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Fed requests comments on 2026 stress test scenarios and enhanced transparency in stress testing proposals

October 31, 2025

On October 24, the Fed requested comments on a set of proposals aimed at increasing the transparency and public accountability of its annual supervisory stress tests for large banks. The Fed issued a notice of proposed rulemaking requesting comments on the models used for the Fed’s stress test, changes to those models implemented in 2026, proposed enhancements to facilitate disclosure of stress test models, and any material changes to models or annual hypothetical stress scenarios going forward. Relatedly, in a separate notice, the Fed requested comments on its proposed 2026 stress test scenarios. The Fed’s announcement explained that the proposed changes were motivated by a desire to avoid litigation regarding its stress testing framework.

The proposed changes would require the annual disclosure of model documentation and scenarios, invite public comments on any material changes to the models or scenarios before implementation, and codify a process for future enhanced disclosures, including the annual disclosure of stress test scenarios. The proposals would also adjust the stress testing timeline to enable a public comment period for the 2026 stress test scenarios, augment the information the Fed collects, and introduce revisions to regulatory reporting forms (i.e., FR Y-14A, FR Y-14M, and FR Y-14Q forms) to reduce reporting burdens and improve risk capture.

Comments on the proposed 2026 stress test scenarios will be due December 1, and comments on the transparency and public accountability proposal will be due by January 22, 2026.