The 2015 Dodd-Frank Act Stress Test process is viewed as more important than the actual results, in that it guides banks to understand capital and credit risk management within their respective institutions. Fitch Ratings examined the Dodd-Frank Act Stress Test process and results, finding that steps taken to gather the data for mid-tier regional banks are a positive development. The stress test process reviewed 60 mid-tier banks and applied the severely adverse scenario which included a 50 percent decline in real estate prices and a nearly 60 percent decline in equity markets over a period of multiple years.
Of the 20 Fitch-rated mid-tier banks, most passed the Dodd-Frank Act Stress Test by comfortable margins, reporting average minimum common equity Tier 1 ratios in excess of the required capital minimums. The average minimum common equity Tier 1 ratio of the Fitch-rated banks over the nine-quarter evaluation period ending December 2016 is 9.9 percent, nearly double the minimum 5 percent threshold. As a comparison, the self-reported bank holding company minimum common equity Tier 1 ratio average for large regionals under stress testing in March 2015 was 9 point 1 percent.
The latest organization to air a grievance about the CFPB's Consumer Complaint Database is the National Association of Federal Credit Unions, which wrote a letter to the Bureau saying that the Database, quote, continues to have practical implications that undermine the complaint resolution process. Close quote. The NAFCU expressed concerns over potential privacy and reputational risks presented by the complaint narratives in the database.