Response to consultation on Guidelines on institution's stress testing

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Question 1: Please provide comments on all proposals put forward in this paper

Article 98 refers to reverse stress test for ICAAP and ILAAP purposes to not be interlinked with recovery planning. As de facto RST creates the conditions to trigger recovery options, should we rather expect to link the two exercises to ensure consistency and continuity in assessing the Institution's capital adequacy under severe stress conditions? Following this path, could even the RST developed for ICAAP/ILAAP be used as starting point for Recovery Plans, assuming all required conditions are met, without duplicating the simulation of near to default situation across the two exercises?

Name of organisation

State Street Bank & Trust