CCAR benchmark 2020

  • 1 July 2020

Every year, ORX conducts a benchmarking study specific to Comprehensive Capital Adequacy Review (CCAR) banks, which is gaining popularity year on year. We had 25 banks take part last year, which is the majority of banks in the CCAR pool. The participants found the combination of quantitative information, such as high-level benchmark ratio of models, and qualitative information, such as how many scenarios are included in the submission and how they are selected, particularly useful. We also set up phone calls to discuss the outcomes of the study and an in-person roundtable event focused on CCAR methodology, which is not offered by any other organisation to the level that we deliver. We are the leaders in this area. 

Changes to CCAR due to COVID-19

On June 25th, the US Federal Reserve Board (FRB) released the results of this year’s Comprehensive Capital Adequacy Review (CCAR) exercise. In addition to the results of the exercise based on scenarios released earlier this year, the FRB also released a publication with details of a sensitivity analysis carried out in light of the coronavirus pandemic. The current economic crisis has exceeded many of the variables included in the original scenarios.

Included in the publication of this sensitivity analysis was an announcement that the FRB will shortly release new scenarios based on potential trajectories of economic recovery. Upon release of these new variables, participating banks will be required to update and resubmit CCAR within 45 days.

Our CCAR working group will meet in July to discuss some preliminary results of the ORX CCAR survey and hear people’s thoughts on the upcoming second submission. There will be a short follow-up study held later in the year following this submission. There will be regular group calls throughout the year to support our CCAR community.

About this year's study

Under the supervision of the US Federal Reserve Board (FRB), the Comprehensive Capital Adequacy Review (CCAR) is a key annual exercise for banks conducting business in the United States. It is one of the most complex stress testing requirements that assess the capital adequacy of the largest bank holding companies (BHCs).

As part of this year's exercise, the adverse scenario was dropped, leaving only the baseline and severely adverse scenarios, the latter of which includes two additional components. These components focus on a global market shock and counterparty default, and institutions may be subject to take one or both of them into account depending on their business activities.

Last year, the Federal Reserve issued letters of regulatory relief, this caused shifts in institutions’ forecasting methodologies, scenario analysis, and material risk identification. This year, there was no relief from CCAR requirements, and we will observe how firms have readjusted. As part of the study, we will also provide individual benchmarks of methodology and model outputs for 2020 CCAR submissions.

Alongside the benchmarks, a report will be published to participants which will take a closer look at forecasting methods, scenario analysis, material risk identification, challenges, and much more.

The survey has now closed, and we are currently in the process of data quality assurance and preliminary analysis.


CCAR 2020 timeline updated 1 July v2

You can download the CCAR benchmark 2019 summary report and individual factsheet sample below. Only participants from last year's study can access the full report, which is available to download on our member website


CCAR benchmark 2019 summary report

CCAR benchmark 2019 individual factsheet sample


There is no charge for ORX members. The cost for non-members is $3,000, which is refundable if you become a member of ORX in 2020.

If you are interested in participating, please get in touch.

Op risk measurement

You can read our CCAR benchmark reports from previous years and find out what other op risk measurement work we've produced. 

See our previous reports