See Deutsche Bundesbank (2022), Rise in energy prices, the exchange rate of the euro and Germany’s price competitiveness, Monthly Report, December 2022, pp. 45-54. 11. See Deutsche Bundesbank (2023), Impact of higher energy costs on the profitability of German industrial enterprises, Monthly Report, March 2023, pp. 69-70. 12.
The Federal Reserve eliminated this element of CCAR for large and noncomplex firms in 2017, in part because of improvements in risk management at those firms.3 In my view, the time has come to normalize the CCAR qualitative assessment by removing the public objection tool, and continuing to evaluate firms’ stress testing practices through normal supervision.