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entitled 'Troubled Asset Relief Program: Bank Stress Test Offers 
Lessons as Regulators Take Further Actions to Strengthen Supervisory 
Oversight' which was released on September 29, 2010. 

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Report to Congressional Committees: 

United States Government Accountability Office:
GAO: 

September 2010: 

Troubled Asset Relief Program: 

Bank Stress Test Offers Lessons as Regulators Take Further Actions to 
Strengthen Supervisory Oversight: 

GAO-10-861: 

GAO Highlights: 

Highlights of GAO-10-861, a report to congressional committees. 

Why GAO Did This Study: 

The Supervisory Capital Assessment Program (SCAP) was established 
under the Capital Assistance Program (CAP)—a component of the Troubled 
Asset Relief Program (TARP)—to assess whether the 19 largest U.S. bank 
holding companies (BHC) had enough capital to withstand a severe 
economic downturn. Led by the Board of Governors of the Federal 
Reserve System (Federal Reserve), federal bank regulators conducted a 
stress test to determine if these banks needed to raise additional 
capital, either privately or through CAP. This report (1) describes 
the SCAP process and participants’ views of the process, (2) assesses 
SCAP’s goals and results and BHCs’ performance, and (3) identifies how 
regulators and the BHCs are applying lessons learned from SCAP. To do 
this work, GAO reviewed SCAP documents, analyzed financial data, and 
interviewed regulatory, industry, and BHC officials. 

What GAO Found: 

The SCAP process appeared to have been mostly successful in promoting 
coordination, transparency, and capital adequacy. The process utilized 
an organizational structure that facilitated coordination and 
communication among regulatory staff from multiple disciplines and 
organizations and with the BHCs. Because SCAP was designed to help 
restore confidence in the banking industry, regulators took unusual 
steps to increase transparency by releasing details of their 
methodology and sensitive BHC-specific results. However, several 
participants criticized aspects of the SCAP process. For example, some 
supervisory and bank industry officials stated that the Federal 
Reserve was not transparent about the linkages between some of the test’
s assumptions and results. But most of the participants in SCAP agreed 
that despite these views, coordination and communication were 
effective and could serve as a model for future supervisory efforts. 
According to regulators, the process resulted in a methodology that 
yielded credible results. By design, the process helped to ensure that 
BHCs would be capitalized for a potentially more severe downturn in 
economic conditions from 2009 through 2010. 

SCAP largely met its goals of increasing the level and quality of 
capital held by the 19 largest U.S. BHCs and, more broadly, 
strengthening market confidence in the banking system. The stress test 
identified 9 BHCs that met the capital requirements under the more 
adverse scenario and 10 that needed to raise additional capital. Nine 
of the 10 BHCs were able to raise capital in the private market, with 
the exception of GMAC LLC, which received additional capital from the 
U.S. Department of the Treasury (Treasury). The resulting capital 
adequacy of the 19 BHCs has generally exceeded SCAP’s requirements, 
and two-thirds of the BHCs have either fully repaid or begun to repay 
their TARP investments. Officials from the BHCs, credit rating 
agencies, and federal banking agencies indicated that the Federal 
Reserve’s public release of the stress test methodology and results in 
the spring of 2009 helped strengthen market confidence. During the 
first year of SCAP (2009), overall actual losses for these 19 BHCs 
have generally been below GAO’s 1-year pro rata loss estimates under 
the more adverse economic scenario. Collectively, the BHCs experienced 
gains in their securities and trading and counterparty portfolios. 
However, some BHCs exceeded the GAO 1-year pro rata estimated 2009 
losses in certain areas, such as consumer and commercial lending. Most 
notably, in 2009, GMAC LLC exceeded the loss estimates in multiple 
categories for the full 2-year SCAP period. More losses in the 
residential and commercial real estate markets and further 
deterioration in economic conditions could challenge the BHCs, even 
though they have been deemed to have adequate capital levels under 
SCAP. 

SCAP provided a number of important lessons for regulators about the 
benefits of increased transparency, the need for regulators to 
strengthen bank supervision, the need for regulators and BHCs to 
improve their risk identification and assessment practices, and the 
need for regulators to improve coordination and communication. First, 
SCAP underscored the potential benefits that increased transparency 
about the financial health of the nation’s largest BHCs can provide. 
Many experts have said that the lack of transparency about potential 
losses from certain assets contributed significantly to the 
instability in financial markets during the current crisis. But 
transparency in the banking supervisory process is a controversial 
issue. Some observers say that publicly disclosing sensitive bank 
information without a federal capital backstop could have unintended 
negative effects, such as runs on banks, that would disproportionately 
affect weaker banks. However, other observers believe that more 
transparency about banks’ asset valuations and losses could help the 
public better understand the risk exposures of BHCs, increase market 
discipline, and improve the oversight of these institutions. A final 
analysis by the Federal Reserve of BHCs’ performance during the full 2-
year SCAP period can help in this regard. The Federal Reserve and 
other banking regulators could benefit from developing a plan to 
improve the transparency of bank supervision. Second, SCAP showed that 
more robust regulatory oversight of bank stress tests was necessary to 
better understand banks’ capacity to withstand downturns in the 
economy. Regulators and BHC officials commented that internal bank 
stress tests prior to SCAP did not comprehensively stress their 
portfolios. The Federal Reserve is finalizing examiner guidance for 
assessing capital adequacy, including stress testing, but it has not 
established criteria for assessing the rigor of the BHCs’ stress test 
assumptions. Without more robust guidance, ensuring that stress tests 
are being evaluated thoroughly and consistently is difficult. Third, 
the SCAP exercise highlighted opportunities to enhance both the 
process and data inputs for conducting future stress tests. The 
Federal Reserve has started to build a plan to enhance its risk 
identification and assessment infrastructure in response to the 
financial crisis, but further planning is needed to reflect recent 
changes under the Dodd-Frank Wall Street Reform and Consumer 
Protection Act of 2010. Finally, SCAP demonstrated the need for robust 
coordination and communication among regulators in examining complex 
institutions. While SCAP promoted coordination and communication, 
further efforts are needed to ensure the participation of relevant 
regulators in multiagency examinations of banks. 

Table 1: Indicative Loss Rates Estimates and Actual SCAP BHCs and 
Banking Industry Average Loss Rates, December 31, 2009: 

Loan category: First-lien mortgage; 
SCAP indicative loss rate estimates: Federal Reserve's more adverse 2-
year loss rate[A]: 7-8.5%; 
SCAP indicative loss rate estimates: GAO's more adverse 1-year pro 
rata loss rate[B]: 3.5-4.25%; 
2009 actual loss rates: SCAP BHCs average loss rate: 1.9%; 
2009 actual loss rates: Banking industry average loss rate[C]: 1.7%. 

Loan category: Second/junior lien mortgages; 
SCAP indicative loss rate estimates: Federal Reserve's more adverse 2-
year loss rate[A]: 12-16%; 
SCAP indicative loss rate estimates: GAO's more adverse 1-year pro 
rata loss rate[B]: 6-8%; 
2009 actual loss rates: SCAP BHCs average loss rate: 4.4%; 
2009 actual loss rates: Banking industry average loss rate[C]: 3.9%. 

Loan category: Commercial and industrial; 
SCAP indicative loss rate estimates: Federal Reserve's more adverse 2-
year loss rate[A]: 5-8%; 
SCAP indicative loss rate estimates: GAO's more adverse 1-year pro 
rata loss rate[B]: 2.5-4%; 
2009 actual loss rates: SCAP BHCs average loss rate: 2.5%; 
2009 actual loss rates: Banking industry average loss rate[C]: 2.3%. 

Loan category: Commercial real estate; 
SCAP indicative loss rate estimates: Federal Reserve's more adverse 2-
year loss rate[A]: 9-12%; 
SCAP indicative loss rate estimates: GAO's more adverse 1-year pro 
rata loss rate[B]: 4.5-6%; 
2009 actual loss rates: SCAP BHCs average loss rate: 2.3%; 
2009 actual loss rates: Banking industry average loss rate[C]: 2.4%. 

Loan category: Credit cards; 
[Empty]; 
SCAP indicative loss rate estimates: Federal Reserve's more adverse 2-
year loss rate[A]: 18-20%; 
SCAP indicative loss rate estimates: GAO's more adverse 1-year pro 
rata loss rate[B]: 9-10%; 
2009 actual loss rates: SCAP BHCs average loss rate: 10.1%; 
2009 actual loss rates: Banking industry average loss rate[C]: 10.2%. 

Loan category: Other consumer; 
SCAP indicative loss rate estimates: Federal Reserve's more adverse 2-
year loss rate[A]: 8-12%; 
SCAP indicative loss rate estimates: GAO's more adverse 1-year pro 
rata loss rate[B]: 4-6%; 
2009 actual loss rates: SCAP BHCs average loss rate: 4.1%; 
2009 actual loss rates: Banking industry average loss rate[C]: 4.4%. 

Loan category: Other loans; 
SCAP indicative loss rate estimates: Federal Reserve's more adverse 2-
year loss rate[A]: 4-10%; 
SCAP indicative loss rate estimates: GAO's more adverse 1-year pro 
rata loss rate[B]: 2-5%; 
[Empty]; 
2009 actual loss rates: SCAP BHCs average loss rate: 1.4%; 
2009 actual loss rates: Banking industry average loss rate[C]: 1.1%. 

Sources: Federal Reserve SCAP results report, GAO analysis of SNL 
Financial Y-9C regulatory data, and Moody's Investors Service for 
prime, Alt-A, and subprime mortgage loss rates data. 

[A] Data as of December 31, 2010. 

[B] GAO calculated the more adverse 1-year pro rata loss rate by 
dividing the SCAP more adverse 2-year loss rates by 2 (i.e., the 
straight-line method). A key limitation of this approach is that it 
assumes equal distribution of losses, revenues, expenses, and changes 
to reserves over time, although these items were unlikely to be 
distributed evenly over the 2-year period. Another important 
consideration is that actual results were not intended and should not 
be expected to align with the SCAP projections. 

[C] Data are for BHCs with greater than $1 billion in total assets. 

[End of table] 

What GAO Recommends: 

This report recommends that the Federal Reserve complete a final 2-
year SCAP analysis, and apply lessons learned from SCAP to improve 
transparency of bank supervision, examiner guidance, risk 
identification and assessment, and regulatory coordination. The 
Federal Reserve agreed with our five recommendations and noted current 
actions that it has underway to address them. Treasury agreed with the 
report’s findings. 

View [hyperlink, http://www.gao.gov/products/GAO-10-861] or key 
components. For more information, contact Orice Williams Brown at 
(202) 512-8678 or williamso@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

SCAP Process Generally Viewed as Promoting Coordination, Transparency, 
and Capital Adequacy: 

While SCAP Increased Capital Levels and Improved Confidence in the 
Banking System, BHCs Could Face Ongoing Challenges: 

SCAP Provided Lessons That Could Help Regulators Strengthen 
Supervisory Oversight and BHCs Improve Risk Management Practices: 

Conclusions: 

Recommendations: 

Agency Comments and Our Evaluation: 

Appendix I: Objectives, Scope, and Methodology: 

Appendix II: Status of Bank Holding Companies' TARP Investments as 
September 22, 2010: 

Appendix III: One-Year Actual Performance Compared to GAO's Pro rata 
Stress Test Loss Projections for Each of the 19 SCAP BHCs: 

Appendix IV: Comments from the Board of Governors of the Federal 
Reserve System: 

Appendix V: Comments from the Department of the Treasury's Office of 
Financial Stability: 

Appendix VI: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: Indicative Loss Rates Estimates and Actual SCAP BHCs and 
Banking Industry Average Loss Rates, December 31, 2009: 

Table 2: Summary of Capital Raised by 10 BHCs to Meet Their SCAP 
Capital Buffer Amount, as of November 9, 2009: 

Table 3: Capital Measures for SCAP BHCs, December 31, 2008 and 
December 31, 2009: 

Table 4: Percentage Change in Tier I Capital Ratios, December 31, 
2008, and December 31, 2009: 

Table 5: Actual and GAO Pro Rata Estimates of Aggregate Losses and 
Changes in Resources Other than Capital to Absorb Losses across the 19 
SCAP BHCs, December 31, 2009: 

Table 6: Items Used to Calculate Tier 1 Capital, Asset Losses, PPNR, 
and ALLL: 

Table 7: Tier 1 Common Capital Calculation: 

Table 8: Crosswalk of Y-9C Net Charge-Offs and Asset Classifications 
to Classifications Used by SCAP: 

Table 9: Crosswalk of Y-9C Loans and Lease Financing Receivables to 
and Classifications used by SCAP: 

Table 10: Status of TARP Investments for the 19 BHCs Participating in 
SCAP, as of September 22, 2010: 

Table 11: Identification of 19 BHCs Subject to the Stress Test: 

Table 12: American Express Company: 

Table 13: Bank of America Corporation: 

Table 14: BB&T Corporation: 

Table 15: The Bank of New York Mellon Corporation: 

Table 16: Capital One Financial Corporation: 

Table 17: Citigroup Inc. 

Table 18: Fifth Third Bancorp: 

Table 19: GMAC LLC: 

Table 20: The Goldman Sachs Group, Inc. 

Table 21: JPMorgan Chase & Co. 

Table 22: KeyCorp: 

Table 23: MetLife, Inc. 

Table 24: Morgan Stanley: 

Table 25: PNC Financial Services Group, Inc. 

Table 26: Regions Financial Corporation: 

Table 27: State Street Corporation: 

Table 28: SunTrust Banks, Inc. 

Table 29: U.S. Bancorp: 

Table 30: Wells Fargo & Company: 

Figures: 

Figure 1: Timeline of Key Activities Regarding Implementation of SCAP, 
February 10, 2009, through December 31, 2009: 

Figure 2: Commercial Bank 2-Year Loan Loss Rates from 1921 through 
2013 Compared to SCAP Loan Loss Rate: 

Figure 3: Actual Economic Performance to Date Versus SCAP More Adverse 
Assumptions: 

Figure 4: Gross Common Equity Issuance by Banks and Thrifts, 2000 to 
First Quarter 2010: 

Figure 5: Stock Market Prices, October 2007 through March 2010: 

Figure 6: Bank Credit Default Swap Spreads, January 2007 through March 
2010: 

Figure 7: Comparison of Actual and GAO Pro Rata Estimated Losses for 
Consumer and Commercial Loans, December 31, 2009: 

Figure 8: Comparison of Actual and GAO Pro Rata Estimated Gains and 
Losses for Securities Available for Sale and Held to Maturity, 
December 31, 2009: 

Figure 9: Comparison of Actual and GAO Pro Rata Estimated Gains and 
Losses for Trading and Counterparty, December 31, 2009: 

Figure 10: Change in the Percentage of Nonperforming Loans for 
Applicable SCAP BHCs, by Loan Type, First Quarter 2007 through Fourth 
Quarter 2009: 

Figure 11: Comparison of Actual and GAO Pro Rata Estimated Resources 
Other Than Capital to Absorb Losses, December 31, 2009: 

Abbreviations: 

ALLL: allowance for loan and lease losses: 

BHC: bank holding company: 

BB&T: BB&T Corporation: 

CAP: Capital Assistance Program: 

CES: common equivalent securities: 

CPP: Capital Purchase Program: 

DTA: deferred tax asset: 

EESA: Emergency Economic Stabilization Act of 2008: 

ESOP: Employee Stock Ownership Plan: 

FDIC: Federal Deposit Insurance Corporation: 

FSP: Financial Stability Plan: 

GDP: gross domestic product: 

GMAC: GMAC LLC: 

ICAAP: internal capital adequacy assessment process: 

OCC: Office of the Comptroller of the Currency: 

PPNR: preprovision net revenue: 

SCAP: Supervisory Capital Assessment Program: 

TARP: Troubled Asset Relief Program: 

TIP: Targeted Investment Program: 

Y-9C: Consolidated Financial Statements for Bank Holding Companies-FR 
Y-9C: 

[End of section] 

United States Government Accountability Office:
Washington, DC 20548: 

September 29, 2010: 

Congressional Committees: 

The recent financial crisis seriously undermined confidence in the 
nation's financial system and institutions. In February 2009, to help 
restore confidence, the U.S. Department of the Treasury (Treasury) 
announced the Financial Stability Plan, which established the 
Supervisory Capital Assessment Program (SCAP).[Footnote 1] SCAP, as 
implemented by the Board of Governors of the Federal Reserve System 
(Federal Reserve) and other federal banking regulators,[Footnote 2] 
was to determine through a stress test whether the largest 19 U.S. 
bank holding companies (BHC)[Footnote 3] had enough capital for the 
next 2 years (2009-2010) to support their lending activities and 
survive a second similar economic shock.[Footnote 4] As of December 
31, 2008, the largest 19 BHCs accounted for approximately 67 percent 
of the assets and more than 50 percent of loans in the U.S. banking 
system. BHCs that were found to need additional capital would be 
allowed, and were encouraged, to raise the funds privately, but if 
they could not, Treasury would provide capital infusions using funding 
available under the Troubled Asset Relief Program's (TARP) Capital 
Assistance Program (CAP).[Footnote 5] However, Treasury made no 
investments under CAP and terminated the program in November 2009. 
When SCAP was first announced in February 2009, and again around the 
time the Federal Reserve released the results of the stress test in 
May 2009, some academics, market participants, and others raised 
concerns about the test, noting that the assumptions used in the more 
adverse economic scenario were not severe enough and that the test did 
not account for differences in institutions' business models. 

As part of GAO's continued analysis and monitoring of Treasury's 
process for implementing the Emergency Economic Stabilization Act of 
2008,[Footnote 6] this report on the stress test expands on SCAP 
activities that we reported on in June 2009.[Footnote 7] Specifically, 
this report (1) describes the process used to design and conduct the 
stress test and participants' views on the process, (2) describes the 
extent to which the stress test achieved its goals and compares its 
estimates with the BHCs' actual results, and (3) identifies the 
lessons regulators and BHCs learned from SCAP and examines how each 
are using those lessons to enhance their risk identification and 
assessment practices. 

To meet the report's objectives, we reviewed the Federal Reserve's The 
Supervisory Capital Assessment Program: Design and Implementation 
(SCAP design and implementation document) dated April 24, 2009, and 
The Supervisory Capital Assessment Program: Overview of Results (SCAP 
results document) dated May 7, 2009. In addition to the publicly 
released BHC-level loss estimates, we analyzed the initial stress test 
results that the Federal Reserve provided to each BHC, the subsequent 
adjustments the Federal Reserve made to these results, and its reasons 
for making them. We also reviewed the BHCs' quarterly regulatory 
filings, such as the Federal Reserve's 2009 Consolidated Financial 
Statements for Bank Holding Companies--FR Y-9C (Y-9C); form 10-Qs and 
annual form 10-Ks; speeches, testimonies, and articles regarding SCAP 
and stress testing; and BHC presentations to shareholders and earnings 
reports. To more completely understand the execution of SCAP, we 
completed a literature search of stress tests that other entities have 
conducted, such as the Committee of European Banking Supervisors and 
the International Monetary Fund. We also reviewed the Congressional 
Oversight Panel's analysis of SCAP. In addition, we reviewed the 
capital plans of the 10 BHCs that were required to raise capital to 
satisfy their SCAP capital requirement. We collected and analyzed data 
on the BHCs' actual performance from a private financial database of 
public information and compared it with the 2-year SCAP estimates and 
with GAO's 1-year pro rata loss estimates for the more adverse 
scenario (pro rata loss estimate). GAO calculated the pro rata loss 
estimates by dividing the SCAP more adverse 2-year loss estimates by 
2. This pro rata estimate methodology has some limitations, because 
losses, expenses, revenues, and changes to reserves are historically 
unevenly distributed and loss rates over a 2-year period in an 
uncertain economic environment can follow an inconsistent path. 
However, the Federal Reserve, the Office of the Comptroller of the 
Currency (OCC), credit rating agencies, an SNL Financial analyst, and 
all of the BHCs we interviewed that are tracking performance relative 
to SCAP estimates are also using the same methodology. We obtained 
Federal Reserve and BHCs comments on our performance comparison. 
Further, we interviewed regulatory and BHC officials to get their 
views on the SCAP stress test. Regulatory officials included bank 
examiners, economists, and attorneys from the Federal Reserve; the 
Federal Reserve district banks; the OCC; the Federal Deposit Insurance 
Corporation (FDIC); the Office of Thrift Supervision; and BHC senior 
officials, including chief financial officers and chief risk officers, 
who participated in the SCAP stress test and were responsible for 
coordinating and discussing the results with regulators. These 
officials represented several types of BHCs, including traditional, 
custodial, investment, auto finance, and credit card institutions. 
Finally, we met with credit rating agency officials to get their views 
on SCAP and understand their own stress testing practices for banks. 
For additional information on the scope and methodology for this 
engagement, see appendix I. 

We conducted this performance audit from August 2009 to September 2010 
in accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

Background: 

Despite efforts undertaken by TARP to bolster capital of the largest 
financial institutions, market conditions in the beginning of 2009 
were deteriorating and public confidence in the ability of financial 
institutions to withstand losses and to continue lending were further 
declining. On February 10, 2009, Treasury announced the Financial 
Stability Plan, which outlined measures to address the financial 
crisis and restore confidence in the U.S. financial and housing 
markets. The goals of the plan were to (1) restart the flow of credit 
to consumers and businesses, (2) strengthen financial institutions, 
and (3) provide aid to homeowners and small businesses. Under SCAP, 
the stress test would assess the ability of the largest 19 BHCs to 
absorb losses if economic conditions deteriorated further in a 
hypothetical "more adverse" scenario, characterized by a sharper and 
more protracted decline in gross domestic product (GDP) growth, 
[Footnote 8] a steeper drop in home prices, and a larger rise in the 
unemployment rate than in a baseline consensus scenario. BHCs that 
were found not to meet the SCAP capital buffer requirement under the 
"more adverse" scenario would need to provide a satisfactory capital 
plan to address any shortfall by raising funds, privately if possible. 
CAP, which was a key part of the plan, would provide backup capital to 
financial institutions unable to raise funds from private investors. 
Any of the 19 BHCs that participated in the stress test and had a 
capital shortfall could apply for capital from CAP immediately if 
necessary.[Footnote 9] The timeline in figure 1 provides some 
highlights of key developments in the implementation of SCAP. 

Figure 1: Timeline of Key Activities Regarding Implementation of SCAP, 
February 10, 2009, through December 31, 2009: 

[Refer to PDF for image: timeline] 

2009: 

February 10: Treasury announces the Financial Stability Plan (FSP) to 
stabilize and repair the financial system and support the flow of 
credit. A key component of FSP is CAP and a key part of CAP is SCAP. 

February 23: Treasury announces SCAP or stress test of the largest 19 
U.S. BHCs. 

February 25: Treasury announces the terms and conditions for CAP. 

April 24: The Federal Reserve releases information regarding the 
design and implementation of the stress test. 

May 7: The Federal Reserve announces the results of the stress test 
and 10 of the 19 BHCs are found to need capital. 

May 8: Wells Fargo & Company issues $8.6 billion and Morgan Stanley 
Inc. issues $8 billion in equity and debt to meet SCAP capital 
requirements and/or pay back taxpayer money. 

June 8: The 10 BHCs that required capital under SCAP submit plans to 
raise capital. 

June 17: Nine of the 19 SCAP BHCs repurchased their preferred stock 
from Treasury. 

June 30: GMAC LLC, a Delaware limited liability company, was converted 
into a Delaware corporation and renamed GMAC Inc. 

September 30: All BHCs but GMAC Inc. have met or exceeded the capital 
requirements of the more adverse scenario. 

November 9: Deadline for raising capital. GMAC Inc. is the only BHC 
unable to raise the capital as required by SCAP. Also, Treasury closes 
CAP with no investments having been made. 

December 30: GMAC Inc. is given $3.8 billion in taxpayer money under 
TARP’s Automotive Industry Financing Program to meet the level of 
capital required by the stress test. 

Source: GAO. 

Note: On May 10, 2010, GMAC Inc. changed its name to Ally Financial 
Inc. 

[End of figure] 

In a joint statement issued on February 10, 2009, Treasury, along with 
the Federal Reserve, FDIC, and OCC (collectively referred to as the 
SCAP regulators), committed to design and implement the stress test. 
According to a Treasury official, the department generally did not 
participate in the design or implementation of SCAP, but was kept 
informed by the Federal Reserve during the stress test. The SCAP 
regulators developed economic assumptions to estimate the potential 
impact of further losses on BHCs' capital under two scenarios. The 
baseline scenario reflected the consensus view about the depth and 
duration of the recession, and the more adverse scenario reflected a 
plausible but deeper and longer recession than the consensus view. 
Regulators then calculated how much capital, if any, was required for 
each BHC to achieve the required SCAP buffer at the end of 2010 under 
the more adverse scenario. 

The SCAP assessment examined tier 1 capital and tier 1 common capital, 
and the BHCs were required to raise capital to meet any identified 
capital shortfall (either tier 1 capital or tier 1 common capital). 
Tier 1 risk-based capital is considered core capital--the most stable 
and readily available for supporting a bank's operations and includes 
elements such as common stock and noncumulative perpetual preferred 
stock.[Footnote 10] SCAP's focus on tier 1 common capital, a subset of 
tier 1 capital, reflects the recent regulatory push for BHCs to hold a 
higher quality of capital.[Footnote 11] The focus on common equity 
reflected both the long held view by bank supervisors that common 
equity should be the dominant component of tier 1 capital and 
increased market scrutiny of common equity ratios, driven in part by 
deterioration in common equity during the financial crisis. Common 
equity offers protection to more senior parts of the capital structure 
because it is the first to absorb losses in the capital structure. 
Common equity also gives a BHC greater permanent loss absorption 
capacity and greater ability to conserve resources under stress by 
changing the amount and timing of dividends and other distributions. 

To protect against risks, financial regulators set minimum standards 
for the capital that firms are to hold.[Footnote 12] However, SCAP set 
a one-time minimum capital buffer target for BHCs to hold to protect 
against losses and preprovision net revenue (PPNR) that were worse 
than anticipated during the 2009 to 2010 period.[Footnote 13] For the 
purposes of SCAP, the one-time target capital adequacy ratios are at 
least 6 percent of risk-weighted assets in tier 1 capital and at least 
4 percent in tier 1 common capital projected as of December 31, 2010. 
For the purposes of the projection, the regulators assumed that BHCs 
would suffer the estimated losses and earned revenues in 2009 and 2010 
in the more adverse scenario. SCAP regulators conducted the stress 
test strictly on the BHCs' assets as of December 31, 2008,[Footnote 
14] and--with the exception of off-balance sheet positions subject to 
Financial Accounting Statements No. 166 and 167, which assumed in the 
analysis to come on balance sheet as of January 1, 2010--did not take 
into account any changes in the composition of their balance sheets 
over the 2-year time frame.[Footnote 15] 

Stress testing is one of many risk management tools used by both BHCs 
and regulators. Complex financial institutions need management 
information systems that can help firms to identify, assess, and 
manage a full range of risks across the whole organization arising 
from both internal and external sources and from assets and 
obligations that are found both on and off the BHC's balance sheet. 
This approach is intended to help ensure that a firmwide approach to 
managing risk has been viewed as being crucial for responding to rapid 
and unanticipated changes in financial markets. Risk management also 
depends on an effective corporate governance system that addresses 
risk across the institution and also within specific areas, such as 
subprime mortgage lending.[Footnote 16] The board of directors, senior 
management, audit committee, internal auditors, external auditors, and 
others play important roles in effectively operating a risk management 
system. The different roles of each of these groups represent critical 
checks and balances in the overall risk management system. However, 
the management information systems at many financial institutions have 
been called into question since the financial crisis began in 2007. 
Identified shortcomings, such as lack of firmwide stress testing, have 
led banking organizations and their regulators to reassess capital 
requirements, risk management practices, and other aspects of bank 
regulation and supervision.[Footnote 17] 

Stress testing has been used throughout the financial industry for 
more than 10 years, but has recently evolved as a risk management tool 
in response to the urgency of the financial crisis. The main evolution 
is towards the use of comprehensive firmwide stress testing as an 
integral and critical part of firms' internal capital adequacy 
assessment processes. In the case of SCAP, the intent of the stress 
test was to help ensure that the capital held by a BHC is sufficient 
to withstand a plausible adverse economic environment over the 2-year 
time frame ending December 31, 2010. The Basel Committee on Banking 
Supervision (Basel Committee) issued a document in May 2009 outlining 
several principles for sound stress testing practices and supervision. 
[Footnote 18] The Basel Committee document endorses stress testing by 
banks as a part of their internal risk management to assess the 
following: 

* Credit risk. The potential for financial losses resulting from the 
failure of a borrower or counterparty to perform on an obligation. 

* Market risk. The potential for financial losses due to an increase 
or decrease in the value of an asset or liability resulting from broad 
price movements; for example, in interest rates, commodity prices, 
stock prices, or the relative value of currencies (foreign exchange). 

* Liquidity risk. The potential for financial losses due to an 
institution's failure to meet its obligations because it cannot 
liquidate assets or obtain adequate funding. 

* Operational risk. The potential for unexpected financial losses due 
to a wide variety of institutional factors including inadequate 
information systems, operational problems, breaches in internal 
controls, or fraud. 

* Legal risk. The potential for financial losses due to breaches of 
law or regulation that may result in heavy penalties or other costs. 

* Compliance risk. The potential for loss arising from violations of 
laws or regulations or nonconformance with internal policies or 
ethical standards. 

* Strategic risk. The potential for loss arising from adverse business 
decisions or improper implementation of decisions. 

* Reputational risk. The potential for loss arising from negative 
publicity regarding an institution's business practices. 

SCAP Process Generally Viewed as Promoting Coordination, Transparency, 
and Capital Adequacy: 

According to SCAP regulators and many market participants we 
interviewed, the process used to design and implement SCAP was 
effective in promoting coordination and transparency among the 
regulators and participating BHCs, but some SCAP participants we 
interviewed expressed concerns about the process. The majority of 
supervisory and bank industry officials we interviewed stated that 
they were satisfied with how SCAP was implemented, especially 
considering the stress test's unprecedented nature, limited time 
frame, and the uncertainty in the economy. SCAP established a process 
for (1) coordinating and communicating among the regulators and with 
the BHCs and (2) promoting transparency of the stress test to the 
public. In addition, according to regulators, the process resulted in 
a methodology that yielded credible results and by design helped to 
assure that the BHCs would be sufficiently capitalized to weather a 
more adverse economic downturn. 

SCAP Process Included Coordination and Communication among the Federal 
Bank Regulators and with the BHCs: 

Robust coordination and communication are essential to programs like 
SCAP when bringing together regulatory staff from multiple agencies 
and disciplines to effectively analyze complex financial institutions 
and understand the interactions among multiple layers of risk. 
Moreover, supervisory guidance emphasizes the importance of 
coordination and communication among regulators to both effectively 
assess banks and conduct coordinated supervisory reviews across a 
group of peer institutions, referred to as "horizontal examinations." 

The regulators implemented each phase of SCAP in a coordinated 
interagency fashion. Also, while some disagreed, most regulators and 
market participants we interviewed were satisfied with the level of 
coordination and communication. They also thought that the SCAP 
process could serve as a model for future supervisory efforts. The 
regulators executed the SCAP process in three broad phases: 

* In the first phase, the Analytical Group, comprising interagency 
economists and supervisors, generated two sets of economic conditions--
a baseline scenario and a more adverse scenario with a worse-than- 
expected economic outcome--and then used these scenarios to aid in 
estimating industrywide indicative loan loss rates. To develop these 
scenarios, the Analytical Group used three primary indicators of 
economic health: the U.S. GDP, housing prices in 10 key U.S. 
cities,[Footnote 19] and the annual average U.S. unemployment 
rate.[Footnote 20] The baseline scenario reflected the consensus view 
of the course for the economy as of February 2009, according to well- 
known professional economic forecasters.[Footnote 21] The Federal 
Reserve developed the more adverse scenario from the baseline scenario 
by taking into account the historical accuracy of the forecasts for 
unemployment and the GDP and the uncertainty of the economic outlook 
at that time by professional forecasters. The Federal Reserve also 
used regulators' judgment about the appropriate severity of assumed 
additional stresses against which BHCs would be required to hold a 
capital buffer, given that the economy was already in a recession at 
the initiation of SCAP. 

* In the second phase, several Supervisory Analytical and Advisory 
Teams--comprising interagency senior examiners, economists, 
accountants, lawyers, financial analysts, and other professionals from 
the SCAP regulators--collected, verified, and analyzed each BHC's 
estimates for losses, PPNR, and allowance for loan and lease losses 
(ALLL).[Footnote 22] The teams also collected additional data to 
evaluate the BHC's estimates, and to allow supervisors to develop 
their own independent estimates of losses for loans, trading assets, 
counterparty credit risk, and securities and PPNR for each BHC. 

* In the third phase, the Capital Assessment Group, comprising 
interagency staff, served as the informal decision-making body for 
SCAP. The Capital Assessment Group developed a framework for combing 
the Supervisory Analytical and Advisory Teams' estimates with other 
independent supervisory estimates of loan losses and resources 
available to absorb these losses.[Footnote 23] They evaluated the 
estimates by comparing across BHCs and by aggregating over the 19 BHCs 
to check for consistency with the specified macroeconomic scenarios to 
calculate the amount, if any, of additional capital needed for each 
BHC to achieve the SCAP buffer target capital ratios as of December 
31, 2010, in the more adverse economic environment. Lastly, the 
Capital Assessment Group set two deadlines: (1) June 8, 2009, for BHCs 
requiring capital to develop and submit a capital plan to the Federal 
Reserve on how they would meet their SCAP capital shortfall and (2) 
November 9, 2009, for these BHCs to raise the required capital. 

A key component of this process was the involvement of 
multidisciplinary interagency teams that leveraged the skills and 
experiences of staff from different disciplines and agencies. The 
Federal Reserve, OCC, and FDIC had representatives on each SCAP team 
(the Analytical Group, Supervisory Analytical and Advisory Teams, and 
the Capital Assessment Group). For example, OCC officials said that 
they contributed to the development of quantitative models required 
for the implementation of SCAP and offered their own models for use in 
assessing the loss rates of certain portfolios. In addition, each of 
the SCAP regulators tapped expertise within their organization for 
specific disciplines, such as accounting, custodial banking, 
macroeconomics, commercial and industry loan loss modeling, and 
consumer risk modeling. According to the FDIC, the broad involvement 
of experts from across the agencies helped validate loss assumptions 
and also helped improve confidence in the results. Further, these 
officials noted that the SCAP process was enhanced because productive 
debate became a common event as team members from different regulatory 
agencies and disciplines brought their own perspectives and ideas to 
the process. For example, some SCAP staff argued for a more moderate 
treatment of securities in BHCs' available for sale portfolios, which 
would have been consistent with generally accepted accounting 
principles under a new change in accounting standards.[Footnote 24] 
They maintained that the modified accounting standard for declines in 
market value (and discounting the impact of liquidity premia) that had 
been implemented after the stress test was announced and before the 
numbers had been finalized was in some ways more reflective of the 
realized credit loss expectations for the affected securities. After 
significant discussion, the regulators decided to allow for the 
accounting change in the baseline loss estimates, but not in the more 
adverse scenario estimates. They believed that under the more adverse 
scenario there was a heightened possibility of increased liquidity 
demands on banks and that many distressed securities would need to be 
liquidated at distressed levels. Consequently, for securities found to 
be other than temporarily impaired in the more adverse scenario, they 
assumed the firm would have to realize all unrealized losses (i.e., 
write down the value of the security to market value as of year end 
2008).[Footnote 25] Similarly, some staff argued against adopting 
other changes in accounting standards that were expected to impact 
BHCs' balance sheets, including their capital adequacy. Primary among 
these was the inclusion of previously off-balance sheet items. 
[Footnote 26] As noted above, ultimately, the more conservative 
approach prevailed and the expected inclusion of these assets was 
addressed in SCAP. 

To facilitate coordination, the Federal Reserve instituted a voting 
system to resolve any contentious issues, but in practice differences 
among regulators were generally resolved through consensus. When SCAP 
regulators met, the Federal Reserve led the discussions and solicited 
input from other regulators. For example, officials from OCC and FDIC 
both told us that they felt that they were adequately involved in 
tailoring the aggregate loss estimates to each BHC as part of the 
determination of each BHC's SCAP capital requirement. SCAP regulators 
were also involved in drafting the design and results documents, which 
were publicly released by the Federal Reserve. 

Representatives from most of the BHCs were satisfied with the SCAP 
regulators' coordination and communication. Many of the BHC officials 
stated that they were generally impressed with the onsite SCAP teams 
and said that these teams improved the BHCs' coordination and 
communication with the regulators. BHC officials said that they 
usually received answers to their questions in a timely manner, either 
during conference calls held three times a week, through the 
distribution of answers to frequently asked questions, or from onsite 
SCAP examiners. Collecting and aggregating data were among the most 
difficult and time-consuming tasks for BHCs, but most of them stated 
that the nature of the SCAP's requests were clear. At the conclusion 
of SCAP, the regulators presented the results to each of the 
institutions showing the final numbers that they planned to publish. 

Market Participants Generally Agreed that the SCAP Process Was 
Transparent: 

The SCAP process included steps to promote transparency, such as the 
release of key program information to SCAP BHCs and the public. 
According to SCAP regulators, BHCs, and credit rating agency officials 
we interviewed, the release of the results provided specific 
information on the financial health and viability of the 19 largest 
BHCs regarding their ability to withstand additional losses during a 
time of significant uncertainty. Many experts have said that the lack 
of transparency about potential losses from certain assets contributed 
significantly to the instability in financial markets during the 
current crisis. Such officials also stated that publicly releasing the 
methodology and results of the stress test helped strengthen market 
confidence. Further, many market observers have commented that the 
Federal Reserve's unprecedented disclosure of sensitive supervisory 
information for each BHC helped European bank regulators decide to 
publicly release detailed results of their own stress tests in July 
2010. 

Not all SCAP participants agreed that the SCAP process was fully 
transparent. For example, some participants questioned the 
transparency of certain assumptions used in developing the stress 
test. According to BHC officials and one regulator, the Federal 
Reserve could have shared more detailed information about SCAP loss 
assumptions and calculations with BHCs.[Footnote 27] According to 
several BHC officials, the Federal Reserve did not fully explain the 
methodology for estimating losses but expected BHC officials to fully 
document and provide supporting data for all of their assumptions. 
Without knowing the details of the methodology, according to some BHC 
officials, they could not efficiently provide all relevant information 
to SCAP examiners. 

SCAP Was Designed to Help Ensure That BHCs Were Adequately Capitalized 
Under the More Adverse Economic Scenario: 

SCAP regulators aimed to ensure that SCAP sufficiently stressed BHCs' 
risk exposures and potential PPNR under the more adverse scenario. To 
accomplish this, the regulators made what they viewed to be 
conservative assumptions and decisions in the following areas. First, 
the regulators decided to stress only assets that were on the BHCs' 
balance sheets as of December 31, 2008, (i.e., a static approach) 
without accounting for new business activity. According to BHC 
officials, new loans were thought to have generally been of better 
quality than legacy loans because BHCs had significantly tightened 
their underwriting standards since the onset of the financial crisis. 
[Footnote 28] As a result, BHCs would have been less likely to charge-
off these loans within the SCAP time period ending December 31, 2010, 
resulting in the potential for greater reported revenue estimates for 
the period. By excluding earnings from new business, risk-weighted 
assets were understated, charge-off rates were overstated, and 
projected capital levels were understated. 

Second, SCAP regulators generally did not allow the BHCs to cut 
expenses to address the anticipated drop in revenues under the more 
adverse scenario. However, some BHC officials told us that they would 
likely cut expenses, including initiating rounds of layoffs, if the 
economy performed in accordance with the more adverse economic 
scenario, especially if they were not generating any new business. 
Federal Reserve officials noted that BHCs were given credit in the 
stress test for cost cuts made in the first quarter of 2009. 

Third, some BHCs were required to assume an increase in their ALLL as 
of the end of 2010, if necessary, to ensure adequate reserves relative 
to their year end 2010 portfolio. Some BHC officials believed that 
this requirement resulted in the BHCs having to raise additional 
capital because the required ALLL increases were subtracted from the 
revenue estimates in calculating the resources available to absorb 
losses. This meant that some BHCs judged to have insufficient year end 
2010 reserve adequacy had to account for this shortcoming in the 
calculation of capital needed to meet the SCAP targeted capital 
requirements as of the end of 2010 while maintaining a sufficient ALLL 
for 2011 losses under the more adverse economic scenario. According to 
some BHCs, the size of the 2010 ALLL was severe given the extent of 
losses are already included in the 2009 and 2010 loss estimates and 
effectively stressed BHCs for a third year. 

Finally, according to many BHC officials and others, the calculations 
used to derive the loan loss rates and other assumptions to stress the 
BHCs were conservative (i.e., more severe). For example, the total 
loan loss rate estimated by the SCAP regulators was 9.1 percent, which 
was greater than the historical 2-year loan loss rates at all 
commercial banks from 1921 until 2008, including the worst levels seen 
during the Great Depression (see figure 2). However, the macroeconomic 
assumptions of the more adverse scenario, which we will discuss later 
in the report, did not meet the definition of a depression. 
Specifically, a 25 percent unemployment rate coupled with economic 
contraction is indicative of a depression. In contrast, the more 
adverse scenario estimated approximately a 10 percent unemployment 
rate with some economic growth in late 2010. 

Figure 2: Commercial Bank 2-Year Loan Loss Rates from 1921 through 
2013 Compared to SCAP Loan Loss Rate: 

[Refer to PDF for image: line graph] 

SCAP total loan loss rate = 9.1%. 

Year: 1921; 
SCAP Loan loss rate: 1.68%. 

Year: 1922; 
SCAP Loan loss rate: 1.43%. 

Year: 1923; 
SCAP Loan loss rate: 1.36%. 

Year: 1924; 
SCAP Loan loss rate: 1.54%. 

Year: 1925; 
SCAP Loan loss rate: 1.75%. 

Year: 1926; 
SCAP Loan loss rate: 1.44%. 

Year: 1927; 
SCAP Loan loss rate: 1.16%. 

Year: 1928; 
SCAP Loan loss rate: 0.9%. 

Year: 1929; 
SCAP Loan loss rate: 0.72%. 

Year: 1930; 
SCAP Loan loss rate: 1.16v 

Year: 1931; 
SCAP Loan loss rate: 3.32%. 

Year: 1932; 
SCAP Loan loss rate: 6.16%. 

Year: 1933; 
SCAP Loan loss rate: 8.75%. 

Year: 1934; 
SCAP Loan loss rate: 8.57%. 

Year: 1935; 
SCAP Loan loss rate: 5.03%. 

Year: 1936; 
SCAP Loan loss rate: 2.48%. 

Year: 1937; 
SCAP Loan loss rate: 1.18%. 

Year: 1938; 
SCAP Loan loss rate: 0.89%. 

Year: 1939; 
SCAP Loan loss rate: 1%. 

Year: 1940; 
SCAP Loan loss rate: 0.68%. 

Year: 1941; 
SCAP Loan loss rate: 0.41%. 

Year: 1942; 
SCAP Loan loss rate: 0.21%. 

Year: 1943; 
SCAP Loan loss rate: 0%. 

Year: 1944; 
SCAP Loan loss rate: -0.13%. 

Year: 1945; 
SCAP Loan loss rate: -0.11%. 

Year: 1946; 
SCAP Loan loss rate: -0.05%. 

Year: 1947; 
SCAP Loan loss rate: 0.13%. 

Year: 1948; 
SCAP Loan loss rate: 0.21%. 

Year: 1949; 
SCAP Loan loss rate: 0.21%. 

Year: 1950; 
SCAP Loan loss rate: 0.2%. 

Year: 1951; 
SCAP Loan loss rate: 0.12%. 

Year: 1952; 
SCAP Loan loss rate: 0.11%. 

Year: 1953; 
SCAP Loan loss rate: 0.14%. 

Year: 1954; 
SCAP Loan loss rate: 0.15%. 

Year: 1955; 
SCAP Loan loss rate: 0.12%. 

Year: 1956; 
SCAP Loan loss rate: 0.16%. 

Year: 1957; 
SCAP Loan loss rate: 0.18%. 

Year: 1958; 
SCAP Loan loss rate: 0.14%. 

Year: 1959; 
SCAP Loan loss rate: 0.11%. 

Year: 1960; 
SCAP Loan loss rate: 0.23%. 

Year: 1961; 
SCAP Loan loss rate: 0.33%. 

Year: 1962; 
SCAP Loan loss rate: 0.27%. 

Year: 1963; 
SCAP Loan loss rate: 0.27%. 

Year: 1964; 
SCAP Loan loss rate: 0.29%. 

Year: 1965; 
SCAP Loan loss rate: 0.3%. 

Year: 1966; 
SCAP Loan loss rate: 0.35%. 

Year: 1967; 
SCAP Loan loss rate: 0.38%. 

Year: 1968; 
SCAP Loan loss rate: 0.35%. 

Year: 1969; 
SCAP Loan loss rate: 0.33%. 

Year: 1970; 
SCAP Loan loss rate: 0.51%. 

Year: 1971; 
SCAP Loan loss rate: 0.68%. 

Year: 1974; 
SCAP Loan loss rate: 0.57%. 

Year: 1973; 
SCAP Loan loss rate: 0.49%. 

Year: 1974; 
SCAP Loan loss rate: 0.6%. 

Year: 1975; 
SCAP Loan loss rate: 0.9%. 

Year: 1976; 
SCAP Loan loss rate: 1.12%. 

Year: 1977; 
SCAP Loan loss rate: 0.95%. 

Year: 1978; 
SCAP Loan loss rate: 0.69%. 

Year: 1979; 
SCAP Loan loss rate: 0.57%. 

Year: 1980; 
SCAP Loan loss rate: 0.63%. 

Year: 1981; 
SCAP Loan loss rate: 0.69%. 

Year: 1982; 
SCAP Loan loss rate: 0.87%. 

Year: 1983; 
SCAP Loan loss rate: 1.19%. 

Year: 1984; 
SCAP Loan loss rate: 1.3%. 

Year: 1985; 
SCAP Loan loss rate: 1.47%. 

Year: 1986; 
SCAP Loan loss rate: 1.78v 

Year: 1987; 
SCAP Loan loss rate: 1.88%. 

Year: 1988; 
SCAP Loan loss rate: 1.91%. 

Year: 1989; 
SCAP Loan loss rate: 2.13%. 

Year: 1990; 
SCAP Loan loss rate: 2.59%. 

Year: 1991; 
SCAP Loan loss rate: 2.91%. 

Year: 1992; 
SCAP Loan loss rate: 2.59%. 

Year: 1993; 
SCAP Loan loss rate: 1.78%. 

Year: 1994; 
SCAP Loan loss rate: 1.09%. 

Year: 1995; 
SCAP Loan loss rate: 0.95%. 

Year: 1996; 
SCAP Loan loss rate: 1.03%. 

Year: 1997; 
SCAP Loan loss rate: 1.13%. 

Year: 1998; 
SCAP Loan loss rate: 1.24%. 

Year: 1999; 
SCAP Loan loss rate: 1.27%. 

Year: 2000; 
SCAP Loan loss rate: 1.53%. 

Year: 2001; 
SCAP Loan loss rate: 2.22%. 

Year: 2002; 
SCAP Loan loss rate: 2.41%. 

Year: 2003; 
SCAP Loan loss rate: 2.01%. 

Year: 2004; 
SCAP Loan loss rate: 1.55%. 

Year: 2005; 
SCAP Loan loss rate: 1.25%. 

Year: 2006; 
SCAP Loan loss rate: 1.17%. 

Year: 2007; 
SCAP Loan loss rate: 1.40%. 

Year: 2008; 
SCAP Loan loss rate: 2.87%. 

Year: 2009; 
SCAP Loan loss rate: 5.66% (estimated). 

Year: 2010; 
SCAP Loan loss rate: 7.74% (estimated). 

Year: 2011; 
SCAP Loan loss rate: 7.37% (estimated). 

Year: 2012; 
SCAP Loan loss rate: 5.97% (estimated). 

Year: 2013; 
SCAP Loan loss rate: 4.75% (estimated). 

Source: International Monetary Fund. 

[End of figure] 

SCAP regulators also estimated ranges for loan loss rates within 
specific loan categories using the baseline and more adverse scenarios 
as guides. They used a variety of methods to tailor loan losses to 
each BHC, including an analysis of past BHC losses and quantitative 
models, and sought empirical support from BHCs regarding the risk 
level of their portfolios. However, some BHCs told us that the Federal 
Reserve made substantial efforts to help ensure conformity with the 
indicative loan loss rates while incorporating BHC-specific 
information where possible and reliable. Table 1 compares the 
different indicative loan loss rate ranges under the more adverse 
scenario for each asset category with actual losses in 2009 for SCAP 
BHCs and the banking industry.[Footnote 29] Some BHCs stated that the 
resulting loan loss rates were indicative of an economy worse off than 
that represented by the more adverse macroeconomic assumptions, 
although they recognized the need for the more conservative approach. 
However, nearly all agreed that the loan loss rates were a more 
important indication of the stringency of SCAP than the assumptions. 

Table 1: Indicative Loss Rates Estimates and Actual SCAP BHCs and 
Banking Industry Average Loss Rates, December 31, 2009: 

Loan category: First-lien mortgage; 
SCAP indicative loss rate estimates: Federal Reserve's more adverse 2-
year loss rate[A]: 7-8.5%; 
SCAP indicative loss rate estimates: GAO's more adverse 1-year pro 
rata loss rate[B]: 3.5-4.25%; 
2009 actual loss rates: SCAP BHCs average loss rate: 1.9%; 
2009 actual loss rates: Banking industry average loss rate[C]: 1.7%. 

Loan category: First-lien mortgage; Prime; 
SCAP indicative loss rate estimates: Federal Reserve's more adverse 2-
year loss rate[A]: 3-4%; 
SCAP indicative loss rate estimates: GAO's more adverse 1-year pro 
rata loss rate[B]: 1.5-2%; 
2009 actual loss rates: SCAP BHCs average loss rate: n/a; 
2009 actual loss rates: Banking industry average loss rate[C]: 0.5%. 

Loan category: First-lien mortgage; Alt-A; 
[Empty]; 
SCAP indicative loss rate estimates: Federal Reserve's more adverse 2-
year loss rate[A]: 9.5-13%; 
SCAP indicative loss rate estimates: GAO's more adverse 1-year pro 
rata loss rate[B]: 4.75-6.5%; 
2009 actual loss rates: SCAP BHCs average loss rate: n/a; 
2009 actual loss rates: Banking industry average loss rate[C]: 3.6%. 

Loan category: First-lien mortgage; Subprime; 
SCAP indicative loss rate estimates: Federal Reserve's more adverse 2-
year loss rate[A]: 21-28%; 
SCAP indicative loss rate estimates: GAO's more adverse 1-year pro 
rata loss rate[B]: 10.5-14%; 
2009 actual loss rates: SCAP BHCs average loss rate: n/a; 
2009 actual loss rates: Banking industry average loss rate[C]: 6.2%. 

Loan category: Second/junior lien mortgages; 
SCAP indicative loss rate estimates: Federal Reserve's more adverse 2-
year loss rate[A]: 12-16%; 
SCAP indicative loss rate estimates: GAO's more adverse 1-year pro 
rata loss rate[B]: 6-8%; 
2009 actual loss rates: SCAP BHCs average loss rate: 4.4%; 
2009 actual loss rates: Banking industry average loss rate[C]: 3.9%. 

Loan category: Second/junior lien mortgages; Closed-end junior liens; 
SCAP indicative loss rate estimates: Federal Reserve's more adverse 2-
year loss rate[A]: 22-25%; 
SCAP indicative loss rate estimates: GAO's more adverse 1-year pro 
rata loss rate[B]: 11-12.5%; 
2009 actual loss rates: SCAP BHCs average loss rate: 7.5%; 
2009 actual loss rates: Banking industry average loss rate[C]: 6.6%. 

Loan category: Second/junior lien mortgages; Home lines of credit; 
SCAP indicative loss rate estimates: Federal Reserve's more adverse 2-
year loss rate[A]: 8-11%; 
SCAP indicative loss rate estimates: GAO's more adverse 1-year pro 
rata loss rate[B]: 4-5.5%; 
2009 actual loss rates: SCAP BHCs average loss rate: 3.6%; 
2009 actual loss rates: Banking industry average loss rate[C]: 3.1%. 

Loan category: Commercial and industrial; 
SCAP indicative loss rate estimates: Federal Reserve's more adverse 2-
year loss rate[A]: 5-8%; 
SCAP indicative loss rate estimates: GAO's more adverse 1-year pro 
rata loss rate[B]: 2.5-4%; 
2009 actual loss rates: SCAP BHCs average loss rate: 2.5%; 
2009 actual loss rates: Banking industry average loss rate[C]: 2.3%. 

Loan category: Commercial real estate; 
SCAP indicative loss rate estimates: Federal Reserve's more adverse 2-
year loss rate[A]: 9-12%; 
SCAP indicative loss rate estimates: GAO's more adverse 1-year pro 
rata loss rate[B]: 4.5-6%; 
2009 actual loss rates: SCAP BHCs average loss rate: 2.3%; 
2009 actual loss rates: Banking industry average loss rate[C]: 2.4%. 

Loan category: Commercial real estate; Construction; 
SCAP indicative loss rate estimates: Federal Reserve's more adverse 2-
year loss rate[A]: 15-18%; 
SCAP indicative loss rate estimates: GAO's more adverse 1-year pro 
rata loss rate[B]: 7.5-9%; 
2009 actual loss rates: SCAP BHCs average loss rate: 5.8%; 
2009 actual loss rates: Banking industry average loss rate[C]: 6.1%. 

Loan category: Commercial real estate; Multifamily; 
SCAP indicative loss rate estimates: Federal Reserve's more adverse 2-
year loss rate[A]: 10-11%; 
SCAP indicative loss rate estimates: GAO's more adverse 1-year pro 
rata loss rate[B]: 5-5.5%; 
2009 actual loss rates: SCAP BHCs average loss rate: 1.1%; 
2009 actual loss rates: Banking industry average loss rate[C]: 1.1%. 

Loan category: Commercial real estate; Nonfarm, nonresidential; 
SCAP indicative loss rate estimates: Federal Reserve's more adverse 2-
year loss rate[A]: 7-9%; 
SCAP indicative loss rate estimates: GAO's more adverse 1-year pro 
rata loss rate[B]: 3.5-4.5%; 
2009 actual loss rates: SCAP BHCs average loss rate: 0.9%; 
2009 actual loss rates: Banking industry average loss rate[C]: 0.8%. 

Loan category: Credit cards; 
[Empty]; 
SCAP indicative loss rate estimates: Federal Reserve's more adverse 2-
year loss rate[A]: 18-20%; 
SCAP indicative loss rate estimates: GAO's more adverse 1-year pro 
rata loss rate[B]: 9-10%; 
2009 actual loss rates: SCAP BHCs average loss rate: 10.1%; 
2009 actual loss rates: Banking industry average loss rate[C]: 10.2%. 

Loan category: Other consumer; 
SCAP indicative loss rate estimates: Federal Reserve's more adverse 2-
year loss rate[A]: 8-12%; 
SCAP indicative loss rate estimates: GAO's more adverse 1-year pro 
rata loss rate[B]: 4-6%; 
2009 actual loss rates: SCAP BHCs average loss rate: 4.1%; 
2009 actual loss rates: Banking industry average loss rate[C]: 4.4%. 

Loan category: Other loans; 
SCAP indicative loss rate estimates: Federal Reserve's more adverse 2-
year loss rate[A]: 4-10%; 
SCAP indicative loss rate estimates: GAO's more adverse 1-year pro 
rata loss rate[B]: 2-5%; 
[Empty]; 
2009 actual loss rates: SCAP BHCs average loss rate: 1.4%; 
2009 actual loss rates: Banking industry average loss rate[C]: 1.1%. 

Sources: Federal Reserve SCAP results report, GAO analysis of SNL 
Financial Y-9C regulatory data, and Moody's Investors Service for 
prime, Alt-A, and subprime mortgage loss rates data. 

Note: n/a means not available. 

[A] Data as of December 31, 2010. 

[B] GAO calculated the more adverse 1-year pro rata loss rate by 
dividing the SCAP more adverse 2-year loss rates by 2 (i.e., the 
straight-line method). A key limitation of this approach is that it 
assumes equal distribution of losses, revenues, expenses, and changes 
to reserves over time, although these items were unlikely to be 
distributed evenly over the 2-year period. Another important 
consideration is that actual results were not intended and should not 
be expected to align with the SCAP projections. 

[C] Data are for BHCs with greater than $1 billion in total assets. 

[End of table] 

After the public release of the SCAP methodology in April 2009, many 
observers commented that the macroeconomic assumptions for a more 
adverse economic downturn were not severe enough given the economic 
conditions at that time. In defining a more adverse economic scenario, 
the SCAP regulators made assumptions about the path of the economy 
using three broad macroeconomic indicators--changes in real GDP, the 
unemployment rate, and home prices--during the 2-year SCAP period 
ending December 2010. The actual performances of GDP and home prices 
have performed better than assumed under the more adverse scenario. 
However, the actual unemployment rate has more closely tracked the 
more adverse scenario (see figure 3). Further, as noted earlier, some 
regulatory and BHC officials have indicated that the loan loss rates 
that the regulators subsequently developed were more severe than one 
would have expected under the macroeconomic assumptions. While our 
analysis of actual and SCAP estimated indicative loan losses (see 
table 1) is generally consistent with this view, these estimates were 
developed at a time of significant uncertainty about the direction of 
the economy and the financial markets, as well as an unprecedented 
deterioration in the U.S. housing markets. 

Figure 3: Actual Economic Performance to Date Versus SCAP More Adverse 
Assumptions: 

[Refer to PDF for image: 3 multiple line graphs] 

GDP actual vs. SCAP adverse: 

Year and quarter: 2008, Q4; 
SCAP more adverse: -0.2%; 
Actual: -5.4%. 

Year and quarter: 2009, Q1; 
SCAP more adverse: -2.1%; 
Actual: -6.4%. 

Year and quarter: 2009, Q2; 
SCAP more adverse: -3.8%; 
Actual: -0.7%. 

Year and quarter: 2009, Q3; 
SCAP more adverse: -3.7%; 
Actual: 2.2%. 

Year and quarter: 2009, Q4; 
SCAP more adverse: -2.7%; 
Actual: 5.6%. 

Year and quarter: 2010, Q1; 
SCAP more adverse: -0.9%; 
Actual: 3.2%. 

Year and quarter: 2010, Q2; 
SCAP more adverse: 0.4%. 

Year and quarter: 2010, Q3; 
SCAP more adverse: 1%. 

Year and quarter: 2010, Q4; 
SCAP more adverse: 1.5%. 

Unemployment actual vs. SCAP adverse: 

Year and quarter: 2008, Q4; 
SCAP more adverse: 6.9%; 
Actual: 7.4%. 

Year and quarter: 2009, Q1; 
SCAP more adverse: 7.9%; 
Actual: 8.6%. 

Year and quarter: 2009, Q2; 
SCAP more adverse: 8.8%; 
Actual: 9.5%. 

Year and quarter: 2009, Q3; 
SCAP more adverse: 9.3%; 
Actual: 9.8%. 

Year and quarter: 2009, Q4; 
SCAP more adverse: 9.7%; 
Actual: 10.0%. 

Year and quarter: 2010, Q1; 
SCAP more adverse: 9.7%; 
Actual: 9.7%. 

Year and quarter: 2010, Q2; 
SCAP more adverse: 10%. 

Year and quarter: 2010, Q3; 
SCAP more adverse: 10.3%. 

Year and quarter: 2010, Q4; 
SCAP more adverse: 10.4%. 

Home price actual vs. SCAP adverse: 

Year and quarter: 2008, Q4; 
SCAP more adverse: 100%; 
Actual: 100%. 

Year and quarter: 2009, Q1; 
SCAP more adverse: 92.4%; 
Actual: 93.5%. 

Year and quarter: 2009, Q2; 
SCAP more adverse: 87%; 
Actual: 94.6%. 

Year and quarter: 2009, Q3; 
SCAP more adverse: 82.7%; 
Actual: 98%. 

Year and quarter: 2009, Q4; 
SCAP more adverse: 79.3%; 
Actual: 97.6%. 

Year and quarter: 2010, Q1; 
SCAP more adverse: 76.7%. 

Year and quarter: 2010, Q2; 
SCAP more adverse: 74.7%. 

Year and quarter: 2010, Q3; 
SCAP more adverse: 73.3%. 

Year and quarter: 2010, Q4; 
SCAP more adverse: 72.5%. 

Source: GAO analysis of Bureau of Economic Analysis, Bureau of Labor 
Statistics, and Standard and Poor's 10-City Case-Shiller data. 

[End of figure] 

While SCAP Increased Capital Levels and Improved Confidence in the 
Banking System, BHCs Could Face Ongoing Challenges: 

SCAP largely met its goals of increasing the level and quality of 
capital held by the 19 largest BHCs and, more broadly, of 
strengthening market confidence in the banking system. The stress test 
identified 10 of the 19 BHCs as needing to raise a total of about $75 
billion in additional capital. The Federal Reserve encouraged the BHCs 
to raise common equity via private sources--for example, through new 
common equity issuances, conversion of existing preferred equity to 
common equity, and sales of businesses or portfolios of assets. Nine 
of the 10 BHCs were able to raise the required SCAP amount of new 
common equity in the private markets by the November 9, 2009, deadline 
(see table 2). Some of these BHCs also raised capital internally from 
other sources.[Footnote 30] GMAC LLC (GMAC) was the only BHC that was 
not able to raise sufficient private capital by the November 9, 2009, 
deadline.[Footnote 31] On December 30, 2009, Treasury provided GMAC 
with a capital investment of $3.8 billion to help fulfill its SCAP 
capital buffer requirement, drawing funds from TARP's Automotive 
Industry Financing Program.[Footnote 32] A unique and additional 
element of the estimated losses for GMAC included the unknown impact 
of possible bankruptcy filings by General Motors Corporation (GM) and 
Chrysler LLC (Chrysler). Thus, a conservative estimate of GMAC's 
capital buffer was developed in response to this possibility. The 
Federal Reserve, in consultation with Treasury, subsequently reduced 
GMAC's SCAP required capital buffer by $1.8 billion--$5.6 billion to 
$3.8 billion--primarily to reflect the lower-than-estimated actual 
losses from the bankruptcy proceedings of GM and Chrysler. GMAC was 
the only company to have its original capital buffer requirement 
reduced. 

Table 2: Summary of Capital Raised by 10 BHCs to Meet Their SCAP 
Capital Buffer Amount, as of November 9, 2009: 

BHC: Bank of America Corporation; 
Sources of capital raised: New shares, asset sales, and conversion[A]; 
Required capital buffer amount: $33.9 billion; 
Capital raised: $35.9 billion. 

BHC: Citigroup Inc.; 
Sources of capital raised: Conversion; 
Required capital buffer amount: $5.5 billion; 
Capital raised: $5.6 billion. 

BHC: Fifth Third Bancorp; 
Sources of capital raised: New shares, asset sales, and conversion; 
Required capital buffer amount: $1.1 billion; 
Capital raised: $1.7 billion. 

BHC: GMAC LLC; 
Sources of capital raised: New shares; 
Required capital buffer amount: $11.5 billion; 
Capital raised: $4.6 billion. 

BHC: KeyCorp; 
Sources of capital raised: New shares, asset sales, and conversion; 
Required capital buffer amount: $1.8 billion; 
Capital raised: $2.3 billion. 

BHC: Morgan Stanley; 
Sources of capital raised: New shares, asset sales, and conversion; 
Required capital buffer amount: $1.8 billion; 
Capital raised: $7.0 billion. 

BHC: PNC Financial Services Group, Inc.; 
Sources of capital raised: New shares and asset sales; 
Required capital buffer amount: $0.6 billion; 
Capital raised: $1.1 billion. 

BHC: Regions Financial Corporation; 
Sources of capital raised: New shares, asset sales, conversion, and 
other actions[B]; 
Required capital buffer amount: $2.5 billion; 
Capital raised: $2.5 billion. 

BHC: SunTrust Banks, Inc.; 
Sources of capital raised: New shares, asset sales, conversion, and 
other actions; 
Required capital buffer amount: $2.2 billion; 
Capital raised: $2.2 billion. 

BHC: Wells Fargo & Company; 
Sources of capital raised: New shares and other actions; 
Required capital buffer amount: $13.7 billion; 
Capital raised: $13.7 billion. 

BHC: Total; 
Required capital buffer amount: $74.6 billion; 
Capital raised: $76.6 billion. 

Source: Federal Reserve documentation. 

Notes: The following nine BHCs were not required to raise SCAP capital 
because they had sufficient capital to withstand a worse-than-expected 
economic downturn through the end of 2010 and continue to meet the 
SCAP capital buffer targets: American Express Company; BB&T 
Corporation; The Bank of New York Mellon Corporation; Capital One 
Financial Corporation; The Goldman Sachs Group, Inc.; JPMorgan Chase & 
Co.; MetLife, Inc.; State Street Corporation; and U.S. Bancorp. Data 
in the "capital raised" column is as of November 9, 2009, according to 
the Federal Reserve. 

[A] "New shares" indicates that BHC issued new common equity, "assets 
sales" represent business lines or products sold to raise cash, and 
"conversion" shows BHC preferred equity that was converted to common 
equity. 

[B] "Other action" indicates equity raised internally (e.g., sale of 
equity to employee stock options plans). 

[End of table] 

Capital adequacy generally improved across all 19 SCAP BHCs during 
2009. As shown in table 3, the largest gains were in tier 1 common 
capital, which increased by about 51 percent in the aggregate across 
the 19 BHCs, rising from $412.5 billion on December 31, 2008, to 
$621.9 billion by December 31, 2009. On an aggregate basis, the tier 1 
common capital ratio at BHCs increased from 5.3 percent to 8.3 percent 
of risk-weighted assets (compared with the SCAP threshold of 4 percent 
at the end of 2010).[Footnote 33] The tier 1 risk-based capital ratio 
also grew from 10.7 percent to 11.3 percent of risk-weighted assets 
(compared with the SCAP threshold of 6 percent at the end of 2010). 
[Footnote 34] While these ratios were helped to some extent by 
reductions in risk-weighted assets, which fell 4.3 percent from $7.815 
trillion on December 31, 2008, to $7.481 trillion on December 31, 
2009, the primary driver of the increases was the increase in total 
tier 1 common capital. 

Table 3: Capital Measures for SCAP BHCs, December 31, 2008 and 
December 31, 2009: 

Capital measures: Capital levels; Tier 1 capital; 
2009: $846.2 billion; 
2008: $836.7 billion; 
Percent difference: 1.1%. 

Capital measures: Capital levels; Tier 1 common capital; 
2009: $621.9 billion; 
2008: $412.5 billion; 
Percent difference: 50.8%. 

Capital measures: Capital levels; Risk-weighted assets; 
2009: $7.48 trillion; 
2008: $7.81 trillion; 
Percent difference: -4.3%. 

Capital measures: Capital ratios; Tier 1 risk-based capital ratio; 
2009: 11.3%; 
2008: 10.7%; 
Percent difference: 5.6%. 

Capital measures: Capital ratios; Tier 1 common capital ratio; 
2009: 8.3%; 
2008: 5.3%; 
Percent difference: 57.5%. 

Sources: GAO analysis of Federal Reserve SCAP, SNL Financial, and 
company data. 

[End of table] 

The quality of capital--measured as that portion of capital made up of 
tier 1 common equity--also increased across most of the BHCs in 2009. 
The tier 1 common capital ratio increased at 17 of the 19 BHCs between 
the end of 2008 and the end of 2009 (see table 4). Citigroup Inc. 
(Citigroup) and The Goldman Sachs Group, Inc. (Goldman Sachs) had the 
largest increases in tier 1 common capital ratios--747 and 450 basis 
points, respectively.[Footnote 35] However, GMAC's tier 1 common 
capital ratio declined by 155 basis points in this period to 4.85 
percent. MetLife, Inc. was the only other BHC to see a drop in its 
tier 1 common capital ratio, which fell by 33 basis points to 8.17 
percent and still more than double the 4 percent target. Based on the 
SCAP results document, the 2008 balances in the table include the 
impact of certain mergers and acquisitions, such as Bank of America 
Corporation's (Bank of America) purchase of Merrill Lynch & Co. Inc. 
Further, the increase in capital levels reflects the capital that was 
raised as a result of SCAP. 

Table 4: Percentage Change in Tier I Capital Ratios, December 31, 
2008, and December 31, 2009: 

Bank holding company: American Express Company; 
Tier 1 common capital ratio: 2009 (percentage): 9.83%; 
Tier 1 common capital ratio: Change from 2008 (basis points): 13; 
Tier 1 risk-based capital ratio: 2009 (percentage): 9.84%; 
Tier 1 risk-based capital ratio: Change from 2008 (basis points): 14. 

Bank holding company: Bank of America Corporation; 
Tier 1 common capital ratio: 2009 (percentage): 7.82%; 
Tier 1 common capital ratio: Change from 2008 (basis points): 322; 
Tier 1 risk-based capital ratio: 2009 (percentage): 10.41%; 
Tier 1 risk-based capital ratio: Change from 2008 (basis points): -19. 

Bank holding company: BB&T Corporation; 
Tier 1 common capital ratio: 2009 (percentage): 8.50%; 
Tier 1 common capital ratio: Change from 2008 (basis points): 140; 
Tier 1 risk-based capital ratio: 2009 (percentage): 11.48%; 
Tier 1 risk-based capital ratio: Change from 2008 (basis points): -82. 

Bank holding company: The Bank of New York Mellon Corporation; 
Tier 1 common capital ratio: 2009 (percentage): 10.53%; 
Tier 1 common capital ratio: Change from 2008 (basis points): 103; 
Tier 1 risk-based capital ratio: 2009 (percentage): 12.12%; 
Tier 1 risk-based capital ratio: Change from 2008 (basis points): -118. 

Bank holding company: Capital One Financial Corporation; 
Tier 1 common capital ratio: 2009 (percentage): 10.62%; 
Tier 1 common capital ratio: Change from 2008 (basis points): 152; 
Tier 1 risk-based capital ratio: 2009 (percentage): 13.75%; 
Tier 1 risk-based capital ratio: Change from 2008 (basis points): 105. 

Bank holding company: Citigroup Inc.; 
Tier 1 common capital ratio: 2009 (percentage): 9.77%; 
Tier 1 common capital ratio: Change from 2008 (basis points): 747; 
Tier 1 risk-based capital ratio: 2009 (percentage): 11.67%; 
Tier 1 risk-based capital ratio: Change from 2008 (basis points): -23. 

Bank holding company: Fifth Third Bancorp; 
Tier 1 common capital ratio: 2009 (percentage): 7.00%; 
Tier 1 common capital ratio: Change from 2008 (basis points): 260; 
Tier 1 risk-based capital ratio: 2009 (percentage): 13.31%; 
Tier 1 risk-based capital ratio: Change from 2008 (basis points): 271. 

Bank holding company: GMAC LLC; 
Tier 1 common capital ratio: 2009 (percentage): 4.85%; 
Tier 1 common capital ratio: Change from 2008 (basis points): -155; 
Tier 1 risk-based capital ratio: 2009 (percentage): 14.15%; 
Tier 1 risk-based capital ratio: Change from 2008 (basis points): 405. 

Bank holding company: The Goldman Sachs Group, Inc.; 
Tier 1 common capital ratio: 2009 (percentage): 12.20%; 
Tier 1 common capital ratio: Change from 2008 (basis points): 450; 
Tier 1 risk-based capital ratio: 2009 (percentage): 14.97%; 
Tier 1 risk-based capital ratio: Change from 2008 (basis points): 237. 

Bank holding company: JPMorgan Chase & Co.; 
Tier 1 common capital ratio: 2009 (percentage): 8.79%; 
Tier 1 common capital ratio: Change from 2008 (basis points): 229; 
Tier 1 risk-based capital ratio: 2009 (percentage): 11.10%; 
Tier 1 risk-based capital ratio: Change from 2008 (basis points): 90. 

Bank holding company: KeyCorp; 
Tier 1 common capital ratio: 2009 (percentage): 7.50%; 
Tier 1 common capital ratio: Change from 2008 (basis points): 190; 
Tier 1 risk-based capital ratio: 2009 (percentage): 12.75%; 
Tier 1 risk-based capital ratio: Change from 2008 (basis points): 185. 

Bank holding company: MetLife, Inc.; 
Tier 1 common capital ratio: 2009 (percentage): 8.17%; 
Tier 1 common capital ratio: Change from 2008 (basis points): -33; 
Tier 1 risk-based capital ratio: 2009 (percentage): 8.91%; 
Tier 1 risk-based capital ratio: Change from 2008 (basis points): -29. 

Bank holding company: Morgan Stanley; 
Tier 1 common capital ratio: 2009 (percentage): 6.71%; 
Tier 1 common capital ratio: Change from 2008 (basis points): 101; 
Tier 1 risk-based capital ratio: 2009 (percentage): 15.30%; 
Tier 1 risk-based capital ratio: Change from 2008 (basis points): 10. 

Bank holding company: PNC Financial Services Group, Inc.; 
Tier 1 common capital ratio: 2009 (percentage): 6.00%; 
Tier 1 common capital ratio: Change from 2008 (basis points): 130; 
Tier 1 risk-based capital ratio: 2009 (percentage): 11.42%; 
Tier 1 risk-based capital ratio: Change from 2008 (basis points): 182. 

Bank holding company: Regions Financial Corporation; 
Tier 1 common capital ratio: 2009 (percentage): 7.15%; 
Tier 1 common capital ratio: Change from 2008 (basis points): 55; 
Tier 1 risk-based capital ratio: 2009 (percentage): 11.54%; 
Tier 1 risk-based capital ratio: Change from 2008 (basis points): 114. 

Bank holding company: State Street Corporation; 
Tier 1 common capital ratio: 2009 (percentage): 15.59%; 
Tier 1 common capital ratio: Change from 2008 (basis points): 9; 
Tier 1 risk-based capital ratio: 2009 (percentage): 17.74%; 
Tier 1 risk-based capital ratio: Change from 2008 (basis points): -246. 

Bank holding company: SunTrust Banks, Inc.; 
Tier 1 common capital ratio: 2009 (percentage): 7.67%; 
Tier 1 common capital ratio: Change from 2008 (basis points): 187; 
Tier 1 risk-based capital ratio: 2009 (percentage): 12.96%; 
Tier 1 risk-based capital ratio: Change from 2008 (basis points): 206. 

Bank holding company: U.S. Bancorp; 
Tier 1 common capital ratio: 2009 (percentage): 6.76%; 
Tier 1 common capital ratio: Change from 2008 (basis points): 166; 
Tier 1 risk-based capital ratio: 2009 (percentage): 9.61v; 
Tier 1 risk-based capital ratio: Change from 2008 (basis points): -99. 

Bank holding company: Wells Fargo & Company; 
Tier 1 common capital ratio: 2009 (percentage): 6.46%; 
Tier 1 common capital ratio: Change from 2008 (basis points): 336; 
Tier 1 risk-based capital ratio: 2009 (percentage): 9.25%; 
Tier 1 risk-based capital ratio: Change from 2008 (basis points): 125. 

Bank holding company: Average (weighted); 
Tier 1 common capital ratio: 2009 (percentage): 8.31%; 
Tier 1 risk-based capital ratio: 2009 (percentage): 11.31%; 
Tier 1 risk-based capital ratio: Change from 2008 (basis points): 60. 

Sources: GAO analysis of Federal Reserve SCAP, SNL Financial, and 
company data. 

[End of table] 

As previously stated by interviewees, the unprecedented public release 
of the stress test results helped to restore investors' confidence in 
the financial markets. Some officials from participating BHCs and 
credit rating agencies also viewed the BHCs' ability to raise the 
capital required by the stress test as further evidence of SCAP's 
success in increasing market confidence and reducing uncertainty. But 
some expressed concerns that the timing of the announcement of SCAP on 
February 10, 2009--nearly 3 months before the results were released on 
May 7, 2009--may have intensified market uncertainty about the 
financial health of the BHCs. 

A broad set of market indicators also suggest that the public release 
of SCAP results may have helped reduce uncertainty in the financial 
markets and increased market confidence. For example, banks' renewed 
ability to raise private capital reflects improvements in perceptions 
of the financial condition of banks. Specifically, banks and thrifts 
raised significant amounts of common equity in 2008, totaling $56 
billion. Banks and thrifts raised $63 billion in common equity in the 
second quarter of 2009 (see figure 4). The substantial increase in 
second quarter issuance of common equity occurred after the stress 
test results were released on May 7, 2009, and was dominated by 
several SCAP institutions. 

Figure 4: Gross Common Equity Issuance by Banks and Thrifts, 2000 to 
First Quarter 2010: 

[Refer to PDF for image: vertical bar graph] 

Year: 2000; 
Gross Common Equity Issuance: $1.4 billion. 

Year: 2001; 
Gross Common Equity Issuance: $2 billion. 

Year: 2002; 
Gross Common Equity Issuance: $2.5 billion. 

Year: 2003; 
Gross Common Equity Issuance: $6 billion. 

Year: 2004; 
Gross Common Equity Issuance: $6.1 billion. 

Year: 2005; 
Gross Common Equity Issuance: $9.7 billion. 

Year: 2006; 
Gross Common Equity Issuance: $3.9 billion. 

Year: 2007; 
Gross Common Equity Issuance: $9 billion. 
Q1: $1.3 billion (22 banks raised capital); 
Q2: $5 billion (18 banks raised capital); 
Q3: $1.2 billion (19 banks raised capital); 
Q4: $1.4 billion (27 banks raised capital). 

Year: 2008; 
Gross Common Equity Issuance: $56 billion; 
Q1: $0.6 billion (19 banks raised capital); 
Q2: $18.7 billion (31 banks raised capital); 
Q3: $13.2 billion (22 banks raised capital); 
Q4: $23.5 billion (30 banks raised capital). 

Year: 2009; 
Gross Common Equity Issuance: $107.4 billion; 
Q1: $0.2 billion (15 banks raised capital); 
Q2: $62.9 billion (51 banks raised capital); 
Q3: $6.8 billion (56 banks raised capital); 
Q4: $37.5 billion (55 banks raised capital). 

Year: 2010; 
Q1: $9.6 billion (47 banks raised capital). 

Source: GAO analysis of data from SNLFinancial. 

Note: The spike in common equity issuance in the fourth quarter of 
2009 primarily relates to Citigroup, Wells Fargo & Company, and other 
banks raising capital to buy back their TARP capital investment from 
Treasury. However, the quarterly data do not reflect $19.29 billion of 
common equivalent securities issued in December 2009 by Bank of 
America that converted to common stock in February 2010. 

[End of figure] 

Similarly, stock market prices since the release of the stress test 
results in May 2009 through October 2009 improved substantially in the 
overall banking sector and among the 18 public BHCs that participated 
in SCAP (see figure 5).[Footnote 36] The initial increase since May 
2009 also suggests that SCAP may have helped bolster investor and 
public confidence. However, equity markets are generally volatile and 
react to a multitude of events. 

Figure 5: Stock Market Prices, October 2007 through March 2010: 

[Refer to PDF for image: multiple line graph] 

Prices indicated are from the first business day of the month. 

October 2007: 	
S & P 500: -0.03%; 
Financial industry measure: 1.14%; 
Simple average of 18 public BHCs: 0.63%. 

November 2007: 	
S & P 500: -2.5%; 
Financial industry measure: -8.51%; 
Simple average of 18 public BHCs: -7.45%. 

December 2007: 	
S & P 500: -4.82%; 
Financial industry measure: -12.08%; 
Simple average of 18 public BHCs: -9.37%. 

January 2008: 	
S & P 500: -6.46%; 
Financial industry measure: -18.19%; 
Simple average of 18 public BHCs: -17.63%. 

February 2008: 
S & P 500: -9.8%; 
Financial industry measure: -14.38%; 
Simple average of 18 public BHCs: -10.23%. 

March 2008: 	
S & P 500: -13.94%; 
Financial industry measure: -26.49%; 
Simple average of 18 public BHCs: -23.12%. 

April 2008: 	
S & P 500: -11.43%; 
Financial industry measure: -22.59%; 
Simple average of 18 public BHCs: -15.65%. 

May 2008: 	
S & P 500: -8.9%; 
Financial industry measure: -19.98%; 
Simple average of 18 public BHCs: -13.1%. 

June 2008: 	
S & P 500: -10.43%; 
Financial industry measure: -29.07%; 
Simple average of 18 public BHCs: -24.87%. 

July 2008: 	
S & P 500: -16.94%; 
Financial industry measure: -40.38%; 
Simple average of 18 public BHCs: -38.14%. 

August 2008: 	
S & P 500: -18.53%; 
Financial industry measure: -36.54%; 
Simple average of 18 public BHCs: -30.55%. 

September 2008: 	
S & P 500: -17.42%; 
Financial industry measure: -36.26%; 
Simple average of 18 public BHCs: -28.32%. 

October 2008: 	
S & P 500: -24.95%; 
Financial industry measure: -38.78%; 
Simple average of 18 public BHCs: -26.1%. 

November 2008: 	
S & P 500: -37.54%; 
Financial industry measure: -53.72%; 
Simple average of 18 public BHCs: -39.67%. 

December 2008: 	
S & P 500: -47.24%; 
Financial industry measure: -68.75%; 
Simple average of 18 public BHCs: -58.93%. 

January 2009: 	
S & P 500: -39.77%; 
Financial industry measure: -61.92%; 
Simple average of 18 public BHCs: -51.84%. 

February 2009: 	
S & P 500: -46.64%; 
Financial industry measure: -72.22%; 
Simple average of 18 public BHCs: -68.06%. 

March 2009: 	
S & P 500: -54.7%; 
Financial industry measure: -78.58%; 
Simple average of 18 public BHCs: -74.78%. 

April 2009: 	
S & P 500: -47.57%; 
Financial industry measure: -72.5%; 
Simple average of 18 public BHCs: -67.58%. 

May 2009: 	
S & P 500: -43.28%; 
Financial industry measure: -67.67%; 
Simple average of 18 public BHCs: -61.13%. 

June 2009: 	
S & P 500: -39.05%; 
Financial industry measure: -62.48%; 
Simple average of 18 public BHCs: -55.14%. 

July 2009: 	
S & P 500: -40.32%; 
Financial industry measure: -63.74%; 
Simple average of 18 public BHCs: -56.78%. 

August 2009: 	
S & P 500: -35.19%; 
Financial industry measure: -59.28%; 
Simple average of 18 public BHCs: -50.55%. 

September 2009: 	
S & P 500: -35.49%; 
Financial industry measure: -57.53%; 
Simple average of 18 public BHCs: -48.36%. 

October 2009: 	
S & P 500: -33.43%; 
Financial industry measure: -56.27%; 
Simple average of 18 public BHCs: -47.32%. 

November 2009: 	
S & P 500: -32.59%; 
Financial industry measure: -56.61%; 
Simple average of 18 public BHCs: -47.07%. 

December 2009: 	
S & P 500: -28.32%; 
Financial industry measure: -55.07%; 
Simple average of 18 public BHCs: -44.82%. 

January 2010: 	
S & P 500: -26.76%; 
Financial industry measure: -54.86%; 
Simple average of 18 public BHCs: -45.29%. 

February 2010: 	
S & P 500: -29.6%; 
Financial industry measure: -55.69%; 
Simple average of 18 public BHCs: -44.48%. 

March 2010: 	
S & P 500: -27.88%; 
Financial industry measure: -54.76%; 
Simple average of 18 public BHCs: -44.51%. 

Source: GAO analysis of Yahoo! Finance data. 

[End of figure] 

Credit default swap spreads, another measure of confidence in the 
banking sector, also improved. A credit default swap is an agreement 
in which a buyer pays a periodic fee to a seller in exchange for 
protection from certain credit events such as bankruptcy, failure to 
pay debt obligations, or a restructuring related to a specific debt 
issuer or issues known as the reference entity. Therefore, the credit 
default swap spread, or market price, is a measure of the credit risk 
of the reference entity, with a higher spread indicating a greater 
amount of credit risk. When the markets' perception of the reference 
entity's credit risk deteriorates or improves, the spread generally 
will widen or tighten, respectively. Following the SCAP results 
release in May 2009, the credit default swap spreads continued to see 
improvements (see figure 6). While many forces interact to influence 
investors' actions, these declining spreads suggest that the market's 
perception of the risk of banking sector defaults was falling. 
Further, the redemption of TARP investments by some banking 
institutions demonstrated that regulators believed these firms could 
continue to serve as a source of financial and managerial strength, as 
well as fulfill their roles as intermediaries that facilitate lending, 
while both reducing reliance on government funding and maintaining 
adequate capital levels. This positive view of the regulators may also 
have helped increase market confidence in the banking system (see 
appendix II for details on the status of TARP investments in the 
institutions participating in SCAP). 

Figure 6: Bank Credit Default Swap Spreads, January 2007 through March 
2010: 

[Refer to PDF for image: multiple line graph] 

Credit default swap spread in basis points indicated are from the 
first business day of the indicated month. 

January 2007; 
Bank index: 12.2; 
Average of 12 of the 19 SCAP BHCs: 22; 
GMAC: 100.5. 

February 2007; 
Bank index: 12.5; 
Average of 12 of the 19 SCAP BHCs: 21.9; 
GMAC: 100.5. 

March 2007; 
Bank index: 18.1; 
Average of 12 of the 19 SCAP BHCs: 26.0; 
GMAC: 100.5. 

April 2007; 
Bank index: 22.4; 
Average of 12 of the 19 SCAP BHCs: 28.9; 
GMAC: 100.5. 

May 2007; 
Bank index: 16.1; 
Average of 12 of the 19 SCAP BHCs: 24.9; 
GMAC: 100.5. 

June 2007; 
Bank index: 14.0; 
Average of 12 of the 19 SCAP BHCs: 27.4; 
GMAC: 133.8. 

July 2007; 
Bank index: 20.4; 
Average of 12 of the 19 SCAP BHCs: 40.3; 
GMAC: 206.7. 

August 2007; 
Bank index: 49.0; 
Average of 12 of the 19 SCAP BHCs: 91.1; 
GMAC: 428.5. 

September 2007; 
Bank index: 53.1; 
Average of 12 of the 19 SCAP BHCs: 112.5; 
GMAC: 589.7. 

October 2007; 
Bank index: 42.0; 
Average of 12 of the 19 SCAP BHCs: 73.2; 
GMAC: 343.8. 

November 2007; 
Bank index: 80.1; 
Average of 12 of the 19 SCAP BHCs: 116.2; 
GMAC: 587.5. 

December 2007; 
Bank index: 116.5; 
Average of 12 of the 19 SCAP BHCs: 148.8; 
GMAC: 675.4. 

January 2008; 
Bank index: 125.3; 
Average of 12 of the 19 SCAP BHCs: 160.6; 
GMAC: 760. 

February 2008; 
Bank index: 121.6; 
Average of 12 of the 19 SCAP BHCs: 192.6; 
GMAC: 772.7. 

March 2008; 
Bank index: 200.8; 
Average of 12 of the 19 SCAP BHCs: 269.1; 
GMAC: 1096.5. 

April 2008; 
Bank index: 188.4; 
Average of 12 of the 19 SCAP BHCs: 227.4; 
GMAC: 1238.8. 

May 2008; 
Bank index: 99.7; 
Average of 12 of the 19 SCAP BHCs: 161.8; 
GMAC: 1029.8. 

June 2008; 
Bank index: 145.4; 
Average of 12 of the 19 SCAP BHCs: 189.2; 
GMAC: 1076.5. 

July 2008; 
Bank index: 216.7; 
Average of 12 of the 19 SCAP BHCs: 293.4; 
GMAC: 1809.5. 

August 2008; 
Bank index: 269.2; 
Average of 12 of the 19 SCAP BHCs: 323.6; 
GMAC: 2065.3 

September 2008; 
Bank index: 367.0; 
Average of 12 of the 19 SCAP BHCs: 337.8; 
GMAC: 1979. 

October 2008; 
Bank index: 247.6; 
Average of 12 of the 19 SCAP BHCs: 697.0; 
GMAC: 4573.7. 

November 2008; 
Bank index: 147.6; 
Average of 12 of the 19 SCAP BHCs: 438.5; 
GMAC: 2515.8. 

December 2008; 
Bank index: 204.1; 
Average of 12 of the 19 SCAP BHCs: 633.6; 
GMAC: 4215.1. 

January 2009; 
Bank index: 142.1; 
Average of 12 of the 19 SCAP BHCs: 280.4; 
GMAC: 805.4. 

February 2009; Announcement of stress test as part of FSP (February 
10); 
Bank index: 185.0; 
Average of 12 of the 19 SCAP BHCs: 328.1; 
GMAC: 1012.6. 

March 2009; 
Bank index: 283.4; 
Average of 12 of the 19 SCAP BHCs: 614.4; 
GMAC: 2798.3. 

April 2009; 
Bank index: 363.1; 
Average of 12 of the 19 SCAP BHCs: 588.9; 
GMAC: 2051.6. 

May 2009; Release of stress test results (May 7); 
Bank index: 291.6; 
Average of 12 of the 19 SCAP BHCs: 420.6; 
GMAC: 977.2. 

June 2009; 
Bank index: 157.5; 
Average of 12 of the 19 SCAP BHCs: 245.0; 
GMAC: 740.4. 

July 2009; 
Bank index: 195.7; 
Average of 12 of the 19 SCAP BHCs: 292.3; 
GMAC: 843.9. 

August 2009; 
Bank index: 131.3; 
Average of 12 of the 19 SCAP BHCs: 216.4; 
GMAC: 675.1. 

September 2009; 
Bank index: 139.9; 
Average of 12 of the 19 SCAP BHCs: 227; 
GMAC: 741.91. 

October 2009; 
Bank index: 116.6; 
Average of 12 of the 19 SCAP BHCs: 194.0; 
GMAC: 712.8. 

November 2009; 
Bank index: 114.5; 
Average of 12 of the 19 SCAP BHCs: 180.2; 
GMAC: 612.3. 

December 2009; 
Bank index: 116.0; 
Average of 12 of the 19 SCAP BHCs: 178.4; 
GMAC: 605.5. 

January 2010; 
Bank index: 93.9; 
Average of 12 of the 19 SCAP BHCs: 131.0; 
GMAC: 409.5. 

February 2010; 
Bank index: 116.8; 
Average of 12 of the 19 SCAP BHCs: 156.3; 
GMAC: 423.1. 

March 2010; 
Bank index: 122.2; 
Average of 12 of the 19 SCAP BHCs: 164.9; 
GMAC: 451.7. 

April 2010; 
Bank index: 98.1; 
Average of 12 of the 19 SCAP BHCs: 131.6; 
GMAC: 334.7. 

Source: GAO analysis of Thomson Reuters Datastream. 

[End of figure] 

The 19 Tested BHCs Experienced Better Performance Than a Pro Rata 
Estimate under the More Adverse Scenario: 

As of the end of 2009, while the SCAP BHCs generally had not 
experienced the level of losses that were estimated on a pro rata 
basis under the stress test's more adverse economic scenario, concerns 
remain that some banks could absorb potentially significant losses in 
certain asset categories that would erode capital levels. 
Collectively, the BHCs' total loan losses of $141.2 billion were 
approximately 38 percent less than the GAO-calculated $229.4 billion 
in pro rata losses under the more adverse scenario for 2009 (see table 
5).[Footnote 37] The BHCs also experienced significant gains in 
securities and trading and counterparty credit risk portfolios 
compared with estimated pro rata losses under SCAP. Total resources 
other than capital to absorb losses (resources) were relatively close 
to the pro rata amount, exceeding it by 4 percent. 

Table 5: Actual and GAO Pro Rata Estimates of Aggregate Losses and 
Changes in Resources Other than Capital to Absorb Losses across the 19 
SCAP BHCs, December 31, 2009: 

Asset category: Consumer and commercial loan losses; First-lien 
mortgages; 
Actual: $19.2 billion; 
GAO pro rata estimate[A]: $51.2 billion; 
Percent difference: -62%. 

Asset category: Consumer and commercial loan losses; Second/junior 
lien mortgages; 
Actual: $26.1 billion; 
GAO pro rata estimate[A]: $41.6 billion; 
Percent difference: -37. 

Asset category: Consumer and commercial loan losses; Commercial and 
industrial loans; 
Actual: $21.2 billion; 
GAO pro rata estimate[A]: $30.1 billion; 
Percent difference: -29. 

Asset category: Consumer and commercial loan losses; Commercial real 
estate loans; 
Actual: $13.5 billion; 
GAO pro rata estimate[A]: $26.5 billion; 
Percent difference: -49. 

Asset category: Consumer and commercial loan losses; Credit card loans; 
Actual: $31.6 billion; 
GAO pro rata estimate[A]: $41.2 billion; 
Percent difference: -23. 

Asset category: Consumer and commercial loan losses; Other[B]; 
Actual: $29.5 billion; 
GAO pro rata estimate[A]: $38.9 billion; 
Percent difference: -24. 

Total consumer and commercial loans losses; 
Actual: $141.2 billion; 
GAO pro rata estimate[A]: $229.4 billion; 
Percent difference: -38%. 

Asset category: Securities--available for sale and held to maturity--
losses (gains); 
Actual: ($3.5 billion); 
GAO pro rata estimate[A]: $17.6 billion; 
Percent difference: -120. 

Asset category: Trading and counterparty losses (gains); 
Actual: ($56.9 billion); 
GAO pro rata estimate[A]: $49.7 billion; 
Percent difference: -215. 

Total asset losses: 
Actual: $80.8 billion; 
GAO pro rata estimate[A]: $296.7 billion; 
Percent difference: -73%. 

Resources other than capital to absorb losses: 
Actual: $188.4 billion; 
GAO pro rata estimate[A]: $181.5 billion; 
Percent difference: 4%. 

Sources: GAO analysis of Federal Reserve SCAP and SNL Financial data. 

Notes: A parenthetical number indicates a gain. 

The trading and counterparty data in the Y-9C includes both customer 
derived revenue from transactions for BHCs that operate as broker- 
dealers, as well as gains and losses from proprietary trading and 
associated expenses. These items are presented on a net basis in the Y-
9C. For the five BHCs that had their trading portfolios stressed 
(Goldman Sachs, Morgan Stanley, Citigroup, JPMorgan Chase & Co., and 
Bank of America), the trading and counterparty line item is based on 
projections of gains or losses from proprietary trading, but 
preprovision net revenue (specifically noninterest revenue) included 
projections of gains or losses from customer derived revenue from 
transactions due to operations as a broker-dealer. These items cannot 
be segregated based on the Y-9C data and therefore are included in the 
net amount in both the trading and counterparty and noninterest income 
line items above. As a result of this limitation, the net amount of 
the trading gains or losses and preprovision net revenue in the table 
may be overstated or understated. 

[A] GAO calculated 1-year pro rata loss estimates by dividing the SCAP 
more adverse 2-year loss estimates by 2 (e., the straight-line 
method). A key limitation of this approach is that it assumes equal 
distribution of losses, revenues, expenses, and changes to reserves 
over time, although these items were unlikely to be distributed evenly 
over the 2-year period. Another important consideration is that actual 
results were not intended and should not be expected to align with the 
SCAP projections. 

[B] For "Other" we excluded about $6 billion in losses for State 
Street Corporation realized in 2009. Since this was a one-time charge 
that was realized in 2009, this effect was segregated from more 
typical loss amounts for our tracking purposes. 

[End of table] 

In tracking BHCs' losses and resources against the SCAP estimates, we 
compared the actual results with those estimated under the more 
adverse scenario. We used the 2-year estimates of the more adverse 
scenario from the SCAP results and annualized those amounts by 
dividing them in half (the "straight line" method) to get pro rata 
loss estimates for 2009 because the SCAP regulators did not develop 
estimates on a quarterly or annual basis. A key limitation of this 
approach is that it assumes equal distribution of losses, revenues, 
expenses, and changes to reserves over time, although these items were 
unlikely to be distributed evenly over the 2-year period. Another 
important consideration is that actual results were not intended and 
should not be expected to align with the SCAP projections. Actual 
economic performance in 2009 differed from the SCAP macroeconomic 
variable inputs, which were based on a scenario that was more adverse 
than was anticipated or than occurred, and other forces in the 
business and regulatory environment could have influenced the timing 
and level of losses. Appendix I contains additional details on our 
methodology, including our data sources and calculations, for tracking 
BHCs' financial performance data. 

Losses Varied by Individual BHCs: 

Although the 19 BHCs' actual combined losses were less than the 2009 
pro rata loss estimates for the more adverse scenario, the loss rates 
varied significantly by individual BHCs. For example, most of the BHCs 
had consumer and commercial loan losses that were below the pro rata 
loss estimates, but three BHCs--GMAC, Citigroup, and SunTrust Banks 
Inc. (SunTrust)--exceeded these estimates in at least one portfolio 
(see figure 7). GMAC was the only one with 2009 loan losses on certain 
portfolios that exceeded SCAP's full 2-year estimate. Specifically, 
GMAC exceeded the SCAP 2-year estimated losses in the first-lien, 
second/junior lien, and commercial real estate portfolios and the 1- 
year pro rata losses in the "Other" portfolio; Citigroup exceeded the 
1-year pro rata estimated losses in the commercial and industrial loan 
portfolio; and SunTrust exceeded the 1-year estimated losses in the 
first-lien and credit card portfolios. Appendix III provides detailed 
data on the individual performance of each of the BHCs. 

Figure 7: Comparison of Actual and GAO Pro Rata Estimated Losses for 
Consumer and Commercial Loans, December 31, 2009: 

[Refer to PDF for image: plotted point graph] 

The graph depicts actual and GAO pro rata estimated losses in the 
following six categories for 19 BHCs: 
Commercial real estate:
Commercial and industrial loans: 
First-lien mortgages:
Second/junior lien mortgages: 
Credit cards: 
Other: 

The 19 BHCs are: 
American Express Co. 
BB&T Corp.
The Bank of New York Mellon Corp. 
Bank of America Corp. 
Capital One Financial Corp. 
Citigroup Inc. 
Fifth Third Bancorp; 
GMAC LLC; 
JPMorgan Chase & Co. 
KeyCorp; 
MetLife, Inc. 
Morgan Stanley; 
PNC Financial Services Group Inc. 
Regions Financial Corp. 
State Street Corp. 
SunTrust Banks. Inc. 
U.S. Bancorp; 
Wells Fargo & Co. 

Included on the chart are the total losses for 19 BHCs. 

Source: GAO analysis of Federal Reserve and SNLFinancial data. 

Notes: Figure shows only those loan loss categories that were 
applicable under SCAP and that showed losses in 2009. In addition, 
Goldman Sachs was not included in the figure because it had no losses 
or recoveries for these loan categories in 2009. The "Other" category 
for State Street Corporation does not include one-time items in the 
actual or estimated amounts. See table 27 in appendix III for 
additional details. 

GAO calculated 1-year pro rata loss estimates by dividing the SCAP 
more adverse 2-year loss estimates by 2 (i.e., the straight-line 
method). A key limitation of this approach is that it assumes equal 
distribution of losses, revenues, expenses, and changes to reserves 
over time, although these items were unlikely to be distributed evenly 
over the 2-year period. Another important consideration is that actual 
results were not intended and should not be expected to align with the 
SCAP projections. 

[End of figure] 

GMAC faced particular challenges in the first year of the assessment 
period and posed some risk to the federal government, a majority 
equity stakeholder.[Footnote 38] GMAC's loan losses in its first-lien 
portfolio were $2.4 billion, compared with the $2 billion projected 
for the full 2-year period. In the second/junior lien portfolio, GMAC 
saw losses of $1.6 billion, compared with the $1.1 billion estimated 
losses for the 2 years. GMAC experienced losses of $710 million in its 
commercial real estate portfolio, compared with $600 million projected 
for the full 2-year period. Further, in its "Other" portfolio (which 
is comprised of auto leases and consumer auto loans), GMAC's losses 
were $2.1 billion, exceeding the 1-year pro rata $2 billion loss 
estimate. With a tier 1 common capital ratio of 4.85 percent--just 
more than the SCAP threshold of 4 percent--at the end of 2009, GMAC 
has a relatively small buffer in the face of potential losses. 

GMAC's position should be placed in context, however, because it is 
relatively unique among the SCAP participants. It was the only 
nonpublicly traded participant, and the federal government owns a 
majority equity stake in the company as a result of capital 
investments made through the Automotive Industry Financing Program 
under TARP. Further, GMAC's core business line--financing for 
automobiles--is dependent on the success of efforts to restructure, 
stabilize, and grow General Motors Company and Chrysler Group 
LLC.[Footnote 39] Finally, the Federal Reserve told us that because 
GMAC only recently became a BHC and had not previously been subject to 
banking regulations, it would take some time before GMAC was fully 
assimilated into a regulated banking environment.[Footnote 40] To 
improve its future operating performance and better position itself to 
become a public company in the future, GMAC officials stated that the 
company posted large losses in the fourth quarter of 2009 as result of 
accelerating its recognition of lifetime losses on loans.[Footnote 41] 
In addition, the company has been restructuring its operations and 
recently sold off some nonperforming assets.[Footnote 42] However, the 
credit rating agencies we met with generally believed that there could 
still be further losses at GMAC, although the agencies were less 
certain about the pace and level of those losses. Two of the agencies 
identified GMAC's Residential Capital, LLC mortgage operation as the 
key source of potential continued losses. 

BHCs Are Generally Not Experiencing the Level of Securities and 
Trading Losses That Were Estimated under the Pro Rata More Adverse 
Scenario, and Some Have Recorded Gains: 

Given that market conditions have generally improved, the BHCs' 
investments in securities and trading account assets performed 
considerably better in 2009 than had been estimated under the pro rata 
more adverse scenario.[Footnote 43] The SCAP assessment of the 
securities portfolio consisted of an evaluation for possible 
impairment of the portfolio's assets, including Treasury securities, 
government agency securities, sovereign debt, and private sector 
securities. In the aggregate, the securities portfolio has experienced 
a gain of $3.5 billion in 2009, compared with a pro rata estimated 
loss of $17.6 billion under the stress test's more adverse scenario. 
As figure 8 shows, 5 of the 19 BHCs recorded securities losses in 
2009,[Footnote 44] 13 recorded gains, and 1 (Morgan Stanley) recorded 
no gain or loss. Losses were projected at 17 of the BHCs under the pro 
rata more adverse scenario, and SCAP regulators did not consider the 
remaining 2 BHCs (American Express Company and Morgan Stanley) to be 
applicable for this category. In the securities portfolio, The Bank of 
New York Mellon Corporation had losses greater than estimated under 
SCAP for the full 2-year period.[Footnote 45] The variances could be 
due to a number of factors, including the extent to which a BHC 
decides to deleverage, how their positions react to changing market 
values, and other factors. 

Figure 8: Comparison of Actual and GAO Pro Rata Estimated Gains and 
Losses for Securities Available for Sale and Held to Maturity, 
December 31, 2009: 

[Refer to PDF for image: horizontal bar graph] 

BHC: AmEx	
Actual results: $0.225 billion; 
GAO pro rata estimates for more adverse scenario: n/a. 

BHC: BB&T	
Actual results: $0.199 billion; 
GAO pro rata estimates for more adverse scenario: -$0.1 billion. 

BHC: BNYM	
Actual results: -$5.369 billion; 
GAO pro rata estimates for more adverse scenario: -$2.1 billion; 

BHC: BofA	
Actual results: $2.528 billion; 
GAO pro rata estimates for more adverse scenario: -$4.3 billion. 

BHC: CapOne	
Actual results: $0.206v; 
GAO pro rata estimates for more adverse scenario: -$0.2 billion. 

BHC: Citi	
Actual results: -$0.91 billion; 
GAO pro rata estimates for more adverse scenario: -$1.5 billion. 

BHC: FifthThird	
Actual results: $0.057 billion; 
GAO pro rata estimates for more adverse scenario: -$0.03 billion. 

BHC: GMAC	
Actual results: $0.166 billion; 
GAO pro rata estimates for more adverse scenario: -$0.25 billion. 

BHC: Goldman	
Actual results: $0.036 billion; 
GAO pro rata estimates for more adverse scenario: -$0.05 billion. 

BHC: JPMC	
Actual results: $1.11 billion; 
GAO pro rata estimates for more adverse scenario: -$0.6 billion. 

BHC: KeyCorp	
Actual results: $0.113 billion; 
GAO pro rata estimates for more adverse scenario: -$0.05 billion. 

BHC: MetLife	
Actual results: -$1.631 billion; 
GAO pro rata estimates for more adverse scenario: -$4.15 billion. 

BHC: PNC	
Actual results: -$0.027 billion; 
GAO pro rata estimates for more adverse scenario: -$0.65 billion. 

BHC: Regions	
Actual results: $0.006 billion; 
GAO pro rata estimates for more adverse scenario: -$0.1 billion. 

BHC: State St	
Actual results: $0.141 billion; 
GAO pro rata estimates for more adverse scenario: -$0.9 billion. 

BHC: SunTrust	
Actual results: $0.098 billion; 
GAO pro rata estimates for more adverse scenario: -$0.01 billion. 

BHC: USB	
Actual results: -$0.451 billion; 
GAO pro rata estimates for more adverse scenario: -$0.65 billion. 

BHC: Wells	
Actual results: $0.205 billion; 
GAO pro rata estimates for more adverse scenario: -$2.1 billion. 

Source: GAO analysis of Federal Reserve and SNLFinancial data. 

Notes: Morgan Stanley was not included in the figure because it has 
not had any available for sale or held to maturity securities gains 
(losses) in 2009 and was deemed to be not applicable for this category 
in SCAP. American Express Company was also deemed not applicable for 
this category in SCAP, but was included in the figure because it had 
securities gains in 2009. 

GAO calculated 1-year pro rata loss estimates by dividing the SCAP 
more adverse 2-year loss estimates by 2 (i.e., the straight-line 
method). A key limitation of this approach is that it assumes equal 
distribution of losses, revenues, expenses, and changes to reserves 
over time, although these items were unlikely to be distributed evenly 
over the 2-year period. Another important consideration is that actual 
results were not intended and should not be expected to align with the 
SCAP projections. 

[End of figure] 

To estimate trading and counterparty losses, SCAP regulators assumed 
that these investments would be subject to the change in value of a 
proportional level as experienced in the last half of 2008.[Footnote 
46] The trading portfolio shows an even greater difference between the 
1-year pro rata estimates and the actual performance--a gain of $56.9 
billion in 2009 rather than the pro rata $49.7 billion estimated loss 
under the more adverse scenario (see table 5). The stress test only 
calculated trading and counterparty credit loss estimates for the five 
BHCs with trading assets that exceeded $100 billion.[Footnote 47] All 
five had trading gains as opposed to losses, based on the publicly 
available data from the Y-9C.[Footnote 48] These gains were the result 
of a number of particular circumstances. First, the extreme spreads 
and risk premium resulting from the lack of liquidity during the 
financial crisis--especially in the second half of 2008--reversed in 
2009, improving the pricing of many risky trading assets that remained 
on BHCs' balance sheets. Because the trading portfolio is valued at 
fair value, it had been written down for the declines in value that 
occurred throughout 2008 and the first quarter of 2009 and saw 
significant gains when the market rebounded through the remainder of 
2009. Second, the crisis led to the failure or absorption of several 
large investment banks, reducing the number of competitors and, 
according to our analysis of Thomson Reuters Datastream, increased 
market share and pricing power for the remaining firms.[Footnote 49] 
Finally, the Federal Reserve's low overnight bank lending rates (near 
0 percent) have prevailed for a long period and have facilitated a 
favorable trading environment for BHCs. This enabled BHCs to fund 
longer-term, higher yielding assets in their trading portfolios with 
discounted wholesale funding (see figure 9).[Footnote 50] 

Figure 9: Comparison of Actual and GAO Pro Rata Estimated Gains and 
Losses for Trading and Counterparty, December 31, 2009: 

[Refer to PDF for image: horizontal bar graph] 

BHC: BofA; 
Actual results: $12.067 billion; 
GAO pro rata estimates for more adverse scenario: -$12.05 billion. 

BHC: Citi; 
Actual results: $4.448 billion; 
GAO pro rata estimates for more adverse scenario: -$11.2 billion. 

BHC: Goldman; 
Actual results: $23.234 billion; 
GAO pro rata estimates for more adverse scenario: -$8.7 billion. 

BHC: JPMC; 
Actual results: $9.87 billion; 
GAO pro rata estimates for more adverse scenario: -$8.35 billion. 

BHC: Morgan Stanley; 
Actual results: $7.279 billion; 
GAO pro rata estimates for more adverse scenario: -$9.35 billion. 

Source: GAO analysis of Federal Reserve and SNLFinancial data. 

Notes: SCAP regulators only generated trading and counterparty 
estimates for the 5 BHCs with a trading book (assets) greater than 
$100 billion, therefore this comparison is not applicable to the other 
14 BHCs. 

GAO calculated 1-year pro rata loss estimates by dividing the SCAP 
more adverse 2-year loss estimates by 2 (i.e., the straight-line 
method). A key limitation of this approach is that it assumes equal 
distribution of losses, revenues, expenses, and changes to reserves 
over time, although these items were unlikely to be distributed evenly 
over the 2-year period. Another important consideration is that actual 
results were not intended and should not be expected to align with the 
SCAP projections. 

[End of figure] 

Potential Losses in Consumer and Commercial Credit Continue to Pose a 
Challenge: 

Potentially large losses in consumer and commercial loans continue to 
challenge SCAP BHCs, and addressing these challenges depends on a 
variety of factors, including, among other things, the effectiveness 
of federal efforts to reduce foreclosures in the residential mortgage 
market. The BHCs absorbed nearly $400 billion in losses in the 18 
months ending December 31, 2008. As they continue to experience the 
effects of the recent financial crisis, estimating precisely how much 
more they could lose is difficult. In March 2010, officials from two 
credit rating agencies indicated that 50 percent or more of the losses 
the banking industry was expected to incur during the current 
financial crisis could still be realized if the economy were to suffer 
further stresses. 

Data for the 19 BHCs show a rapid rise in the percentage of 
nonperforming loans over the course of 2009 (see figure 10).[Footnote 
51] Specifically, total nonperforming loans grew from 1 percent in the 
first quarter of 2007 to 6.6 percent in the fourth quarter of 2009 for 
SCAP BHCs. In particular, increases in total nonperforming loans were 
driven by significant growth in nonperforming first-lien mortgages and 
commercial real estate loans. Standard & Poor's Corporation noted that 
many nonperforming loans may ultimately have to be charged-off, 
exposing the BHCs to further potential losses. According to the credit 
rating agencies that we interviewed, federal housing policy to aid 
homeowners who are facing foreclosures, as well as time lags in the 
commercial real estate markets, will likely continue to affect the 
number of nonperforming loans for the remainder of the SCAP time frame 
(December 2010). 

Figure 10: Change in the Percentage of Nonperforming Loans for 
Applicable SCAP BHCs, by Loan Type, First Quarter 2007 through Fourth 
Quarter 2009: 

[Refer to PDF for image: multiple line graph] 

2007, Q1; 
Total loans: 1%; 
First-lien mortgages: 1.5%; 
Second/junior lien mortgages: 0.5%; 
Commercial and industrial loans: 0.6%; 
Commercial real estate: 0.5%; 
Credit cards: 2.3%; 
Other: 0.7%. 

2007, Q2; 
Total loans: 1%; 
First-lien mortgages: 1.6%; 
Second/junior lien mortgages: 0.6%; 
Commercial and industrial loans: 0.6%; 
Commercial real estate: 0.6v
Credit cards: 2.1%; 
Other: 0.7%. 

2007, Q3; 
Total loans: 1.1%; 
First-lien mortgages: 1.9%; 
Second/junior lien mortgages: 0.7%; 
Commercial and industrial loans: 0.6v
Commercial real estate: 0.8%; 
Credit cards: 2.3%; 
Other: 0.9%. 

2007, Q4; 
Total loans: 1.4%; 
First-lien mortgages: 2.4%; 
Second/junior lien mortgages: 1%; 
Commercial and industrial loans: 0.7%; 
Commercial real estate: 1.2%; 
Credit cards: 2.6%; 
Other: 1.1%. 

2008, Q1; 
Total loans: 1.7%; 
First-lien mortgages: 3%; 
Second/junior lien mortgages: 1.3%; 
Commercial and industrial loans: 0.8%; 
Commercial real estate: 1.8%; 
Credit cards: 2.7%; 
Other: 1.2%. 

2008, Q2; 
Total loans: 2%; 
First-lien mortgages: 3.7%; 
Second/junior lien mortgages: 1.4%; 
Commercial and industrial loans: 1.1%; 
Commercial real estate: 2.5%; 
Credit cards: 2.7%; 
Other: 1.2%. 

2008, Q3; 
Total loans: 2.5%; 
First-lien mortgages: 5.3%; 
Second/junior lien mortgages: 1.7%; 
Commercial and industrial loans: 1.4%; 
Commercial real estate: 2.7%; 
Credit cards: 2.6%; 
Other: 1.3%. 

2008, Q4; 
Total loans: 3.4%; 
First-lien mortgages: 7.1%; 
Second/junior lien mortgages: 1.9%; 
Commercial and industrial loans: 2%; 
Commercial real estate: 3.3%; 
Credit cards: 3%; 
Other: 1.9%. 

2009, Q1; 
Total loans: 4.3%; 
First-lien mortgages: 8.7%; 
Second/junior lien mortgages: 2.4%; 
Commercial and industrial loans: 2.6%; 
Commercial real estate: 4.7%; 
Credit cards: 3.8%; 
Other: 2.2%. 

2009, Q2; 
Total loans: 5.1%; 
First-lien mortgages: 10.3%; 
Second/junior lien mortgages: 2.5%; 
Commercial and industrial loans: 3.4%; 
Commercial real estate: 6.5%; 
Credit cards: 4%; 
Other: 2.4%. 

2009, Q3; 
Total loans: 6%; 
First-lien mortgages: 12.7%; 
Second/junior lien mortgages: 2.6%; 
Commercial and industrial loans: 4.4%; 
Commercial real estate: 7.8%; 
Credit cards: 3.5%; 
Other: 2.5%. 

2009, Q4; 
Total loans: 6.6%; 
First-lien mortgages: 14.9%; 
Second/junior lien mortgages: 2.6%; 
Commercial and industrial loans: 4.3%; 
Commercial real estate: 8.6%; 
Credit cards: 3.8%; 
Other: 2.4%. 

[End of figure] 

Note: Because they converted to BHCs in late 2008, American Express 
Company, Goldman Sachs, and Morgan Stanley did not submit Y-9Cs to the 
Federal Reserve until the first quarter of 2009, and GMAC did not 
submit its Y-9C until the second quarter of 2009. As a result, the 
data do not include information on these holding companies before 
those dates. 

Source: GAO analysis of Federal Reserve and SNLFinancial data. 

The Economic and Regulatory Environment Could Impact BHCs' Net 
Revenues and Loss Reserves: 

The total amount of resources other than capital to absorb losses 
(resources) has tracked the amount GAO prorated under the stress 
test's more adverse scenario. Resources measure how much cushion the 
BHCs have to cover loans losses. As shown previously in table 5, the 
aggregate actual results through the end of 2009 for resources showed 
a total of $188.4 billion, or 4 percent more than GAO's pro rata 
estimated $181.5 billion in the stress test's more adverse scenario. 
Eleven of the 19 BHCs tracked greater than the pro rata estimated 
amount in 2009, while the remaining 8 tracked less than the estimate 
(see figure 11). GMAC and MetLife, Inc. had negative resources in 
2009, although only GMAC was projected to have negative resources over 
the full 2-year period. 

Figure 11: Comparison of Actual and GAO Pro Rata Estimated Resources 
Other Than Capital to Absorb Losses, December 31, 2009: 

[Refer to PDF for image: horizontal bar graph] 

BHC: American Express Co.
Actual results: $7.37 billion; 
GAO pro rata estimates for more adverse scenario: $5.95 billion. 

BHC: BB&T Corp.
Actual results: $2.61 billion; 
GAO pro rata estimates for more adverse scenario: $2.75 billion. 

BHC: The Bank of NewYork Mellon Corp. 
Actual results: $3.36 billion; 
GAO pro rata estimates for more adverse scenario: $3.35 billion. 

BHC: Bank of America Corp. 
Actual results: $29.55 billion; 
GAO pro rata estimates for more adverse scenario: $37.25 billion. 

BHC: Capital One Financial Corp. 
Actual results: $5.76 billion; 
GAO pro rata estimates for more adverse scenario: $4.5 billion. 

BHC: Citigroup Inc. 
Actual results: $25.45 billion; 
GAO pro rata estimates for more adverse scenario: $24.5 billion. 

BHC: Fifth Third Bancorp: 
Actual results: $3.29 billion; 
GAO pro rata estimates for more adverse scenario: $2.75 billion. 

BHC: GMAC LLC: 
Actual results: -$1.07 billion; 
GAO pro rata estimates for more adverse scenario: -$0.25 billion. 

BHC: The GoldmanSachs Group Inc. 
Actual results: $19.42 billion; 
GAO pro rata estimates for more adverse scenario: $9.25 billion. 

BHC: JPMorgan Chase & Co. 
Actual results: $38.34 billion; 
GAO pro rata estimates for more adverse scenario: $36.2 billion. 

BHC: KeyCorp: 
Actual results: $0.06 billion; 
GAO pro rata estimates for more adverse scenario: $1.05 billion. 

BHC: MetLife, Inc.
Actual results: -$1.09 billion; 
GAO pro rata estimates for more adverse scenario: $2.8 billion. 

BHC: Morgan Stanley: 
Actual results: $1.01 billion; 
GAO pro rata estimates for more adverse scenario: $3.55v 

BHC: PNC FinancialServices Group, Inc.
Actual results: $6.18 billion; 
GAO pro rata estimates for more adverse scenario: $4.8 billion. 

BHC: Regions Financial Corp. 
Actual results: $1.07 billion; 
GAO pro rata estimates for more adverse scenario: $1.65 billion. 

BHC: State Street Corp.
Actual results: $2.48 billion; 
GAO pro rata estimates for more adverse scenario: $2.15 billion. 

BHC: SunTrust Banks, Inc. 
Actual results: $1.44 billion; 
GAO pro rata estimates for more adverse scenario: $2.35 billion. 

BHC: U.S. Bancorp: 
Actual results: $7.08 billion; 
GAO pro rata estimates for more adverse scenario: $6.85 billion. 

BHC: Wells Fargo & Co. 
Actual results: $36.14 billion; 
GAO pro rata estimates for more adverse scenario: $30 billion. 

Source: GAO analysis of Federal Reserve and SNL Financial data. 

Notes: Resources other than capital to absorb losses are calculated as 
preprovision net revenue less the change in allowance for loan and 
lease losses. 

GAO calculated 1-year pro rata loss estimates by dividing the SCAP 
more adverse 2-year loss estimates by 2 (i.e., the straight-line 
method). A key limitation of this approach is that it assumes equal 
distribution of losses, revenues, expenses, and changes to reserves 
over time, although these items were unlikely to be distributed evenly 
over the 2-year period. Another important consideration is that actual 
results were not intended and should not be expected to align with the 
SCAP projections. 

[End of figure] 

Our calculation considers increases in ALLL during 2009 to be a drain 
on resources in order to mirror the regulators' calculation for the 
full 2-year projection. However, the ALLL may ultimately be used as a 
resource in 2010, causing available resources to be higher than they 
currently appear in our tracking. PPNR is based on numerous factors, 
including interest income, trading revenues, and expenses. The future 
course of this resource will be affected by factors such as the 
performance of the general economy, the BHCs' business strategies, and 
regulatory changes, including the Dodd-Frank Wall Street Reform and 
Consumer Protection Act of 2010 (Dodd-Frank Act) and the Credit Card 
Accountability, Responsibility, and Disclosure Act of 2009.[Footnote 
52] Such regulatory changes could impose additional costs or reduce 
future profitability, either of which would impact future PPNR. 

SCAP Provided Lessons That Could Help Regulators Strengthen 
Supervisory Oversight and BHCs Improve Risk Management Practices: 

The SCAP stress test provided lessons in a number of areas that can be 
incorporated in the bank supervision process and used to improve BHCs' 
risk management practices. First, the transparency that was part of 
SCAP helped bolster market confidence, but the Federal Reserve has not 
yet developed a plan that incorporates transparency into the 
supervisory process. Second, the SCAP experience highlighted that 
BHCs' stress tests in the past were not sufficiently comprehensive and 
we found that regulators' oversight of these tests has been generally 
weak. Third, we identified opportunities to enhance both the process 
and data inputs for conducting stress testing in the future. Finally, 
SCAP demonstrated the importance of robust coordination and 
communication among the different regulators as an integral part of 
any effective supervisory process. By incorporating these lessons 
going forward, regulators will be able to enhance their ability to 
efficiently and effectively oversee the risk-taking in the banking 
industry. 

SCAP's Transparency Helped Bolster Market Confidence, but the Federal 
Reserve Has Yet to Implement a Plan to Incorporate Greater 
Transparency into the Supervisory Process: 

As stated earlier and as agreed generally by market participants, the 
public release of the SCAP design and results helped restore 
confidence in the financial system during a period of severe turmoil. 
Some agency officials stated that their experience in implementing 
SCAP suggested that greater transparency would also be beneficial in 
the supervisory process. In recent statements, the chairman and a 
governor of the Federal Reserve have both stated that, while 
protecting the confidentiality of firm-specific proprietary 
information is imperative, greater transparency about the methods and 
conclusions of future stress tests could benefit from greater scrutiny 
by the public.[Footnote 53] The Federal Reserve governor also noted 
that feedback from the public could help to improve the methodologies 
and assumptions used in the supervisory process. In addition, they 
noted that more transparency about the central bank's activities 
overall would ultimately enhance market discipline and that the 
Federal Reserve is looking at ways to enhance its disclosure policies. 
[Footnote 54] 

Consistent with the goal of greater transparency, we previously 
recommended that the Federal Reserve consider periodically disclosing 
to the public the aggregate performance of the 19 BHCs against the 
SCAP estimates for the 2-year forecast period.[Footnote 55] 
Subsequently, the chairman and a governor of the Federal Reserve have 
publicly disclosed 2009 aggregate information about the performance of 
the 19 BHCs based on the Federal Reserve's internal tracking. As the 2-
year SCAP period comes to a close at the end of 2010, completing a 
final analysis that compares the performance of BHCs with the 
estimated performance under the more adverse economic scenario would 
be useful; however, at the time of the review, Federal Reserve 
officials told us that they have not decided whether to conduct and 
publicly release any type of analysis. Given that the chairman and a 
governor of the Federal Reserve have already publicly disclosed some 
aggregate BHC performance against the more adverse scenario for 2009, 
providing the 2-year results would provide the public with consistent 
and reliable information from the chief architect of the stress test 
that could be used to further establish the importance of 
understanding such tests and consider lessons learned about the rigor 
of the stress test estimates. 

Increasing transparency in the bank supervisory process is a more 
controversial issue to address. Supervisory officials from OCC 
(including the then Comptroller) and the Federal Reserve question the 
extent to which greater transparency would improve day-to-day bank 
supervision. And, some BHCs we interviewed also were against public 
disclosure of future stress tests results. They noted that SCAP was a 
one-time stress test conducted under unique circumstances. 
Specifically, during the financial crisis, Treasury had provided a 
capital backstop for BHCs that were unable to raise funds privately. 
They expressed concern that public disclosure of certain unfavorable 
information about individual banks in a normal market environment 
could cause depositors to withdraw funds en masse creating a "run" on 
the bank. In addition, banks that appear weaker than their peers could 
be placed at a competitive disadvantage and may encourage them to 
offer more aggressive rates and terms for new depositors, thereby 
increasing their riskiness and further affecting their financial 
stability. While these concerns are valid and deserve further 
consideration, they have to be weighed against the potential benefits 
of greater transparency about the financial health of financial 
institutions and the banking system in general to investors, 
creditors, and counterparties. 

The Dodd-Frank Act takes significant steps toward greater 
transparency. For example, the act requires the Federal Reserve to 
perform annual stress tests on systematically significant institutions 
and publicly release a summary of results. Also, the act requires each 
of the systematically significant institutions to publicly report the 
summary of internal stress tests semiannually.[Footnote 56] Given 
comments by its senior leadership, the Federal Reserve is willing to 
engage in a constructive dialogue about creating a plan for greater 
transparency that could benefit the entire financial sector. The other 
federal bank regulators--FDIC, OCC, and the Office of the Thrift 
Supervision--are also critical stakeholders in developing such a plan. 
While Federal Reserve officials have discussed possible options for 
increasing transparency, the regulators have yet to engage in a formal 
dialogue about these issues and have not formalized a plan for the 
public disclosure of regulatory banking information or developed a 
plan for integrating public disclosures into the ongoing supervisory 
process. Without a plan for reconciling these divergent views and for 
incorporating steps to enhance transparency into the supervisory 
process and practices, including the public disclosure of certain 
information, bank regulators may miss a significant opportunity to 
enhance market discipline by providing investors, creditors, and 
counterparties with information such as bank asset valuations. 

Limited Use and Weak Oversight of BHCs' Stress Tests Prior to SCAP 
Highlights the Need for More Rigorous Testing and Better Monitoring of 
Tests: 

SCAP highlighted that the development and utilization of BHCs' stress 
tests were limited. Further, BHC officials noted that they failed to 
adequately stress test for the effects of a severe economic downturn 
scenario and did not test on a firmwide basis or test frequently 
enough. We also found that the regulator's oversight of these tests 
were weak, reinforcing the need for more rigorous and firmwide stress 
testing, better risk governance processes by BHCs, and more vigorous 
oversight of BHCs' stress tests by regulators. Going forward, as 
stress tests become a fundamental part of oversights of individual 
banks and the financial system, more specific guidance needs to be 
developed for examiners. BHCs and regulators stated that they are 
taking steps to address these shortcomings. 

BHCs Generally Did Not Perform Firmwide Stress Tests Prior to SCAP: 

Prior to SCAP, many BHCs generally performed stress tests on 
individual portfolios, such as commercial real estate or proprietary 
trading, rather than on a firmwide basis. SCAP led some institutions 
to look at their businesses in the aggregate to determine how losses 
would affect the holding company's capital base rather than individual 
portfolios' capital levels. As a result, some BHC officials indicated 
that they had begun making detailed assessments of their capital 
adequacy and risk management processes and are making improvements. 
Officials from one BHC noted that before SCAP their financial and risk 
control teams had run separate stress tests, but had not communicate 
or coordinate with each other about their stress testing activities. 
Officials from another BHC noted that their senior management and 
board of directors were not actively involved in the oversight of the 
stress testing process. These officials said that since participating 
in SCAP, they have improved in these areas by institutionalizing the 
internal communication and coordination procedures between the 
financial risk and control teams, and by increasing communication with 
senior management and board of directors about the need for active 
involvement in risk management oversight, respectively. These 
improvements can enhance the quality of the stress testing process. 
Moreover, officials of BHCs that were involved in ongoing bank mergers 
during the SCAP process credited SCAP with speeding up of the 
conversion process of the two institutions' financial systems since 
the BHCs' staff had to work together to be able to quickly provide, 
among other things, the aggregate asset valuations and losses of the 
combined firm's balance sheets to the regulators. 

BHC officials also stated that their stress tests would take a 
firmwide view, that is, taking into account all business units and 
risks within the holding company structure and would include updates 
of the economic inputs used to determine potential losses and capital 
needs in adverse scenarios. One BHC noted that it had developed 
several severe stress scenarios for liquidity because the recent 
financial crisis had shown that liquidity could deteriorate more 
quickly than capital, endangering a company's prospects for survival. 
This danger became evident in the failures of major financial 
institutions during the recent financial crisis--for example, IndyMac 
Bank, Lehman Brothers, and Bear Stearns. 

BHCs Did Not Sufficiently Stress Their Portfolios for Unexpected 
Losses Prior to SCAP: 

Officials from many SCAP BHCs and the Federal Reserve noted that 
internal bank stress test models generally did not use macroeconomic 
assumptions and loss rates inputs as conservative as those used in the 
SCAP stress test. According to Federal Reserve officials, using the 
SCAP macroeconomic assumptions, most of the 19 BHCs that took part in 
SCAP initially determined that they would not need additional capital 
to weather the more adverse scenario. However, the SCAP test results 
subsequently showed that more than half of them (10 of 19) did need to 
raise capital to meet the SCAP capital buffer requirements. Some BHCs 
indicated that future stress tests would be more comprehensive than 
SCAP. BHCs can tailor their stress test assumptions to match their 
specific business models, while SCAP generally used a one-size-fits-
all assumptions approach. For example, some BHCs noted that they use 
macroeconomic inputs (such as disability claims, prolonged 
stagflation, or consumer confidence) that were not found in the SCAP 
stress test. 

Although the Federal Reserve has required BHCs to conduct stress tests 
since 1998, officials from several BHCs noted that their institutions 
had not conducted rigorous stress tests in the years prior to SCAP, a 
statement that is consistent with regulatory findings during the same 
period. To some degree, this lack of rigorous testing reflected the 
relatively good economic times that preceded the financial crisis. 
According to one credit rating agency and a BHC, stress test 
assumptions generally tend to be more optimistic in good economic 
times and more pessimistic in bad economic times. In addition, one BHC 
noted that it had conducted stress tests on and off for about 20 
years, but usually only as the economy deteriorated. To address this 
issue, many BHC officials said that they have incorporated or are 
planning to incorporate more conservative inputs into their stress 
test models and are conducting more rigorous, firmwide stress testing 
more frequently. 

Regulators Required Stress Tests Prior to SCAP, but Oversight Was 
Limited: 

Although regulators' guidelines have required for over 10 years that 
financial institutions use stress tests to assess their capacity to 
withstand losses, we found that regulators' oversight of these tests 
had been limited. Horizontal examinations by the regulators from 2006 
through 2008 identified multiple weaknesses in institutions' risk 
management systems, including deficiencies in stress testing. Areas of 
weaknesses found during examination included that the BHCs' stress 
testing of their balance sheets lacked severity, were not performed 
frequently enough, and were not done on a firmwide basis. Also, it was 
found that BHCs' risk governance process lacked the active and 
effective involvement of BHC senior management and board of directors. 
The SCAP stress test and the financial crisis revealed the same 
shortcomings in BHCs' risk management and stress testing practices. 

However, we previously found that regulators did not always 
effectively address these weaknesses or in some cases fully appreciate 
their magnitude.[Footnote 57] Specifically, regulators did not take 
measures to push forcefully for institutions to better understand and 
manage risks in a timely and effective manner. In addition, according 
to our discussions with some SCAP participants, oversight of these 
tests through routine examinations was limited in scope and tended to 
be discretionary. For example, regulators would review firms' internal 
bank stress tests of counterparty risk and would make some 
suggestions, but reviews of these tests were done at the discretion of 
the individual supervisory team and were not consistently performed 
across teams. Even though BHCs have for many years performed stress 
tests to one degree or another, they have not been required to report 
the results of their testing to the Federal Reserve unless it 
specifically requested the information. 

The Federal Reserve recently issued a letter to the largest banking 
organizations outlining its view on good practices with respect to the 
use of stress testing in the context of internal capital adequacy 
assessment practices (ICAAP). For example, some areas highlighted in 
the letter include how frequent a stress test should be performed, the 
minimum time frame that the test should cover, documentation of the 
process, involvement of senior management and board of directors, and 
types of scenarios and risks to include in such tests. Some BHC 
officials believed that stress testing would become an integral part 
of future risk management practices and noted that SCAP helped them 
see how bank examiners would want them to stress their portfolios in 
the future. In anticipation of future action by regulators, many BHCs 
were designing at least part of their stress tests along the lines of 
SCAP. However, a few BHC officials hoped that future stress tests 
would not be performed in the same manner as SCAP, with the largest 
institutions tested simultaneously in a largely public setting, but 
rather as part of the confidential supervisory review process. 

Regulatory Oversight Is to Focus on More Rigorous Stress Testing, but 
Examiners Need More Specific Guidance: 

Federal Reserve officials stated that going forward, stress tests will 
become a fundamental part of the agency's oversight of individual 
banks and the financial system. As a result of SCAP, Federal Reserve 
officials stated that they are placing greater emphasis on the BHCs' 
internal capital adequacy planning through their ICAAP. This 
initiative is intended to improve the measurement of firmwide risk and 
the incorporation of all risks into firms' capital planning assessment 
and planning processes. In addition to enhanced supervisory focus on 
these practices across BHCs, stress testing is also a key component of 
the Basel II capital framework (Pillar 2).[Footnote 58] Under Pillar 
2, supervisory review is intended to help ensure that banks have 
adequate capital to support all risks and to encourage that banks 
develop and use better risk management practices. All BHCs, including 
those adopting Basel II, must have a rigorous process of assessing 
capital adequacy that includes strong board and senior management 
oversight, comprehensive assessment of risks, rigorous stress testing 
and scenario analyses, validation programs, and independent review and 
oversight. In addition, Pillar 2 requires supervisors to review and 
evaluate banks' internal capital adequacy assessments and monitor 
compliance with regulatory capital requirements. The Federal Reserve 
wants the large banks to conduct this work for themselves and report 
their findings to their senior management and boards of directors. 
According to Federal Reserve officials, for BHCs to satisfy the 
totality of expectations for ICAAP it may take 18 to 24 months, partly 
because the BHCs are taking actions to enhance practices where needed--
including with respect to the use of stress testing and scenario 
analyses in internal capital assessments--and the Federal Reserve then 
needs to evaluate these actions across a relatively large number of 
BHCs. 

In addition, the Federal Reserve is finalizing guidance for examiners 
to assess the capital adequacy process, including stress testing, for 
BHCs. Examiners are expected to evaluate how BHCs' stress tests inform 
the process for identifying and measuring risk and decisions about 
capital adequacy. Federal Reserve officials stated that examiners are 
expected to look closely at BHCs' internal stress test methodologies 
and results. In a letter to BHCs, the Federal Reserve also emphasized 
that institutions should look at time frames of 2 or more years and 
considers losses firmwide. It also suggested that BHCs develop their 
own stress test scenarios and then review these scenarios and the 
results for appropriate rigor and quantification of risk. 

While these are positive steps, examiners do not have specific 
criteria for assessing the quality of these tests. For example, the 
Federal Reserve has not established criteria for assessing the 
severity of the assumptions used to stress BHCs' balance sheets. The 
Federal Reserve officials stated that they intend to have technical 
teams determine the type of criteria that will be needed to evaluate 
these assumptions, but they are in the early planning stages. 
Development of such criteria will be particularly helpful in ensuring 
the effective implementation of the stress test requirements under the 
Dodd-Frank Act. Without specific criteria, Federal Reserve examiners 
will not be able to ensure the rigor of BHCs' stress tests--an 
important part of the capital adequacy planning. Furthermore, the 
absence of such guidance could lead to variations in the intensity of 
these assessments by individual examiners and across regional 
districts. 

Risk Identification and Assessment Infrastructure Needs to be Upgraded 
to Improve Oversight: 

Following SCAP, regulatory and BHC officials we met with identified 
opportunities to enhance both the process and data inputs for 
conducting stress testing in the future. This would include processes 
for obtaining, analyzing, and sharing data and capabilities for data 
modeling and forecasting, which potentially could increase the Federal 
Reserve's abilities to assess risks in the banking system. According 
to the Federal Reserve, an essential component of this new system will 
be a quantitative surveillance mechanism for large, complex financial 
institutions that will combine a more firmwide and multidisciplinary 
approach for bank supervision. This quantitative surveillance 
mechanism will use supervisory information, firm-specific data 
analysis, and market-based indicators to identify developing strains 
and imbalances that may affect multiple institutions, as well as 
emerging risks within specific institutions. This effort by the 
Federal Reserve may also improve other areas of supervision which rely 
on data and quantitative analysis, such as assessing the process used 
by BHC's to determine their capital adequacy, forecasting revenue, and 
assessing and measuring risk, which is critical to supervising large, 
complex banks. Officials at the Federal Reserve told us that examiners 
should be analyzing BHC performances versus their stress test 
projections to provide insight into the agency's loss forecasting 
approach. Moreover, Federal Reserve officials stated that they are 
always looking to increase their analytical capabilities, and they 
have recently implemented a new governance structure to address some 
of their management information infrastructure challenges. However, 
not enough time has passed to determine the extent to which such 
measures will improve banking supervision. 

In addition, some other deficiencies were found in the data reported 
to the Federal Reserve by BHCs using the Y-9C, as well as the Federal 
Reserve's ability to analyze the risk of losses pertaining to certain 
portfolios that were identified during the SCAP stress test. This led 
the Federal Reserve to develop a more robust risk identification and 
assessment infrastructure including internally developed models or 
purchased analytical software and tools from data vendors. Going 
forward, such models and analytics would facilitate improved risk 
identification and assessment capabilities and oversight, including 
the oversight of systemic risk. Moreover, a risk identification and 
assessment system that can gauge risk in the banking sector by 
collecting data on a timelier basis is necessary to better ensure the 
safety and soundness of the banking industry. Specific areas in which 
data collection and risk identification and assessment could be 
enhanced include mortgage default modeling to include more analysis of 
nontraditional mortgage products, counterparty level exposures, 
country and currency exposures, and commodity exposures. An example of 
where the Federal Reserve used SCAP to significantly upgrade its 
ability to assess risks across large BHCs is the development of a 
system that allowed BHCs to submit their securities positions and 
market values at a fixed date and apply price shocks. This process was 
enhanced during SCAP to facilitate the stress analysis of securities 
portfolios held by SCAP BHCs.[Footnote 59] This system allowed the 
Federal Reserve to analyze approximately 100,000 securities in a 
relatively short time period. The Federal Reserve intends to continue 
using this database to receive and analyze updated positions from BHCs. 

With other portfolios, the Federal Reserve contracted with outside 
data and analytical systems providers. For multifamily loan 
portfolios, nonfarm loans, and nonresidential loans with a maturity 
beyond 2 years, all of which are subsets of commercial and industrial 
loans or commercial real estate portfolios, the Federal Reserve used 
internal models and purchased an outside vendor service that allowed 
it to estimate losses for these portfolios. For the remaining 
commercial portfolios, the Federal Reserve used different existing 
models found at both the Federal Reserve and Federal Reserve district 
banks and new models developed to meet the needs of SCAP. When 
analyzing BHCs' mortgage portfolios, the consumer loans Supervisory 
Analytical and Advisory Team provided templates to the BHCs to collect 
granular data for such analysis, allowing the system to separate BHCs' 
mortgage portfolios into much more granular tranches than would be 
possible using data from regulatory filings. The Federal Reserve 
further used data from various sources, including a large 
comprehensive loan-level database of most mortgages that have been 
securitized in the United States to assist in developing its own loss 
estimates to benchmark against the BHCs' proprietary estimates. 

These examples point to enhancements in the ability to assess risks to 
individual firms and across the banking sector that resulted from the 
SCAP stress test. The Federal Reserve has made clear that it views 
many of these innovations in its ability to assess and model risks and 
potential losses as permanent additions to its toolkit, and has also 
recognized the need for more timely and granular information to 
improve its supervision of BHCs and other institutions. However, the 
extent to which these models and tools will be distributed across the 
Federal Reserve district banks and other federal banking regulators is 
unclear. In addition, as the stress test applied to trading positions 
was limited to those BHCs that held trading positions of at least $100 
billion as of February 20, 2009, the Federal Reserve has not indicated 
that it will roll out its new system to BHCs with smaller trading 
positions. The Federal Reserve has taken steps to maintain and enhance 
the tools and data used during SCAP. Further, improving the Federal 
Reserve's financial data collection and supervisory tools will require 
additional resources, training for bank examiners, coordination in the 
dissemination of new infrastructure across all U.S. financial 
regulators, and, according to a Federal Reserve governor, would 
benefit from relief from the Paperwork Reduction Act of 1980 as well. 

The Federal Reserve lacks a complete plan on how it will achieve 
permanent improvements in its risk identification and assessment 
infrastructure, but according to officials, such a plan is in 
development. The Federal Reserve has finalized a plan that describes a 
governance structure for overseeing large, complex financial 
organizations. The plan defines the roles and responsibilities of 
various committees and teams within the Federal Reserve that will 
carry out its supervisory responsibilities over these organizations. 
However, further planning is needed to incorporate lessons learned 
from SCAP for addressing data and modeling gaps that existed prior to 
the crisis and a structure for disseminating improvements to risk 
identification and assessment. Specifically, this plan will also be 
critical to addressing improvements to data and modeling 
infrastructure in supervising not only large financial holding 
companies but also smaller institutions. A fully developed plan would 
also consider how to disseminate data, models, and other 
infrastructure to the entire Federal Reserve System and bank 
regulatory agencies, as well as the newly established Financial 
Stability Oversight Council and Treasury's Office of Financial 
Research. Without such a plan, the agency runs the risk of not 
optimizing its oversight responsibilities, especially in light of its 
new duties as the systemic risk regulator under the Dodd-Frank Act. 

More Coordination and Communication across Regulators Is Critical for 
Understanding Risks to Individual Institutions and Financial Markets: 

Another critical lesson from SCAP was the need for robust coordination 
and communication among the regulators in examining large, complex 
financial institutions. Officials from the regulatory agencies and 
BHCs stated that the degree of cooperation among the SCAP regulators 
was unprecedented and improved the understanding of the risks facing 
the individual BHCs and the financial market. Such coordination and 
communication will become increasingly important as banking regulators 
increase their oversight role. Even with recent major reform to the 
financial regulatory structure, multiple regulatory agencies continue 
to oversee the banking industry, and regulators will need to 
prioritize efforts to promote coordination and communication among 
staff from these agencies so that emerging problematic issues 
affecting the financial industry are identified in a timely manner and 
effectively addressed. 

Going forward, based on our discussions with various SCAP participants 
and statements by Federal Reserve officials, including the chairman, 
the regulators' experience with SCAP is anticipated to lead to the 
expanded use of horizontal examinations and multidisciplinary staff 
that will require extensive interagency coordination. Horizontal 
examinations may involve multiple regulators and underscore the 
importance of effective coordination and communication. 

Currently, regulators are conducting horizontal examinations of 
internal processes that evaluate the capital adequacy at the 28 
largest U.S. BHCs. Their focus is on the use of stress testing and 
scenario analyses in ICAAP, as well as how shortcomings in fundamental 
risk management practices and governance and oversight by the board of 
directors for these processes could impair firms' abilities to 
estimate their capital needs. Regulators recently completed the 
initial phase of horizontal examinations of incentive compensation 
practices at 25 large U.S. BHCs. As part of this review, each 
organization was required to submit an analysis of shortcomings or 
"gaps" in its existing practices relative to the principles contained 
in the proposed supervisory guidance issued by the Federal Reserve in 
the fall of 2009 as well as plans--including timetables--for 
addressing any weaknesses in the firm's incentive compensation 
arrangements and related risk-management and corporate governance 
practices. In May 2010, regulators provided the banking organizations 
feedback on the firms' analyses and plans. These organizations 
recently submitted revised plans to the Federal Reserve for addressing 
areas of deficiencies in their incentive compensation programs. In a 
June 2010 press release, the Federal Reserve noted that to monitor and 
encourage improvements in compensation practices by banking 
organizations, its staff will prepare a report after 2010 on trends 
and developments in such practices at banking organizations. 

Our prior work has found that coordination and communication among 
regulatory agencies is an ongoing challenge.[Footnote 60] For example, 
in 2007, OCC onsite examiners, as well as officials in headquarters, 
told us that coordination issues hampered the Federal Reserve's 
horizontal examinations. Also, in 2007, a bank told us that it had 
initially received conflicting information from the Federal Reserve, 
its consolidated supervisor, and the OCC, its primary bank supervisor, 
regarding a key policy interpretation. Officials from the bank also 
noted that when the Federal Reserve collected information, it did not 
coordinate with OCC, the primary bank examiner of the lead bank, 
resulting in unnecessary duplication. We noted that to improve 
oversight in the future, regulators will need to work closely together 
to expedite examinations and avoid such duplications. 

Since the SCAP stress test was concluded, the following examples 
highlight ongoing challenges in coordination and communication: 

* Officials from OCC and FDIC indicated that they were not always 
involved in important discussions and decisions. For example, they 
were not involved in the decision to reduce GMAC's SCAP capital 
requirement, even though they were significantly involved in 
establishing the original capital requirement. Also, FDIC noted that 
it was excluded from such decision even though it is the primary 
federal bank regulator for GMAC's retail bank (Ally Bank). 

* The Federal Reserve held an internal meeting to discuss lessons 
learned from SCAP, but has yet to reach out to the other SCAP 
regulators. The OCC and FDIC told us that they had not met with the 
Federal Reserve as a group to evaluate the SCAP process and document 
lessons learned. As a result, the FDIC and OCC did not have an 
opportunity to share their views on what aspects of SCAP worked and 
did not work, as well as any potential improvements that can be 
incorporated into future horizontal reviews or other coordinated 
efforts. 

* In the recent horizontal examinations, both FDIC and OCC noted that 
the interagency process for collaboration--especially in the initial 
design stages--was not as effective as it was for SCAP. OCC commented 
that more collaboration up front would have been preferable. Also, 
FDIC stated that the Federal Reserve did not include it in meetings to 
formulate aggregate findings for the horizontal examination of 
incentive compensation programs, and it experienced difficulties in 
obtaining aggregate findings from the Federal Reserve. The Federal 
Reserve commented that the FDIC was involved in the development of 
findings for those organizations that control an FDIC-supervised 
subsidiary bank and that FDIC has since been provided information on 
the findings across the full range of organizations included in the 
horizontal review, the majority of which do not control an FDIC-
supervised subsidiary bank. 

These continued challenges in ensuring effective coordination and 
communication underscore the need for sustained commitment and effort 
by the regulators to ensure the inclusion of all relevant agencies in 
key discussions and decisions regarding the design, implementation, 
and results of multiagency horizontal examinations. As the SCAP 
process has shown, active participation by all relevant regulators can 
strengthen approaches used by examiners in performing their 
supervisory activities. Without continuous coordination and 
communication, the regulators will miss opportunities to leverage 
perspectives and experiences that could further strengthen the 
supervision of financial institutions, especially during horizontal 
examinations of financial institutions. 

Conclusions: 

Publicly reporting a comparison of the actual performance of the SCAP 
BHCs and the estimated performance under a more adverse scenario 
provides insights into the financial strength of the nation's largest 
BHCs. Senior Federal Reserve officials have publicly disclosed select 
aggregate information about the performance of the 19 BHCs consistent 
with the recommendation in our June 2009 report. Specifically, we 
recommended that the Federal Reserve consider periodically disclosing 
to the public the performance of the 19 BHCs against the SCAP 
estimates during the 2-year period. However, the Federal Reserve has 
yet to commit to completing a final analysis that compares the BHCs' 
actual performance with the estimated performance under SCAP's more 
adverse economic scenario for the entire 2-year period and making this 
analysis public. Such an analysis is important for the market and BHCs 
to assess the rigor of the stress test methodology. Publicly releasing 
the results also would allow the public to gauge the health of the 
BHCs that participated in SCAP, which is a strong proxy for the entire 
U.S. banking industry. And public disclosure of this analysis could 
act as a catalyst for a public discussion of the value of effective 
bank risk management and enhance confidence in the regulatory 
supervision of financial institutions. 

The public release of the stress test methodology and results helped 
improve market confidence in the largest BHCs during the recent 
financial crisis and provided an unprecedented window into bank 
supervision process. Subsequently, the Chairman of the Federal Reserve 
and a Federal Reserve governor have publicly stated that greater 
transparency should be built into the supervisory process and that 
feedback from the public could help increase the integrity of the 
supervisory process. Increased transparency can also augment the 
information that is available to investors and counterparties of the 
institutions tested and enhance market discipline. Despite these 
statements, the Federal Reserve and other bank regulators have yet to 
start a formal dialogue about this issue, nor have they developed a 
plan for integrating public disclosures into the ongoing supervisory 
process. Such a plan could detail the types of information that would 
benefit the markets if it were publicly released; the planned 
methodology for the stress tests, including assumptions; the frequency 
with which information would be made public; and the various means of 
disseminating the information. Taking into account the need to protect 
proprietary information and other market-sensitive information would 
be an important part of such a plan. While regulators will undoubtedly 
face challenges in determining how best to overcome skepticism about 
the potential effects on the financial markets of disclosing sensitive 
information on the financial health of banks, the Dodd-Frank Act 
requires that the Federal Reserve and certain banks publicly release a 
summary of results from periodic stress tests. Without a plan for 
enhancing the transparency of supervisory processes and practices, 
bank regulators may miss a significant opportunity to further 
strengthen market discipline and confidence in the banking industry by 
providing investors, creditors, and counterparties with useful 
information. 

The SCAP stress test shed light on areas for further improvement in 
the regulators' bank supervision processes, including oversight of 
risk management practices at BHCs. Prior to SCAP, regulatory oversight 
of stress tests performed by the BHCs themselves was ineffective. 
Specifically, although regulators required stress tests, the 
guidelines for conducting them were more than a decade old, and the 
individual banks were responsible for designing and executing them. 
The Federal Reserve's reviews of the internal stress tests were done 
at the discretion of the BHCs' individual supervisory teams and were 
not consistently performed. Further, even though BHCs performed stress 
tests, they were not required to report the results of their stress 
testing to the Federal Reserve without a specific request from 
regulators. Post-SCAP, however, the Federal Reserve has stated that 
stress testing will now be a fundamental part of their oversight of 
individual banks. The Federal Reserve expects to play a more prominent 
role in reviewing assumptions, results, and providing input into the 
BHCs' risk management practices. While the Federal Reserve has begun 
to take steps to augment its oversight, currently Federal Reserve 
examiners lack specific criteria for assessing the severity of BHCs' 
stress tests. Without specific criteria, Federal Reserve examiners 
will not be able to ensure the rigor of BHCs' stress tests. 
Furthermore, the absence of such criteria could lead to variations in 
the intensity of these assessments by individual examiners and across 
regional districts. 

The experience with SCAP also showed that regulators needed relevant 
and detailed data to improve oversight of individual banks and to 
identify and assess risks. As the Federal Reserve and the other 
regulators conduct more horizontal reviews, they will need a robust 
plan for quantitatively assessing the risk in the banking sector. 
Collecting timely data for the annual stress testing and other 
supervisory actions will be critical in order to better ensure the 
safety and soundness of the banking industry. The Federal Reserve has 
finalized a plan that describes a governance structure for overseeing 
large, complex financial organizations. However, further planning is 
needed to incorporate lessons learned from SCAP for addressing data 
and modeling gaps and a structure for disseminating improvements to 
risk identification and assessment. Further, efforts to improve the 
risk identification and assessment infrastructure will need to be 
effectively coordinated with other regulators and the newly 
established Financial Stability Oversight Council and Treasury's 
Office of Financial Research in order to ensure an effective 
systemwide risk assessment. Without fully developing a plan that can 
identify BHCs' risks in time to take appropriate supervisory action, 
the Federal Reserve may not be well-positioned to anticipate and 
minimize future banking problems and ensure the soundness of the 
banking system. 

Despite the positive coordination and communication experience of the 
SCAP stress test, developments since the completion of SCAP have 
renewed questions about the effectiveness of regulators' efforts to 
strengthen their coordination and communication. For example, on 
important issues, such as finalizing GMAC's SCAP capital amount, the 
Federal Reserve chose not to seek the views of other knowledgeable 
bank regulators. While the Dodd-Frank Act creates formal mechanisms 
that require coordination and communication among regulators, the 
experiences from SCAP point to the need for a sustained commitment by 
each of the banking regulators to enhance coordination and 
communication. In particular, ensuring inclusion of relevant agencies 
in key discussions and decisions regarding the design, implementation, 
and results of multiagency horizontal examinations will be critical. 
If regulators do not consistently coordinate and communicate 
effectively during horizontal examinations, they run the risk of 
missing opportunities to leverage perspectives and experiences that 
could further strengthen bank supervision. 

Recommendations: 

To gain a better understanding of SCAP and inform the use of similar 
stress tests in the future, we recommend that the Chairman of the 
Federal Reserve direct the Division of Banking Supervision and 
Regulation to: 

* Compare the performance of the 19 largest BHCs against the more 
adverse scenario projections following the completion of the 2-year 
period covered in the SCAP stress test ending December 31, 2010, and 
disclose the results of the analysis to the public. 

* To leverage the lessons learned from SCAP to the benefit of other 
regulated bank and thrift institutions, we recommend that the Chairman 
of the Federal Reserve in consultation with the heads of the FDIC and 
OCC take the following actions: 

* Follow through on the Federal Reserve's commitment to improve the 
transparency of bank supervision by developing a plan that reconciles 
the divergent views on transparency and allows for increased 
transparency in the regular supervisory process. Such a plan should, 
at a minimum, outline steps for releasing supervisory methodologies 
and analytical results for stress testing. 

* Develop more specific criteria to include in its guidance to 
examiners for assessing the quality of stress tests and how these 
tests inform BHCs' capital adequacy planning. These guidelines should 
clarify the stress testing procedures already incorporated into 
banking regulations and incorporate lessons learned from SCAP. 

* Fully develop its plan for maintaining and improving the use of 
data, risk identification and assessment infrastructure, and requisite 
systems in implementing its supervisory functions and new 
responsibilities under the Dodd-Frank Act. This plan should also 
ensure the dissemination of these enhancements throughout the Federal 
Reserve System and other financial regulators, as well as new 
organizations established in the Dodd-Frank Act. 

* Take further steps to more effectively coordinate and communicate 
among themselves. For example, ensuring that all applicable regulatory 
agencies are included in discussions and decisions regarding the 
development, implementation, and results of multiagency activities, 
such as horizontal examinations of financial institutions. 

Agency Comments and Our Evaluation: 

We provided a draft of this report to the Federal Reserve, FDIC, OCC, 
OTS, and Treasury for review and comment. We received written comments 
from the Chairman of the Federal Reserve Board of Governors and the 
Assistant Secretary for Financial Stability. These comments are 
summarized below and reprinted in appendixes IV and V, respectively. 
We also received technical comments from the Federal Reserve, FDIC, 
OCC, and Treasury, which we incorporated into the report as 
appropriate. OTS did not provide any comments. In addition, we 
received technical comments from the Federal Reserve and most of the 
19 SCAP BHCs on the accuracy of our tracking of revenues and losses in 
2009 for each of the SCAP BHCs and incorporated them into the report 
as appropriate. 

In its comment letter, the Federal Reserve agreed with all five of our 
recommendations for building on the successes of SCAP to improve bank 
supervision. The Federal Reserve noted that our recommendations 
generally relate to actions it is currently undertaking or planning to 
take under the Dodd-Frank Act. It also cited that in coordination with 
FDIC and OCC, it would provide a public assessment of BHCs' 
performance relative to the loss and preprovision net revenue 
estimates under the more adverse scenario, taking into account the 
limitations of such an analysis. For our remaining recommendations 
related to increased transparency, examiner guidance, risk 
identification and assessment, and coordination and communication of 
multiagency activities, the Federal Reserve generally noted that it 
has taken step in these areas and will continue to consult with the 
FDIC and OCC in implementing our recommendations and its new 
responsibilities under the Dodd-Frank Act. 

While our report recognizes the steps that the Federal Reserve has 
taken related to transparency, examiner guidance, risk identification 
and assessment, and coordination and communication of multiagency 
activities, these areas warrant ongoing attention. For example, as we 
note in the report, while the Federal Reserve is in the process of 
finalizing examination guidance for reviewing stress tests, examiners 
currently do not have specific criteria for assessing the severity of 
these tests nor have they coordinated with the other bank regulators. 
Until this guidance is completed, examiners will lack the information 
needed to fully ensure the rigor of BHCs' stress tests, and the Board 
will not be able to fully ensure the consistency of the assessment by 
individual examiners. Our report also notes the positive coordination 
and communication experience of the SCAP stress test, but we continued 
to find specific instances since the completion of SCAP that have 
renewed questions about the effectiveness of regulators' efforts to 
strengthen their coordination and communication. For instance, while 
the Federal Reserve included relevant agencies in key discussions and 
decisions regarding the design, implementation, and results of SCAP, 
we found that the Federal Reserve missed opportunities to include 
other bank regulators when planning more recent horizontal 
examinations. 

Treasury agreed with our report findings, noting that it appreciated 
our acknowledgment that SCAP met its goals of providing a 
comprehensive, forward-looking assessment of the balance sheet risks 
of the largest banks and increasing the level and quality of capital 
held by such banks. It further noted that the unprecedented public 
release of the stress test results led to an increase in the market 
confidence in the banking system, which aided in improving the capital 
adequacy of the largest banks. 

We are sending copies of this report to the appropriate congressional 
committees; Chairman of the Federal Reserve, the Acting Comptroller of 
Currency, Chairman of the FDIC, the Acting Director of the Office of 
the Thrift Supervision, and the Secretary of the Treasury. Also, we 
are sending copies of this report to the Congressional Oversight 
Panel, Financial Stability Oversight Board, the Special Inspector 
General for TARP, and other interested parties. In addition, the 
report will be available at no charge on the GAO Web site at 
[hyperlink, http://www.gao.gov]. 

Should you or your staff have any questions on the matters discussed 
in this report, please contact me at (202) 512-8678 or 
williamso@gao.gov. Contact points for our Offices of Congressional 
Relations and Public Affairs may be found on the last page of this 
letter. GAO staff who made key contributions to this report are listed 
in appendix VI. 

Signed by: 

Orice Williams Brown: 
Director, Financial Markets and Community Investment: 

List of Committees: 

The Honorable Daniel K. Inouye: 
Chairman: 
The Honorable Thad Cochran: 
Vice Chairman: 
Committee on Appropriations: 
United States Senate: 

The Honorable Christopher J. Dodd: 
Chairman: 
The Honorable Richard C. Shelby: 
Ranking Member: 
Committee on Banking, Housing, and Urban Affairs: 
United States Senate: 

The Honorable Kent Conrad: 
Chairman: 
The Honorable Judd Gregg: 
Ranking Member: 
Committee on the Budget: 
United States Senate: 

The Honorable Max Baucus: 
Chairman: 
The Honorable Charles E. Grassley: 
Ranking Member: 
Committee on Finance: 
United States Senate: 

The Honorable David R. Obey: 
Chairman: 
The Honorable Jerry Lewis: 
Ranking Member: 
Committee on Appropriations: 
House of Representatives: 

The Honorable John M. Spratt Jr. 
Chairman: 
The Honorable Paul Ryan: 
Ranking Member: 
Committee on the Budget: 
House of Representatives: 

The Honorable Barney Frank: 
Chairman: 
The Honorable Spencer Bachus: 
Ranking Member: 
Committee on Financial Services: 
House of Representatives: 

The Honorable Sander M. Levin: 
Chairman: 
The Honorable Dave Camp: 
Ranking Member: 
Committee on Ways and Means: 
House of Representatives: 

[End of section] 

Appendix I: Objectives, Scope, and Methodology: 

The objectives of this report were to (1) describe the process used to 
design and conduct the stress test and participants views' of the 
process, (2) describe the extent to which the stress test achieved its 
goals and compare its estimates with the bank holding companies' (BHC) 
actual results, and (3) identify the lessons regulators and BHCs 
learned from the Supervisory Capital Assessment Program (SCAP) and 
examine how each are using those lessons to enhance their risk 
identification and assessment practices. 

To meet the report's objectives, we reviewed the Board of Governors of 
the Federal Reserve System's (Federal Reserve) The Supervisory Capital 
Assessment Program: Design and Implementation (SCAP design and 
implementation document) dated April 24, 2009, and The Supervisory 
Capital Assessment Program: Overview of Results (SCAP results 
document) dated May 7, 2009. We analyzed the initial stress test data 
that the Federal Reserve provided to each BHC, the subsequent 
adjustments the Federal Reserve made to these estimates, and the 
reasons for these adjustments. We reviewed BHC regulatory filings such 
as the Federal Reserve's 2009 Consolidated Financial Statements for 
Bank Holding Companies---FR Y-9C (Y-9C);[Footnote 61] company 
quarterly 10-Qs and annual 10-Ks; speeches and testimonies regarding 
SCAP and stress testing; BHCs' presentations to shareholders and 
earnings reports; bank supervision guidance issued by the Federal 
Reserve, Office of the Comptroller of the Currency (OCC), and the 
Federal Deposit Insurance Corporation (FDIC); and documents regarding 
the impact of SCAP and the financial crisis and proposed revisions to 
bank regulation and supervisory oversight.[Footnote 62] To further 
understand these documents and obtain different perspectives on the 
SCAP stress test, we interviewed officials from the Federal Reserve, 
OCC, FDIC, and the Office of the Thrift Supervision, as well as 
members of the multidisciplinary teams created to execute SCAP. 
[Footnote 63] 

We also collected data from SNL Financial--a private financial 
database that contains publicly filed regulatory and financial 
reports, including those of the BHCs involved in SCAP--in order to 
compare the BHCs' actual performance in 2009 against the regulators' 2-
year SCAP loss estimates and GAO's 1-year pro rata loss estimates. To 
obtain additional background information regarding the tracking of the 
BHCs, perspectives on their performance, anticipated loan losses, and 
the success of SCAP in achieving its goals, we interviewed relevant 
officials (e.g., chief risk officers and chief financial officers) 
from 11 of the 19 BHCs that participated in the SCAP stress test. The 
BHCs we interviewed were the American Express Company; Bank of America 
Corporation; The Bank of New York Mellon Corporation; BB&T 
Corporation; Citigroup Inc.; GMAC LLC;[Footnote 64] The Goldman Sachs 
Group, Inc.; JPMorgan Chase & Co.; MetLife, Inc.; Regions Financial 
Corporation; and Wells Fargo & Company. We selected these BHCs to 
reflect differences in size, types of financial services provided, 
geographic location, primary bank regulator, and participation in the 
Troubled Asset Relief Program (TARP). In addition, we met with credit 
rating agency officials from the Standard and Poor's Corporation, 
Moody's Corporation, and Fitch Ratings Inc. for their perspective on 
SCAP and their own stress test practices. To more completely 
understand the execution of SCAP, we completed a literature search of 
stress tests conducted by others--for example, the Committee on 
European Banking Supervisors and the International Monetary Fund. We 
also reviewed relevant credit rating agency reports and the reports of 
other oversight bodies such as the Congressional Oversight Panel and 
the Special Inspector General for the Troubled Asset Relief Program on 
topics related to stress testing and TARP. We also reviewed our past 
work on the bank supervisory process and SCAP.[Footnote 65] 

In addition, to track the actual performance of the 19 BHCs, we 
collected data from several sources. We then compared the BHCs' actual 
performance to the December 31, 2008, capital levels presented in SCAP 
and the projections made under the more adverse scenario for estimated 
losses for loans, securities (available for sale and held to 
maturity), trading and counterparty, and resources other than capital 
to absorb losses.[Footnote 66] Our primary source for SCAP estimates 
was the May 7, 2009, SCAP results document, which contained the 
estimates for each of the 19 BHCs and aggregate data for all BHCs. We 
also reviewed the confidential April 24, 2009, and May 5, 2009, 
presentations that the SCAP regulators made to each of the 19 BHCs to 
identify estimates of preprovision net revenue (PPNR) and changes in 
allowance for loan and lease losses (ALLL) for the 2 years ended 2010. 
Our primary source for the actual results at the BHCs was the Federal 
Reserve's Y-9C. In doing so, we used the SNL Financial database to 
extract data on the Y-9C and the Securities and Exchange Commission 
forms 10-K and 10-Q. These data were collected following the close of 
the fourth quarter of 2009, the halfway point of the SCAP's 2-year 
time frame. 

Since losses were not estimated on a quarter-by-quarter or yearly 
basis but projected for the full 2-year period, we assumed that losses 
and revenue estimates under the more adverse scenario were distributed 
at a constant rate across the projection period. Thus, we compared the 
actual 2009 year end values with half of the Federal Reserve's 2-year 
SCAP projections. This methodology has some limitations because 
losses, expenses, revenues, and changes to reserves are historically 
unevenly distributed and loss rates over a 2-year period in an 
uncertain economic environment can follow an inconsistent path. 
However, the Federal Reserve, OCC, credit rating agencies, an SNL 
Financial analyst, and most of the BHCs we interviewed who are 
tracking performance relative to SCAP estimates are also using the 
same methodology. We assessed the reliability of the SNL Financial 
database by following GAO's best practices for data reliability and 
found that the data was sufficiently reliable for our purposes. 
[Footnote 67] To confirm the accuracy of our BHC tracking data, we 
shared our data with the Federal Reserve and the 19 SCAP BHCs. We 
received comments and incorporated them as appropriate. 

Some of the data that we collected were not in a form that was 
immediately comparable to the categories used in the SCAP results, and 
we had to make adjustments in order to make the comparison. For tier 1 
common capital, most asset categories, and resources other than 
capital to absorb losses, we had to find a methodology suited to 
aggregating these data so that we could compare it to the 
corresponding SCAP data. For example, net-charge offs for the various 
loan categories are broken out into more subcategories in the Y-9C 
than those listed in the SCAP results. In addition, we calculated 
"Resources Other than Capital to Absorb Losses" to correspond to the 
SCAP definition of PPNR minus the change in ALLL, which required 
obtaining data from multiple entries within the Y-9C. When calculating 
noninterest expense we removed the line item for goodwill impairment 
losses because this item was not included in the SCAP regulators' 
projections. We also used the calculation of a change in ALLL until 
December 31, 2009. But the SCAP regulators considered an increase in 
ALLL over the full 2-year period to be a drain on resources, because 
the provisions made to increase the ALLL balance would not be 
available to absorb losses during the 2-year SCAP time frame. This 
notion creates a problem in using the formula for 1-year tracking 
purposes because an increase in ALLL during 2009 would require 
provisions for that increase, but those added reserves could 
ultimately be used to absorb losses during 2010. To maintain 
consistency, our calculation considers ALLL increases during 2009 to 
be a drain on resources, but we recognize that this money could act as 
a resource to absorb losses rather than a drain on those resources. 

We faced an additional limitation pertaining to the ALLL calculation 
and a challenge with regard to the treatment of trading and 
counterparty revenues. In our review of SCAP documentation, we found 
that SCAP regulators used two different ALLL calculations--1 
calculation for 4 of the BHCs that included a reserve for off-balance 
sheet items and another for the remaining 15 BHCs that did not include 
off-balance sheet reserves. The Federal Reserve confirmed that there 
were two different calculations that were not adjusted for 
consistency. In order to be consistent across the BHCs, we applied the 
same methodology that the regulators used for 15 of the BHCs to the 4 
that remained. The treatment of trading and counterparty revenue 
created a challenge because the data in the Y-9C includes both 
customer derived revenue from transactions for BHCs that operate as 
broker-dealers and gains (or losses) from proprietary trading and 
certain associated expenses. These items are presented only in net 
form in the Y-9C. However, for the five BHCs (Bank of America 
Corporation; Citigroup, Inc.; Goldman Sachs Group, Inc.; JPMorgan 
Chase & Co.; and Morgan Stanley) that had their trading portfolios 
stressed, the trading and counterparty line is based on projections of 
gains (losses) from proprietary trading, but PPNR (specifically 
noninterest revenue) is based on gains from customer derived revenue 
from transactions for BHCs that operate as broker-dealers. Because we 
could not segregate these items based on the Y-9C, we have included 
the net amount in both the trading and counterparty and noninterest 
income line items. This means that the net amount of the trading gains 
or losses as reported in the Y-9C are included in two places in our 
tracking table for those five BHCs. For the remaining 14 BHCs, we 
included the entire line item in noninterest income, as that is where 
it was located in the SCAP projections. 

Table 6 shows the items we used to calculate tier 1 capital, asset 
losses, PPNR, and ALLL as of December 31, 2009 and the specific 
sources we used. We also included specific references to the sources 
we used. Some elements within the table required a more detailed 
aggregation or calculation and are therefore explained further in 
tables 7 and 8 below. For reporting these capital measures and asset 
balances for the year ending December 31, 2008, we generally relied on 
the figures published in various SCAP documents. 

Table 6: Items Used to Calculate Tier 1 Capital, Asset Losses, PPNR, 
and ALLL: 

Capital measure: Tier 1 capital; 
Actual at 12/31/09 and source: From line 11 ("tier 1 capital") of 
Schedule HC-R (page 40) of the FR Y-9C. 

Capital measure: Tier 1 common capital; 
Actual at 12/31/09 and source: See table 7. 

Capital measure: Risk-weighted assets; 
Actual at 12/31/09 and source: From line 62 ("total risk-weighted 
assets") of Schedule HC-R (page 43) of the FR Y-9C. 

Capital measure: Tier 1 risk-based ratio; 
Actual at 12/31/09 and source: Calculated as tier 1 capital divided by 
risk-weighted assets. 

Capital measure: Tier 1 common capital ratio; 
Actual at 12/31/09 and source: Calculated as tier 1 common capital 
divided by risk-weighted assets. 

Asset category[A]: First-lien mortgages; 
Actual at 12/31/09 and source: See table 8. 

Asset category[A]: Second/junior lien mortgages; 
Actual at 12/31/09 and source: See table 8. 

Asset category[A]: Commercial and industrial loans; 
Actual at 12/31/09 and source: See table 8. 

Asset category[A]: Commercial real estate loans; 
Actual at 12/31/09 and source: See table 8. 

Asset category[A]: Credit card loans; 
Actual at 12/31/09 and source: See table 8. 

Asset category[A]: Securities (available for sale and held to 
maturity); 
Actual at 12/31/09 and source: Calculated as: total of line 6a 
("realized gains (losses) on held-to-maturity securities") and line 6b 
("realized gains (losses) on available-for-sale securities") of 
Schedule HI (page 2) of the FR Y-9C. 

Asset category[A]: Trading and counterparty; 
Actual at 12/31/09 and source: For the 5 BHCs that had their trading 
and counterparty portfolio stressed: line 5c ("trading revenue") of 
Schedule HI (page 1) of the FR Y-9C. For all other BHCs, this line 
item was left blank. 

Asset category[A]: Other; 
Actual at 12/31/09 and source: See table 8. 

Asset category[A]: One-time items (included in "Other" in SCAP 
results); 
Actual at 12/31/09 and source: If one-time losses (gains) could be 
identified, they were located here and removed from the respective 
category above. This only applies to State Street Corporation. 

Resources other than capital to absorb losses (Total PPNR less change 
in ALLL)[B]: 

Preprovision net revenue (PPNR)[C]: Net interest income (expense); 
Actual at 12/31/09 and source: Line 3 ("net interest income") of 
Schedule HI (page 1) of the FR Y-9C. 

Preprovision net revenue (PPNR)[C]: Noninterest income; 
Actual at 12/31/09 and source: Line 5m ("total noninterest income") of 
Schedule HI (page 2) of the FR Y-9C. 

Preprovision net revenue (PPNR)[C]: Less noninterest expense; 
Actual at 12/31/09 and source: Calculated as: line 7e ("total 
noninterest expense") less Line 7c (1) ("goodwill impairment losses") 
of Schedule HI (page 2) of the FR Y-9C. 

Change in allowance for loan and lease losses (ALLL)[D]: ALLL at 
12/31/08; 
Actual at 12/31/09 and source: Line 1 ("balance most recently reported 
at the end of previous year") of Part II of the Schedule HI-B (page 7) 
of the 12/31/09 FR Y-9C. 

Change in allowance for loan and lease losses (ALLL)[D]: ALLL at 
12/31/09; 
Actual at 12/31/09 and source: Line 7 ("balance at end of current 
period") of Part II of the Schedule HI-B (page 7) of the 12/31/09 FRY-
9C. 

Source: GAO analysis of Federal Reserve 2009 Y-9C information. 

[A] Calculated as the total of the losses (gains) below. Categories 
that were n/a in the SCAP were included in this total. 

[B] Calculated as Total PPNR less the change in ALLL. 

[C] Calculated as net interest income (expense) plus noninterest 
income less noninterest expense. 

[D] Calculated as ALLL at 12/31/09 less ALLL at 12/31/08. 

[End of table] 

Table 7 shows our methodology for calculating tier 1 common capital, 
including the part of the Y-9C in which the data can be found. 
Currently, there is no defined regulatory method for calculating tier 
1 common capital, and it is not a required data field for BHCs to file 
in their Y-9C submissions. As a result, we developed a formula 
consistent with the Federal Reserve's by reviewing the guidance 
available in the SCAP design and implementation and SCAP results 
documents and consulting with SNL Financial regarding its methodology. 

Table 7: Tier 1 Common Capital Calculation: 

Location within the FR Y 9-C: Line 11 of Schedule HC-R (page 40); 
Tier 1 common capital calculation: Tier 1 capital. 

Location within the FR Y 9-C: Line 23 of Schedule HC (page 12); 
Tier 1 common capital calculation: Less: perpetual preferred stock and 
related surplus. 

Location within the FR Y 9-C: Line 6a of Schedule HC-R (page 40); 
Tier 1 common capital calculation: Less: qualifying Class A 
noncontrolling (minority) interests in consolidated subsidiaries. 

Location within the FR Y 9-C: Line 6b of Schedule HC-R (page 40); 
Tier 1 common capital calculation: Less: qualifying restricted core 
capital elements (other than cumulative perpetual preferred stock). 

Location within the FR Y 9-C: Line 6c of Schedule HC-R (page 40); 
Tier 1 common capital calculation: Less: qualifying mandatory 
convertible preferred securities of internationally active bank 
holding companies. 

Location within the FR Y 9-C: Line 1 of the "notes to the balance; 
sheet-other" (page 49); 
Tier 1 common capital calculation: Less: amount of excess restricted 
core capital elements included in Schedule HC-R, item 10. 

Location within the FR Y 9-C: Line 5 of Schedule HC-R (page 40); 
Tier 1 common capital calculation: Add: nonqualifying perpetual 
preferred stock. 

Tier 1 common capital calculation: Total = Tier 1 common capital. 

Source: Federal Reserve 2009 Y-9C documentation. 

[End of table] 

Table 8 provides a crosswalk for the asset classification we used to 
group the various charge-off categories listed in the Y-9C. 

Table 8: Crosswalk of Y-9C Net Charge-Offs and Asset Classifications 
to Classifications Used by SCAP: 

Y-9C classification: 1. Loans secured by real estate: a. Construction, 
land development, and other land loans in domestic offices: (1) One to 
four family residential construction loans; 
Classification used in GAO analysis: Overall category: Commercial real 
estate; 
Classification used in GAO analysis: Primary category: Commercial real 
estate; 
Classification used in GAO analysis: Sub-category: Construction. 

Y-9C classification: 1. Loans secured by real estate: a. Construction, 
land development, and other land loans in domestic offices: (2) Other 
construction loans and all land development and other land loans; 
Classification used in GAO analysis: Overall category: Commercial real 
estate; 
Classification used in GAO analysis: Primary category: Commercial real 
estate; 
Classification used in GAO analysis: Sub-category: Construction. 

Y-9C classification: 1. Loans secured by real estate: b. Secured by 
farmland in domestic offices; 
Classification used in GAO analysis: Overall category: Other; 
Classification used in GAO analysis: Primary category: Other loans; 
Classification used in GAO analysis: Sub-category: n/a. 

Y-9C classification: 1. Loans secured by real estate: c. Secured by 
one to four family residential properties in domestic offices: (1) 
Revolving, open-end loans secured by one to four family residential 
properties under lines of credit; 
Classification used in GAO analysis: Overall category: Second/junior 
lien; 
Classification used in GAO analysis: Primary category: Second/junior 
lien; 
Classification used in GAO analysis: Sub-category: Home equity line of 
credit. 

Y-9C classification: 1. Loans secured by real estate: c. Secured by 
one to four family residential properties in domestic offices: (2) 
Closed-end loans secured by one to four family residential properties 
in domestic offices: (a) Secured by first liens; 
Classification used in GAO analysis: Overall category: First lien; 
Classification used in GAO analysis: Primary category: First lien; 
Classification used in GAO analysis: Sub-category: n/a. 

Y-9C classification: 1. Loans secured by real estate: c. Secured by 
one to four family residential properties in domestic offices: (2) 
Closed-end loans secured by one to four family residential properties 
in domestic offices: (b) Secured by junior liens; 
Classification used in GAO analysis: Overall category: Second/junior 
lien; 
Classification used in GAO analysis: Primary category: Second/junior 
lien; 
Classification used in GAO analysis: Sub-category: Closed-end junior 
liens. 

Y-9C classification: 1. Loans secured by real estate: d. Secured by 
mutlifamily (five or more) residential properties in domestic offices; 
Classification used in GAO analysis: Overall category: Commercial real 
estate; 
Classification used in GAO analysis: Primary category: Commercial real 
estate; 
Classification used in GAO analysis: Sub-category: Multifamily. 

Y-9C classification: 1. Loans secured by real estate: e. Secured by 
nonfarm nonresidential properties in domestic offices: (1) Loans 
secured by owner-occupied nonfarm nonresidential properties; 
Classification used in GAO analysis: Overall category: Commercial real 
estate; 
Classification used in GAO analysis: Primary category: Commercial real 
estate; 
Classification used in GAO analysis: Sub-category: Nonfarm, 
nonresidential. 

Y-9C classification: 1. Loans secured by real estate: e. Secured by 
nonfarm nonresidential properties in domestic offices: ((2) Loans 
secured by other nonfarm nonresidential properties; 
Classification used in GAO analysis: Overall category: Commercial real 
estate; 
Classification used in GAO analysis: Primary category: Commercial real 
estate; 
Classification used in GAO analysis: Sub-category: Nonfarm, 
nonresidential. 

Y-9C classification: 1. Loans secured by real estate: f. In foreign 
offices; 
Classification used in GAO analysis: Overall category: Other; 
Classification used in GAO analysis: Primary category: Other loans; 
Classification used in GAO analysis: Sub-category: n/a. 

Y-9C classification: 2. Loans to depository institutions and 
acceptances of other banks: a. To U.S. banks and other U.S. depository 
institutions; 
Classification used in GAO analysis: Overall category: Other; 
Classification used in GAO analysis: Primary category: Other loans; 
Classification used in GAO analysis: Sub-category: n/a. 

Y-9C classification: 2. Loans to depository institutions and 
acceptances of other banks: b. To foreign banks; 
Classification used in GAO analysis: Overall category: Other; 
Classification used in GAO analysis: Primary category: Other loans; 
Classification used in GAO analysis: Sub-category: n/a. 

Y-9C classification: 3. Loans to finance agricultural production and 
other loans to farmers; 
Classification used in GAO analysis: Overall category: Other; 
Classification used in GAO analysis: Primary category: Other loans; 
Classification used in GAO analysis: Sub-category: n/a. 

Y-9C classification 4. Commercial and industrial loans: a. To U.S. 
addresses (domicile); 
Classification used in GAO analysis: Overall category: Commercial and 
industrial; 
Classification used in GAO analysis: Primary category: Commercial and 
industrial; 
Classification used in GAO analysis: Sub-category: n/a. 

Y-9C classification 4. Commercial and industrial loans: b. To non-U.S. 
addresses (domicile); 
Classification used in GAO analysis: Overall category: Commercial and 
industrial; 
Classification used in GAO analysis: Primary category: Commercial and 
industrial; 
Classification used in GAO analysis: Sub-category: n/a. 

Y-9C classification: 5. Loans to individuals for household, family, 
and other personal expenditures: a. Credit cards; 
Classification used in GAO analysis: Overall category: Credit cards; 
Classification used in GAO analysis: Primary category: Credit cards; 
Classification used in GAO analysis: Sub-category: n/a. 

Y-9C classification: 5. Loans to individuals for household, family, 
and other personal expenditures: b. Other (includes single payment, 
installment, all student loans, and revolving credit plans other than 
credit cards); 
Classification used in GAO analysis: Overall category: Other; 
Classification used in GAO analysis: Primary category: Other consumer; 
Classification used in GAO analysis: Sub-category: n/a. 

Y-9C classification: 6. Loans to foreign governments and official 
institutions; 
Classification used in GAO analysis: Overall category: Other; 
Classification used in GAO analysis: Primary category: Other loans; 
Classification used in GAO analysis: Sub-category: n/a. 

Y-9C classification: 7. All other loans; 
Classification used in GAO analysis: Overall category: Other; 
Classification used in GAO analysis: Primary category: Other loans; 
Classification used in GAO analysis: Sub-category: n/a. 

Y-9C classification: 8. Lease financing receivables: a. Leases to 
individuals for household, family, and other personal expenditures; 
Classification used in GAO analysis: Overall category: Other; 
Classification used in GAO analysis: Primary category: Other consumer; 
Classification used in GAO analysis: Sub-category: n/a. 

Y-9C classification: 8. Lease financing receivables: b. All other 
leases; 
Classification used in GAO analysis: Overall category: Other; 
Classification used in GAO analysis: Primary category: Other loans; 
Classification used in GAO analysis: Sub-category: n/a. 

Source: Federal Reserve 2009 Schedule HI-B of the Y-9C. 

Note: N/a means not applicable. 

[End of table] 

To ensure additional comparability with SCAP, we attempted to identify 
any unique circumstances that could skew the results. For example, 
after we shared our initial tracking estimates with the 19 BHCs, one 
BHC had identified an issue with our calculation of tier 1 common 
capital that resulted from the way information is reported on the Y-
9C. After discussing the issue with the BHC and verifying their 
explanation, we adjusted our calculation to more accurately reflect 
their position. Another BHC also had a one-time charge that had been 
included in the "Other" loss category, and we decided to segregate 
this item as a separate line item. We have also submitted our tracking 
spreadsheet to the Federal Reserve and to each BHC to give them an 
opportunity to provide input and ensure the accuracy and comparability 
of our numbers. Appropriate adjustments to 2009 numbers based on 
information received from the Federal Reserve and individual BHCs are 
noted, where applicable, in the tables in appendix III. 

Some items that impact precise comparisons between actual results and 
the pro rata estimates are disclosed in our footnotes, rather than as 
adjustments to our calculations. For example, the stress test was 
applied to loan and other asset portfolios as of December 31, 2008, 
without including a calculation for ongoing banking activities. 
Because the Y-9C data includes ongoing activity as of the date of the 
report, the actual results are slightly different than the performance 
of the stressed assets as the BHCs were treated as liquidating 
concerns rather than going concerns in the SCAP stress test. 
Distinguishing between the gains (losses) from legacy assets and those 
that resulted from new assets is not possible using public data. Other 
examples are that SCAP did not include the impact of the owned debt 
value adjustment or one-time items (occurring subsequent to SCAP) in 
their projections of PPNR.[Footnote 68] As credit default swap spreads 
narrowed in 2009,[Footnote 69] liability values increased at most 
banks, causing a negative impact on revenue at those banks that chose 
to account for their debt at fair value; but these losses were not 
included in the SCAP estimates. One-time items, such as sales of 
business lines, were also not included in the SCAP estimates of PPNR, 
as these events occurred subsequent to the stress test and, in part, 
could not be fully predicted as a part of SCAP. Rather than remove the 
losses from the owned debt value adjustments and the gains (or losses) 
due to one-time items from the BHCs' 2009 PPNR results, we disclosed 
the amounts in footnotes for the applicable BHCs. We chose this 
treatment so that PPNR would reflect actual results at the BHCs, while 
still disclosing the adjustments needed for more precise comparability 
to SCAP. 

We identified the TARP status of each of the 19 BHCs that participated 
in SCAP by reviewing data from the Treasury's Office of Financial 
Stability's TARP Transactions Report for the Period Ending September 
22, 2010 (TARP Transactions Report) and the SCAP results document. We 
used the SCAP results document to identify BHCs that were required to 
raise capital. The TARP Transactions Report, was then used to identify 
the program under which TARP funds were received (if any), the amount 
of funds received, capital repayment date, amount repaid, and warrant 
disposition date and to determine whether the warrants were 
repurchased or sold by Treasury in a public offering. 

To gain a better understanding of future potential losses, we 
determined the percentage of BHCs' total loans that are either 
nonaccrual or more than 90 days past due using Y-9C data from the SNL 
Financial database.[Footnote 70] We used quarterly data for the period 
2007 through 2009 on nonaccrual loans and past due balances of more 
than 90 days, for each of the BHCs. We aggregated the data into the 
same six loan categories used in SCAP: first-lien mortgages, second/ 
junior-lien mortgages, commercial and industrial loans, commercial 
real estate loans, credit card balances, and "Other." (See tables 8 
and 9 for details.) Once the data were aggregated, we divided that 
data by the applicable total loan balance for each category at each 
point in time (i.e., quarterly basis). One limitation is that Y-9C 
data were not available for all periods for four of the BHCs (American 
Express Company; GMAC LLC; The Goldman Sachs Group, Inc.; and Morgan 
Stanley) because they had recently became BHCs.[Footnote 71] As a 
result, we did not include these BHCs in the calculation during those 
periods where their Y-9Cs were not available (fourth quarter of 2008 
and earlier for all except GMAC LLC, which also did not have a Y-9C in 
the first quarter of 2009). 

We collected Y-9C data from the SNL Financial database to calculate 
the loan loss rates across BHCs with more than $1 billion of assets 
and compare the 19 BHCs with the indicative loss rates provided by the 
SCAP regulators. We used annual data for the year ended December 31, 
2009, on loan charge-offs. We also used average total loan balances. 
In the Y-9C total loan balances were categorized somewhat differently 
from charge-offs. Table 9 provides a crosswalk for the asset 
classification. We aggregated loan balance data into the same 
categories that were used in the indicative loss rate table in SCAP: 
first-lien mortgages, prime mortgages, Alt-A mortgages, subprime 
mortgages, second/junior lien mortgages, closed-end junior liens, home 
equity lines of credit, commercial and industrial loans, commercial 
real estate loans, construction loans, multifamily loans, nonfarm 
nonresidential loans, credit card balances, other consumer, and other 
loans. Once the data were aggregated into these categories, we divided 
the net charge-offs by the applicable average loan balance. This 
calculation showed the loss rate for each category (e.g., first-lien 
mortgages and commercial real estate) for the year ended December 31, 
2009. This methodology was applied to calculate the loss rates for the 
19 SCAP BHCs and all BHCs with more than $1 billion of assets, 
respectively. Because those institutions had recently converted to 
being BHCs, Y-9C data on loan balances was not available for the 
fourth quarter of 2008 for American Express Company; The Goldman Sachs 
Group, Inc.; and Morgan Stanley, and was not available for GMAC LLC 
for both the first quarter of 2009 and the fourth quarter of 2008. 
Therefore, we approximated the loan balances in these periods for GMAC 
LLC and American Express Company based on their Form 10-Q for these 
time periods. Because The Goldman Sachs Group, Inc. and Morgan Stanley 
have considerably smaller loan balances, in general, than the other 
BHCs; the fourth quarter of 2008 balance was not approximated for 
these BHCs. Instead, the average loan balance was simply based on the 
available data (e.g., first quarter of 2009 through fourth quarter of 
2009). 

Table 9: Crosswalk of Y-9C Loans and Lease Financing Receivables to 
and Classifications used by SCAP: 

Y-9C classification: 1. Loans secured by real estate: a. Construction, 
land development, and other land loans in domestic offices: (1) One to 
four family residential construction loans; 
Classification used in GAO analysis: Overall category: Commercial real 
estate; 
Classification used in GAO analysis: Primary category: Commercial real 
estate; 
Classification used in GAO analysis: Sub-category: Construction. 

Y-9C classification: 1. Loans secured by real estate: a. Construction, 
land development, and other land loans in domestic offices: (2) Other 
construction loans and all land development and other land loans; 
Classification used in GAO analysis: Overall category: Commercial real 
estate; 
Classification used in GAO analysis: Primary category: Commercial real 
estate; 
Classification used in GAO analysis: Sub-category: Construction. 

Y-9C classification: 1. Loans secured by real estate: b. Secured by 
farmland; 
Classification used in GAO analysis: Overall category: Other; 
Classification used in GAO analysis: Primary category: Other loans; 
Classification used in GAO analysis: Sub-category: n/a. 

Y-9C classification: 1. Loans secured by real estate: c. Secured by 
one to four family residential properties: (1) Revolving, open-end 
loans secured by one to four family residential properties and 
extended under lines of credit; 
Classification used in GAO analysis: Overall category: Second/junior 
lien; 
Classification used in GAO analysis: Primary category: Second/junior 
lien; 
Classification used in GAO analysis: Sub-category: Home equity lines 
of credit. 

Y-9C classification: 1. Loans secured by real estate: c. Secured by 
one to four family residential properties: (2) Closed-end loans 
secured by one to four family residential properties: (a) Secured by 
first liens; 
Classification used in GAO analysis: Overall category: First lien; 
Classification used in GAO analysis: Primary category: First lien; 
Classification used in GAO analysis: Sub-category: n/a. 

Y-9C classification: 1. Loans secured by real estate: c. Secured by 
one to four family residential properties: (2) Closed-end loans 
secured by one to four family residential properties: (b) Secured by 
junior liens; 
Classification used in GAO analysis: Overall category: Second/junior 
lien; 
Classification used in GAO analysis: Primary category: Second/junior 
lien; 
Classification used in GAO analysis: Sub-category: Closed-end junior 
liens. 

Y-9C classification: 1. Loans secured by real estate: d. Secured by 
mutlifamily (five or more) residential properties; 
Classification used in GAO analysis: Overall category: Commercial real 
estate; 
Classification used in GAO analysis: Primary category: Commercial real 
estate; 
Classification used in GAO analysis: Sub-category: Multifamily. 

Y-9C classification: 1. Loans secured by real estate: e. Secured by 
nonfarm nonresidential properties: (1) Loans secured by owner-occupied 
nonfarm nonresidential properties; 
Classification used in GAO analysis: Overall category: Commercial real 
estate; 
Classification used in GAO analysis: Primary category: Commercial real 
estate; 
Classification used in GAO analysis: Sub-category: Nonfarm, 
nonresidential. 

Y-9C classification: 1. Loans secured by real estate: e. Secured by 
nonfarm nonresidential properties: (2) Loans secured by other nonfarm 
nonresidential properties; 
Classification used in GAO analysis: Overall category: Commercial real 
estate; 
Classification used in GAO analysis: Primary category: Commercial real 
estate; 
Classification used in GAO analysis: Sub-category: Nonfarm, 
nonresidential. 

Y-9C classification: 2. Loans to depository institutions and 
acceptances of other banks: a. To U.S. banks and other U.S. depository 
institutions; 
Classification used in GAO analysis: Overall category: Other; 
Classification used in GAO analysis: Primary category: Other loans; 
Classification used in GAO analysis: Sub-category: n/a. 

Y-9C classification: 2. Loans to depository institutions and 
acceptances of other banks: b. To foreign banks; 
Classification used in GAO analysis: Overall category: Other; 
Classification used in GAO analysis: Primary category: Other loans; 
Classification used in GAO analysis: Sub-category: n/a. 

Y-9C classification: 3. Loans to finance agricultural production and 
other loans to farmers; 
Classification used in GAO analysis: Overall category: Other; 
Classification used in GAO analysis: Primary category: Other loans; 
Classification used in GAO analysis: Sub-category: n/a. 

Y-9C classification: 4. Commercial and industrial loans: a. To U.S. 
addresses (domicile); 
Classification used in GAO analysis: Overall category: Commercial and 
industrial; 
Classification used in GAO analysis: Primary category: Commercial and 
industrial; 
Classification used in GAO analysis: Sub-category: n/a. 

Y-9C classification: 4. Commercial and industrial loans: b. To non-
U.S. addresses (domicile); 
Classification used in GAO analysis: Overall category: Commercial and 
industrial; 
Classification used in GAO analysis: Primary category: Commercial and 
industrial; 
Classification used in GAO analysis: Sub-category: n/a. 

Y-9C classification: 6. Loans to individuals for household, family, 
and other personal expenditures: a. Credit cards; 
Classification used in GAO analysis: Overall category: Credit cards; 
Classification used in GAO analysis: Primary category: Credit cards; 
Classification used in GAO analysis: Sub-category: n/a. 

Y-9C classification: 6. Loans to individuals for household, family, 
and other personal expenditures: b. Other revolving credit plans; 
Classification used in GAO analysis: Overall category: Other; 
Classification used in GAO analysis: Primary category: Other consumer; 
Classification used in GAO analysis: Sub-category: n/a. 

Y-9C classification: 6. Loans to individuals for household, family, 
and other personal expenditures: c. Other consumer (includes single 
payment, installment, and all student loans); 
Classification used in GAO analysis: Overall category: Other; 
Classification used in GAO analysis: Primary category: Other consumer; 
Classification used in GAO analysis: Sub-category: n/a. 

Y-9C classification: 7. Loans to foreign governments and official 
institutions (including foreign central banks); 
Classification used in GAO analysis: Overall category: Other; 
Classification used in GAO analysis: Primary category: Other loans; 
Classification used in GAO analysis: Sub-category: n/a. 

Y-9C classification: 9. a. Loans for purchasing and carrying 
securities (secured and unsecured); 
Classification used in GAO analysis: Overall category: Other; 
Classification used in GAO analysis: Primary category: Other loans; 
Classification used in GAO analysis: Sub-category: n/a. 

Y-9C classification: 9. b. All other loans; 
Classification used in GAO analysis: Overall category: Other; 
Classification used in GAO analysis: Primary category: Other loans; 
Classification used in GAO analysis: Sub-category: n/a. 

Y-9C classification: 10. Lease financing receivables (net of unearned 
income): a. Leases to individuals for household, family, and other 
personal expenditures; 
Classification used in GAO analysis: Overall category: Other; 
Classification used in GAO analysis: Primary category: Other consumer; 
Classification used in GAO analysis: Sub-category: n/a. 

Y-9C classification: 10. Lease financing receivables (net of unearned 
income): b. All other leases; 
Classification used in GAO analysis: Overall category: Other; 
Classification used in GAO analysis: Primary category: Other loans; 
Classification used in GAO analysis: Sub-category: n/a. 

Y-9C classification: 11. Less: Any unearned income on loans reflected 
in items 1-9 above; 
Classification used in GAO analysis: Overall category: [A]; 
Classification used in GAO analysis: Primary category: [A]; 
Classification used in GAO analysis: Sub-category: [A]. 

Source: Federal Reserve 2009 Schedule HC-C of the Y-9C. 

Notes: Foreign office real estate was also included in our calculation 
of the total loans, but is not distinguishable in the table above. We 
pulled it directly from the SNL Financial database. This amount 
equates to the difference, in Schedule HC-C, between line item 1 for 
the "Consolidated" and "In Domestic Offices" columns (these columns 
are not depicted above). The classification of these loans in our 
calculations was as "Other" and the primary category was "Other loans." 

N/a means not applicable. 

[A] For calculations for the 19 SCAP BHCs, unearned income was 
distributed to all loan balances based on the percent that each line 
item represented of total loans for that BHC (excludes lease financing 
receivables). For calculations for all BHCs with total assets greater 
than $1 billion, unearned income was distributed to the aggregate 
balances for each line item based on the respective percentage that 
each balance represented of the total. 

[End of table] 

We conducted this performance audit from August 2009 to September 2010 
in accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

[End of section] 

Appendix II: Status of Bank Holding Companies' TARP Investments as 
September 22, 2010: 

Twelve of the 19 bank holding companies (BHC) that participated in the 
Supervisory Capital Assessment Program (SCAP) had redeemed their 
Troubled Asset Relief Program (TARP) investments and had their 
warrants disposed of as of September 22, 2010, and most of them were 
not required to raise capital under SCAP (table 10). Six of the 19 
BHCs tested under SCAP have not repaid TARP investments or disposed of 
warrants, and one, MetLife, Inc., did not receive any TARP 
investments. BHCs participating in SCAP must follow specific criteria 
to repay TARP funds. In approving applications from participating 
banks that want to repay TARP funds, the Federal Reserve considers 
various factors. Some of these factors[Footnote 72] include whether 
the banks can demonstrate an ability to access the long-term debt 
market without relying on the Federal Deposit Insurance Corporation's 
(FDIC) Temporary Liquidity Guarantee Program and whether they can 
successfully access the public equity markets, remain in a position to 
facilitate lending, and maintain capital levels in accord with 
supervisory expectations.[Footnote 73] BHCs intending to repay TARP 
investments must have post repayment capital ratios that meet or 
exceed SCAP requirements. 

Table 10: Status of TARP Investments for the 19 BHCs Participating in 
SCAP, as of September 22, 2010: 

BHC that was not a recipient of TARP funding: 

Bank holding company: MetLife, Inc.; 
Required to raise capital under SCAP?: No; 
Type of TARP received: n/a; 
Capital amount received: n/a; 
Capital repayment date: n/a; 
Capital amount repaid: n/a; 
Warrant disposition date: n/a; 
Warrants repurchased (R) or sold via auction (A)?[A]: n/a. 

BHCs that were recipients of TARP funding and have exited TARP: 

Bank holding company: American Express Company; 
Required to raise capital under SCAP?: No; 
Type of TARP received: CPP[B]; 
Capital amount received: $3.4 billion; 
Capital repayment date: 06/17/09; 
Capital amount repaid: $3.4 billion; 
Warrant disposition date: 07/29/09; 
Warrants repurchased (R) or sold via auction (A)?[A]: R. 

Bank holding company: Bank of America Corporation; 
Required to raise capital under SCAP?: Yes; 
Type of TARP received: CPP; 
Capital amount received: $25.0 billion; 
Capital repayment date: 12/09/09; 
Capital amount repaid: $25.0 billion; 
Warrant disposition date: 03/03/10; 
Warrants repurchased (R) or sold via auction (A)?[A]: A. 

Bank holding company: Bank of America Corporation; 
Required to raise capital under SCAP?: BHC that was not a recipient of 
TARP funding: Yes; 
Type of TARP received: TIP[C]; 
Capital amount received: $20.0 billion; 
Capital repayment date: 12/09/09; 
Capital amount repaid: $20.0 billion; 
Warrant disposition date: 03/03/10; 
Warrants repurchased (R) or sold via auction (A)?[A]: A. 

Bank holding company: BB&T Corporation; 
Required to raise capital under SCAP?: No; 
Type of TARP received: CPP; 
Capital amount received: $3.1 billion; 
Capital repayment date: 06/17/09; 
Capital amount repaid: $3.1 billion; 
Warrant disposition date: 07/22/09; 
Warrants repurchased (R) or sold via auction (A)?[A]: R. 

Bank holding company: The Bank of New York Mellon Corporation; 
Required to raise capital under SCAP?: No; 
Type of TARP received: CPP; 
Capital amount received: $3.0 billion; 
Capital repayment date: 06/17/09; 
Capital amount repaid: $3.0 billion; 
Warrant disposition date: 08/05/09; 
Warrants repurchased (R) or sold via auction (A)?[A]: R. 

Bank holding company: Capital One Financial Corporation; 
Required to raise capital under SCAP?: No; 
Type of TARP received: CPP; 
Capital amount received: $3.6 billion; 
Capital repayment date: 06/17/09; 
Capital amount repaid: $3.6 billion; 
Warrant disposition date: 12/03/09; 
Warrants repurchased (R) or sold via auction (A)?[A]: A. 

Bank holding company: The Goldman Sachs Group, Inc.; 
Required to raise capital under SCAP?: No; 
Type of TARP received: CPP; 
Capital amount received: $10.0 billion; 
Capital repayment date: 06/17/09; 
Capital amount repaid: $10.0 billion; 
Warrant disposition date: 07/22/09; 
Warrants repurchased (R) or sold via auction (A)?[A]: R. 

Bank holding company: JPMorgan Chase & Co.; 
Required to raise capital under SCAP?: No; 
Type of TARP received: CPP; 
Capital amount received: $25.0 billion; 
Capital repayment date: 06/17/09; 
Capital amount repaid: $25.0 billion; 
Warrant disposition date: 12/10/09; 
Warrants repurchased (R) or sold via auction (A)?[A]: A. 

Bank holding company: Morgan Stanley; 
Required to raise capital under SCAP?: Yes; 
Type of TARP received: CPP; 
Capital amount received: $10.0 billion; 
Capital repayment date: 06/17/09; 
Capital amount repaid: $10.0 billion; 
Warrant disposition date: 08/12/09; 
Warrants repurchased (R) or sold via auction (A)?[A]: R. 

Bank holding company: PNC Financial Services Group, Inc; 
Required to raise capital under SCAP?: Yes; 
Type of TARP received: CPP; 
Capital amount received: $7.6 billion; 
Capital repayment date: 02/02/10; 
Capital amount repaid: $7.6 billion; 
Warrant disposition date: 04/29/10; 
Warrants repurchased (R) or sold via auction (A)?[A]: A. 

Bank holding company: State Street Corporation; 
Required to raise capital under SCAP?: No; 
Type of TARP received: CPP; 
Capital amount received: $2.0 billion; 
Capital repayment date: 06/17/09; 
Capital amount repaid: $2.0 billion; 
Warrant disposition date: 07/08/09; 
Warrants repurchased (R) or sold via auction (A)?[A]: R. 

Bank holding company: U.S. Bancorp; 
Required to raise capital under SCAP?: No; 
Type of TARP received: CPP; 
Capital amount received: $6.6 billion; 
Capital repayment date: 06/17/09; 
Capital amount repaid: $6.6 billion; 
Warrant disposition date: 07/15/09; 
Warrants repurchased (R) or sold via auction (A)?[A]: R. 

Bank holding company: Wells Fargo & Company; 
Required to raise capital under SCAP?: Yes; 
Type of TARP received: CPP; 
Capital amount received: $25.0 billion; 
Capital repayment date: 12/23/09; 
Capital amount repaid: $25.0 billion; 
Warrant disposition date: 05/21/10; 
Warrants repurchased (R) or sold via auction (A)?[A]: A. 

BHCs that have not fully repaid TARP funding or disposed of warrants: 

Bank holding company: Citigroup Inc.[D]; 
Required to raise capital under SCAP?: Yes; 
Type of TARP received: CPP; 
Capital amount received: $25.0 billion; 
Capital repayment date: [Empty];
Capital amount repaid: [Empty];
Warrant disposition date: [Empty];
Warrants repurchased (R) or sold via auction (A)?[A]: [Empty]. 

Bank holding company: Citigroup Inc.[D]; 
Required to raise capital under SCAP?: Yes; 
Type of TARP received: TIP; 
Capital amount received: $20.0 billion; 
Capital repayment date: 12/23/09; 
Capital amount repaid: $20.0 billion; 
Warrant disposition date: [Empty]; 
Warrants repurchased (R) or sold via auction (A)?[A]: [Empty]. 

Bank holding company: Fifth Third Bancorp; 
Required to raise capital under SCAP?: Yes; 
Type of TARP received: CPP; 
Capital amount received: $3.4 billion; 
Capital repayment date: [Empty]; 
Capital amount repaid: [Empty]; 
Warrant disposition date: [Empty]; 
Warrants repurchased (R) or sold via auction (A)?[A]: [Empty]. 

Bank holding company: GMAC LLC[E]; 
Required to raise capital under SCAP?: Yes; 
Type of TARP received: AIFP; 
Capital amount received: $16.3 billion; 
Capital repayment date: [Empty]; 
Capital amount repaid: [Empty]; 
Warrant disposition date: [Empty]; 
Warrants repurchased (R) or sold via auction (A)?[A]: [Empty]. 

Bank holding company: KeyCorp; 
Required to raise capital under SCAP?: Yes; 
Type of TARP received: CPP; 
Capital amount received: $2.5 billion; 
Capital repayment date: [Empty]; 
Capital amount repaid: [Empty]; 
Warrant disposition date: [Empty]; 
Warrants repurchased (R) or sold via auction (A)?[A]: [Empty]. 

Bank holding company: Regions Financial Corporation; 
Required to raise capital under SCAP?: Yes; 
Type of TARP received: CPP; 
Capital amount received: $3.5 billion; 
Capital repayment date: [Empty]; 
Capital amount repaid: [Empty]; 
Warrant disposition date: [Empty]; 
Warrants repurchased (R) or sold via auction (A)?[A]: [Empty]. 

Bank holding company: SunTrust Banks, Inc.; 
Required to raise capital under SCAP?: Yes; 
Type of TARP received: CPP; 
Capital amount received: $4.9 billion; 
Capital repayment date: [Empty]; 
Capital amount repaid: [Empty]; 
Warrant disposition date: [Empty]; 
Warrants repurchased (R) or sold via auction (A)?[A]: [Empty]. 

Sources: Federal Reserve's SCAP results document and Treasury's TARP 
Transactions Report for the Period Ending September XX, 2010. 

Note: N/a means not applicable since MetLife, Inc. did not receive any 
TARP funding. 

[A] "R" indicates that the warrants were repurchased by the financial 
institution via negotiations with Treasury. "A" indicates that 
Treasury sold the warrants in a registered public auction. 

[B] The Capital Purchase Program (CPP) is a program in which Treasury 
invests in preferred securities issued by qualified financial 
institutions. 

[C] Treasury created the Targeted Investment Program (TIP) to 
stabilize the financial system by making investments in institutions 
that are determined to be critical to the functioning of the financial 
system. 

[D] As part of an exchange offer designed to strengthen Citigroup 
Inc.'s capital, in June 2009, Treasury agreed to exchange its $25 
billion of CPP preferred stock in Citigroup for 7.7 billion shares of 
Citigroup Inc. common stock at a price of $3.25 per common share. In 
May 2010, Treasury sold 1.5 billion of its 7.7 billion common shares. 
In June 2010, Treasury sold 1.1 billion shares and has a remaining 
ownership of 5.1 billion common shares. 

[E] On June 30, 2009, GMAC LLC changed its corporate structure and 
became GMAC Inc., and on May 10, 2010, GMAC Inc. changed its name to 
Ally Financial Inc. 

[End of table] 

[End of section] 

Appendix III: One-Year Actual Performance Compared to GAO's Pro rata 
Stress Test Loss Projections for Each of the 19 SCAP BHCs: 

[End of section] 

Table 11 shows the names, location, and total assets as of December 
31, 2008, of the 19 bank holding companies (BHC) subject to the 
Supervisory Capital Assessment Program (SCAP) stress test that was 
conducted by the federal bank regulators in the spring of 2009. The 
stress test was a forward-looking exercise intended to help federal 
banking regulators gauge the extent of the additional capital buffer 
necessary to keep the BHCs strongly capitalized and lending even if 
economic conditions are worse than had been expected between December 
2008 and December 2010. 

Table 11: Identification of 19 BHCs Subject to the Stress Test: 

Dollars in thousands: 

Table number: 12; 
Name of bank holding company: American Express Company; 
Location of headquarters: New York, NY; 
Total assets as of December 31, 2008: $126,074,000. 

Table number: 13; 
Name of bank holding company: Bank of America Corporation; 
Location of headquarters: Charlotte, NC; 
Total assets as of December 31, 2008: $1,817,943,000. 

Table number: 14; 
Name of bank holding company: BB&T Corporation; 
Location of headquarters: Winston-Salem, NC; 
Total assets as of December 31, 2008: $152,015,000. 

Table number: 15; 
Name of bank holding company: The Bank of New York Mellon Corporation; 
Location of headquarters: New York, NY; 
Total assets as of December 31, 2008: $237,512,000. 

Table number: 16; 
Name of bank holding company: Capital One Financial Corporation; 
Location of headquarters: McLean, VA; 
Total assets as of December 31, 2008: $165,913,452. 

Table number: 17; 
Name of bank holding company: Citigroup Inc.; 
Location of headquarters: New York, NY; 
Total assets as of December 31, 2008: $1,938,470,000. 

Table number: 18; 
Name of bank holding company: Fifth Third Bancorp; 
Location of headquarters: Cincinnati, OH; 
Total assets as of December 31, 2008: $119,764,000. 

Table number: 19; 
Name of bank holding company: GMAC LLC; 
Location of headquarters: Detroit, MI; 
Total assets as of December 31, 2008: $189,476,000. 

Table number: 20; 
Name of bank holding company: The Goldman Sachs Group, Inc.; 
Location of headquarters: New York, NY; 
Total assets as of December 31, 2008: $884,547,000. 

Table number: 21; 
Name of bank holding company: JPMorgan Chase & Co.; 
Location of headquarters: New York, NY; 
Total assets as of December 31, 2008: $2,175,052,000. 

Table number: 22; 
Name of bank holding company: KeyCorp; 
Location of headquarters: Cleveland, OH; 
Total assets as of December 31, 2008: $104,531,000. 

Table number: 23; 
Name of bank holding company: MetLife, Inc.; 
Location of headquarters: New York, NY; 
Total assets as of December 31, 2008: $501,678,000. 

Table number: 24; 
Name of bank holding company: Morgan Stanley; 
Location of headquarters: New York, NY; 
Total assets as of December 31, 2008: $676,764,000. 

Table number: 25; 
Name of bank holding company: PNC Financial Services Group, Inc.; 
Location of headquarters: Pittsburgh, PA; 
Total assets as of December 31, 2008: $291,081,000. 

Table number: 26; 
Name of bank holding company: Regions Financial Corporation; 
Location of headquarters: Birmingham, AL; 
Total assets as of December 31, 2008: $146,247,810. 

Table number: 27; 
Name of bank holding company: State Street Corporation; 
Location of headquarters: Boston, MA; 
Total assets as of December 31, 2008: $173,631,000. 

Table number: 28; 
Name of bank holding company: SunTrust Banks, Inc.; 
Location of headquarters: Atlanta, GA; 
Total assets as of December 31, 2008: $189,137,961. 

Table number: 29; 
Name of bank holding company: U.S. Bancorp; 
Location of headquarters: Minneapolis, MN; 
Total assets as of December 31, 2008: $265,912,000. 

Table number: 30; 
Name of bank holding company: Wells Fargo & Company; 
Location of headquarters: San Francisco, CA; 
Total assets as of December 31, 2008: $1,309,639,000. 

Source: GAO. 

The following tables (12 through 30) compare the 2009 performance of 
the 19 BHCs involved in SCAP to the 2-year SCAP estimates and the GAO 
1-year pro rata estimates for the more adverse economic scenario. 
Specifically, these tables include comparison of actual and estimates 
of losses and gains associated with loans, securities, trading and 
counterparty, resources, preprovision net revenue (PPNR), and 
allowance for loan and lease losses (ALLL). These tables also include 
a comparison of actual capital levels at December 31, 2009, and 
December 31, 2008. Totals may not add due to rounding. For a more 
detailed explanation of the calculations made in constructing this 
analysis, see appendix I. 

[End of table] 

Table 12: American Express Company: 

Tier 1 capital; 
Actual at 12/31/09: $11.5 billion; 
12/31/08 balance per SCAP: $10.1 billion; 
Difference: $1.4 billion; 
12/31/09 as a percent of the 12/31/08 balance: 113.5%. 

Tier 1 common capital; 
Actual at 12/31/09: $11.5 billion; 
12/31/08 balance per SCAP: $10.1 billion; 
Difference: $1.4 billion; 
12/31/09 as a percent of the 12/31/08 balance: 113.5%. 

Risk-weighted assets; 
Actual at 12/31/09: $116.6 billion; 
12/31/08 balance per SCAP: $104.4 billion; 
Difference: $12.2 billion; 
12/31/09 as a percent of the 12/31/08 balance: 111.6%. 

Tier 1 risk-based ratio; 
Actual at 12/31/09: 9.8%; 
12/31/08 balance per SCAP: 9.7%; 
Difference: 0.1%; 
12/31/09 as a percent of the 12/31/08 balance: 101.4%. 

Tier 1 common capital ratio; 
Actual at 12/31/09: 9.8%; 
12/31/08 balance per SCAP: 9.7%; 
Difference: 0.1%; 
12/31/09 as a percent of the 12/31/08 balance: 101.4%. 

Total asset losses; 
Actual for year ended 12/31/09: $4.4 billion; 
2-year SCAP estimate: $11.2 billion; 
GAO 1-year pro rate estimate: $5.6 billion; 
Difference: ($1.2 billion); 
Actual as a percent of the 12/31/08 balance: 78.0%. 

Total asset losses: First-lien mortgages; 
Actual for year ended 12/31/09: 0.0; 
2-year SCAP estimate: n/a; 
GAO 1-year pro rate estimate: n/a; 
Difference: n/a; 
Actual as a percent of the 12/31/08 balance: n/a. 

Total asset losses: Second/junior lien mortgages; 
Actual for year ended 12/31/09: 0.0; 
2-year SCAP estimate: n/a; 
GAO 1-year pro rate estimate: n/a; 
Difference: n/a; 
Actual as a percent of the 12/31/08 balance: n/a. 

Total asset losses: Commercial and industrial loans; 
Actual for year ended 12/31/09: 0.0; 
2-year SCAP estimate: n/a; 
GAO 1-year pro rate estimate: n/a; 
Difference: n/a; 
Actual as a percent of the 12/31/08 balance: n/a. 

Total asset losses: Commercial real estate loans; 
Actual for year ended 12/31/09: 0.0; 
2-year SCAP estimate: n/a; 
GAO 1-year pro rate estimate: n/a; 
Difference: n/a; 
Actual as a percent of the 12/31/08 balance: n/a. 

Total asset losses: Credit card loans; 
Actual for year ended 12/31/09: $3.4 billion; 
2-year SCAP estimate: $8.5 billion; 
GAO 1-year pro rate estimate: $4.3 billion; 
Difference: ($0.9 billion); 
Actual as a percent of the 12/31/08 balance: 79.9%. 

Total asset losses: Securities (available for sale and held to 
maturity); 
Actual for year ended 12/31/09: ($0.2 billion); 
2-year SCAP estimate: n/a; 
GAO 1-year pro rate estimate: n/a; 
Difference: n/a; 
Actual as a percent of the 12/31/08 balance: n/a. 

Total asset losses: Trading and counterparty; 
Actual for year ended 12/31/09: [A]; 
2-year SCAP estimate: n/a; 
GAO 1-year pro rate estimate: n/a; 
Difference: n/a; 
Actual as a percent of the 12/31/08 balance: n/a. 

Total asset losses: Other; 
Actual for year ended 12/31/09: $1.2 billion; 
2-year SCAP estimate: $2.7 billion; 
GAO 1-year pro rate estimate: $1.4 billion; 
Difference: ($0.2 billion); 
Actual as a percent of the 12/31/08 balance: 88.0%. 

Resources other than capital to absorb losses (Total PPNR less change 
in ALLL); 
Actual for year ended 12/31/09: $7.4 billion; 
2-year SCAP estimate: $11.9 billion; 
GAO 1-year pro rate estimate: $6.0 billion; 
Difference: $1.4 billion; 
Actual as a percent of the 12/31/08 balance: 123.8%. 

PPNR; 
Actual for year ended 12/31/09: $7.8 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Net interest income (expense); 
Actual for year ended 12/31/09: $5.3 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Noninterest income; 
Actual for year ended 12/31/09: $19.0 billion[A]; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Less: noninterest expense; 
Actual for year ended 12/31/09: $16.5 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL); 
Actual for year ended 12/31/09: $0.4 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL): ALLL at 12/31/08; 
Actual for year ended 12/31/09: $3.4 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL): ALLL at 12/31/09; 
Actual for year ended 12/31/09: $3.8 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Source: GAO analysis of Federal Reserve and SNL Financial data. 

Note: N/a means not applicable. 

[A] Trading and counterparty positions were not stressed because the 
total portfolio is less than the $100 billion required for stress 
testing in SCAP, but trading (gain) loss information for this BHC was 
included in the "trading revenue" line of Schedule HI of the Y-9C in 
2009. In SCAP, the projections of trading gains or losses for this BHC 
were included in the estimate of PPNR rather than the trading and 
counterparty line. Therefore, we have included the actual trading 
results in PPNR (specifically noninterest income). 

[End of table] 

Table 13: Bank of America Corporation: 

Tier 1 capital; 
Actual at 12/31/09: $160.6 billion; 
12/31/08 balance per SCAP: $173.2 billion; 
Difference: ($12.6) billion; 
12/31/09 as a percent of the 12/31/08 balance: 92.7%. 

Tier 1 common capital; 
Actual at 12/31/09: $120.6[A] billion; 
12/31/08 balance per SCAP: $74.5 billion; 
Difference: $46.1 billion; 
12/31/09 as a percent of the 12/31/08 balance: 161.9%. 

Risk-weighted assets; 
Actual at 12/31/09: $1,541.6 billion; 
12/31/08 balance per SCAP: $1,633.8 billion; 
Difference: ($92.2) billion; 
12/31/09 as a percent of the 12/31/08 balance: 94.4%. 

Tier 1 risk-based ratio; 
Actual at 12/31/09: 10.4%; 
12/31/08 balance per SCAP: 10.6%; 
Difference: (0.2%); 
12/31/09 as a percent of the 12/31/08 balance: 98.3%. 

Tier 1 common capital ratio; 
Actual at 12/31/09: 7.8%; 
12/31/08 balance per SCAP: 4.6%; 
Difference: 3.2%; 
12/31/09 as a percent of the 12/31/08 balance: 170.1%. 

Total asset losses; 
Actual for year ended 12/31/09: $12.3 billion; 
2-year SCAP estimate: $136.6 billion; 
GAO 1-year pro rate estimate: $68.4 billion; 
Difference: ($56.0 billion); 
Actual as a percent of the 12/31/08 balance: 18.1%. 

Total asset losses: First-lien mortgages; 
Actual for year ended 12/31/09: $3.6 billion; 
2-year SCAP estimate: $22.1 billion; 
GAO 1-year pro rate estimate: $11.1 billion; 
Difference: ($7.5 billion); 
Actual as a percent of the 12/31/08 balance: $32.5%. 

Total asset losses: Second/junior lien mortgages; 
Actual for year ended 12/31/09: $7.6 billion; 
2-year SCAP estimate: $21.4 billion; 
GAO 1-year pro rate estimate: $10.7 billion; 
Difference: ($3.1 billion); 
Actual as a percent of the 12/31/08 balance: 70.9%. 

Total asset losses: Commercial and industrial loans; 
Actual for year ended 12/31/09: $5.0 billion; 
2-year SCAP estimate: $15.7 billion; 
GAO 1-year pro rate estimate: $7.9 billion; 
Difference: ($2.8 billion); 
Actual as a percent of the 12/31/08 balance: 63.8%. 

Total asset losses: Commercial real estate loans; 
Actual for year ended 12/31/09: $3.3 billion; 
2-year SCAP estimate: $9.4 billion; 
GAO 1-year pro rate estimate: $4.7 billion; 
Difference: ($1.4 billion); 
Actual as a percent of the 12/31/08 balance: 69.4%. 

Total asset losses: Credit card loans; 
Actual for year ended 12/31/09: $7.8 billion; 
2-year SCAP estimate: $19.1 billion; 
GAO 1-year pro rate estimate: $9.6 billion; 
Difference: ($1.8 billion); 
Actual as a percent of the 12/31/08 balance: 81.5%. 

Total asset losses: Securities (available for sale and held to 
maturity); 
Actual for year ended 12/31/09: ($9.3 billion); 
2-year SCAP estimate: $8.5 billion; 
GAO 1-year pro rate estimate: $4.3 billion; 
Difference: ($13.5 billion); 
Actual as a percent of the 12/31/08 balance: (218.4%). 

Total asset losses: Trading and counterparty; 
Actual for year ended 12/31/09: ($12.1 billion)[B]; 
2-year SCAP estimate: $24.1 billion; 
GAO 1-year pro rate estimate: $12.1 billion; 
Difference: ($24.1 billion); 
Actual as a percent of the 12/31/08 balance: (100.1%). 

Total asset losses: Other; 
Actual for year ended 12/31/09: $6.4 billion; 
2-year SCAP estimate: $16.4 billion; 
GAO 1-year pro rate estimate: $8.2 billion; 
Difference: ($1.8 billion); 
Actual as a percent of the 12/31/08 balance: 78.7%. 

Resources other than capital to absorb losses (Total PPNR less change 
in ALLL); 
Actual for year ended 12/31/09: $29.5 billion; 
2-year SCAP estimate: $74.5 billion; 
GAO 1-year pro rate estimate: $37.3 billion; 
Difference: ($7.7 billion); 
Actual as a percent of the 12/31/08 balance: 79.3%. 

PPNR; 
Actual for year ended 12/31/09: $43.7 billion [C,D]; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Net interest income (expense); 
Actual for year ended 12/31/09: $47.8 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Noninterest income; 
Actual for year ended 12/31/09: $62.6[B]; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Less: noninterest expense; 
Actual for year ended 12/31/09: $66.7 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL); 
Actual for year ended 12/31/09: $14.1 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL): ALLL at 12/31/08; 
Actual for year ended 12/31/09: $23.1 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL): ALLL at 12/31/09; 
Actual for year ended 12/31/09: $37.2 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Source: GAO analysis of Federal Reserve and SNL Financial data. 

Note: N/a means not applicable. 

[A] Tier 1 common capital includes $19.29 billion of common equivalent 
securities (CES) issued in December 2009. As described in Bank of 
America Corporation's (Bank of America) Form 10-K for the year ended 
December 31, 2009, CES are included in tier 1 common capital based 
upon applicable regulatory guidance and the expectation that the 
underlying securities would convert to common stock following 
shareholder approval of additional authorized shares. Shareholders 
approved the increase in the number of authorized shares of common 
stock at the special meeting of shareholders held on February 23, 
2010, and the CES converted to common stock on February 24, 2010. 

[B] The trading and counterparty data in the Y-9C includes both 
customer derived revenue from transactions for BHCs that operate as 
broker-dealers as well as gains and losses from proprietary trading 
and associated expenses. These items are presented in net form only in 
the Y-9C. For the five BHCs that had their trading portfolios stressed 
(including Bank of America), the trading and counterparty line is 
based on projections of (gains) losses from proprietary trading, but 
PPNR (specifically noninterest revenue) included projections of gains 
(losses) from customer derived revenue from transactions due to 
operations as a broker-dealer. Because we could not segregate these 
items based on the Y-9C, we have included the net amount in the 
trading and counterparty and noninterest income line items above. As a 
result of this limitation, the net amount of the trading gains or 
losses and PNNR in the table may be overstated or understated. 

[C] PPNR includes an owned debt value adjustment of ($4.80) billion, 
which was not stressed in SCAP. As Bank of America's credit spreads 
narrowed during 2009, this caused the liability values to increase. 
This offsets the gains Bank of America experienced in 2008 when its 
credit spreads widened. 

[D] PPNR includes one-time items totaling $4.90 billion, which were 
not included in SCAP. 

[End of table] 

Table 14: BB&T Corporation: 

Tier 1 capital; 
Actual at 12/31/09: $13.5 billion; 
12/31/08 balance per SCAP: $13.4 billion; 
Difference: $0.1 billion; 
12/31/09 as a percent of the 12/31/08 balance: 100.4%. 

Tier 1 common capital; 
Actual at 12/31/09: $10.0 billion; 
12/31/08 balance per SCAP: $7.8 billion; 
Difference: $2.2 billion; 
12/31/09 as a percent of the 12/31/08 balance: 127.7%. 

Risk-weighted assets; 
Actual at 12/31/09: $117.2 billion; 
12/31/08 balance per SCAP: $109.8 billion; 
Difference: $7.4 billion; 
12/31/09 as a percent of the 12/31/08 balance: 106.7%. 

Tier 1 risk-based ratio; 
Actual at 12/31/09: 11.5%; 
12/31/08 balance per SCAP: 12.3%; 
Difference: (0.8%); 
12/31/09 as a percent of the 12/31/08 balance: 93.4%. 

Tier 1 common capital ratio; 
Actual at 12/31/09: 8.5%; 
12/31/08 balance per SCAP: 7.1%; 
Difference: 1.4%; 
12/31/09 as a percent of the 12/31/08 balance: 170.1%. 

Total asset losses; 
Actual for year ended 12/31/09: $1.6 billion; 
2-year SCAP estimate: $8.7 billion; 
GAO 1-year pro rate estimate: $4.4 billion; 
Difference: ($2.8 billion); 
Actual as a percent of the 12/31/08 balance: 36.2%. 

Total asset losses: First-lien mortgages; 
Actual for year ended 12/31/09: $0.3 billion; 
2-year SCAP estimate: $1.1 billion; 
GAO 1-year pro rate estimate: $0.6 billion; 
Difference: ($0.3 billion); 
Actual as a percent of the 12/31/08 balance: 47.8%. 

Total asset losses: Second/junior lien mortgages; 
Actual for year ended 12/31/09: $0.1 billion; 
2-year SCAP estimate: $0.7 billion; 
GAO 1-year pro rate estimate: $0.4 billion; 
Difference: ($0.2 billion); 
Actual as a percent of the 12/31/08 balance: 40.9%. 

Total asset losses: Commercial and industrial loans; 
Actual for year ended 12/31/09: $0.2 billion; 
2-year SCAP estimate: $0.7 billion; 
GAO 1-year pro rate estimate: $0.4 billion; 
Difference: ($0.2 billion); 
Actual as a percent of the 12/31/08 balance: 56.5%. 

Total asset losses: Commercial real estate loans; 
Actual for year ended 12/31/09: $0.7 billion; 
2-year SCAP estimate: $4.5 billion; 
GAO 1-year pro rate estimate: $2.3 billion; 
Difference: ($1.5 billion); 
Actual as a percent of the 12/31/08 balance: 32.3%. 

Total asset losses: Credit card loans; 
Actual for year ended 12/31/09: $0.1 billion; 
2-year SCAP estimate: $0.2 billion; 
GAO 1-year pro rate estimate: $0.1 billion; 
Difference: ($0.0 billion); 
Actual as a percent of the 12/31/08 balance: 81.6%. 

Total asset losses: Securities (available for sale and held to 
maturity); 
Actual for year ended 12/31/09: ($0.2 billion); 
2-year SCAP estimate: $0.2 billion; 
GAO 1-year pro rate estimate: $0.1 billion; 
Difference: ($0.3 billion); 
Actual as a percent of the 12/31/08 balance: -199.3%. 

Total asset losses: Trading and counterparty; 
Actual for year ended 12/31/09: [A]; 
2-year SCAP estimate: n/a; 
GAO 1-year pro rate estimate: n/a; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Total asset losses: Other; 
Actual for year ended 12/31/09: $0.4 billion; 
2-year SCAP estimate: $1.3 billion; 
GAO 1-year pro rate estimate: $0.7 billion; 
Difference: ($0.3 billion); 
Actual as a percent of the 12/31/08 balance: 55.6%. 

Resources other than capital to absorb losses (Total PPNR less change 
in ALLL); 
Actual for year ended 12/31/09: $2.6 billion; 
2-year SCAP estimate: $5.5 billion; 
GAO 1-year pro rate estimate: $2.8 billion; 
Difference: ($0.1 billion); 
Actual as a percent of the 12/31/08 balance: 94.9%. 

PPNR; 
Actual for year ended 12/31/09: $3.6 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Net interest income (expense); 
Actual for year ended 12/31/09: $4.8 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Noninterest income; 
Actual for year ended 12/31/09: $3.5[B]; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Less: noninterest expense; 
Actual for year ended 12/31/09: $4.7 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL); 
Actual for year ended 12/31/09: $1.0 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL): ALLL at 12/31/08; 
Actual for year ended 12/31/09: $1.6 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL): ALLL at 12/31/09; 
Actual for year ended 12/31/09: $2.6 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Source: GAO analysis of Federal Reserve and SNL Financial data. 

Note: N/a means not applicable. 

On August 14, 2009, BB&T Corporation (BB&T) entered into a purchase 
and assumption agreement with the Federal Deposit Insurance 
Corporation (FDIC) to acquire certain assets and assume substantially 
all of the deposits and certain liabilities of Colonial Bank, an 
Alabama state-chartered bank headquartered in Montgomery, Alabama. As 
further discussed in BB&T's Form 10-K for the year ended December 31, 
2009, BB&T entered into loss sharing agreements with the FDIC related 
to certain loans, securities, and other assets. The actual results 
include BB&T's performance including the Colonial Bank acquisition. 

[A] Trading and counterparty positions were not stressed because the 
total portfolio is less than the $100 billion required for stress 
testing in SCAP, but trading (gain) loss information for this BHC was 
included in the "trading revenue" line of Schedule HI of the Y-9C in 
2009. In SCAP, the projections of trading gains or losses for this BHC 
were included in the estimate of PPNR rather than the trading and 
counterparty line. Therefore, we have included the actual trading 
results in PPNR (specifically noninterest income). 

[End of table] 

Table 15: The Bank of New York Mellon Corporation: 

Dollars in billions: 

Tier 1 capital; 
Actual at 12/31/09: $12.9; 
12/31/08 balance per SCAP: $15.4; 
Difference: ($2.5); 
12/31/09 as a percent of the 12/31/08 balance: 83.7%. 

Tier 1 common capital; 
Actual at 12/31/09: $11.2; 
12/31/08 balance per SCAP: $11.0; 
Difference: $0.2; 
12/31/09 as a percent of the 12/31/08 balance: 101.8%. 

Risk-weighted assets; 
Actual at 12/31/09: $106.3; 
12/31/08 balance per SCAP: $115.8; 
Difference: ($9.5); 
12/31/09 as a percent of the 12/31/08 balance: 91.8%. 

Tier 1 risk-based ratio; 
Actual at 12/31/09: 12.1%; 
12/31/08 balance per SCAP: 13.3%; 
Difference: (1.2%); 
12/31/09 as a percent of the 12/31/08 balance: 91.1%. 

Tier 1 common capital ratio; 
Actual at 12/31/09: 10.5%; 
12/31/08 balance per SCAP: 9.5%; 
Difference: 1.0%; 
12/31/09 as a percent of the 12/31/08 balance: 110.8%. 

Total asset losses; 
Actual for year ended 12/31/09: $56. billion; 
2-year SCAP estimate: $5.4 billion; 
GAO 1-year pro rate estimate: $2.7 billion; 
Difference: $2.9 billion; 
Actual as a percent of the 12/31/08 balance: 207.6%. 

Total asset losses: First-lien mortgages; 
Actual for year ended 12/31/09: $0.1 billion; 
2-year SCAP estimate: $0.2 billion; 
GAO 1-year pro rate estimate: $0.1 billion; 
Difference: $0.0 billion; 
Actual as a percent of the 12/31/08 balance: 60.0%. 

Total asset losses: Second/junior lien mortgages; 
Actual for year ended 12/31/09: $0.0 billion; 
2-year SCAP estimate: n/a; 
GAO 1-year pro rate estimate: n/a; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Total asset losses: Commercial and industrial loans; 
Actual for year ended 12/31/09: $0.1 billion; 
2-year SCAP estimate: $0.4 billion; 
GAO 1-year pro rate estimate: $0.2 billion; 
Difference: ($0.1 billion); 
Actual as a percent of the 12/31/08 balance: 45.0%. 

Total asset losses: Commercial real estate loans; 
Actual for year ended 12/31/09: $0.1 billion; 
2-year SCAP estimate: $0.2 billion; 
GAO 1-year pro rate estimate: $0.1 billion; 
Difference: ($0.1 billion); 
Actual as a percent of the 12/31/08 balance: 50.0%. 

Total asset losses: Credit card loans; 
Actual for year ended 12/31/09: 0.0; 
2-year SCAP estimate: n/a; 
GAO 1-year pro rate estimate: n/a; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Total asset losses: Securities (available for sale and held to 
maturity); 
Actual for year ended 12/31/09: $5.4 billion[A]; 
2-year SCAP estimate: $4.2 billion; 
GAO 1-year pro rate estimate: $2.1 billion; 
Difference: $3.3 billion); 
Actual as a percent of the 12/31/08 balance: 255.7%. 

Total asset losses: Trading and counterparty; 
Actual for year ended 12/31/09: [B]; 
2-year SCAP estimate: n/a; 
GAO 1-year pro rate estimate: n/a; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Total asset losses: Other; 
Actual for year ended 12/31/09: $0.0; 
2-year SCAP estimate: $0.4 billion; 
GAO 1-year pro rate estimate: $0.2 billion; 
Difference: ($0.2 billion); 
Actual as a percent of the 12/31/08 balance: 17.0%. 

Resources other than capital to absorb losses (Total PPNR less change 
in ALLL); 
Actual for year ended 12/31/09: $3.4 billion; 
2-year SCAP estimate: $6.7 billion; 
GAO 1-year pro rate estimate: $3.4 billion; 
Difference: $0.0; 
Actual as a percent of the 12/31/08 balance: 100.2%. 

PPNR; 
Actual for year ended 12/31/09: $3.5billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Net interest income (expense); 
Actual for year ended 12/31/09: $2.0 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Noninterest income; 
Actual for year ended 12/31/09: $10.1[B] billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Less: noninterest expense; 
Actual for year ended 12/31/09: $9.6 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL); 
Actual for year ended 12/31/09: $0.1 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL): ALLL at 12/31/08; 
Actual for year ended 12/31/09: $0.4 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL): ALLL at 12/31/09; 
Actual for year ended 12/31/09: $0.5 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Source: GAO analysis of Federal Reserve and SNL Financial data. 

Note: N/a means not applicable. 

[A] Based on discussions with Bank of New York Mellon Corporation 
(Bank of New York Mellon) officials, the company's securities 
portfolio underwent a significant restructuring in the third quarter 
of 2009 in order to de-risk this portfolio, causing the recognition of 
significant losses in that period. However, The Bank of New York 
Mellon sold off many of its riskiest holdings in that period, 
including many Alt-A residential mortgage-backed securities, so that 
it expects to see gains in this portfolio in the future, causing the 
final 2-year loss amount to be less than the amount projected under 
SCAP in the securities (available for sale and held to maturity) 
portfolio. See the Bank of New York Mellon's Form 10-K for the year 
ended December 31, 2009, and other public disclosures for additional 
information. As a result of the write downs taken due to the 
restructuring of the securities portfolio, Bank of New York Mellon 
expects an increase in net interest revenue of $200 million in 2010. 
As of the second quarter of 2010 year to date, the BHC experienced a 
gain of $20 million in this portfolio. 

[B] Trading and counterparty positions were not stressed because the 
total portfolio is less than the $100 billion required for stress 
testing in SCAP, but trading (gain) loss information for this BHC was 
included in the "trading revenue" line of Schedule HI of the Y-9C in 
2009. In SCAP, the projections of trading gains or losses for this BHC 
were included in the estimate of PPNR rather than the trading and 
counterparty line. Therefore, we have included the actual trading 
results in PPNR (specifically noninterest income). 

[End of table] 

Table 16: Capital One Financial Corporation: 

Dollars in billions: 

Tier 1 capital; 
Actual at 12/31/09: $16.0 billion; 
12/31/08 balance per SCAP: $16.8 billion; 
Difference: ($0.8) billion; 
12/31/09 as a percent of the 12/31/08 balance: 95.2%. 

Tier 1 common capital; 
Actual at 12/31/09: $12.4 billion; 
12/31/08 balance per SCAP: $12.0 billion; 
Difference: $0.4 billion; 
12/31/09 as a percent of the 12/31/08 balance: 103.0%. 

Risk-weighted assets; 
Actual at 12/31/09: $116.3 billion; 
12/31/08 balance per SCAP: $131.8 billion; 
Difference: ($15.5) billion; 
12/31/09 as a percent of the 12/31/08 balance: 88.2%. 

Tier 1 risk-based ratio; 
Actual at 12/31/09: 13.7%; 
12/31/08 balance per SCAP: 12.7%; 
Difference: 1.0%; 
12/31/09 as a percent of the 12/31/08 balance: 108.2%. 

Tier 1 common capital ratio; 
Actual at 12/31/09: 10.6%; 
12/31/08 balance per SCAP: 9.1%; 
Difference: 1.5%; 
12/31/09 as a percent of the 12/31/08 balance: 116.7%. 

Total asset losses; 
Actual for year ended 12/31/09: $4.4 billion; 
2-year SCAP estimate: $1.4 billion; 
GAO 1-year pro rate estimate: $6.7 billion; 
Difference: ($2.3 billion); 
Actual as a percent of the 12/31/08 balance: 65.1%. 

Total asset losses: First-lien mortgages; 
Actual for year ended 12/31/09: $0.1 billion; 
2-year SCAP estimate: $1.8 billion; 
GAO 1-year pro rate estimate: $0.9 billion; 
Difference: ($0.8 billion); 
Actual as a percent of the 12/31/08 balance: 7.8%. 

Total asset losses: Second/junior lien mortgages; 
Actual for year ended 12/31/09: $0.2 billion; 
2-year SCAP estimate: $0.7 billion; 
GAO 1-year pro rate estimate: $0.4 billion; 
Difference: ($0.1 billion); 
Actual as a percent of the 12/31/08 balance: 63.0%. 

Total asset losses: Commercial and industrial loans; 
Actual for year ended 12/31/09: $0.6 billion; 
2-year SCAP estimate: $1.5 billion; 
GAO 1-year pro rate estimate: $0.8 billion; 
Difference: ($0.1 billion); 
Actual as a percent of the 12/31/08 balance: 81.5%. 

Total asset losses: Commercial real estate loans; 
Actual for year ended 12/31/09: $0.3 billion; 
2-year SCAP estimate: $1.1 billion; 
GAO 1-year pro rate estimate: $0.6 billion; 
Difference: ($0.2 billion); 
Actual as a percent of the 12/31/08 balance: 62.4%. 

Total asset losses: Credit card loans; 
Actual for year ended 12/31/09: $1.8 billion; 
2-year SCAP estimate: $3.6 billion; 
GAO 1-year pro rate estimate: $1.8 billion; 
Difference: ($0.0 billion); 
Actual as a percent of the 12/31/08 balance: 98.0%. 

Total asset losses: Securities (available for sale and held to 
maturity); 
Actual for year ended 12/31/09: ($0.2 billion); 
2-year SCAP estimate: $0.4 billion; 
GAO 1-year pro rate estimate: $0.2 billion; 
Difference: ($0.4 billion); 
Actual as a percent of the 12/31/08 balance: (103.1%). 

Total asset losses: Trading and counterparty; 
Actual for year ended 12/31/09: [A]; 
2-year SCAP estimate: n/a; 
GAO 1-year pro rate estimate: n/a; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Total asset losses: Other; 
Actual for year ended 12/31/09: $1.6 billion; 
2-year SCAP estimate: $4.3 billion; 
GAO 1-year pro rate estimate: $2.2 billion; 
Difference: ($0.6 billion); 
Actual as a percent of the 12/31/08 balance: 72.5%. 

Resources other than capital to absorb losses (Total PPNR less change 
in ALLL); 
Actual for year ended 12/31/09: $5.8 billion; 
2-year SCAP estimate: $9.0 billion; 
GAO 1-year pro rate estimate: $4.5 billion; 
Difference: $1.3 billion; 
Actual as a percent of the 12/31/08 balance: 128.0%. 

PPNR; 
Actual for year ended 12/31/09: $5.4; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Net interest income (expense); 
Actual for year ended 12/31/09: $7.7 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Noninterest income; 
Actual for year ended 12/31/09: $5.0[B]; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Less: noninterest expense; 
Actual for year ended 12/31/09: $7.3 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL); 
Actual for year ended 12/31/09: ($0.4) billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL): ALLL at 12/31/08; 
Actual for year ended 12/31/09: $4.5 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL): ALLL at 12/31/09; 
Actual for year ended 12/31/09: $4.1 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Source: GAO analysis of Federal Reserve and SNL Financial data. 

Note: N/a means not applicable. 

[A] Trading and counterparty positions were not stressed because the 
total portfolio is less than the $100 billion required for stress 
testing in SCAP, but trading (gain) loss information for this BHC was 
included in the "trading revenue" line of Schedule HI of the Y-9C in 
2009. In SCAP, the projections of trading gains or losses for this BHC 
were included in the estimate of PPNR rather than the trading and 
counterparty line. Therefore, we have included the actual trading 
results in PPNR (specifically noninterest income). 

[End of table] 

Table 17: Citigroup Inc. 

Dollars in billions: 

Tier 1 capital; 
Actual at 12/31/09: $127.0 billion; 
12/31/08 balance per SCAP: $118.8 billion; 
Difference: $8.2 billion; 
12/31/09 as a percent of the 12/31/08 balance: 106.9%. 

Tier 1 common capital; 
Actual at 12/31/09: $106.4 billion; 
12/31/08 balance per SCAP: $22.9 billion; 
Difference: $83.5 billion; 
12/31/09 as a percent of the 12/31/08 balance: 464.5%. 

Risk-weighted assets; 
Actual at 12/31/09: $1,088.5 billion; 
12/31/08 balance per SCAP: $996.2 billion; 
Difference: $92.3 billion; 
12/31/09 as a percent of the 12/31/08 balance: 109.3%. 

Tier 1 risk-based ratio; 
Actual at 12/31/09: 11.7%; 
12/31/08 balance per SCAP: 11.9%; 
Difference: (0.2%); 
12/31/09 as a percent of the 12/31/08 balance: 98.1%. 

Tier 1 common capital ratio; 
Actual at 12/31/09: 9.8%; 
12/31/08 balance per SCAP: 2.3%; 
Difference: 7.5%; 
12/31/09 as a percent of the 12/31/08 balance: 424.9%. 

Total asset losses; 
Actual for year ended 12/31/09: $27.2 billion; 
2-year SCAP estimate: $104.7 billion; 
GAO 1-year pro rate estimate: $52.4 billion; 
Difference: ($25.1 billion); 
Actual as a percent of the 12/31/08 balance: 52.0%. 

Total asset losses: First-lien mortgages; 
Actual for year ended 12/31/09: $4.2 billion; 
2-year SCAP estimate: $15.3 billion; 
GAO 1-year pro rate estimate: $7.7 billion; 
Difference: ($3.5 billion); 
Actual as a percent of the 12/31/08 balance: 54.5%. 

Total asset losses: Second/junior lien mortgages; 
Actual for year ended 12/31/09: $4.7 billion; 
2-year SCAP estimate: $12.2 billion; 
GAO 1-year pro rate estimate: $6.1 billion; 
Difference: ($1.4 billion); 
Actual as a percent of the 12/31/08 balance: 76.8%. 

Total asset losses: Commercial and industrial loans; 
Actual for year ended 12/31/09: $5.1 billion; 
2-year SCAP estimate: $8.9 billion; 
GAO 1-year pro rate estimate: $4.5 billion; 
Difference: $0.6 billion; 
Actual as a percent of the 12/31/08 balance: 113.6%. 

Total asset losses: Commercial real estate loans; 
Actual for year ended 12/31/09: $0.7 billion; 
2-year SCAP estimate: $2.7 billion; 
GAO 1-year pro rate estimate: $1.4 billion; 
Difference: ($0.6 billion); 
Actual as a percent of the 12/31/08 balance: 52.2%. 

Total asset losses: Credit card loans; 
Actual for year ended 12/31/09: $6.5 billion; 
2-year SCAP estimate: $19.9 billion; 
GAO 1-year pro rate estimate: $10.0 billion; 
Difference: ($3.4 billion); 
Actual as a percent of the 12/31/08 balance: 65.4%. 

Total asset losses: Securities (available for sale and held to 
maturity); 
Actual for year ended 12/31/09: $0.9 billion; 
2-year SCAP estimate: $2.9 billion; 
GAO 1-year pro rate estimate: $1.5 billion; 
Difference: ($0.5 billion); 
Actual as a percent of the 12/31/08 balance: 62.8%. 

Total asset losses: Trading and counterparty; 
Actual for year ended 12/31/09: ($4.4 billion)[A]; 
2-year SCAP estimate: $22.4 billion; 
GAO 1-year pro rate estimate: $11.2 billion; 
Difference: ($15.6 billion); 
Actual as a percent of the 12/31/08 balance: (39.7%). 

Total asset losses: Other; 
Actual for year ended 12/31/09: $9.6 billion; 
2-year SCAP estimate: $20.4 billion; 
GAO 1-year pro rate estimate: $10.2 billion; 
Difference: ($0.6 billion); 
Actual as a percent of the 12/31/08 balance: 94.3%. 

Resources other than capital to absorb losses (Total PPNR less change 
in ALLL); 
Actual for year ended 12/31/09: $25.5 billion; 
2-year SCAP estimate: $49.0 billion; 
GAO 1-year pro rate estimate: $24.5 billion; 
Difference: $1.0 billion; 
Actual as a percent of the 12/31/08 balance: 103.9%. 

PPNR; 
Actual for year ended 12/31/09: $31.9 billion [B,C]; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Net interest income (expense); 
Actual for year ended 12/31/09: $50.4 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Noninterest income; 
Actual for year ended 12/31/09: $32.1[A]; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Less: noninterest expense; 
Actual for year ended 12/31/09: $50.6 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL); 
Actual for year ended 12/31/09: $6.4 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL): ALLL at 12/31/08; 
Actual for year ended 12/31/09: $29.6 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL): ALLL at 12/31/09; 
Actual for year ended 12/31/09: $36.0 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Source: GAO analysis of Federal Reserve and SNL Financial data. 

Note: N/a means not applicable. 

[A] The trading and counterparty data in the Y-9C includes both 
customer derived revenue from transactions for BHCs that operate as 
broker-dealers as well as gains and losses from proprietary trading 
and associated expenses. These items are presented in net form only in 
the Y-9C. For the five BHCs that had their trading portfolios stressed 
(including Citigroup Inc.), the trading and counterparty line is based 
on projections of (gains) losses from proprietary trading, but PPNR 
(specifically noninterest revenue) included projections of gains 
(losses) from customer derived revenue from transactions due to 
operations as a broker-dealer. Because we could not segregate these 
items based on the Y-9C, we have included the net amount in both the 
trading and counterparty and noninterest income line items above. As a 
result of this limitation, the net amount of the trading gains or 
losses and PPNR in the table may be overstated or understated. 

[B] PPNR includes an owned debt value adjustment of ($4.23) billion, 
which was not included stressed in SCAP. As Citigroup's credit spreads 
narrowed during 2009, this caused the liability values to increase. 
This offsets the gains Citigroup Inc. experienced in 2008 when its 
credit spreads widened. 

[C] PPNR includes one-time items totaling $2.73 billion, which were 
not included in SCAP. 

[End of table] 

Table 18: Fifth Third Bancorp: 

Dollars in billions: 

Tier 1 capital; 
Actual at 12/31/09: $13.4 billion; 
12/31/08 balance per SCAP: $11.9 billion; 
Difference: $1.5 billion; 
12/31/09 as a percent of the 12/31/08 balance: 112.8%. 

Tier 1 common capital; 
Actual at 12/31/09: $7.1 billion; 
12/31/08 balance per SCAP: $4.9 billion; 
Difference: $2.2 billion; 
12/31/09 as a percent of the 12/31/08 balance: 144.0%. 

Risk-weighted assets; 
Actual at 12/31/09: $100.9 billion; 
12/31/08 balance per SCAP: $112.6 billion; 
Difference: ($11.7) billion; 
12/31/09 as a percent of the 12/31/08 balance: 89.6%. 

Tier 1 risk-based ratio; 
Actual at 12/31/09: 13.3%; 
12/31/08 balance per SCAP: 10.6%; 
Difference: 2.7%; 
12/31/09 as a percent of the 12/31/08 balance: 125.6%. 

Tier 1 common capital ratio; 
Actual at 12/31/09: 7.0%; 
12/31/08 balance per SCAP: 4.4%; 
Difference: 2.6%; 
12/31/09 as a percent of the 12/31/08 balance: 159.0%. 

Total asset losses; 
Actual for year ended 12/31/09: $2.5 billion; 
2-year SCAP estimate: $9.1 billion; 
GAO 1-year pro rate estimate: $4.6 billion; 
Difference: ($2.1 billion); 
Actual as a percent of the 12/31/08 balance: 54.6%. 

Total asset losses: First-lien mortgages; 
Actual for year ended 12/31/09: $0.3 billion; 
2-year SCAP estimate: $1.1 billion; 
GAO 1-year pro rate estimate: $0.6 billion; 
Difference: ($0.3 billion); 
Actual as a percent of the 12/31/08 balance: 49.1%. 

Total asset losses: Second/junior lien mortgages; 
Actual for year ended 12/31/09: $0.3 billion; 
2-year SCAP estimate: $1.1 billion; 
GAO 1-year pro rate estimate: $0.6 billion; 
Difference: ($0.2 billion); 
Actual as a percent of the 12/31/08 balance: 57.8%. 

Total asset losses: Commercial and industrial loans; 
Actual for year ended 12/31/09: $0.6 billion; 
2-year SCAP estimate: $2.8 billion; 
GAO 1-year pro rate estimate: $1.4 billion; 
Difference: ($0.8 billion); 
Actual as a percent of the 12/31/08 balance: 39.4%. 

Total asset losses: Commercial real estate loans; 
Actual for year ended 12/31/09: $1.0 billion; 
2-year SCAP estimate: $2.9 billion; 
GAO 1-year pro rate estimate: $1.5 billion; 
Difference: ($0.4 billion); 
Actual as a percent of the 12/31/08 balance: 70.8%. 

Total asset losses: Credit card loans; 
Actual for year ended 12/31/09: $0.2 billion; 
2-year SCAP estimate: $0.4 billion; 
GAO 1-year pro rate estimate: $0.2 billion; 
Difference: ($0.0 billion); 
Actual as a percent of the 12/31/08 balance: 84.6%. 

Total asset losses: Securities (available for sale and held to 
maturity); 
Actual for year ended 12/31/09: ($0.1 billion); 
2-year SCAP estimate: $0.1 billion; 
GAO 1-year pro rate estimate: $0.0 billion; 
Difference: ($0.1 billion); 
Actual as a percent of the 12/31/08 balance: (227.5%). 

Total asset losses: Trading and counterparty; 
Actual for year ended 12/31/09: [A]; 
2-year SCAP estimate: n/a; 
GAO 1-year pro rate estimate: n/a; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Total asset losses: Other; 
Actual for year ended 12/31/09: $0.2 billion; 
2-year SCAP estimate: $0.9 billion; 
GAO 1-year pro rate estimate: $0.5 billion; 
Difference: ($0.2 billion); 
Actual as a percent of the 12/31/08 balance: 54.6%. 

Resources other than capital to absorb losses (Total PPNR less change 
in ALLL); 
Actual for year ended 12/31/09: $3.3 billion; 
2-year SCAP estimate: $5.5 billion; 
GAO 1-year pro rate estimate: $2.8 billion; 
Difference: $0.5 billion; 
Actual as a percent of the 12/31/08 balance: 119.7%. 

PPNR; 
Actual for year ended 12/31/09: $4.3[B]; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Net interest income (expense); 
Actual for year ended 12/31/09: $3.5 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Noninterest income; 
Actual for year ended 12/31/09: $4.6[A]; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Less: noninterest expense; 
Actual for year ended 12/31/09: $3.8 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL); 
Actual for year ended 12/31/09: $1.0 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL): ALLL at 12/31/08; 
Actual for year ended 12/31/09: $2.8 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL): ALLL at 12/31/09; 
Actual for year ended 12/31/09: $3.7 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Source: GAO analysis of Federal Reserve and SNL Financial data. 

Note: N/a means not applicable. 

[A] Trading and counterparty positions were not stressed because the 
total portfolio is less than the $100 billion required for stress 
testing in SCAP, but trading (gain) loss information for this BHC was 
included in the "trading revenue" line of Schedule HI of the Y-9C in 
2009. In SCAP, the projections of trading gains or losses for this BHC 
were included in the estimate of PPNR rather than the trading and 
counterparty line. Therefore, we have included the actual trading 
results in PPNR (specifically noninterest income). 

[B] Fifth Third Bancorp's PPNR includes one-time items totaling $2.05 
billion, which were not included in SCAP. 

[End of table] 

Table 19: GMAC LLC: 

Dollars in billions: 

Tier 1 capital; 
Actual at 12/31/09: $22.4 billion; 
12/31/08 balance per SCAP: $17.4 billion; 
Difference: $5.0 billion; 
12/31/09 as a percent of the 12/31/08 balance: 128.7%. 

Tier 1 common capital; 
Actual at 12/31/09: $7.7 billion; 
12/31/08 balance per SCAP: $11.1 billion; 
Difference: ($3.4) billion; 
12/31/09 as a percent of the 12/31/08 balance: 69.2%. 

Risk-weighted assets; 
Actual at 12/31/09: $158.3 billion; 
12/31/08 balance per SCAP: $172.7 billion; 
Difference: ($14.4) billion; 
12/31/09 as a percent of the 12/31/08 balance: 91.7%. 

Tier 1 risk-based ratio; 
Actual at 12/31/09: 14.1%; 
12/31/08 balance per SCAP: 10.1%; 
Difference: 4.0%; 
12/31/09 as a percent of the 12/31/08 balance: 140.1%. 

Tier 1 common capital ratio; 
Actual at 12/31/09: 4.8%; 
12/31/08 balance per SCAP: 6.4%; 
Difference: (1.6%); 
12/31/09 as a percent of the 12/31/08 balance: 75.8%. 

Total asset losses; 
Actual for year ended 12/31/09: $6.9 billion; 
2-year SCAP estimate: $9.2 billion; 
GAO 1-year pro rate estimate: $4.6 billion; 
Difference: $2.3 billion; 
Actual as a percent of the 12/31/08 balance: 150.7%. 

Total asset losses: First-lien mortgages; 
Actual for year ended 12/31/09: $2.4 billion; 
2-year SCAP estimate: $2.0 billion; 
GAO 1-year pro rate estimate: $1.0 billion; 
Difference: $1.4 billion; 
Actual as a percent of the 12/31/08 balance: 239.9%. 

Total asset losses: Second/junior lien mortgages; 
Actual for year ended 12/31/09: $1.6 billion; 
2-year SCAP estimate: $1.1 billion; 
GAO 1-year pro rate estimate: $0.6 billion; 
Difference: $1.0 billion; 
Actual as a percent of the 12/31/08 balance: 287.3%. 

Total asset losses: Commercial and industrial loans; 
Actual for year ended 12/31/09: $0.4 billion; 
2-year SCAP estimate: $1.0 billion; 
GAO 1-year pro rate estimate: $0.5 billion; 
Difference: ($0.1 billion); 
Actual as a percent of the 12/31/08 balance: 71.2%. 

Total asset losses: Commercial real estate loans; 
Actual for year ended 12/31/09: $0.7 billion; 
2-year SCAP estimate: $0.6 billion; 
GAO 1-year pro rate estimate: $0.3 billion; 
Difference: $0.4 billion; 
Actual as a percent of the 12/31/08 balance: 236.7%. 

Total asset losses: Credit card loans; 
Actual for year ended 12/31/09: $0.0 billion; 
2-year SCAP estimate: n/a; 
GAO 1-year pro rate estimate: n/a; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Total asset losses: Securities (available for sale and held to 
maturity); 
Actual for year ended 12/31/09: ($0.2 billion); 
2-year SCAP estimate: $0.5 billion; 
GAO 1-year pro rate estimate: $0.3 billion; 
Difference: ($0.4 billion); 
Actual as a percent of the 12/31/08 balance: (66.4%). 

Total asset losses: Trading and counterparty; 
Actual for year ended 12/31/09: [B]; 
2-year SCAP estimate: n/a; 
GAO 1-year pro rate estimate: n/a; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Total asset losses: Other; 
Actual for year ended 12/31/09: $2.1 billion; 
2-year SCAP estimate: $4.0 billion; 
GAO 1-year pro rate estimate: $2.1 billion; 
Difference: $0.1 billion; 
Actual as a percent of the 12/31/08 balance: 102.7%. 

Resources other than capital to absorb losses (Total PPNR less change 
in ALLL); 
Actual for year ended 12/31/09: ($1.1 billion); 
2-year SCAP estimate: ($0.5 billion); 
GAO 1-year pro rate estimate: ($0.3 billion); 
Difference: ($0.8 billion); 
Actual as a percent of the 12/31/08 balance: (429.6%). 

PPNR; 
Actual for year ended 12/31/09: ($2.1 billion); 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Net interest income (expense); 
Actual for year ended 12/31/09: $0.1 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Noninterest income; 
Actual for year ended 12/31/09: $10.1; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Less: noninterest expense; 
Actual for year ended 12/31/09: $12.3 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL); 
Actual for year ended 12/31/09: ($1.0 billion); 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL): ALLL at 12/31/08; 
Actual for year ended 12/31/09: $3.4 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL): ALLL at 12/31/09; 
Actual for year ended 12/31/09: $2.4 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Source: GAO analysis of Federal Reserve and SNL Financial data. 

Notes: N/a means not applicable. 

GMAC LLC (GMAC) experienced a loss from discontinued operations 
totaling $2.4 billion in 2009. The item was not included in our 
calculation of PPNR. 

GMAC changed its corporate name to GMAC Inc. on June 30, 2009. On May 
10, 2010, GMAC Inc. changed its name to Ally Financial Inc. 

[A] According to GMAC officials, in order to be positioned for better 
future performance the company pulled losses forward into the fourth 
quarter of 2009 by recognizing the lifetime losses on assets in that 
period; and as a result of the accelerated loss recognition less 
losses would be expected in 2010. GMAC had a profit in the first and 
second quarters of 2010, its first profits since the fourth quarter of 
2008. GMAC's tier 1 common capital ratio also improved to 5 percent 
and 5.2 percent, respectively. 

[B] Trading and counterparty positions were not stressed because the 
total portfolio is less than the $100 billion required for stress 
testing in SCAP, but trading (gain) loss information for this BHC was 
included in the "trading revenue" line of Schedule HI of the Y-9C in 
2009. In SCAP, the projections of trading gains or losses for this BHC 
were included in the estimate of PPNR rather than the trading and 
counterparty line. Therefore, we have included the actual trading 
results in PPNR (specifically noninterest income). 

[C] GMAC's "Other" loans category per SCAP included only automobile- 
related loans. However, our classification of "Other" using Y-9C data 
includes automobile loans and other loans such as European home 
mortgages, which had substantial losses in 2009. Automobile loan 
losses totaled about $600 million in 2009 compared to the $2.0 billion 
prorated SCAP estimate, according to GMAC officials. On April 12, 
2010, GMAC's mortgage subsidiary, Residential Capital, LLC agreed to 
sell its European mortgage assets and business. The assets in the 
transactions are valued at approximately the levels established in the 
fourth quarter of 2009, and there is no material gain or loss expected. 

[End of table] 

Table 20: The Goldman Sachs Group, Inc. 

Dollars in billions: 

Tier 1 capital; 
Actual at 12/31/09: $64.6 billion; 
12/31/08 balance per SCAP: $55.9 billion; 
Difference: $8.7 billion; 
12/31/09 as a percent of the 12/31/08 balance: 115.6%. 

Tier 1 common capital; 
Actual at 12/31/09: $52.7 billion; 
12/31/08 balance per SCAP: $34.4 billion; 
Difference: $18.3 billion; 
12/31/09 as a percent of the 12/31/08 balance: 153.2%. 

Risk-weighted assets; 
Actual at 12/31/09: $431.9 billion; 
12/31/08 balance per SCAP: $444.8 billion; 
Difference: ($12.9) billion; 
12/31/09 as a percent of the 12/31/08 balance: 97.1%. 

Tier 1 risk-based ratio; 
Actual at 12/31/09: 15.0%; 
12/31/08 balance per SCAP: 12.6%; 
Difference: 2.4%; 
12/31/09 as a percent of the 12/31/08 balance: 118.8%. 

Tier 1 common capital ratio; 
Actual at 12/31/09: 12.2%; 
12/31/08 balance per SCAP: 7.7%; 
Difference: 4.5%; 
12/31/09 as a percent of the 12/31/08 balance: 158.4%. 

Total asset losses; 
Actual for year ended 12/31/09: ($23.3 billion); 
2-year SCAP estimate: $17.8 billion; 
GAO 1-year pro rate estimate: $8.9 billion; 
Difference: ($32.2 billion); 
Actual as a percent of the 12/31/08 balance: (261.3%). 

Total asset losses: First-lien mortgages; 
Actual for year ended 12/31/09: $0.0 billion; 
2-year SCAP estimate: n/a; 
GAO 1-year pro rate estimate: n/a; 
Difference: n/a; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Total asset losses: Second/junior lien mortgages; 
Actual for year ended 12/31/09: $0.0 billion; 
2-year SCAP estimate: n/a; 
GAO 1-year pro rate estimate: n/a; 
Difference: n/a; 
Actual as a percent of the 12/31/08 balance: [Empty]%. 

Total asset losses: Commercial and industrial loans; 
Actual for year ended 12/31/09: $0.0 billion; 
2-year SCAP estimate: $0.0 billion; 
GAO 1-year pro rate estimate: $0.0 billion; 
Difference: ($0.0 billion); 
Actual as a percent of the 12/31/08 balance: 0.0%. 

Total asset losses: Commercial real estate loans; 
Actual for year ended 12/31/09: $0.0 billion; 
2-year SCAP estimate: n/a; 
GAO 1-year pro rate estimate: n/a; 
Difference: n/a; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Total asset losses: Credit card loans; 
Actual for year ended 12/31/09: $0.0 billion; 
2-year SCAP estimate: n/a; 
GAO 1-year pro rate estimate: n/a; 
Difference: n/a; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Total asset losses: Securities (available for sale and held to 
maturity); 
Actual for year ended 12/31/09: ($0.0 billion); 
2-year SCAP estimate: $0.1 billion; 
GAO 1-year pro rate estimate: $0.1 billion; 
Difference: ($0.1 billion); 
Actual as a percent of the 12/31/08 balance: (72.0%). 

Total asset losses: Trading and counterparty; 
Actual for year ended 12/31/09: ($23.2 billion)[A]; 
2-year SCAP estimate: $17.4 billion; 
GAO 1-year pro rate estimate: $8.7 billion; 
Difference: ($31.9 billion); 
Actual as a percent of the 12/31/08 balance: (267.1%). 

Total asset losses: Other; 
Actual for year ended 12/31/09: $0.0 billion; 
2-year SCAP estimate: $0.3 billion; 
GAO 1-year pro rate estimate: $0.2 billion; 
Difference: ($0.2 billion); 
Actual as a percent of the 12/31/08 balance: 0.0%. 

Resources other than capital to absorb losses (Total PPNR less change 
in ALLL); 
Actual for year ended 12/31/09: $19.4 billion; 
2-year SCAP estimate: $18.5 billion; 
GAO 1-year pro rate estimate: $9.3 billion; 
Difference: $10.2 billion; 
Actual as a percent of the 12/31/08 balance: 209.9%. 

PPNR; 
Actual for year ended 12/31/09: $19.4 billion[B]; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Net interest income (expense); 
Actual for year ended 12/31/09: $7.4 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Noninterest income; 
Actual for year ended 12/31/09: $37.3[A]; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Less: noninterest expense; 
Actual for year ended 12/31/09: $25.3 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL); 
Actual for year ended 12/31/09: $0.0 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL): ALLL at 12/31/08; 
Actual for year ended 12/31/09: $0.0 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL): ALLL at 12/31/09; 
Actual for year ended 12/31/09: $0.0 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Source: GAO analysis of Federal Reserve and SNL Financial data. 

Note: N/a means not applicable. 

[A] The trading and counterparty data in the Y-9C includes both 
customer derived revenue from transactions for BHCs that operate as 
broker-dealers as well as gains and losses from proprietary trading 
and associated expenses. These items are presented in net form only in 
the Y-9C. For the five BHCs that had their trading portfolios stressed 
(including Goldman Sachs Group, Inc.), the trading and counterparty 
line is based on projections of (gains) losses from proprietary 
trading, but PPNR (specifically noninterest revenue) included 
projections of gains (losses) from customer derived revenue from 
transactions due to operations as a broker-dealer. Because we could 
not segregate these items based on the Y-9C, we have included the net 
amount in both the trading and counterparty and noninterest income 
line items above. As a result of this limitation, the net amount of 
the trading gains or losses and PPNR in the table may be overstated or 
understated. 

[B] PPNR includes an owned debt value adjustment of ($770) million, 
which was not stressed in SCAP. As Goldman Sachs Group, Inc.'s credit 
spreads narrowed during 2009, this caused the liability values to 
increase. This offsets the gains Goldman Sachs Group, Inc. experienced 
in 2008 when its credit spreads widened. 

[End of table] 

Table 21: JPMorgan Chase & Co. 

Dollars in billions: 

Tier 1 capital; 
Actual at 12/31/09: $133.0 billion; 
12/31/08 balance per SCAP: $136.2 billion; 
Difference: ($3.2) billion; 
12/31/09 as a percent of the 12/31/08 balance: 97.6%. 

Tier 1 common capital; 
Actual at 12/31/09: $105.3 billion; 
12/31/08 balance per SCAP: $87.0 billion; 
Difference: $18.3billion; 
12/31/09 as a percent of the 12/31/08 balance: 121.0%. 

Risk-weighted assets; 
Actual at 12/31/09: $1,198.0 billion; 
12/31/08 balance per SCAP: $1,337.5 billion; 
Difference: ($139.5) billion; 
12/31/09 as a percent of the 12/31/08 balance: 89.6%. 

Tier 1 risk-based ratio; 
Actual at 12/31/09: 11.1%; 
12/31/08 balance per SCAP: 10.2%; 
Difference: 0.9%; 
12/31/09 as a percent of the 12/31/08 balance: 108.8%. 

Tier 1 common capital ratio; 
Actual at 12/31/09: 8.8%; 
12/31/08 balance per SCAP: 6.5%; 
Difference: 2.3%; 
12/31/09 as a percent of the 12/31/08 balance: 135.2%. 

Total asset losses; 
Actual for year ended 12/31/09: $12.0 billion; 
2-year SCAP estimate: $97.4 billion; 
GAO 1-year pro rate estimate: $48.7 billion; 
Difference: ($36.7 billion); 
Actual as a percent of the 12/31/08 balance: 24.6%. 

Total asset losses: First-lien mortgages; 
Actual for year ended 12/31/09: $3.5 billion; 
2-year SCAP estimate: $18.8 billion; 
GAO 1-year pro rate estimate: $9.4 billion; 
Difference: ($5.9 billion); 
Actual as a percent of the 12/31/08 balance: 37.7%. 

Total asset losses: Second/junior lien mortgages; 
Actual for year ended 12/31/09: $4.7 billion; 
2-year SCAP estimate: $20.1 billion; 
GAO 1-year pro rate estimate: $10.1 billion; 
Difference: ($5.4 billion); 
Actual as a percent of the 12/31/08 balance: 46.3%. 

Total asset losses: Commercial and industrial loans; 
Actual for year ended 12/31/09: $5.0 billion; 
2-year SCAP estimate: $15.7 billion; 
GAO 1-year pro rate estimate: $7.9 billion; 
Difference: ($2.8 billion); 
Actual as a percent of the 12/31/08 balance: 63.8%. 

Total asset losses: Commercial real estate loans; 
Actual for year ended 12/31/09: $3.6 billion; 
2-year SCAP estimate: $10.3 billion; 
GAO 1-year pro rate estimate: $5.2 billion; 
Difference: ($1.5 billion); 
Actual as a percent of the 12/31/08 balance: 70.8%. 

Total asset losses: Credit card loans; 
Actual for year ended 12/31/09: $8.1 billion; 
2-year SCAP estimate: $21.2 billion; 
GAO 1-year pro rate estimate: $10.6 billion; 
Difference: ($2.5 billion); 
Actual as a percent of the 12/31/08 balance: 76.1%. 

Total asset losses: Securities (available for sale and held to 
maturity); 
Actual for year ended 12/31/09: ($1.1 billion); 
2-year SCAP estimate: $1.2 billion; 
GAO 1-year pro rate estimate: $0.6 billion; 
Difference: ($1.7 billion); 
Actual as a percent of the 12/31/08 balance: (185.0%). 

Total asset losses: Trading and counterparty; 
Actual for year ended 12/31/09: ($9.9 billion)[A]; 
2-year SCAP estimate: $16.7 billion; 
GAO 1-year pro rate estimate: $8.4 billion; 
Difference: ($1.82 billion); 
Actual as a percent of the 12/31/08 balance: (118.2%). 

Total asset losses: Other; 
Actual for year ended 12/31/09: $2.2 billion; 
2-year SCAP estimate: $5.3 billion; 
GAO 1-year pro rate estimate: $2.7 billion; 
Difference: ($0.4 billion); 
Actual as a percent of the 12/31/08 balance: 83.7%. 

Resources other than capital to absorb losses (Total PPNR less change 
in ALLL); 
Actual for year ended 12/31/09: $38.3 billion; 
2-year SCAP estimate: $72.4 billion; 
GAO 1-year pro rate estimate: $36.2 billion; 
Difference: $2.1 billion; 
Actual as a percent of the 12/31/08 balance: 109.5%. 

PPNR; 
Actual for year ended 12/31/09: $46.8 billion[B]; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Net interest income (expense); 
Actual for year ended 12/31/09: $51.3 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Noninterest income; 
Actual for year ended 12/31/09: $48.5[A]; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Less: noninterest expense; 
Actual for year ended 12/31/09: $53.0 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL); 
Actual for year ended 12/31/09: $8.4 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL): ALLL at 12/31/08; 
Actual for year ended 12/31/09: $23.2 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL): ALLL at 12/31/09; 
Actual for year ended 12/31/09: $31.6 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Source: GAO analysis of Federal Reserve and SNL Financial data. 

[A] The trading and counterparty data in the Y-9C includes both 
customer derived revenue from transactions for BHCs that operate as 
broker-dealers as well as gains and losses from proprietary trading 
and associated expenses. These items are presented in net form only in 
the Y-9C. For the five BHCs that had their trading portfolios stressed 
(including JPMorgan Chase & Co.), the trading and counterparty line is 
based on projections of (gains) losses from proprietary trading, but 
PPNR (specifically noninterest revenue) included projections of gains 
(losses) from customer derived revenue from transactions due to 
operations as a broker-dealer. Because we could not segregate these 
items based on the Y-9C, we have included the net amount in both the 
trading and counterparty and noninterest income line items above. As a 
result of this limitation, the net amount of the trading gains or 
losses and PPNR in the table may be overstated or understated. 

[B] PPNR includes an owned debt value adjustment of ($1.57) billion, 
which was not stressed in SCAP. As JPMorgan Chase & Co.'s credit 
spreads narrowed during 2009, this caused the liability values to 
increase. This offsets the gains JPMorgan Chase & Co. experienced in 
2008 when its credit spreads widened. 

[End of table] 

Table 22: KeyCorp: 

Dollars in billions: 

Tier 1 capital; 
Actual at 12/31/09: $11.0 billion; 
12/31/08 balance per SCAP: $11.6 billion; 
Difference: ($0.6) billion; 
12/31/09 as a percent of the 12/31/08 balance: 94.4%. 

Tier 1 common capital; 
Actual at 12/31/09: $6.4 billion; 
12/31/08 balance per SCAP: $6.0 billion; 
Difference: $0.4 billion; 
12/31/09 as a percent of the 12/31/08 balance: 107.4%. 

Risk-weighted assets; 
Actual at 12/31/09: $85.9 billion; 
12/31/08 balance per SCAP: $106.7 billion; 
Difference: ($20.8) billion; 
12/31/09 as a percent of the 12/31/08 balance: 80.5%. 

Tier 1 risk-based ratio; 
Actual at 12/31/09: 12.8%; 
12/31/08 balance per SCAP: 10.9%; 
Difference: 1.9%; 
12/31/09 as a percent of the 12/31/08 balance: 117.0%. 

Tier 1 common capital ratio; 
Actual at 12/31/09: 7.5%; 
12/31/08 balance per SCAP: 5.6%; 
Difference: 1.9%; 
12/31/09 as a percent of the 12/31/08 balance: 133.9%. 

Total asset losses; 
Actual for year ended 12/31/09: $2.3 billion; 
2-year SCAP estimate: $6.7 billion; 
GAO 1-year pro rate estimate: $3.3 billion; 
Difference: ($1.0 billion); 
Actual as a percent of the 12/31/08 balance: 69.3%. 

Total asset losses: First-lien mortgages; 
Actual for year ended 12/31/09: $0.0 billion; 
2-year SCAP estimate: $0.1 billion; 
GAO 1-year pro rate estimate: $0.1 billion; 
Difference: ($0.0 billion); 
Actual as a percent of the 12/31/08 balance: 55.7%. 

Total asset losses: Second/junior lien mortgages; 
Actual for year ended 12/31/09: $0.2 billion; 
2-year SCAP estimate: $0.6 billion; 
GAO 1-year pro rate estimate: $0.3 billion; 
Difference: ($0.1 billion); 
Actual as a percent of the 12/31/08 balance: 52.3%. 

Total asset losses: Commercial and industrial loans; 
Actual for year ended 12/31/09: $0.6 billion; 
2-year SCAP estimate: $1.7 billion; 
GAO 1-year pro rate estimate: $0.9 billion; 
Difference: ($0.2 billion); 
Actual as a percent of the 12/31/08 balance: 76.0%. 

Total asset losses: Commercial real estate loans; 
Actual for year ended 12/31/09: $1.0 billion; 
2-year SCAP estimate: $2.3 billion; 
GAO 1-year pro rate estimate: $1.2 billion; 
Difference: ($0.2 billion); 
Actual as a percent of the 12/31/08 balance: 85.8%. 

Total asset losses: Credit card loans; 
Actual for year ended 12/31/09: $0.0 billion; 
2-year SCAP estimate: $0.0 billion; 
GAO 1-year pro rate estimate: $0.0 billion; 
Difference: ($0.0 billion); 
Actual as a percent of the 12/31/08 balance: 44.4%. 

Total asset losses: Securities (available for sale and held to 
maturity); 
Actual for year ended 12/31/09: ($0.1 billion); 
2-year SCAP estimate: $0.1 billion; 
GAO 1-year pro rate estimate: $0.1 billion; 
Difference: ($0.2 billion); 
Actual as a percent of the 12/31/08 balance: (225.7%). 

Total asset losses: Trading and counterparty; 
Actual for year ended 12/31/09: [A]; 
2-year SCAP estimate: n/a; 
GAO 1-year pro rate estimate: n/a; 
Difference: n/a; 
Actual as a percent of the 12/31/08 balance: n/a. 

Total asset losses: Other; 
Actual for year ended 12/31/09: $0.6 billion; 
2-year SCAP estimate: $1.8 billion; 
GAO 1-year pro rate estimate: $0.9 billion; 
Difference: ($0.3 billion); 
Actual as a percent of the 12/31/08 balance: 64.6%. 

Resources other than capital to absorb losses (Total PPNR less change 
in ALLL); 
Actual for year ended 12/31/09: $0.1 billion; 
2-year SCAP estimate: $2.1 billion; 
GAO 1-year pro rate estimate: $1.1 billion; 
Difference: ($1.0 billion); 
Actual as a percent of the 12/31/08 balance: 5.3%. 

PPNR; 
Actual for year ended 12/31/09: $0.9 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Net interest income (expense); 
Actual for year ended 12/31/09: $2.4 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Noninterest income; 
Actual for year ended 12/31/09: $1.8[A]; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Less: noninterest expense; 
Actual for year ended 12/31/09: $3.3 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL); 
Actual for year ended 12/31/09: $0.9 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL): ALLL at 12/31/08; 
Actual for year ended 12/31/09: $1.8 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL): ALLL at 12/31/09; 
Actual for year ended 12/31/09: $2.7 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Source: GAO analysis of Federal Reserve and SNL Financial data. 

Note: N/a means not applicable. 

[A] Trading and counterparty positions were not stressed because the 
total portfolio is less than the $100 billion required for stress 
testing in SCAP, but trading (gain) loss information for this BHC was 
included in the "trading revenue" line of Schedule HI of the Y-9C in 
2009. In SCAP, the projections of trading gains or losses for this BHC 
were included in the estimate of PPNR rather than the trading and 
counterparty line. Therefore, we have included the actual trading 
results in PPNR (specifically noninterest income). 

[End of table] 

Table 23: MetLife, Inc. 

Dollars in billions: 

Tier 1 capital; 
Actual at 12/31/09: $28.8 billion; 
12/31/08 balance per SCAP: $30.1 billion; 
Difference: ($1.3 billion); 
12/31/09 as a percent of the 12/31/08 balance: 95.6%. 

Tier 1 common capital; 
Actual at 12/31/09: $26.4 billion; 
12/31/08 balance per SCAP: $27.8 billion; 
Difference: ($1.4 billion); 
12/31/09 as a percent of the 12/31/08 balance: 94.8%. 

Risk-weighted assets; 
Actual at 12/31/09: $322.8 billion; 
12/31/08 balance per SCAP: $326.4 billion; 
Difference: ($3.6) billion; 
12/31/09 as a percent of the 12/31/08 balance: 98.9%. 

Tier 1 risk-based ratio; 
Actual at 12/31/09: 8.9%; 
12/31/08 balance per SCAP: 9.2%; 
Difference: -0.3%; 
12/31/09 as a percent of the 12/31/08 balance: 96.9%. 

Tier 1 common capital ratio; 
Actual at 12/31/09: 8.2%; 
12/31/08 balance per SCAP: 8.5%; 
Difference: -0.3%; 
12/31/09 as a percent of the 12/31/08 balance: 96.1%. 

Total asset losses; 
Actual for year ended 12/31/09: $1.7 billion; 
2-year SCAP estimate: $9.6 billion; 
GAO 1-year pro rate estimate: $4.8 billion; 
Difference: ($3.1 billion); 
Actual as a percent of the 12/31/08 balance: 35.1%. 

Total asset losses: First-lien mortgages; 
Actual for year ended 12/31/09: $0.0 billion; 
2-year SCAP estimate: $0.0 billion; 
GAO 1-year pro rate estimate: $0.0 billion; 
Difference: ($0.0 billion); 
Actual as a percent of the 12/31/08 balance: 24.0%. 

Total asset losses: Second/junior lien mortgages; 
Actual for year ended 12/31/09: $0.0 billion; 
2-year SCAP estimate: $0.0 billion; 
GAO 1-year pro rate estimate: $0.0 billion; 
Difference: ($0.0 billion); 
Actual as a percent of the 12/31/08 balance: 0.0%. 

Total asset losses: Commercial and industrial loans; 
Actual for year ended 12/31/09: $0.0 billion; 
2-year SCAP estimate: $0.0 billion; 
GAO 1-year pro rate estimate: $0.0 billion; 
Difference: ($0.0 billion); 
Actual as a percent of the 12/31/08 balance: 0.0%. 

Total asset losses: Commercial real estate loans; 
Actual for year ended 12/31/09: $0.0 billion; 
2-year SCAP estimate: $0.8 billion; 
GAO 1-year pro rate estimate: $0.4 billion; 
Difference: ($0.4 billion); 
Actual as a percent of the 12/31/08 balance: 6.9%. 

Total asset losses: Credit card loans; 
Actual for year ended 12/31/09: $0.0 billion; 
2-year SCAP estimate: n/a; 
GAO 1-year pro rate estimate: n/a; 
Difference: n/a; 
Actual as a percent of the 12/31/08 balance: n/a%. 

Total asset losses: Securities (available for sale and held to 
maturity); 
Actual for year ended 12/31/09: $1.6 billion; 
2-year SCAP estimate: $8.3 billion; 
GAO 1-year pro rate estimate: $4.2 billion; 
Difference: ($2.5 billion); 
Actual as a percent of the 12/31/08 balance: 39.3%. 

Total asset losses: Trading and counterparty; 
Actual for year ended 12/31/09: [A]; 
2-year SCAP estimate: n/a; 
GAO 1-year pro rate estimate: n/a; 
Difference: n/a; 
Actual as a percent of the 12/31/08 balance: n/a. 

Total asset losses: Other; 
Actual for year ended 12/31/09: $0.0 billion; 
2-year SCAP estimate: $0.5 billion; 
GAO 1-year pro rate estimate: $0.3 billion; 
Difference: ($0.2 billion); 
Actual as a percent of the 12/31/08 balance: 10.7%. 

Resources other than capital to absorb losses (Total PPNR less change 
in ALLL); 
Actual for year ended 12/31/09: ($1.1 billion); 
2-year SCAP estimate: $5.6 billion; 
GAO 1-year pro rate estimate: $2.8 billion; 
Difference: ($3.9 billion); 
Actual as a percent of the 12/31/08 balance: (38.9%). 

PPNR; 
Actual for year ended 12/31/09: ($0.7 billion); 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Net interest income (expense); 
Actual for year ended 12/31/09: $14.1 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Noninterest income; 
Actual for year ended 12/31/09: $29.4[A]; 
2-year SCAP estimate: $44.1[B]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Less: noninterest expense; 
Actual for year ended 12/31/09: $44.1[B] billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL); 
Actual for year ended 12/31/09: $0.4 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL): ALLL at 12/31/08; 
Actual for year ended 12/31/09: $0.3 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL): ALLL at 12/31/09; 
Actual for year ended 12/31/09: $0.7 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Source: GAO analysis of Federal Reserve and SNL Financial data. 

Note: N/a means not applicable. 

[A] Trading and counterparty positions were not stressed because the 
total portfolio is less than the $100 billion required for stress 
testing in SCAP, but trading (gain) loss information for this BHC was 
included in the "trading revenue" line of Schedule HI of the Y-9C in 
2009. In SCAP, the projections of trading gains or losses for this BHC 
were included in the estimate of PPNR rather than the trading and 
counterparty line. Therefore, we have included the actual trading 
results in PPNR (specifically noninterest income). 

[B] MetLife, Inc. (MetLife) experienced high noninterest expense in 
2009 largely due to derivative losses from interest rate hedging, 
which protects MetLife against lower interest rates among other 
things. Similar to the owned debt value adjustment, as MetLife's 
credit spreads narrowed during 2009, this caused the liability values 
to increase. This offsets the gains MetLife experienced in 2008 when 
its credit spreads widened. 

[End of table] 

Table 24: Morgan Stanley: 

Dollars in billions: 

Tier 1 capital; 
Actual at 12/31/09: $46.7 billion; 
12/31/08 balance per SCAP: $47.2 billion; 
Difference: ($0.5 billion); 
12/31/09 as a percent of the 12/31/08 balance: 98.9%. 

Tier 1 common capital; 
Actual at 12/31/09: $20.5 billion; 
12/31/08 balance per SCAP: $17.8 billion; 
Difference: $2.7 billion; 
12/31/09 as a percent of the 12/31/08 balance: 115.0%. 

Risk-weighted assets; 
Actual at 12/31/09: $305.0 billion; 
12/31/08 balance per SCAP: $310.6 billion; 
Difference: ($5.6) billion; 
12/31/09 as a percent of the 12/31/08 balance: 98.2%. 

Tier 1 risk-based ratio; 
Actual at 12/31/09: 15.3%; 
12/31/08 balance per SCAP: 15.2%; 
Difference: 0.1%; 
12/31/09 as a percent of the 12/31/08 balance: 100.7%. 

Tier 1 common capital ratio; 
Actual at 12/31/09: 6.7%; 
12/31/08 balance per SCAP: 5.7%; 
Difference: 1.0%; 
12/31/09 as a percent of the 12/31/08 balance: 117.8%. 

Total asset losses; 
Actual for year ended 12/31/09: ($7.1 billion); 
2-year SCAP estimate: $19.7 billion; 
GAO 1-year pro rate estimate: $9.8 billion; 
Difference: ($16.9 billion); 
Actual as a percent of the 12/31/08 balance: -72.7%. 

Total asset losses: First-lien mortgages; 
Actual for year ended 12/31/09: $0.0 billion; 
2-year SCAP estimate: n/a; 
GAO 1-year pro rate estimate: n/a; 
Difference: n/a; 
Actual as a percent of the 12/31/08 balance: n/a. 

Total asset losses: Second/junior lien mortgages; 
Actual for year ended 12/31/09: $0.0 billion; 
2-year SCAP estimate: n/a; 
GAO 1-year pro rate estimate: n/a; 
Difference: n/a; 
Actual as a percent of the 12/31/08 balance: n/a. 

Total asset losses: Commercial and industrial loans; 
Actual for year ended 12/31/09: $0.0 billion; 
2-year SCAP estimate: $0.1 billion; 
GAO 1-year pro rate estimate: $0.1 billion; 
Difference: ($0.0 billion); 
Actual as a percent of the 12/31/08 balance: 20.0%. 

Total asset losses: Commercial real estate loans; 
Actual for year ended 12/31/09: $0.1 billion; 
2-year SCAP estimate: $0.6 billion; 
GAO 1-year pro rate estimate: $0.3 billion; 
Difference: ($0.2 billion); 
Actual as a percent of the 12/31/08 balance: 46.7%. 

Total asset losses: Credit card loans; 
Actual for year ended 12/31/09: $0.0 billion; 
2-year SCAP estimate: n/a; 
GAO 1-year pro rate estimate: n/a; 
Difference: n/a; 
Actual as a percent of the 12/31/08 balance: n/a. 

Total asset losses: Securities (available for sale and held to 
maturity); 
Actual for year ended 12/31/09: $0.0 billion; 
2-year SCAP estimate: n/a; 
GAO 1-year pro rate estimate: n/a; 
Difference: n/a; 
Actual as a percent of the 12/31/08 balance: n/a. 

Total asset losses: Trading and counterparty; 
Actual for year ended 12/31/09: (7.3%)[A]; 
2-year SCAP estimate: $18.7 billion; 
GAO 1-year pro rate estimate: $9.4 billion; 
Difference: ($16.6 billion); 
Actual as a percent of the 12/31/08 balance: -77.9%. 

Total asset losses: Other; 
Actual for year ended 12/31/09: $0.0 billion; 
2-year SCAP estimate: $0.2 billion; 
GAO 1-year pro rate estimate: $0.1 billion; 
Difference: ($0.1 billion); 
Actual as a percent of the 12/31/08 balance: 0.0%. 

Resources other than capital to absorb losses (Total PPNR less change 
in ALLL); 
Actual for year ended 12/31/09: $1.0 billion; 
2-year SCAP estimate: $7.1 billion; 
GAO 1-year pro rate estimate: $3.6 billion; 
Difference: ($2.5 billion); 
Actual as a percent of the 12/31/08 balance: 28.4%. 

PPNR; 
Actual for year ended 12/31/09: $3.6 billion[B,C]; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Net interest income (expense); 
Actual for year ended 12/31/09: $0.9 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Noninterest income; 
Actual for year ended 12/31/09: $22.7[A]; 
2-year SCAP estimate: $44.1[B]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Less: noninterest expense; 
Actual for year ended 12/31/09: $22.5 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL); 
Actual for year ended 12/31/09: $0.1 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL): ALLL at 12/31/08; 
Actual for year ended 12/31/09: $0.0 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL): ALLL at 12/31/09; 
Actual for year ended 12/31/09: $0.2 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Source: GAO analysis of Federal Reserve and SNL Financial data. 

Note: N/a means not applicable. 

[A] The trading and counterparty data in the Y-9C includes both 
customer derived revenue from transactions for BHCs that operate as 
broker-dealers as well as gains and losses from proprietary trading 
and associated expenses. These items are presented in net form only in 
the Y-9C. For the five BHCs that had their trading portfolios stressed 
(including Morgan Stanley), the trading and counterparty line is based 
on projections of (gains) losses from proprietary trading, but PPNR 
(specifically noninterest revenue) included projections of gains 
(losses) from customer derived revenue from transactions due to 
operations as a broker-dealer. Because we could not segregate these 
items based on the Y-9C, we have included the net amount in both the 
trading and counterparty and noninterest income line items above. As a 
result of this limitation, the net amount of the trading gains or 
losses and preprovision net revenue in the table may be overstated or 
understated. 

[B] PPNR includes an owned debt value adjustment of ($5.30) billion, 
which was not included as a stress in SCAP. As Morgan Stanley's credit 
spreads narrowed during 2009, this caused the liability values to 
increase. This offsets the gains Morgan Stanley experienced in 2008 
when its credit spreads widened. 

[C] PPNR includes one-time items totaling $710 million, which were not 
included in SCAP. 

[End of table] 

Table 25: PNC Financial Services Group, Inc. 

Dollars in billions: 

Tier 1 capital; 
Actual at 12/31/09: $26.5 billion; 
12/31/08 balance per SCAP: $24.1 billion; 
Difference: $2.4 billion; 
12/31/09 as a percent of the 12/31/08 balance: 110.1%. 

Tier 1 common capital; 
Actual at 12/31/09: $13.9 billion; 
12/31/08 balance per SCAP: $11.7 billion; 
Difference: $2.2 billion; 
12/31/09 as a percent of the 12/31/08 balance: 119.2%. 

Risk-weighted assets; 
Actual at 12/31/09: $232.3 billion; 
12/31/08 balance per SCAP: $250.9 billion; 
Difference: ($18.6) billion; 
12/31/09 as a percent of the 12/31/08 balance: 92.6%. 

Tier 1 risk-based ratio; 
Actual at 12/31/09: 11.4%; 
12/31/08 balance per SCAP: 9.6%; 
Difference: 1.8%; 
12/31/09 as a percent of the 12/31/08 balance: 119.0%. 

Tier 1 common capital ratio; 
Actual at 12/31/09: 6.0%; 
12/31/08 balance per SCAP: 4.7%; 
Difference: 1.3%; 
12/31/09 as a percent of the 12/31/08 balance: 127.7%. 

Total asset losses; 
Actual for year ended 12/31/09: $2.7 billion; 
2-year SCAP estimate: $18.8 billion; 
GAO 1-year pro rate estimate: $9.4 billion; 
Difference: $6.6 billion; 
Actual as a percent of the 12/31/08 balance: 29.3%. 

Total asset losses: First-lien mortgages; 
Actual for year ended 12/31/09: $0.1 billion; 
2-year SCAP estimate: $2.4 billion; 
GAO 1-year pro rate estimate: $1.2 billion; 
Difference: ($1.1 billion); 
Actual as a percent of the 12/31/08 balance: 4.6%. 

Total asset losses: Second/junior lien mortgages; 
Actual for year ended 12/31/09: $0.4 billion; 
2-year SCAP estimate: $4.6 billion; 
GAO 1-year pro rate estimate: $2.3 billion; 
Difference: ($1.9 billion); 
Actual as a percent of the 12/31/08 balance: 19.4%. 

Total asset losses: Commercial and industrial loans; 
Actual for year ended 12/31/09: $0.9 billion; 
2-year SCAP estimate: $3.2 billion; 
GAO 1-year pro rate estimate: $1.6 billion; 
Difference: ($0.7 billion); 
Actual as a percent of the 12/31/08 balance: 57.8%. 

Total asset losses: Commercial real estate loans; 
Actual for year ended 12/31/09: $0.8 billion; 
2-year SCAP estimate: $4.5 billion; 
GAO 1-year pro rate estimate: $2.3 billion; 
Difference: ($1.5 billion); 
Actual as a percent of the 12/31/08 balance: 33.4%. 

Total asset losses: Credit card loans; 
Actual for year ended 12/31/09: $0.2 billion; 
2-year SCAP estimate: $0.4 billion; 
GAO 1-year pro rate estimate: $0.2 billion; 
Difference: ($0.0 billion); 
Actual as a percent of the 12/31/08 balance: 85.6%. 

Total asset losses: Securities (available for sale and held to 
maturity); 
Actual for year ended 12/31/09: ($0.0 billion); 
2-year SCAP estimate: $1.3 billion; 
GAO 1-year pro rate estimate: $0.7 billion; 
Difference: ($0.6 billion); 
Actual as a percent of the 12/31/08 balance: 4.2%. 

Total asset losses: Trading and counterparty; 
Actual for year ended 12/31/09: [A]; 
2-year SCAP estimate: n/a; 
GAO 1-year pro rate estimate: n/a; 
Difference: n/a; 
Actual as a percent of the 12/31/08 balance: n/a. 

Total asset losses: Other; 
Actual for year ended 12/31/09: $0.4 billion; 
2-year SCAP estimate: $2.3 billion; 
GAO 1-year pro rate estimate: $1.2 billion; 
Difference: ($0.8 billion); 
Actual as a percent of the 12/31/08 balance: 31.4%. 

Resources other than capital to absorb losses (Total PPNR less change 
in ALLL); 
Actual for year ended 12/31/09: $6.2 billion; 
2-year SCAP estimate: $9.6 billion; 
GAO 1-year pro rate estimate: $4.8 billion; 
Difference: $1.4 billion; 
Actual as a percent of the 12/31/08 balance: 128.6%. 

PPNR; 
Actual for year ended 12/31/09: $7.3 billion[B]; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Net interest income (expense); 
Actual for year ended 12/31/09: $9.1 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Noninterest income; 
Actual for year ended 12/31/09: $7.9[A]; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Less: noninterest expense; 
Actual for year ended 12/31/09: $9.6 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL); 
Actual for year ended 12/31/09: $1.2 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL): ALLL at 12/31/08; 
Actual for year ended 12/31/09: $3.9 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL): ALLL at 12/31/09; 
Actual for year ended 12/31/09: $5.1 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Source: GAO analysis of Federal Reserve and SNL Financial data. 

Note: N/a means not applicable. 

[A] Trading and counterparty positions were not stressed because the 
total portfolio is less than the $100 billion required for stress 
testing in SCAP, but trading (gain) loss information for this BHC was 
included in the "trading revenue" line of Schedule HI of the Y-9C in 
2009. In SCAP, the projections of trading gains or losses for this BHC 
were included in the estimate of PPNR rather than the trading and 
counterparty line. Therefore, we have included the actual trading 
results in PPNR (specifically noninterest income). 

[B] PPNR includes one-time items totaling $1.08 billion, which were 
not included in SCAP. 

[End of table] 

Table 26: Regions Financial Corporation: 

Dollars in billions: 

Tier 1 capital; 
Actual at 12/31/09: $11.9 billion; 
12/31/08 balance per SCAP: $12.1 billion; 
Difference: ($0.2 billion); 
12/31/09 as a percent of the 12/31/08 balance: 98.5%. 

Tier 1 common capital; 
Actual at 12/31/09: $7.4 billion; 
12/31/08 balance per SCAP: $7.6 billion; 
Difference: ($0.2 billion); 
12/31/09 as a percent of the 12/31/08 balance: 97.2%. 

Risk-weighted assets; 
Actual at 12/31/09: $103.3 billion; 
12/31/08 balance per SCAP: $116.3 billion; 
Difference: ($13.0) billion; 
12/31/09 as a percent of the 12/31/08 balance: 88.8%. 

Tier 1 risk-based ratio; 
Actual at 12/31/09: 11.5%; 
12/31/08 balance per SCAP: 10.4%; 
Difference: 1.1%; 
12/31/09 as a percent of the 12/31/08 balance: 111.0%. 

Tier 1 common capital ratio; 
Actual at 12/31/09: 7.1%; 
12/31/08 balance per SCAP: 6.6%; 
Difference: 0.5%; 
12/31/09 as a percent of the 12/31/08 balance: 108.3%. 

Total asset losses; 
Actual for year ended 12/31/09: $2.2 billion; 
2-year SCAP estimate: $9.2 billion; 
GAO 1-year pro rate estimate: $4.6 billion; 
Difference: ($2.4 billion); 
Actual as a percent of the 12/31/08 balance: 48.8%. 

Total asset losses: First-lien mortgages; 
Actual for year ended 12/31/09: $0.2 billion; 
2-year SCAP estimate: $1.0 billion; 
GAO 1-year pro rate estimate: $0.5 billion; 
Difference: ($0.3 billion); 
Actual as a percent of the 12/31/08 balance: 36.7%. 

Total asset losses: Second/junior lien mortgages; 
Actual for year ended 12/31/09: $0.4 billion; 
2-year SCAP estimate: $1.1 billion; 
GAO 1-year pro rate estimate: $0.6 billion; 
Difference: ($0.2 billion); 
Actual as a percent of the 12/31/08 balance: 72.0%. 

Total asset losses: Commercial and industrial loans; 
Actual for year ended 12/31/09: $0.3 billion; 
2-year SCAP estimate: $1.2 billion; 
GAO 1-year pro rate estimate: $0.6 billion; 
Difference: ($0.3 billion); 
Actual as a percent of the 12/31/08 balance: 43.2%. 

Total asset losses: Commercial real estate loans; 
Actual for year ended 12/31/09: $1.1 billion; 
2-year SCAP estimate: $4.9 billion; 
GAO 1-year pro rate estimate: $2.5 billion; 
Difference: ($1.3 billion); 
Actual as a percent of the 12/31/08 balance: 46.7%. 

Total asset losses: Credit card loans; 
Actual for year ended 12/31/09: $0.0 billion; 
2-year SCAP estimate: n/a; 
GAO 1-year pro rate estimate: n/a; 
Difference: n/a; 
Actual as a percent of the 12/31/08 balance: n/a. 

Total asset losses: Securities (available for sale and held to 
maturity); 
Actual for year ended 12/31/09: ($0.0 billion); 
2-year SCAP estimate: $0.2 billion; 
GAO 1-year pro rate estimate: $0.1 billion; 
Difference: ($0.1 billion); 
Actual as a percent of the 12/31/08 balance: (6.4%). 

Total asset losses: Trading and counterparty; 
Actual for year ended 12/31/09: [A]; 
2-year SCAP estimate: n/a; 
GAO 1-year pro rate estimate: n/a; 
Difference: n/a; 
Actual as a percent of the 12/31/08 balance: n/a. 

Total asset losses: Other; 
Actual for year ended 12/31/09: $0.3 billion; 
2-year SCAP estimate: $0.8 billion; 
GAO 1-year pro rate estimate: $0.4 billion; 
Difference: ($0.1 billion); 
Actual as a percent of the 12/31/08 balance: 67.9%. 

Resources other than capital to absorb losses (Total PPNR less change 
in ALLL); 
Actual for year ended 12/31/09: $1.1 billion; 
2-year SCAP estimate: $3.3 billion; 
GAO 1-year pro rate estimate: $1.7 billion; 
Difference: ($0.6 billion); 
Actual as a percent of the 12/31/08 balance: 64.9%. 

PPNR; 
Actual for year ended 12/31/09: $2.4 billion[B]; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Net interest income (expense); 
Actual for year ended 12/31/09: $3.3 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Noninterest income; 
Actual for year ended 12/31/09: $3.5 billion[A]; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Less: noninterest expense; 
Actual for year ended 12/31/09: $4.5 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL); 
Actual for year ended 12/31/09: $1.3 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL): ALLL at 12/31/08; 
Actual for year ended 12/31/09: $1.8 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL): ALLL at 12/31/09; 
Actual for year ended 12/31/09: $3.1 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Source: GAO analysis of Federal Reserve and SNL Financial data. 

Note: N/a means not applicable. 

[A] Trading and counterparty positions were not stressed because the 
total portfolio is less than the $100 billion required for stress 
testing in SCAP, but trading (gain) loss information for this BHC was 
included in the "trading revenue" line of Schedule HI of the Y-9C in 
2009. In SCAP, the projections of trading gains or losses for this BHC 
were included in the estimate of PPNR rather than the trading and 
counterparty line. Therefore, we have included the actual trading 
results in PPNR (specifically noninterest income). 

[B] PPNR includes one-time items totaling $140 million, which were not 
included in SCAP. 

[End of table] 

Table 27: State Street Corporation: 

Dollars in billions: 

Tier 1 capital; 
Actual at 12/31/09: $12.0 billion; 
12/31/08 balance per SCAP: $14.1 billion; 
Difference: ($2.1) billion; 
12/31/09 as a percent of the 12/31/08 balance: 85.1%. 

Tier 1 common capital; 
Actual at 12/31/09: $10.6 billion; 
12/31/08 balance per SCAP: $10.8 billion; 
Difference: ($0.2) billion; 
12/31/09 as a percent of the 12/31/08 balance: 97.7%. 

Risk-weighted assets; 
Actual at 12/31/09: $67.7 billion; 
12/31/08 balance per SCAP: $69.6 billion; 
Difference: ($1.9) billion; 
12/31/09 as a percent of the 12/31/08 balance: 97.3%. 

Tier 1 risk-based ratio; 
Actual at 12/31/09: 17.7%; 
12/31/08 balance per SCAP: 20.2%; 
Difference: (2.5%); 
12/31/09 as a percent of the 12/31/08 balance: 87.8%. 

Tier 1 common capital ratio; 
Actual at 12/31/09: 15.6%; 
12/31/08 balance per SCAP: 15.5%; 
Difference: 0.1%; 
12/31/09 as a percent of the 12/31/08 balance: 100.6%. 

Total asset losses; 
Actual for year ended 12/31/09: ($0.1) billion; 
2-year SCAP estimate: $2.2 billion; 
GAO 1-year pro rate estimate: $1.1 billion; 
Difference: ($1.2 billion); 
Actual as a percent of the 12/31/08 balance: (4.7%). 

Total asset losses: First-lien mortgages; 
Actual for year ended 12/31/09: 0.0; 
2-year SCAP estimate: n/a; 
GAO 1-year pro rate estimate: n/a; 
Difference: n/a; 
Actual as a percent of the 12/31/08 balance: n/a. 

Total asset losses: Second/junior lien mortgages; 
Actual for year ended 12/31/09: 0.0; 
2-year SCAP estimate: n/a; 
GAO 1-year pro rate estimate: n/a; 
Difference: n/a; 
Actual as a percent of the 12/31/08 balance: n/a. 

Total asset losses: Commercial and industrial loans; 
Actual for year ended 12/31/09: 0.0; 
2-year SCAP estimate: 0.0; 
GAO 1-year pro rate estimate: 0.0; 
Difference: 0.0; 
Actual as a percent of the 12/31/08 balance: 0.0. 

Total asset losses: Commercial real estate loans; 
Actual for year ended 12/31/09: $0.1 billion; 
2-year SCAP estimate: $0.3 billion; 
GAO 1-year pro rate estimate: $0.2 billion; 
Difference: ($0.1 billion); 
Actual as a percent of the 12/31/08 balance: 46.5%. 

Total asset losses: Credit card loans; 
Actual for year ended 12/31/09: 0.0; 
2-year SCAP estimate: n/a; 
GAO 1-year pro rate estimate: n/a; 
Difference: n/a; 
Actual as a percent of the 12/31/08 balance: n/a. 

Total asset losses: Securities (available for sale and held to 
maturity); 
Actual for year ended 12/31/09: ($0.1 billion); 
2-year SCAP estimate: $1.8 billion; 
GAO 1-year pro rate estimate: $0.9 billion; 
Difference: ($1.0 billion); 
Actual as a percent of the 12/31/08 balance: (15.6%). 

Total asset losses: Trading and counterparty; 
Actual for year ended 12/31/09: [A]; 
2-year SCAP estimate: n/a; 
GAO 1-year pro rate estimate: n/a; 
Difference: n/a; 
Actual as a percent of the 12/31/08 balance: n/a. 

Total asset losses: Other; 
Actual for year ended 12/31/09: $0.0; 
2-year SCAP estimate: $0.1 billion; 
GAO 1-year pro rate estimate: $0.1 billion; 
Difference: ($0.0 billion); 
Actual as a percent of the 12/31/08 balance: 37.5%. 

Total asset losses: One-time items in SCAP[B]; 
Actual for year ended 12/31/09: $6.1 billion; 
2-year SCAP estimate: $5.9 billion; 
GAO 1-year pro rate estimate: n/a; 
Difference: $0.2 billion; 
Actual as a percent of the 12/31/08 balance: 103.4%. 

Resources other than capital to absorb losses (Total PPNR less change 
in ALLL); 
Actual for year ended 12/31/09: $2.5 billion; 
2-year SCAP estimate: $4.3 billion; 
GAO 1-year pro rate estimate: $2.2 billion; 
Difference: $0.3 billion; 
Actual as a percent of the 12/31/08 balance: 115.1%. 

PPNR; 
Actual for year ended 12/31/09: $2.5 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Net interest income (expense); 
Actual for year ended 12/31/09: $2.6 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Noninterest income; 
Actual for year ended 12/31/09: $5.9[A]; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Less: noninterest expense; 
Actual for year ended 12/31/09: $6.0 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL); 
Actual for year ended 12/31/09: $0.1 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL): ALLL at 12/31/08; 
Actual for year ended 12/31/09: $0.0 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL): ALLL at 12/31/09; 
Actual for year ended 12/31/09: $0.1 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Source: GAO analysis of Federal Reserve and SNL Financial data. 

Note: N/a means not applicable. 

[A] Trading and counterparty positions were not stressed because the 
total portfolio is less than the $100 billion required for stress 
testing in SCAP, but trading (gain) loss information for this BHC was 
included in the "trading revenue" line of Schedule HI of the Y-9C in 
2009. In SCAP, the projections of trading gains or losses for this BHC 
were included in the estimate of PPNR rather than the trading and 
counterparty line. Therefore, we have included the actual trading 
results in PPNR (specifically noninterest income): 

[B] We broke out "other" losses into two categories--"Other" and "One- 
time items." As discussed in State Street Corporation's (State Street) 
May 7, 2009, press release, $5.9 billion of the amount listed in the 
"Other" category in the SCAP results was a pretax charge that was 
expected to occur when certain asset-backed commercial paper conduits 
administered by State Street were consolidated onto its balance sheet 
in 2009. Since this was a one-time charge that was realized in 2009, 
this effect was segregated from more typical loss amounts for tracking 
purposes. Upon consolidation, the actual amount realized was $6.1 
billion, as reported in State Street's Form 10-Q for the second 
quarter of 2009. 

[End of table] 

Table 28: SunTrust Banks, Inc. 

Dollars in billions: 

Tier 1 capital; 
Actual at 12/31/09: $18.1 billion; 
12/31/08 balance per SCAP: $17.6 billion; 
Difference: $0.5 billion; 
12/31/09 as a percent of the 12/31/08 balance: 10.7%. 

Tier 1 common capital; 
Actual at 12/31/09: $10.7 billion; 
12/31/08 balance per SCAP: $9.4 billion; 
Difference: $1.3 billion; 
12/31/09 as a percent of the 12/31/08 balance: 113.7%. 

Risk-weighted assets; 
Actual at 12/31/09: $139.4 billion; 
12/31/08 balance per SCAP: $162.0 billion; 
Difference: ($22.6) billion; 
12/31/09 as a percent of the 12/31/08 balance: 86.0%. 

Tier 1 risk-based ratio; 
Actual at 12/31/09: 13.0%; 
12/31/08 balance per SCAP: 10.9%; 
Difference: 2.1%; 
12/31/09 as a percent of the 12/31/08 balance: 118.9%. 

Tier 1 common capital ratio; 
Actual at 12/31/09: 7.7%; 
12/31/08 balance per SCAP: 5.8%; 
Difference: 1.9%; 
12/31/09 as a percent of the 12/31/08 balance: 132.3%. 

Total asset losses; 
Actual for year ended 12/31/09: $3.1 billion; 
2-year SCAP estimate: $11.8 billion; 
GAO 1-year pro rate estimate: $5.9 billion; 
Difference: ($2.8 billion); 
Actual as a percent of the 12/31/08 balance: 53.1%. 

Total asset losses: First-lien mortgages; 
Actual for year ended 12/31/09: $1.1 billion; 
2-year SCAP estimate: $2.2 billion; 
GAO 1-year pro rate estimate: $1.1 billion; 
Difference: ($0.0 billion); 
Actual as a percent of the 12/31/08 balance: 101.5%. 

Total asset losses: Second/junior lien mortgages; 
Actual for year ended 12/31/09: $0.8 billion; 
2-year SCAP estimate: $3.1 billion; 
GAO 1-year pro rate estimate: $1.6 billion; 
Difference: ($0.8 billion); 
Actual as a percent of the 12/31/08 balance: 48.8%. 

Total asset losses: Commercial and industrial loans; 
Actual for year ended 12/31/09: $0.5 billion; 
2-year SCAP estimate: $1.5 billion; 
GAO 1-year pro rate estimate: $0.8 billion; 
Difference: ($0.2 billion); 
Actual as a percent of the 12/31/08 balance: 69.9%. 

Total asset losses: Commercial real estate loans; 
Actual for year ended 12/31/09: $0.6 billion; 
2-year SCAP estimate: $2.8 billion; 
GAO 1-year pro rate estimate: $1.4 billion; 
Difference: ($0.8 billion); 
Actual as a percent of the 12/31/08 balance: 39.8%. 

Total asset losses: Credit card loans; 
Actual for year ended 12/31/09: $0.1 billion; 
2-year SCAP estimate: $0.1 billion; 
GAO 1-year pro rate estimate: $0.1 billion; 
Difference: $0.0 billion; 
Actual as a percent of the 12/31/08 balance: 115.3%. 

Total asset losses: Securities (available for sale and held to 
maturity); 
Actual for year ended 12/31/09: ($0.1 billion); 
2-year SCAP estimate: $0.0 billion; 
GAO 1-year pro rate estimate: $0.0 billion; 
Difference: ($0.1 billion); 
Actual as a percent of the 12/31/08 balance: (980.2%). 

Total asset losses: Trading and counterparty; 
Actual for year ended 12/31/09: [A]; 
2-year SCAP estimate: n/a; 
GAO 1-year pro rate estimate: n/a; 
Difference: n/a; 
Actual as a percent of the 12/31/08 balance: n/a. 

Total asset losses: Other; 
Actual for year ended 12/31/09: $0.2 billion; 
2-year SCAP estimate: $2.1 billion; 
GAO 1-year pro rate estimate: $1.1 billion; 
Difference: ($0.8 billion); 
Actual as a percent of the 12/31/08 balance: 21.6%. 

Resources other than capital to absorb losses (Total PPNR less change 
in ALLL); 
Actual for year ended 12/31/09: $1.4 billion; 
2-year SCAP estimate: $4.7 billion; 
GAO 1-year pro rate estimate: $2.4 billion; 
Difference: ($0.9 billion); 
Actual as a percent of the 12/31/08 balance: 61.3%. 

PPNR; 
Actual for year ended 12/31/09: $2.2 billion [B,C]; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Net interest income (expense); 
Actual for year ended 12/31/09: $4.5 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Noninterest income; 
Actual for year ended 12/31/09: $3.6[B] billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Less: noninterest expense; 
Actual for year ended 12/31/09: $5.9 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL); 
Actual for year ended 12/31/09: $0.8 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL): ALLL at 12/31/08; 
Actual for year ended 12/31/09: $2.4 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL): ALLL at 12/31/09; 
Actual for year ended 12/31/09: $3.1 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Source: GAO analysis of Federal Reserve and SNL Financial data. 

Note: N/a means not applicable. 

[A] Trading and counterparty positions were not stressed because the 
total portfolio is less than the $100 billion required for stress 
testing in SCAP, but trading (gain) loss information for this BHC was 
included in the "trading revenue" line of Schedule HI of the Y-9C in 
2009. In SCAP, the projections of trading gains or losses for this BHC 
were included in the estimate of PPNR rather than the trading and 
counterparty line. Therefore, we have included the actual trading 
results in PPNR (specifically noninterest income). 

[B] PPNR includes an owned debt value adjustment of ($150) million, 
which was not stressed in SCAP. As SunTrust Banks Inc.'s credit 
spreads narrowed during 2009, this caused the liability values to 
increase. This offsets the gains SunTrust experienced in 2008 when its 
credit spreads widened. 

[C] PPNR includes one-time items totaling $110 million, which were not 
included in SCAP. 

[End of table] 

Table 29: U.S. Bancorp: 

Dollars in billions: 

Tier 1 capital; 
Actual at 12/31/09: $22.6 billion; 
12/31/08 balance per SCAP: $24.4 billion; 
Difference: ($1.8) billion; 
12/31/09 as a percent of the 12/31/08 balance: 92.7%. 

Tier 1 common capital; 
Actual at 12/31/09: $15.9 billion; 
12/31/08 balance per SCAP: $11.8 billion; 
Difference: $4.1 billion; 
12/31/09 as a percent of the 12/31/08 balance: 134.7%. 

Risk-weighted assets; 
Actual at 12/31/09: $235.2 billion; 
12/31/08 balance per SCAP: $230.6 billion; 
Difference: $4.6 billion; 
12/31/09 as a percent of the 12/31/08 balance: 102.0%. 

Tier 1 risk-based ratio; 
Actual at 12/31/09: 9.6%; 
12/31/08 balance per SCAP: 10.6%; 
Difference: (1.0%); 
12/31/09 as a percent of the 12/31/08 balance: 90.7%. 

Tier 1 common capital ratio; 
Actual at 12/31/09: 6.8%; 
12/31/08 balance per SCAP: 5.1%; 
Difference: 1.7%; 
12/31/09 as a percent of the 12/31/08 balance: 132.5%. 

Total asset losses; 
Actual for year ended 12/31/09: $4.3 billion; 
2-year SCAP estimate: $15.7 billion; 
GAO 1-year pro rate estimate: $8.0 billion; 
Difference: ($3.6 billion); 
Actual as a percent of the 12/31/08 balance: 54.3%. 

Total asset losses: First-lien mortgages; 
Actual for year ended 12/31/09: $0.5 billion; 
2-year SCAP estimate: $1.8 billion; 
GAO 1-year pro rate estimate: $0.9 billion; 
Difference: ($0.4 billion); 
Actual as a percent of the 12/31/08 balance: 54.3%. 

Total asset losses: Second/junior lien mortgages; 
Actual for year ended 12/31/09: $0.3 billion; 
2-year SCAP estimate: $1.7 billion; 
GAO 1-year pro rate estimate: $0.9 billion; 
Difference: ($0.5 billion); 
Actual as a percent of the 12/31/08 balance: 39.8%. 

Total asset losses: Commercial and industrial loans; 
Actual for year ended 12/31/09: $0.6 billion; 
2-year SCAP estimate: $2.3 billion; 
GAO 1-year pro rate estimate: $1.2 billion; 
Difference: ($0.6 billion); 
Actual as a percent of the 12/31/08 balance: 50.9%. 

Total asset losses: Commercial real estate loans; 
Actual for year ended 12/31/09: $0.6 billion; 
2-year SCAP estimate: $3.2 billion; 
GAO 1-year pro rate estimate: $1.6 billion; 
Difference: ($1.0 billion); 
Actual as a percent of the 12/31/08 balance: 38.6%. 

Total asset losses: Credit card loans; 
Actual for year ended 12/31/09: $1.0 billion; 
2-year SCAP estimate: $2.8 billion; 
GAO 1-year pro rate estimate: $1.4 billion; 
Difference: ($0.4 billion); 
Actual as a percent of the 12/31/08 balance: 73.6%. 

Total asset losses: Securities (available for sale and held to 
maturity); 
Actual for year ended 12/31/09: $0.5 billion; 
2-year SCAP estimate: $1.3 billion; 
GAO 1-year pro rate estimate: $0.7 billion; 
Difference: ($0.2 billion); 
Actual as a percent of the 12/31/08 balance: 69.4%. 

Total asset losses: Trading and counterparty; 
Actual for year ended 12/31/09: [A]; 
2-year SCAP estimate: n/a; 
GAO 1-year pro rate estimate: n/a; 
Difference: n/a; 
Actual as a percent of the 12/31/08 balance: n/a. 

Total asset losses: Other; 
Actual for year ended 12/31/09: $0.8 billion; 
2-year SCAP estimate: $2.8 billion; 
GAO 1-year pro rate estimate: $1.4 billion; 
Difference: ($0.6 billion); 
Actual as a percent of the 12/31/08 balance: 57.7%. 

Resources other than capital to absorb losses (Total PPNR less change 
in ALLL); 
Actual for year ended 12/31/09: $7.1 billion; 
2-year SCAP estimate: $13.7 billion; 
GAO 1-year pro rate estimate: $6.9 billion; 
Difference: $0.2 billion; 
Actual as a percent of the 12/31/08 balance: 103.3%. 

PPNR; 
Actual for year ended 12/31/09: $8.6 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Net interest income (expense); 
Actual for year ended 12/31/09: $8.5 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Noninterest income; 
Actual for year ended 12/31/09: $8.4[B]; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Less: noninterest expense; 
Actual for year ended 12/31/09: $8.3 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL); 
Actual for year ended 12/31/09: $1.6 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL): ALLL at 12/31/08; 
Actual for year ended 12/31/09: $3.5 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL): ALLL at 12/31/09; 
Actual for year ended 12/31/09: $5.1 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Source: GAO analysis of Federal Reserve and SNL Financial data. 

Note: N/a means not applicable. 

[A] Trading and counterparty positions were not stressed because the 
total portfolio is less than the $100 billion required for stress 
testing in SCAP, but trading (gain) loss information for this BHC was 
included in the "trading revenue" line of Schedule HI of the Y-9C in 
2009. In SCAP, the projections of trading gains or losses for this BHC 
were included in the estimate of PPNR rather than the trading and 
counterparty line. Therefore, we have included the actual trading 
results in PPNR (specifically noninterest income). 

[End of table] 

Table 30: Wells Fargo & Company: 

Dollars in billions: 

Tier 1 capital; 
Actual at 12/31/09: $93.8 billion; 
12/31/08 balance per SCAP: $86.4 billion; 
Difference: $7.4 billion; 
12/31/09 as a percent of the 12/31/08 balance: 108.6%. 

Tier 1 common capital; 
Actual at 12/31/09: $65.5[A] billion; 
12/31/08 balance per SCAP: $33.9 billion; 
Difference: $3.6 billion; 
12/31/09 as a percent of the 12/31/08 balance: 193.2%. 

Risk-weighted assets; 
Actual at 12/31/09: $1,013.6 billion; 
12/31/08 balance per SCAP: $1,082.3 billion; 
Difference: ($68.7) billion; 
12/31/09 as a percent of the 12/31/08 balance: 93.7%. 

Tier 1 risk-based ratio; 
Actual at 12/31/09: 9.3%; 
12/31/08 balance per SCAP: 8.0%; 
Difference: 1.3%; 
12/31/09 as a percent of the 12/31/08 balance: 115.7%. 

Tier 1 common capital ratio; 
Actual at 12/31/09: 6.5%; 
12/31/08 balance per SCAP: 3.1%; 
Difference: 3.4%; 
12/31/09 as a percent of the 12/31/08 balance: 208.4%. 

Total asset losses; 
Actual for year ended 12/31/09: $18.0 billion; 
2-year SCAP estimate: $86.1 billion; 
GAO 1-year pro rate estimate: $43.1 billion; 
Difference: ($25.1 billion); 
Actual as a percent of the 12/31/08 balance: 41.7%. 

Total asset losses: First-lien mortgages; 
Actual for year ended 12/31/09: $3.0 billion; 
2-year SCAP estimate: $32.4 billion; 
GAO 1-year pro rate estimate: $16.2 billion; 
Difference: ($13.2 billion); 
Actual as a percent of the 12/31/08 balance: 18.4%. 

Total asset losses: Second/junior lien mortgages; 
Actual for year ended 12/31/09: $4.9 billion; 
2-year SCAP estimate: $14.7 billion; 
GAO 1-year pro rate estimate: $7.4 billion; 
Difference: ($2.5 billion); 
Actual as a percent of the 12/31/08 balance: 66.1%. 

Total asset losses: Commercial and industrial loans; 
Actual for year ended 12/31/09: $2.8 billion; 
2-year SCAP estimate: $9.0 billion; 
GAO 1-year pro rate estimate: $4.5 billion; 
Difference: ($1.7 billion); 
Actual as a percent of the 12/31/08 balance: 61.5%. 

Total asset losses: Commercial real estate loans; 
Actual for year ended 12/31/09: $1.5 billion; 
2-year SCAP estimate: $8.4 billion; 
GAO 1-year pro rate estimate: $4.2 billion; 
Difference: ($2.7 billion); 
Actual as a percent of the 12/31/08 balance: 35.8%. 

Total asset losses: Credit card loans; 
Actual for year ended 12/31/09: $2.6 billion; 
2-year SCAP estimate: $6.1 billion; 
GAO 1-year pro rate estimate: $3.1 billion; 
Difference: ($0.5 billion); 
Actual as a percent of the 12/31/08 balance: 83.7%. 

Total asset losses: Securities (available for sale and held to 
maturity); 
Actual for year ended 12/31/09: ($0.2 billion); 
2-year SCAP estimate: $4.2 billion; 
GAO 1-year pro rate estimate: $2.1 billion; 
Difference: ($2.3 billion); 
Actual as a percent of the 12/31/08 balance: (9.8%). 

Total asset losses: Trading and counterparty; 
Actual for year ended 12/31/09: [B]; 
2-year SCAP estimate: n/a; 
GAO 1-year pro rate estimate: n/a; 
Difference: n/a; 
Actual as a percent of the 12/31/08 balance: n/a. 

Total asset losses: Other; 
Actual for year ended 12/31/09: $3.5 billion; 
2-year SCAP estimate: $11.3 billion; 
GAO 1-year pro rate estimate: $5.7 billion; 
Difference: ($2.1 billion); 
Actual as a percent of the 12/31/08 balance: 62.1%. 

Resources other than capital to absorb losses (Total PPNR less change 
in ALLL); 
Actual for year ended 12/31/09: $36.1 billion; 
2-year SCAP estimate: $60.0 billion; 
GAO 1-year pro rate estimate: $30.0 billion; 
Difference: $6.1 billion; 
Actual as a percent of the 12/31/08 balance: 120.5%. 

PPNR; 
Actual for year ended 12/31/09: $39.6 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Net interest income (expense); 
Actual for year ended 12/31/09: $46.9 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Noninterest income; 
Actual for year ended 12/31/09: $41.5[B]; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

PPNR: Less: noninterest expense; 
Actual for year ended 12/31/09: $48.8 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL); 
Actual for year ended 12/31/09: $3.5 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL): ALLL at 12/31/08; 
Actual for year ended 12/31/09: $1.0 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Change in allowance for loan and lease losses (ALLL): ALLL at 12/31/09; 
Actual for year ended 12/31/09: $24.5 billion; 
2-year SCAP estimate: [Empty]; 
GAO 1-year pro rate estimate: [Empty]; 
Difference: [Empty]; 
Actual as a percent of the 12/31/08 balance: [Empty]. 

Source: GAO analysis of Federal Reserve and SNL Financial data. 

Note: N/a means not applicable. 

[A] The tier 1 common calculation has been adjusted to provide for 
appropriate treatment of preferred shares Wells Fargo & Company (Wells 
Fargo) issued as a part of its Employee Stock Ownership Plan (ESOP). 
Each share of ESOP preferred stock released from the unallocated 
reserve of the 401(k) plan is converted into shares of Wells Fargo's 
common stock based on the stated value of the ESOP preferred stock and 
the current market price of Wells Fargo's common stock. Wells Fargo 
sells ESOP preferred stock to its 401(k) plan and lends the 401(k) 
plan cash to purchase those shares. The loan is recorded as "Unearned 
ESOP Preferred Shares." While the ESOP preferred shares are counted as 
an addition to equity, the loans recorded as Unearned ESOP Preferred 
Shares are treated as a reduction to equity, and so there is no net 
impact on the equity accounts (including tier 1 capital). However, the 
tier 1 common capital calculation removes the ESOP preferred shares 
without also removing the corresponding loans recorded as Unearned 
ESOP Preferred Shares. After consulting with Wells Fargo, GAO adjusted 
the tier 1 common capital calculation by removing the $442 million of 
Unearned ESOP Preferred Shares outstanding as of December 31, 2009 
(the Unearned ESOP Preferred Shares is a negative amount; thus, 
removing this item leads to the addition of $442 million in tier 1 
capital), which is consistent with SCAP's treatment. 

[B] Trading and counterparty positions were not stressed because the 
total portfolio is less than the $100 billion required for stress 
testing in SCAP, but trading (gain) loss information for this BHC was 
included in the "trading revenue" line of Schedule HI of the Y-9C in 
2009. In SCAP, the projections of trading gains or losses for this BHC 
were included in the estimate of PPNR rather than the trading and 
counterparty line. Therefore, we have included the actual trading 
results in PPNR (specifically noninterest income). 

[End of table] 

[End of section] 

Appendix IV: Comments from the Board of Governors of the Federal 
Reserve System: 

Board Of Governors Of The Federal Reserve System: 
Ben S. Bernanke, Chairman: 
Washington, DC 20551: 

September 27, 2010: 

Ms. Orice M. Williams: 
Director: 
Financial Markets and Community Investment: 
Government Accountability Office: 
441 G Street, NW: 
Washington, D.C. 20548: 

Dear Ms. Williams: 

The Supervisory Capital Assessment Program (SCAP) was a very 
successful program that helped to restore confidence in the banking 
system by assessing the potential capital needs of the largest bank 
holding companies under a scenario of an economic environment that was 
more adverse than anticipated at the time. The program resulted in 
significant additional capital being raised by the banking industry 
and provided the public with assurance that these very large and 
complex institutions would remain viable even in the face of more 
severely negative economic conditions. 

The Government Accountability Office's (GAO's) report "Bank Stress 
Test Offers Lesson as Regulators Take Further Actions to Strengthen 
Supervisory Oversight," GA0-10-861, recognizes the success of the SCAP 
and recommends five ways to build on those successes. These 
recommendations relate to actions the Federal Reserve already is 
undertaking, either on its own initiative or as part of the 
implementation of the Dodd-Frank Wall Street Reform and Consumer 
Protection Act of 2010 (Dodd-Frank Act). 

Recommendation One: The Chairman of the Federal Reserve should direct 
the Division of Banking Supervision and Regulation to compare the 
performance of the 19 bank holding companies against the more adverse 
scenario projections following the completion of the two-year period 
covered in the SCAP exercise ending December 31, 2010, and disclose 
the results of the analysis to the public. 

As we have noted in the past, the size and character of the bank 
holding companies has, in many cases, changed materially over the 
interim period, making before-and-after comparisons difficult and 
potentially misleading. In addition, the SCAP process was not designed 
as a tool for measuring bank holding company performance over the 
course of the 2009 to 2010 period, but rather was designed to estimate 
the potential capital needs of bank holding companies under a more-
adverse—than-anticipated economic environment and during a very 
turbulent time for the economy in early 2009. Given that the SCAP was 
designed to estimate potential losses and resulting capital needs in a 
worse-than-anticipated scenario, measuring performance against the 
estimates may imply an attempt to test the accuracy of these 
estimates. By design, the SCAP used estimates of potential losses in a 
scenario that has not materialized, and thus would not be expected to 
accurately reflect the BBC's losses and overall operating performance 
over the two-year period ending at year-end 2010. With these important 
considerations and limitations in mind, the Federal Reserve intends to 
provide a public assessment of the performance of the firms relative 
to the loss and pre-provision net revenue estimates under the "more 
adverse scenario" used in the SCAP. The Federal Reserve will 
coordinate with the Federal Deposit Insurance Corporation (FDIC) and 
the Office of the Comptroller of the Currency (OCC) on this 
assessment, as well as on designing the specifics of what will be 
publicly reported. 

Recommendation Two: That the Chairman of the Federal Reserve, in 
consultation with the heads of the FDIC and OCC, should develop a plan 
that reconciles divergent views on transparency and allows for 
increased transparency in the regular supervisory process, 
specifically addressing steps for releasing supervisory methodologies 
and analytical results for stress testing. 

The recently passed Dodd-Frank Act requires annual stress tests for 
certain financial institutions and further requires the disclosure of 
certain stress test results. The Dodd-Frank Act also requires the 
federal regulatory agencies, including the Federal Reserve, FDIC, and 
OCC, to develop consistent and comparable regulations governing the 
publications of the results of these required stress tests. The 
Federal Reserve will coordinate with the other agencies in the 
development of these regulations. In addition, the Federal Reserve 
will continue to examine options for increasing the information that 
supervisors may make valuable. 

Recommendation Three: That the Chairman of the Federal Reserve, in 
consultation with the heads of the FDIC and OCC, should develop more 
specific criteria to include in its guidance to examiners for 
assessing the quality of stress tests that are used in firms' internal 
capital assessment and capital planning processes, and for how these 
tests inform bank holding companies' internal capital adequacy 
assessments and capital planning. 

The Federal Reserve is in the process of developing guidance for its 
examiners regarding the assessment of stress testing procedures. Once 
the guidance is completed it will be supplemented in a manner that is 
consistent with this recommendation. For purposes of sharing best 
practices and carrying out the Dodd-Frank Act, the Federal Reserve 
will continue to consult with the FDIC and OCC regarding general 
principles, common to all supervisors, to guide regulatory agencies 
when evaluating stress testing. 

Recommendation Four: That the Chairman of the Federal Reserve, in 
consultation with the heads of the FDIC and OCC, should fully develop 
the Federal Reserve's plan for maintaining and improving the use of 
data, risk identification and assessment infrastructure, and requisite 
systems consistent with new responsibilities under the Dodd-Frank Act, 
and should disseminate these enhancements among the Federal Reserve 
System and other regulators and new organizations established under 
the Dodd-Frank Act. 

As the recommendation suggests, the Federal Reserve has taken a number 
of steps to enhance risk identification, including data collection and 
dissemination. 

The Federal Reserve will continue to consult with the FDIC and OCC on 
best practices in the areas of risk assessment and data collection and 
sharing, and will ensure the continued dissemination of these 
improvements throughout the Federal Reserve System. The Federal 
Reserve will also continue to provide information about these 
enhancements to other regulators and, as appropriate, to new 
organizations established by the Dodd-Frank Act. 

Recommendation Five: That the Chairman of the Federal Reserve, in 
consultation with the heads of the FDIC and OCC, should take further 
steps to more effectively coordinate and communicate multiagency 
activities. 

As noted in the GAO report, the SCAP process is considered by many to 
be an example of effective inter-agency coordination and communication 
in relation to a multiagency activity, but it should be noted that it 
is simply the most public example. The agencies coordinate on 
supervisory issues on a daily basis and have done so for many years. 
The Federal Reserve believes these consultations result in more 
effective and uniform supervisory practices and will continue its 
practice of consulting with the FDIC and OCC, especially in the 
context of implementation of the Dodd-Frank Act. 

Sincerely, 

Signed by: 

Ben S. Bernanke: 

[End of section] 

Appendix V: Comments from the Department of the Treasury's Office of 
Financial Stability: 

Department Of The Treasury: 
Assistant Secretary: 
Washington, DC 20220: 

September 14, 2010: 

Thomas J. McCool: 
Director, Center for Economics Applied Research and Methods: 
U.S. Government Accountability Office: 
441 G Street, N.W. 
Washington, D.C. 20548: 

Dear Mr. McCool: 

Thank you for providing the Department of the Treasury ("Treasury") an 
opportunity to review and comment on your recent report on the 
Troubled Asset Relief Program ("TARP") titled, Bank Stress Test Offers 
Lessons as Regulators Take Further Actions to Strengthen Supervisory 
Oversight ("Draft Report"). 

Treasury appreciates the GAO's comprehensive review of the Supervisory 
Capital Assessment Program ("SCAP") and its acknowledgement that SCAP 
met its goals of providing a comprehensive, forward-looking assessment 
of risk on the balance sheets of our largest banks. By doing so with 
unprecedented transparency, the SCAP strengthened market confidence in 
the banking system and led to significant increase in the level and 
quality of capital held by the largest banks. The GAO issued no 
recommendations to Treasury in the Draft Report. 

Treasury looks forward to reviewing the final audit report when 
issued. We thank you again for your diligence and continuing work in 
reviewing Treasury's efforts to stabilize the financial system. 

Sincerely, 

Signed by: 

Herbert M. Allison, Jr. 
Assistant Secretary for Financial Stability: 

[End of section] 

Appendix VI: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Orice Williams Brown, (202) 512-8678 or williamso@gao.gov: 

Staff Acknowledgments: 

Daniel Garcia-Diaz (Assistant Director), Michael Aksman, Emily 
Chalmers, Rachel DeMarcus, Laurier Fish, Joe Hunter, William King, 
Matthew McDonald, Sarah M. McGrath, Timothy Mooney, Marc Molino, Linda 
Rego, and Cynthia Taylor made important contributions to this report. 

[End of section] 

Footnotes: 

[1] Treasury, Financial Stability Plan (Feb. 10, 2009). SCAP was a key 
component of the Capital Assistance Program. 

[2] The other federal banking regulators involved in SCAP were the 
Federal Deposit Insurance Corporation and the Office of the 
Comptroller of the Currency. The Office of Thrift Supervision did not 
participate. The Federal Reserve led the SCAP stress test since it is 
the primary federal bank regulator for bank holding companies. 

[3] The 19 BHCs each had at least $100 billion in risk-weighted assets 
as of December 31, 2008, meeting the established threshold for 
required participation in the SCAP stress test. Risk-weighted assets 
are the total assets and off-balance sheet items, adjusted for risks 
that institutions hold. A BHC is a company that owns or controls one 
or more banks or one that owns or controls one or more BHCs. See 12 
U.S.C. § 1841(a). Since a BHC may also own another BHC, which in turn 
owns or controls a bank, the company at the top of the ownership chain 
is commonly called the top holder. The Federal Reserve is responsible 
for regulating and supervising BHCs, even if the bank owned by the 
holding company is under the primary supervision of a different 
federal banking agency. For example, the Federal Reserve is 
responsible for regulating and supervising Citigroup Inc. (the BHC) 
and the Office of the Comptroller of the Currency is responsible for 
regulating and supervising Citibank N.A. (the main bank in the holding 
company structure). 

[4] Capital is a source of long-term funding, contributed largely by a 
bank's equity stockholders and its own returns in the form of retained 
earnings that provides banks with a cushion to absorb unexpected 
losses. A stress test is a "what-if" scenario that is not a prediction 
or expected outcome of the economy. 

[5] GAO is required to report at least every 60 days on TARP 
activities and performance. TARP was authorized under the Emergency 
Economic Stabilization Act of 2008 (EESA), Pub. L. No. 110-343, 122 
Stat. 3765 (2008), codified at 12 U.S.C. §§ 5201 et seq. EESA 
originally authorized Treasury to purchase or guarantee up to $700 
billion in troubled assets. The Helping Families Save Their Homes Act 
of 2009, Pub. L. No. 111-22, Div. A, 123 Stat. 1632 (2009), codified 
at 12 U.S.C. § 5225(a)(3), amended ESSA to reduce the maximum 
allowable amount of outstanding troubled assets under ESSA by almost 
$1.3 billion, from $700 billion to $698.741 billion. 

[6] 12 U.S.C. § 5226. 

[7] GAO, Troubled Asset Relief Program: June 2009 Status of Efforts to 
Address Transparency and Accountability Issues, [hyperlink, 
http://www.gao.gov/products/GAO-09-658] (Washington, D.C.: June 2009). 

[8] Percent change in the annual average of real GDP. GDP is defined 
as the total market value of goods and services produced domestically 
during a given period (i.e., one year). 

[9] Financial institutions that were not subject to the stress test 
could, after supervisory review, also apply for capital from CAP if 
they were in need of additional capital. 

[10] Common stock is a security that represents ownership in a company 
and gives the stockholder the right to vote for the company's board of 
directors and benefit from its financial success. Noncumulative 
perpetual preferred stock is a security that has no fixed maturity 
date and pays its stated dividend forever or "in perpetuity," but any 
unpaid dividends do not accumulate or accrue to stockholders. 

[11] In general, tier 1 common capital is voting common equity subject 
to certain deductions from capital. 

[12] For example, to be well-capitalized under Federal Reserve 
definitions, on a consolidated basis, a BHC must have a tier 1 risk- 
based capital ratio of at least 6 percent of total risk-weighted 
assets, among other things, 12 C.F.R. § 225.2(r)(1)(ii). 

[13] PPNR is defined as net interest income plus noninterest income 
minus noninterest expense. 

[14] Trading book positions and counterparty exposures were stress 
tested as of February 20, 2009. 

[15] These statements became effective on January 1, 2010, and require 
banking organizations to bring onto their balance sheets off-balance 
sheet positions. However, for regulatory purposes, the BHCs and other 
institutions may defer bringing such positions onto their balance 
sheets until the end of 2010. 

[16] Subprime mortgages are mortgages granted to borrowers whose 
credit history includes significant impairments resulting in lower 
credit scores. 

[17] For a more detailed discussion about risk management practices in 
place during the market turmoil, see the following reports: Senior 
Supervisors Group, Observations on Risk Management Practices during 
the Recent Market Turbulence (New York, Mar. 6, 2008); The President's 
Working Group on Financial Markets, Policy Statement on Financial 
Market Developments (March 2008); International Monetary Fund, Global 
Financial Stability Report: Containing Systemic Risk and Restoring 
Financial Soundness (Washington, D.C., April 2008); Financial 
Stability Forum, Report of the Financial Stability Forum on Enhancing 
Market and Institutional Resilience (April 2008); Institute of 
International Finance, Final Report of the IIF Committee on Market 
Best Practices: Principles of Conduct and Best Practice 
Recommendations (July 2008); Credit Risk Management Policy Group III, 
Containing Systemic Risk: The Road to Reform (August 2008); and Senior 
Supervisors Group, Risk Management Lessons from the Global Banking 
Crisis of 2008 (Oct. 21, 2009). 

[18] The Basel Committee seeks to improve the quality of banking 
supervision worldwide, in part by developing broad supervisory 
standards. The Basel Committee consists of central bank and regulatory 
officials from 27 member countries. The Basel Committee's supervisory 
standards are also often adopted by nonmember countries. See Basel 
Committee on Banking Supervision, Principles for Sound Stress Testing 
Practices and Supervision. (Basel, Switzerland, May 2009). 

[19] Regulators used the Case-Shiller 10-City Composite index to 
forecast changes in housing prices. 

[20] The unemployment rate is the number of jobless people who are 
available for work but not currently employed and are actively seeking 
jobs, expressed as a percentage of the labor force. 

[21] According to the Federal Reserve's SCAP design and implementation 
document, the professionals are the Consensus Forecasts, Blue Chip 
survey, and Survey of Professional Forecasters. 

[22] ALLL is the capital reserve set aside to cover anticipated losses. 

[23] Resources available to absorb losses is defined as PPNR less the 
change in ALLL from December 31, 2008, to December 31, 2010. 

[24] Financial Accounting Standards Board position numbers 115-2 and 
124-2 focus on whether firms with debt securities held in the 
available for sale and held to maturity accounts intended or would be 
required to sell securities at a lower price than its cost basis. 
Generally accepted accounting principles are a widely accepted set of 
rules, conventions, standards, and procedures for reporting financial 
information established by the Financial Accounting Standards Board. 

[25] Other than temporarily impaired write down is measured as the 
difference between a security's book value and market value. 

[26] See Financial Accounting Statements No. 166 and 167. 

[27] In its June 2009 SCAP analysis report, the Congressional 
Oversight Panel also noted that there was a lack of transparency about 
the linkage between the loan losses and the three macroeconomic 
assumptions. 

[28] According to the Federal Reserve, legacy loans refer to those 
bank loans made during the 2005 to 2007 period. Underwriting standards 
refer to guidelines used by lenders to ensure that loans meet credit 
standards and that the terms and conditions of a loan are appropriate 
to its risk and maturity. 

[29] Loss rate ranges under the more adverse scenario were later 
tailored to each BHC. 

[30] Other forms of raising capital included the use of deferred tax 
assets (DTA), employee stock option awards, and restriction on 
dividend payments. A DTA represents the amount by which taxes can be 
reduced in future years as a result of temporary tax differences for 
financial reporting and tax reporting purposes. DTAs are includable as 
tier 1 capital up to no more than 10 percent of a BHC's tier 1 capital. 

[31] The SCAP results required GMAC to raise a total of $1l.5 billion 
in capital, of which $9.1 billion had to be in new equity capital. On 
May 21, 2009, Treasury made a capital investment of $3.5 billion in 
GMAC via the TARP Automotive Industry Financing Program to be applied 
as a down payment towards GMAC's SCAP capital buffer of $9.1 billion 
in new equity capital. GMAC had to raise the remaining amount of $5.6 
billion by the November 9, 2009, deadline from either the private 
markets or through further Treasury assistance. In December 2009, 
Treasury converted its existing $5.25 billion of preferred stock into 
mandatorily convertible preferred stock and converted $3 billion of 
existing GMAC mandatorily convertible preferred securities into common 
equity that allowed GMAC to meet its total SCAP capital requirement of 
$11.5 billion. 

[32] The Automotive Industry Financing Program was created in December 
2008 by Treasury under TARP to prevent a significant disruption of the 
American automotive industry. Treasury determined that such a 
disruption would pose a systemic risk to financial market stability 
and have a negative effect on the U.S. economy. 

[33] Tier 1 common capital ratio equals tier 1 common capital divided 
by total risk-weighted assets. 

[34] Tier 1 risk-based capital ratio equals tier 1 capital divided by 
total risk-weighted assets. 

[35] A basis point is a common measure used in quoting yields on 
bills, notes, and bonds and represents 1/100 of a percent of yield. 
For example, an increase from 4.35 percent to 4.45 percent would be an 
increase of 10 basis points. 

[36] GMAC is the only nonpublic BHC that was included in SCAP. 

[37] The asset categories are first-lien mortgages consisting of 
prime, Alt-A, and subprime residential mortgages; second/junior lien 
mortgages consisting of closed-end junior liens and home equity line 
of credit residential mortgages; commercial and industrial loans 
consisting of large corporate and middle market, small business, and 
asset-based lending loans; commercial real estate loans consisting of 
construction and land development, multifamily, and nonfarm 
nonresidential loans; credit card loans, consisting of credit cards; 
other loans consisting of auto, personal, and student loans, and 
farmland lending, loans to depository institutions, loans to 
governments, and other categories; securities (available for sale and 
held to maturity) consisting of a majority of Treasury securities, 
government agency securities, sovereign debt, and high-grade municipal 
securities and corporate bonds, equities, asset-backed securities, 
commercial mortgage-backed securities, and nonagency residential 
mortgage-backed securities; and trading and counterparty, or trading 
book positions (e.g., securities such as common stock and derivatives). 

[38] As of September 22, 2010, Treasury has a 56.3 percent ownership 
stake in GMAC. 

[39] General Motors Company and Chrysler Group LLC are the new names 
that the former GM and Chrysler adopted, respectively, after emerging 
from bankruptcy. 

[40] The Federal Reserve approved GMAC's application to become a BHC 
on December 24, 2008. 

[41] Lifetime losses are those losses which occur from origination to 
the life-end of the loans. 

[42] According to an April 12, 2010, GMAC press release, GMAC's 
mortgage subsidiary--Residential Capital, LLC--agreed to sell its 
European mortgage assets and businesses to Fortress Investment Group 
LLC. These transactions represent approximately 10 percent of 
Residential Capital, LLC's December 31, 2009, total assets and 
approximately 40 percent of total assets on a pro forma basis, 
adjusted for the required accounting treatment for certain off-balance 
sheet securitizations that are recorded on-balance sheet effective 
January 1, 2010, (see Financial Accounting Statement No. 167). The 
assets in the transactions are valued at approximately the levels 
established in the fourth quarter of 2009, and there is no material 
gain or loss expected. GMAC reported positive earnings for the first 
and second quarters of 2010, although it continued to show losses in 
certain portfolios. These were its first profits since the fourth 
quarter of 2008. GMAC's tier 1 common capital ratio also improved to 5 
percent and 5.2 percent, respectively. 

[43] Trading account assets are assets held to hedge risks or 
speculate on price changes for the bank or its customers. Because the 
more adverse scenario was plausible but unlikely to occur, the actual 
results were not intended and should not be expected to align with 
such scenario. 

[44] The five BHCs are The Bank of New York Mellon Corporation; 
Citigroup; MetLife, Inc.; SunTrust; and U.S. Bancorp. 

[45] Based on discussion with The Bank of New York Mellon Corporation 
officials and as stated in a October 20, 2009, company press release, 
the BHC's securities portfolio underwent a significant restructuring 
in the third quarter of 2009 in order to reduce its balance sheet 
risk, causing it to recognize significant losses in that period. The 
officials noted that the BHC sold off many of its riskiest holdings in 
that period, including many Alt-A residential mortgage-backed 
securities, so that they expect to see gains in this portfolio in the 
future, keeping the final 2-year loss under the SCAP projected amount. 
As of the second quarter of 2010 year to date, the BHC experienced a 
gain of $20 million in this portfolio. 

[46] A counterparty loss is a loss resulting from a counterparty to a 
transaction failing to fulfill its financial obligation in a timely 
manner or from a credit valuation adjustment. 

[47] These BHCs include Bank of America, Citigroup, Goldman Sachs, 
JPMorgan Chase & Co., and Morgan Stanley were stress tested in SCAP. 

[48] Limitations of the Y-9C make it difficult to compare the actual 
results to the projections of SCAP. The trading and counterparty data 
in the Y-9C includes both customer derived revenue from transactions 
for BHCs that operate as broker-dealers, as well as gains and losses 
from proprietary trading and associated expenses. These items are 
presented on a net basis in the Y-9C. For the five BHCs that had their 
trading portfolios stressed (Goldman Sachs, Morgan Stanley, Citigroup, 
JPMorgan Chase & Co., and Bank of America), the trading and 
counterparty line item is based on projections of gains or losses from 
proprietary trading, but preprovision net revenue (specifically 
noninterest revenue) included projections of gains or losses from 
customer derived revenue from transactions due to operations as a 
broker-dealer. These items cannot be segregated based on the Y-9C data 
and therefore are included in the net amount in both the trading and 
counterparty and noninterest income line items above. As a result of 
this limitation, the net amount of the trading gains or losses and 
preprovision net revenue in the table may be over-or understated. 

[49] In 2008, Lehman Brothers Holdings Inc. failed, Merrill Lynch & 
Co. Inc. was acquired by Bank of America, and The Bear Stearns 
Companies Inc. was sold to JP Morgan Chase & Co. 

[50] Wholesale funding describes a class of funding used by banks to 
meet their liquidity needs. Wholesale funding providers include, but 
are not limited to, money market funds, trust funds, pension funds, 
corporations, banks, government agencies, and insurance companies. 
Wholesale funding instruments include, but are not limited to, federal 
funds, public funds, Federal Home Loan Bank advances, the Federal 
Reserve's primary credit program, foreign deposits, brokered deposits, 
and deposits obtained through the Internet or certificate of deposits 
listing services. 

[51] Nonperforming loans, for the purposes of this figure, represent 
the total of loans that are either 90 plus days past due or in 
nonaccrual status. As defined by the instructions to the Y-9C, an 
asset is in nonaccrual status if: (1) it is maintained on a cash basis 
because of deterioration in the financial condition of the borrower, 
(2) payment in full of principal or interest is not expected, or (3) 
principal or interest as been in default for a period of 90 days or 
more unless the asset is both well secured and in the process of 
collection. Per the Y-9C instructions, an asset is 90 plus days past 
due if payment is due and unpaid for 90 days or more, and if that 
asset is not in nonaccrual status. 

[52] Pub. L. No. 111-203, 124 Stat. 1376 (2010); Pub. L. No. 111-24, 
123 Stat. 1734 (2009). 

[53] Ben S. Bernanke, "The Supervisory Capital Assessment Program--One 
Year Later," speech delivered at the Federal Reserve Bank of Chicago 
2010 46th Annual Conference on Bank Structure and Competition 
(Chicago, Illinois, May 6, 2010). Daniel K. Tarullo, "Lessons from the 
Crisis Stress Tests," speech delivered at the Federal Reserve Board 
2010 International Research Forum on Monetary Policy (Washington, 
D.C., Mar. 26, 2010). 

[54] Daniel K. Tarullo, "Involving Markets and the Public in Financial 
Regulation," speech delivered at the Council of Institutional 
Investors Meeting (Washington, D.C., Apr. 13, 2010). Bernanke "The 
Supervisory Capital Assessment Program--One Year Later" (2010). 

[55] GAO, Troubled Asset Relief Program: June 2009 Status of Efforts 
to Address Transparency and Accountability Issues, [hyperlink, 
http://www.gao.gov/products/GAO-09-658] (Washington, D.C.: June 17, 
2009). 

[56] The act also establishes the Financial Stability Oversight 
Council and Treasury's Office of Financial Research in order to 
further the goals of effective systemic risk measurement. 

[57] GAO, Financial Regulation: Review of Regulators' Oversight of 
Risk Management System at a Limited Number of Large, Complex Financial 
Institutions, [hyperlink, http://www.gao.gov/products/GAO-09-499T] 
(Washington, D.C.: Mar. 18, 2009). 

[58] Basel II is an international risk-based capital framework that 
aims to align minimum capital requirements with enhanced risk 
measurement techniques and to encourage banks to develop a more 
disciplined approach to risk management. It was organized with three 
main principles of capital known as pillars: Pillar 1 relates to 
minimum capital requirements. Pillar 2 relates to the supervisory 
review of an institution's internal assessment process and capital 
adequacy relative to the institution's overall risk profile. Pillar 3 
relates to the effective use of disclosure to strengthen market 
discipline as a complement to supervisory efforts. 

[59] These portfolios were the only ones tested under the SCAP for 
which the positions were taken as of a different date than December 
31, 2008. Positions were taken as of February 20, 2009, as it was both 
more relevant to the actual risk exposure of the BHCs at the time of 
SCAP and easier for the BHCs to provide. 

[60] GAO, Financial Market Regulation: Agencies Engaged in 
Consolidated Supervision Can Strengthen Performance Measurement and 
Collaboration, [hyperlink, http://www.gao.gov/products/GAO-07-154] 
(Washington, D.C.: Mar. 15, 2007). 

[61] The Y-9C is a Federal Reserve reporting form that collects basic 
financial data from a domestic BHC on a consolidated basis in the form 
of a balance sheet, an income statement, and detailed supporting 
schedules, including a schedule of off balance-sheet items. The 
information is used to assess and monitor the financial condition of 
BHC organizations, which may include parent, bank, and nonbank 
entities. The Y-9C is a primary analytical tool used to monitor 
financial institutions between on-site inspections and is filed 
quarterly as of the last calendar day of March, June, September, and 
December. The Federal Reserve used such format to collect data from 
the BHCs for purposes of conducting the SCAP stress test. 

[62] For a more detailed discussion about risk-management practices in 
place during the market turmoil, see the following reports: Senior 
Supervisors Group, Observations on Risk Management Practices during 
the Recent Market Turbulence (New York, Mar. 6, 2008); International 
Monetary Fund, Global Financial Stability Report: Containing Systemic 
Risk and Restoring Financial Soundness (Washington, D.C.: April 2008); 
Financial Stability Forum, Report of the Financial Stability Forum on 
Enhancing Market and Institutional Resilience (April 2008); Institute 
of International Finance, Final Report of the IIF Committee on Market 
Best Practices: Principles of Conduct and Best Practice 
Recommendations (July 2008); Credit Risk Management Policy Group III, 
Containing Systemic Risk: The Road to Reform (August 2008); Senior 
Supervisors Group, Risk Management Lessons from the Global Banking 
Crisis of 2008 (Oct. 21, 2009); Basel Committee on Banking 
Supervision, Principles for Sound Stress Testing Practices and 
Supervision (Basel, Switzerland, May 2009); and the President's 
Working Group on Financial Markets, Policy Statement on Financial 
Market Developments (March 2008). 

[63] The Office of the Thrift Supervision did not participate in 
conducting the stress test. 

[64] On June 30, 2009, GMAC LLC changed its corporate structure and 
became GMAC Inc., and on May 10, 2010, GMAC Inc. changed its name to 
Ally Financial Inc. 

[65] See GAO, Financial Market Regulation: Agencies Engaged in 
Consolidated Supervision Can Strengthen Performance Measurement and 
Collaboration, [hyperlink, http://www.gao.gov/products/GAO-07-154] 
(Washington, D.C.: Mar. 15, 2007); Financial Regulation: A Framework 
for Crafting and Assessing Proposals to Modernize the Outdated U.S. 
Financial Regulatory System, [hyperlink, 
http://www.gao.gov/products/GAO-09-216] (Washington, D.C.: Jan. 8, 
2009); Financial Regulation: Review of Regulators' Oversight of Risk 
Management Systems at a Limited Number of Large, Complex Financial 
Institutions, [hyperlink, http://www.gao.gov/products/GAO-09-499T] 
(Washington, D.C.: Mar. 18, 2009); and Troubled Asset Relief Program: 
June 2009 Status of Efforts to Address Transparency and Accountability 
Issues, [hyperlink, http://www.gao.gov/products/GAO-09-658] 
(Washington, D.C.: June 2009). Also, see Congressional Oversight 
Panel's Stress Testing and Shoring Up Bank Capital (June 9, 2009). 

[66] The BHCs had to maintain a tier 1 capital ratio of at least 6 
percent of risk-weighted assets and a tier 1 common capital ratio of 
at least 4 percent of risk-weighted assets at the end of 2010. PPNR is 
defined as net interest income plus noninterest income minus 
noninterest expense. Allowance for loan and lease losses is defined as 
the capital reserve set aside to cover anticipated losses. 

[67] See GAO, Assessing the Reliability of Computer-Processed Data, 
Version 1, [hyperlink, http://www.gao.gov/products/GAO-02-15G] 
(Washington, D.C.: September 2002). 

[68] The owned debt value adjustment is an adjustment made to BHC 
financial statements if the BHC chose to value its own debt on a mark- 
to-market basis rather than book value. As the BHC's debt becomes 
cheaper, this creates a positive impact on its financial statements, 
while, as seen in 2009, the debt becomes more expensive, it has a 
negative impact on the BHC's financial statements. 

[69] A credit default swap spread is one measure of investors' 
confidence in the banking sector. It is an agreement in which a buyer 
pays a periodic fee to a seller, in exchange for protection from 
certain credit events such as bankruptcy, failure to pay debt 
obligations, or a restructuring related to a specific debt issuer or 
issues known as the reference entity. Therefore, the credit default 
swap spread, or market price, is a measure of the credit risk of the 
reference entity, with a higher spread indicating a greater amount of 
credit risk. When the markets' perception of the reference entity's 
credit risk deteriorates or improves, the spread generally will widen 
or tighten, respectively. 

[70] Nonperforming loans represent the total of loans that are either 
90 plus days past due or in nonaccrual status. As defined by the 
instructions to the Y-9C, an asset is in nonaccrual status if: (1) it 
is maintained on a cash basis because of deterioration in the 
financial condition of the borrower, (2) payment in full of principal 
or interest is not expected, or (3) principal or interest as been in 
default for a period of 90 days or more unless the asset is both well 
secured and in the process of collection. Per the Y-9C instructions, 
an asset is 90 plus days past due if payment is due and unpaid for 90 
days or more, and if that asset is not in nonaccrual status. 

[71] The Goldman Sachs Group, Inc. and Morgan Stanley were approved by 
the Federal Reserve to become BHCs on September 22, 2008; American 
Express Company was approved on November 10, 2008; and GMAC LLC was 
approved on December 24, 2008. 

[72] See Federal Reserve's June 1, 2009, press release that sets forth 
the criteria that SCAP BHCs must meet before they can pay back their 
TARP investments. 

[73] FDIC created this facility in November 2008 to encourage 
liquidity in the banking system by guaranteeing newly issued senior 
unsecured debt of banks, thrifts, and certain holding companies and by 
providing full coverage of noninterest-bearing deposit transaction 
accounts. The facility is scheduled to end in 2010. 

[End of section] 

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