CCAR Means Comprehensive Capital Analysis and Review

The Comprehensive Capital Analysis and Review (CCAR) is an annual exercise by the Federal Reserve to assess whether the largest bank holding companies operating in the United States have sufficient capital to continue operations throughout times of economic and financial stress and that they have robust, forward-looking capital-planning processes that account for their unique risks.
As part of this exercise, the Federal Reserve evaluates institutions’ capital adequacy, internal capital adequacy assessment processes, and their individual plans to make capital distributions, such as dividend payments or stock repurchases. – United States Federal Reserve

Regions covered by the Federal Reserve Banks
Regions covered by the Federal Reserve Banks

There is no one who has had a career is CCAR because it was only created in 2010 and first performed in 2011. Previous to this exercise, a similar assessment was done under the name of Supervisory Capital Assessment Program (SCAP). It was performed once in 2009. SCAP was inspiration for CCAR, which is not performed yearly in the first quarter. The Federal reserve are in constant discussions about the test during the process and provides a previous of the assessment in March to the banks that are involved in the assessment. There are 31 banks that must participate in CCAR. Participation primarily has to do with size and market reach because CCAR is testing the financial system’s ability avoid a bank crisis.


About the Author: Marcus Maltempo is a compliance professional with more than a decade of experience helping banks, law firms and clients manage investigations and regulatory responses.


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Financial Crime Briefing: Strengthening Controls to Address Evolving Risk Trends

On Monday, January 26, Associations of Certified Anti-Money Laundering Specialists (hereon ACAMS) held its Third Annual AML Risk Management Conference at The Conrad Hotel in downtown New York. Over the course of this week, summaries and takeaways from the key notes and panel discussions will be shared in this blog.

  • William Langford, Moderator, Global Head of Compliance Architecture and Strategy, Citigroup
  • Martin Cunningham, CAMS, Regional Head – Financial Crime Intelligence – Americas, Standard Chartered Bank
  • Justin Bogert, CAMS, Global Controls Manager, Paypal

HeaderThis panel discussion, the final for the conference, was a well-rounded compliance function discussion. Compliance department has a lot of roles: adviser, monitor, surveillance, investigation, risk mitigation, oversight and control, and regulatory relations. The focus of this panel was monitoring, surveillance and investigation. Both Martin Cunningham and Justin Bogert have military intelligence backgrounds. Cunningham is at a traditional financial institution and Bogert is at a money services business (MSB). Many of the issues are the same but the institutions differing in two main ways, in terms of compliance:

  1. MSB’s collect far less information during onboarding a client, and
  2. MSB’s have more issues pertaining to charities being abused for money laundering or terror financing.

Paypal silos risk into three buckets: Brand Risk, Fraud Risk and Transaction Risk. Traditional anti-money laundering program development are utilized to research typology. Special effort is made to collect information as transactions, both financial and non-financial, take place on Paypal’s platform to create risk profiles. Paypal has developed an internal visualization tool to find relationships.

Standard Chartered Bank is highly exposed to developing economies. For this reason, geo-political expertise is highly valued. SCB’s AML teams are made up of four groups of people: Law Enforcement, Intelligence, Bankers and Trade/Tool personnel. Law Enforcement are good at documentation and analysis of the collected information. Intelligence are good at bringing outside information in to provide context. Bankers bring institutional knowledge about how the organization reacts to transactions and relationships. Trade and Tools personnel provide execution expertise in both preventing and investigating crimes.


About the Author: Marcus Maltempo is a compliance professional with more than a decade of experience helping banks, law firms and clients manage investigations and regulatory responses.
He tweets @MoneyCompliance