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Complying With CCAR and DFAST Federal Regulations

Challenge

A U.S. bank holding company need to comply with the Federal Reserve Bank’s Comprehensive Capital Analysis and Review (CCAR) process and the Dodd-Frank Act’s Annual Stress Test (DFAST) for this client was unmanageable due to its numerous and individually managed risk management offices across the enterprise.

Solution

Mobilized a team to rapidly implement a full compliant CCAR/DFAST stress test program by:
  • Forming a management office (PMO) that involved risk groups across the lines of businesses and enterprise
  • Defining communication methods and cadences within teams, across teams, lines of businesses, and to executive management
  • Training team members on compliance requirements and how risk management concepts, methodologies, and internal controls testing enable regulatory compliance
  • Defining processes for documenting Risk and Control Self-Assessments (and creating templates for risk analysts to archive critical controls and self-assessments
  • Creating content management governance to store project artifacts and results
  • Implementing and deploying change control methods for managing documentation updates

Outcome

Our client was able to immediately adhere to federally mandated regulations and plan for long-term success by:
  • Instituting a consistent approach, toolset, and guidance across the enterprise and within lines of businesses (LOB)
  • Educating each LOB to understand compliance expectations and ensure full compliance with CCAR and DFAST on a semi-annual and annual basis
  • Enabling ongoing compliance adoption and sustainability through clear and consistent organizational structure, processes, and tools
Published March 17, 2020