Let me repeat here what all three federal banking agencies have explained in the clearest possible terms, both publicly, in examiner training, and in oneon-one discussions with bankers: that Dodd-Frank Act Stress Test (DFAST) and Comprehensive Capital Analysis and Review requirements and expectations for enterprisewide capital stress testing do not apply to community banking organizations, either explicitly or implicitly.
22 For example, while it may be sensible supervisory practice to inquire of a growing $ billion bank if it has begun thinking about how it would meet DFAST requirements should it reach the current $ billion statutory threshold, that bank does not need to start meeting those requirements until it has actually crossed the threshold.