs’ capital adequacy planning. These guidelines should clarify the stress testing procedures already incorporated into banking regulations and incorporate lessons learned from SCAP.

Fully develop its plan for maintaining and improving the use of data, risk identification and assessment infrastructure, and requisite systems in implementing its supervisory functions and new responsibilities under the Dodd-Frank Act. This plan should also ensure the dissemination of these enhancements throughout the Federal Reserve System and other financial regulators, as well as new organizations established in the Dodd-Frank Act.

Take further steps to more effectively coordinate and communicate among themselves. For example, ensuring that all applicable regulatory agencies are included in discussions and decisions regarding the development, implementation, and results of multiagency activities, such as horizontal examinations of financial institutions.

Agency Comments and Our Evaluation

We provided a draft of this report to the Federal Reserve, FDIC, OCC, OTS, and Treasury for review and comment. We received written comments from the Chairman of the Federal Reserve Board of Governors and the Assistant Secretary for Financial Stability. These comments are summarized below and reprinted in appendixes IV and V, respectively. We also received technical comments from the Federal Reserve, FDIC, OCC, and Treasury, which we incorporated into the report as appropriate. OTS did not provide any comments. In addition, we received technical comments from the Federal Reserve and most of the 19 SCAP BHCs on the accuracy of our tracking of revenues and losses in 2009 for each of the SCAP BHCs and incorporated them into the report as appropriate.

In its comment letter, the Federal Reserve agreed with all five of our recommendations for building on the successes of SCAP to improve bank supervision. The Federal Reserve noted that our recommendations generally relate to actions it is currently undertaking or planning to take under the Dodd-Frank Act. It also cited that in coordination with FDIC and OCC, it would provide a public assessment of BHCs’ performance relative to the loss and preprovision net revenue estimates under the more adverse scenario, taking into account the limitations of such an analysis. For our remaining recommendations related to increased transparency, examiner guidance, risk identification and assessment, and coordination and communication of multiagency activities, the Federal Reserve generally noted that it has taken step in these areas and will continue to consult with the FDIC and OCC in implementing our recommendations and its new responsibilities under the Dodd-Frank Act.

While our report recognizes the steps that the Federal Reserve has taken related to transparency, examiner guidance, risk identification and assessment, and coordination and communication of multiagency activities, these areas warrant ongoing attention. For example, as we note in the report, while the Federal Reserve is in the process of finalizing examination guidance for reviewing stress tests, examiners currently do not have specific criteria for assessing the severity of these tests nor have they coordinated with the other bank regulators. Until this guidance is completed, examiners will lack the information needed to fully ensure the rigor of BHCs’ stress tests, and the Board will not be able to fully ensure the consistency of the assessment by individual examiners. Our report also notes the positive coordination and communication experience of the SCAP stress test, but we continued to find specific instances since the completion of SCAP that have renewed questions about the effectiveness of regulators’ efforts to strengthen their coordination and communication. For instance, while the Federal Reserve included relevant agencies in key discussions and decisions regarding the design, implementation, and results of SCAP, we found that the Federal Reserve missed opportunities to include other bank regulators when planning more recent horizontal examinations.

Treasury agreed with our report findings, noting that it appreciated our acknowledgment that SCAP met its goals of providing a comprehensive, forward-looking assessment of the balance sheet risks of the largest banks and increasing the level and quality of capital held by such banks. It further noted that the unprecedented public release of the stress test results led to an increase in the market confidence in the banking system, which aided in improving the capital adequacy of the largest banks.

We are sending copies of this report to the appropriate congressional committees; Chairman of the Federal Reserve, the Acting Comptroller of Currency, Chairman of the FDIC, the Acting Director of the Office of the Thrift Supervision, and the Secretary of the Treasury. Also, we are sending copies of this report to the Congressional Oversight Panel, Financial Stability Oversight Board, the Special Inspector General for TARP, and other interested parties. In addition, the report will be available at no charge on the GAO Web site at http://www.gao.gov.

Should you or your staff have any questions on the matters discussed in this report, please contact me at (202) 512-8678 or williamso@gao.gov. Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this letter. GAO staff who made key contributions to this report are listed in appendix VI.

Appendix I: Objectives, Scope, and Methodology

The objectives of this report were to (1) describe the process used to design and conduct the stress test and participants views’ of the process, (2) describe the extent to which the stress test achieved its goals and compare its estimates with the bank holding companies’ (BHC) actual results, and (3) identify the lessons regulators and BHCs learned from the Supervisory Capital Assessment Program (SCAP) and examine how each are using those lessons to enhance their risk identification and assessment practices.

To meet the report’s objectives, we reviewed the Board of Governors of the Federal Reserve System’s (Federal Reserve) The Supervisory Capital Assessment Program: Design and Implementation (SCAP design and implementation document) dated April 24, 2009, and The Supervisory Capital Assessment Program: Overview of Results (SCAP results document) dated May 7, 2009. We analyzed the initial stress test data that the Federal Reserve provided to each BHC, the subsequent adjustments the Federal Reserve made to these estimates, and the reasons for these adjustments. We reviewed BHC regulatory filings such as the Federal Reserve’s 2009 Consolidated Financial Statements for Bank Holding Companies—-FR Y-9C (Y-9C); company quarterly 10-Qs and annual 10-Ks; speeches and testimonies regarding SCAP and stress testing; BHCs’ presentations to shareholders and earnings reports; bank supervision guidance issued by the Federal Reserve, Office of the Comptroller of the Currency (OCC), and the Federal Deposit Insurance Corporation (FDIC); and documents regarding the impact of SCAP and the financial crisis and proposed revisions to bank regulation and supervisory oversight. To further understand these documents and obtain different perspectives on the SCAP stress test, we interviewed officials from the Federal Reserve, OCC, FDIC, and the Office of the Thrift Supervision, as well as members of the multidisciplinary teams created to execute SCAP.

We also collected data from SNL Financial—a private financial database that contains publicly filed regulatory and financial reports, including those of the BHCs involved in SCAP—in order to compare the BHCs’ actual performance in 2009 against the regulators’ 2-year SCAP loss estimates and GAO’s 1-year pro rata loss estimates. To obtain additional background information regarding the tracking of the BHCs, perspectives on their performance, anticipated loan losses, and the success of SCAP in achieving its goals, we interviewed relevant officials (e.g., chief risk officers and chief financial officers) from 11 of the 19 BHCs that participated in the SCAP stress test. The BHCs we interviewed were the American Express Company; Bank of America Corporation; The Bank of New York Mellon Corporation; BB&T Corporation; Citigroup Inc.; GMAC LLC; The Goldman Sachs Group, Inc.; JPMorgan Chase & Co.; MetLife, Inc.; Regions Financial Corporation; and Wells Fargo & Company. We selected these BHCs to reflect differences in size, types of financial services provided, geographic location, primary bank regulator, and participation in the Troubled Asset Relief Program (TARP). In addition, we met with credit rating agency officials from the Standard and Poor’s Corporation, Moody’s Corporation, and Fitch Ratings Inc. for their perspective on SCAP and their own stress test practices. To more completely understand the execution of SCAP, we completed a literature search of stress tests conducted by others—for example, the Committee on European Banking Supervisors and the International Monetary Fund. We also reviewed relevant credit rating agency reports and the reports of other oversight bodies such as the Congressional Oversight Panel and the Special Inspector General for the Troubled Asset Relief Program on topics related to stress testing and TARP. We also reviewed our past work on the bank supervisory process and SCAP.

In addition, to track the actual performance of the 19 BHCs, we collected data from several sources. We then compared the BHCs’ actual performance to the December 31, 2008, capital levels presented in SCAP and the projections made under the more adverse scenario for estimated losses for loans, securities (available for sale and held to maturity), trading and counterparty, and resources other than capital to absorb losses. Our primary source for SCAP estimates was the May 7, 2009, SCAP results document, which contained the estimates for each of the 19 BHCs and aggregate data for all BHCs. We also reviewed the confidential April 24, 2009, and May 5, 2009, presentations that the SCAP regulators made to each of the 19 BHCs to identify estimates of preprovision net revenue (PPNR) and changes in allowance for loan and lease losses (ALLL) for the 2 years ended 2010. Our primary source for the actual results at the BHCs was the Federal Reserve’s Y-9C. In doing so, we used the SNL Financial database to extract data on the Y-9C and the Securities and Exchange Commission forms 10-K and 10-Q. These data were collected following the close of the fourth quarter of 2009, the halfway point of the SCAP’s 2-year time frame.

Since losses were not estimated on a quarter-by-quarter or yearly basis but projected for the full 2-year period, we assumed that losses and revenue estimates under the more adverse scenario were distributed at a constant rate across the projection period. Thus, we compared the actual 2009 year end values with half of the Federal Reserve’s 2-year SCAP projections. This methodology has some limitations because losses, expenses, revenues, and changes to reserves are historically unevenly distributed and loss rates over a 2-year period in an uncertain economic environment can follow an inconsistent path. However, the Federal Reserve, OCC, credit rating agencies, an SNL Financial analyst, and most of the BHCs we interviewed who are tracking performance relative to SCAP estimates are also using the same methodology. We assessed the reliability of the SNL Financial database by following GAO’s best practices for data reliability and found that the data was sufficiently reliable for our purposes. To confirm the accuracy of our BHC tracking data, we shared our data with the Federal Reserve and the 19 SCAP BHCs. We received comments and incorporated them as appropriate.

Some of the data that we collected were not in a form that was immediately comparable to the categories used in the SCAP results, and we had to make adjustments in order to make the comparison. For tier 1 common capital, most asset categories, and resources other than capital to absorb losses, we had to find a methodology suited to aggregating these data so that we could compare it to the corresponding SCAP data. For example, net-charge offs for the various loan categories are broken out into more subcategories in the Y-9C than those listed in the SCAP results. In addition, we calculated “Resources Other than Capital to Absorb Losses” to correspond to the SCAP definition of PPNR minus the change in ALLL, which required obtaining data from multiple entries within the Y- 9C. When calculating noninterest expense we removed the line item for goodwill impairment losses because this item was not included in the SCAP regulators’ projections. We also used the calculation of a change in ALLL until December 31, 2009. But the SCAP regulators considered an increase in ALLL over the full 2-year period to be a drain on resources, because the provisions made to increase the ALLL balance would not be available to absorb losses during the 2-year SCAP time frame. This notion creates a problem in using the formula for 1-year tracking purposes because an increase in ALLL during 2009 would require provisions for that increase, but those added reserves could ultimately be used to absorb losses during 2010. To maintain consistency, our calculation considers ALLL increases during 2009 to be a drain on resources, but we recognize that this money could act as a resource to absorb losses rather than a drain on those resources.

We faced an additional limitation pertaining to the ALLL calculation and a challenge with regard to the treatment of trading and counterparty revenues. In our review of SCAP documentation, we found that SCAP regulators used two different ALLL calculations—1 calculation for 4 of the BHCs that included a reserve for off-balance sheet items and another for the remaining 15 BHCs that did not include off-balance sheet reserves. The Federal Reserve confirmed that there were two different calculations that were not adjusted for consistency. In order to be consistent across the BHCs, we applied the same methodology that the regulators used for 15 of the BHCs to the 4 that remained. The treatment of trading and counterparty revenue created a challenge because the data in the Y-9C includes both customer derived revenue from transactions for BHCs that operate as broker-dealers and gains (or losses) from proprietary trading and certain associated expenses. These items are presented only in net form in the Y-9C. However, for the five BHCs (Bank of America Corporation; Citigroup, Inc.; Goldman Sachs Group, Inc.; JPMorgan Chase & Co.; and Morgan Stanley) that had their trading portfolios stressed, the trading and counterparty line is based on projections of gains (losses) from proprietary trading, but PPNR (specifically noninterest revenue) is based on gains from customer derived revenue from transactions for BHCs that operate as broker-dealers. Because we could not segregate these items based on the Y-9C, we have included the net amount in both the trading and counterparty and noninterest income line items. This means that the net amount of the trading gains or losses as reported in the Y-9C are included in two places in our tracking table for those five BHCs. For the remaining 14 BHCs, we included the entire line item in noninterest income, as that is where it was located in the SCAP projections.

Table 6 shows the items we used to calculate tier 1 capital, asset losses, PPNR, and ALLL as of December 31, 2009 and the specific sources we used. We also included specific references to the sources we used. Some elements within the table required a more detailed aggregation or calculation and are therefore explained further in tables 7 and 8 below. For reporting these capital measures and asset balances for the year ending December 31, 2008, we generally relied on the figures published in various SCAP documents.

Table 7 shows our methodology for calculating tier 1 common capital, including the part of the Y-9C in which the data can be found. Currently, there is no defined regulatory method for calculating tier 1 common capital, and it is not a required data field for BHCs to file in their Y-9C submissions. As a result, we developed a formula consistent with the Federal Reserve’s by reviewing the guidance available in the SCAP design and implementation and SCAP results documents and consulting with SNL Financial regarding its methodology.

Table 8 provides a crosswalk for the asset classification we used to group the various charge-off categories listed in the Y-9C.

To ensure additional comparability with SCAP, we attempted to identify any unique circumstances that could skew the results. For example, after we shared our initial tracking estimates with the 19 BHCs, one BHC had identified an issue with our calculation of tier 1 common capital that resulted from the way information is reported on the Y-9C. After discussing the issue with the BHC and verifying their explanation, we adjusted our calculation to more accurately reflect their position. Another BHC also had a one-time charge that had been included in the “Other” loss category, and we decided to segregate this item as a separate line item. We have also submitted our tracking spreadsheet to the Federal Reserve and to each BHC to give them an opportunity to provide input and ensure the accuracy and comparability of our numbers. Appropriate adjustments to 2009 numbers based on information received from the Federal Reserve and individual BHCs are noted, where applicable, in the tables in appendix III.

Some items that impact precise comparisons between actual results and the pro rata estimates are disclosed in our footnotes, rather than as adjustments to our calculations. For example, the stress test was applied to loan and other asset portfolios as of December 31, 2008, without including a calculation for ongoing banking activities. Because the Y-9C data includes ongoing activity as of the date of the report, the actual results are slightly different than the performance of the stressed assets as the BHCs were treated as liquidating concerns rather than going concerns in the SCAP stress test. Distinguishing between the gains (losses) from legacy assets and those that resulted from new assets is not possible using public data. Other examples are that SCAP did not include the impact of the owned debt value adjustment or one-time items (occurring subsequent to SCAP) in their projections of PPNR. As credit default swap spreads narrowed in 2009, liability values increased at most banks, causing a negative impact on revenue at those banks that chose to account for their debt at fair value; but these losses were not included in the SCAP estimates. One-time items, such as sales of business lines, were also not included in the SCAP estimates of PPNR, as these events occurred subsequent to the stress test and, in part, could not be fully predicted as a part of SCAP. Rather than remove the losses from the owned debt value adjustments and the gains (or losses) due to one-time items from the BHCs’ 2009 PPNR results, we disclosed the amounts in footnotes for the applicable BHCs. We chose this treatment so that PPNR would reflect actual results at the BHCs, while still disclosing the adjustments needed for more precise comparability to SCAP.

We identified the TARP status of each of the 19 BHCs that participated in SCAP by reviewing data from the Treasury’s Office of Financial Stability’s TARP Transactions Report for the Period Ending September 22, 2010 (TARP Transactions Report) and the SCAP results document. We used the SCAP results document to identify BHCs that were required to raise capital. The TARP Transactions Report, was then used to identify the program under which TARP funds were received (if any), the amount of funds received, capital repayment date, amount repaid, and warrant disposition date and to determine whether the warrants were repurchased or sold by Treasury in a public offering.

To gain a better understanding of future potential losses, we determined the percentage of BHCs’ total loans that are either nonaccrual or more than 90 days past due using Y-9C data from the SNL Financial database. We used quarterly data for the period 2007 through 2009 on nonaccrual loans and past due balances of more than 90 days, for each of the BHCs. We aggregated the data into the same six loan categories used in SCAP: first-lien mortgages, second/junior-lien mortgages, commercial and industrial loans, commercial real estate loans, credit card balances, and “Other.” (See tables 8 and 9 for details.) Once the data were aggregated, we divided that data by the applicable total loan balance for each category at each point in time (i.e., quarterly basis). One limitation is that Y-9C data were not available for all periods for four of the BHCs (American Express Company; GMAC LLC; The Goldman Sachs Group, Inc.; and Morgan Stanley) because they had recently became BHCs. As a result, we did not include these BHCs in the calculation during those periods where their Y- 9Cs were not available (fourth quarter of 2008 and earlier for all except GMAC LLC, which also did not have a Y-9C in the first quarter of 2009).

We collected Y-9C data from the SNL Financial database to calculate the loan loss rates across BHCs with more than $1 billion of assets and compare the 19 BHCs with the indicative loss rates provided by the SCAP regulators. We used annual data for the year ended December 31, 2009, on loan charge-offs. We also used average total loan balances. In the Y-9C total loan balances were categorized somewhat differently from charge- offs. Table 9 provides a crosswalk for the asset classification. We aggregated loan balance data into the same categories that were used in the indicative loss rate table in SCAP: first-lien mortgages, prime mortgages, Alt-A mortgages, subprime mortgages, second/junior lien mortgages, closed-end junior liens, home equity lines of credit, commercial and industrial loans, commercial real estate loans, construction loans, multifamily loans, nonfarm nonresidential loans, credit card balances, other consumer, and other loans. Once the data were aggregated into these categories, we divided the net charge-offs by the applicable average loan balance. This calculation showed the loss rate for each category (e.g., first-lien mortgages and commercial real estate) for the year ended December 31, 2009. This methodology was applied to calculate the loss rates for the 19 SCAP BHCs and all BHCs with more than $1 billion of assets, respectively. Because those institutions had recently converted to being BHCs, Y-9C data on loan balances was not available for the fourth quarter of 2008 for American Express Company; The Goldman Sachs Group, Inc.; and Morgan Stanley, and was not available for GMAC LLC for both the first quarter of 2009 and the fourth quarter of 2008. Therefore, we approximated the loan balances in these periods for GMAC LLC and American Express Company based on their Form 10-Q for these time periods. Because The Goldman Sachs Group, Inc. and Morgan Stanley have considerably smaller loan balances, in general, than the other BHCs; the fourth quarter of 2008 balance was not approximated for these BHCs. Instead, the average loan balance was simply based on the available data (e.g., first quarter of 2009 through fourth quarter of 2009).

We conducted this performance audit from August 2009 to September 2010 in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives.

Appendix II: Status of Bank Holding Companies’ TARP Investments as September 22, 2010

Twelve of the 19 bank holding companies (BHC) that participated in the Supervisory Capital Assessment Program (SCAP) had redeemed their Troubled Asset Relief Program (TARP) investments and had their warrants disposed of as of September 22, 2010, and most of them were not required to raise capital under SCAP (table 10). Six of the 19 BHCs tested under SCAP have not repaid TARP investments or disposed of warrants, and one, MetLife, Inc., did not receive any TARP investments. BHCs participating in SCAP must follow specific criteria to repay TARP funds. In approving applications from participating banks that want to repay TARP funds, the Federal Reserve considers various factors. Some of these factors include whether the banks can demonstrate an ability to access the long-term debt market without relying on the Federal Deposit Insurance Corporation’s (FDIC) Temporary Liquidity Guarantee Program and whether they can successfully access the public equity markets, remain in a position to facilitate lending, and maintain capital levels in accord with supervisory expectations. BHCs intending to repay TARP investments must have post repayment capital ratios that meet or exceed SCAP requirements.

Appendix III: One-Year Actual Performance Compared to GAO’s Pro rata Stress Test Loss Projections for Each of the 19 SCAP BHCs

Table 11 shows the names, location, and total assets as of December 31, 2008, of the 19 bank holding companies (BHC) subject to the Supervisory Capital Assessment Program (SCAP) stress test that was conducted by the federal bank regulators in the spring of 2009. The stress test was a forward-looking exercise intended to help federal banking regulators gauge the extent of the additional capital buffer necessary to keep the BHCs strongly capitalized and lending even if economic conditions are worse than had been expected between December 2008 and December 2010.

The following tables (12 through 30) compare the 2009 performance of the 19 BHCs involved in SCAP to the 2-year SCAP estimates and the GAO 1- year pro rata estimates for the more adverse economic scenario. Specifically, these tables include comparison of actual and estimates of losses and gains associated with loans, securities, trading and counterparty, resources, preprovision net revenue (PPNR), and allowance for loan and lease losses (ALLL). These tables also include a comparison of actual capital levels at December 31, 2009, and December 31, 2008. Totals may not add due to rounding. For a more detailed explanation of the calculations made in constructing this analysis, see appendix I.

Appendix IV: Comments from the Board of Governors of the Federal Reserve System

Appendix V: Comments from the Department of the Treasury’s Office of Financial Stability

Appendix VI: GAO Contact and Staff Acknowledgments

GAO Contact

Staff Acknowledgments

Daniel Garcia-Diaz (Assistant Director), Michael Aksman, Emily Chalmers, Rachel DeMarcus, Laurier Fish, Joe Hunter, William King, Matthew McDonald, Sarah M. McGrath, Timothy Mooney, Marc Molino, Linda Rego, and Cynthia Taylor made important contributions to this report.