While no institutions below $ billion in assets are subject to supervisory stress testing or the requirements of CCAR, the Dodd-Frank Act does require that institutions with between $ billion and $ billion in assets conduct their own stress tests.10 The initial tests by these  7  A capital plan describes a firm’s capital planning strategies and its processes for measuring potential capital needs both under expected and stressed operating environments and for ensuring that it is holding adequate capital to be able to continue to function even under stress.
See Board of Governors of the Federal Reserve System (2011), “Capital Plans,” final rule (Docket No. R-1425), Federal Register, vol. 76 (December 1), pp. 74631–48. 8  See Board of Governors, “Federal Reserve Announces Results of CCAR,” in note 3.