Banking and Finance Law Daily Wrap Up, FINANCIAL STABILITY—Banking associations request comment extension on Fed’s stress test proposal, (Nov 13, 2025)

By Colleen M. Svelnis, J.D.

The groups point out that for this notice of proposed rulemaking, the Fed is requesting public comment on comprehensive model documentation, which contains almost 1,500 pages of technical detail.

Several banking associations have requested a 30-day extension on the Federal Reserve Board’s recent request for public comment on a notice of proposed rulemaking. The groups have sent a joint letter requesting that the Fed extend by 30 days the deadline for public comments—which is currently set at Jan. 22, 2026—on its Notice of Proposed Rulemaking on enhanced transparency and public accountability of the Supervisory Stress Test Models and Scenarios; Modifications to the Capital Planning and Stress Capital Buffer Requirement Rule, Enhanced Prudential Standards Rule, and Regulation LL. The associations specifically noted in their letter that they are not requesting an extension of the Dec. 1, 2025, comment period deadline with respect to the Fed’s Notice of Proposed Rulemaking regarding the Request for Comment on Scenarios for the Fed’s 2026 Supervisory Stress Test, which was also issued by the Fed on October 24. The groups point out that, in connection with the Enhanced Transparency NPR, the Fed is requesting public comment on comprehensive model documentation, which contains almost 1,500 pages of technical detail.

Last month, the Fed requested public comment on proposals to enhance the transparency and public accountability of its annual supervisory stress test. The Fed invited comment on the proposed supervisory stress-test models.

The associations write that the Fed's stated goal of the Enhanced Transparency NPR is to solicit public input regarding the models used to conduct the Fed's supervisory stress test, the changes to those models to be implemented in the 2026 stress test, and proposed changes to enhance the transparency and public accountability of the Board’s stress testing framework.

The groups state that they “are engaged in a careful review and analysis of the Enhanced Transparency NPR and the related documentation, and will prepare a comment letter that we expect will provide the Board with helpful feedback and analysis to improve its supervisory stress testing process.” In the letter the groups ask for a new deadline for public comments of no earlier than Feb. 21, 2026.

Companies: American Bankers Association; Bank Policy Institute; Financial Services Forum; International Swaps and Derivatives Association, Inc.; The Securities Industry and Financial Markets Association

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