The stress tests started in 2009 with the Supervisory Capital Assessment Program (SCAP), and they continued with the Comprehensive Capital Analysis and Review (CCAR) in late 2010 and early 2011, in which we evaluated the capital planning processes of the firms and responded to requests to resume or increase shareholder payouts.
This implies lower costs for the bank in complying with the regulatory requirements. Common rules and methods of supervision also have a broader impact on competition among banks, not only for international but also domestically oriented banks. The banks are treated equally in supervision and regulatory capture can be fully avoided, thereby ensuring a level playing field.