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Fed Finalizes Overhaul of Large-Bank Ratings, Allowing One Deficient Mark and Still 'Well Managed'

The move prioritizes overall safety and soundness over isolated weaknesses.

Overview

  • The revised framework deems a firm with no more than one deficient-1 component rating as well managed, while any deficient-2 rating still disqualifies that status.
  • The changes take effect 60 days after publication in the Federal Register and apply parallel adjustments to insurers overseen by the Board.
  • Scope includes bank and certain savings and loan holding companies with at least $100 billion in assets and foreign intermediate holding companies with at least $50 billion.
  • Board staff estimated the number of large firms not rated well managed would drop from 17 to 7 among 36 previously assessed institutions.
  • The final notice narrows automatic enforcement presumptions and removes references to reputational risk in the insurance framework, drawing a formal dissent from Governor Michael Barr.