These should be an important focus of ongoing supervisory oversight and of discussions between firms and supervisors. Only in unusual circumstances should supervisors learn for the first time during CCAR of significant problems in the quality of the capital planning processes, and only in unusual circumstances should firms be surprised at the outcome of the qualitative assessment. 12  See 12 CFR 225.8(e)(2)(ii).
13  It is also worth emphasizing that both elements of CCAR – the qualitative and the quantitative assessments – only apply to BHCs with $ billion or more in total consolidated assets. The Dodd-Frank Act requires companies with between $ and 50 billion in assets to conduct an annual company-run stress test.