## Comprehensive Capital Analysis and Review 2013: Assessment Framework

and Results

- Capital Plan Assessment Factors
- Resubmissions and Feedback
- Appendix: Disclosure Tables

## Appendix: Disclosure Tables

- Table A.1. 18 participating bank holding companies
- Table A.2. Ally Financial Inc.
- Table A.3. American Express Company
- Table A.4. Bank of America Corporation
- Table A.5. The Bank of New York Mellon Corporation
- Table A.6. BB&T Corporation
- Table A.7. Capital One Financial Corporation
- Table A.8. Citigroup Inc.
- Table A.9. Fifth Third Bancorp
- Table A.10. The Goldman Sachs Group, Inc.
- Table A.11. JPMorgan Chase & Co.
- Table A.12. KeyCorp
- Table A.13. Morgan Stanley
- Table A.14. The PNC Financial Services Group, Inc.
- Table A.15. Regions Financial Corporation
- Table A.16. State Street Corporation
- Table A.17. SunTrust Banks, Inc.
- Table A.18. U.S. Bancorp
- Table A.19. Wells Fargo & Company

### Table A.1. Comprehensive Capital Analysis and Review 2013

Projected minimum regulatory capital ratios and tier 1 common ratios,

Q4 2012 to Q4 2014

Federal Reserve estimates in the severely adverse scenario

**18 participating bank holding companies**

The capital ratios are calculated using original and adjusted planned capital actions from 2013 annual capital plans. These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital ratios. The center column shows the minimum ratios assuming the capital actions originally submitted by the BHCs in their January 2013 annual capital plans. The right column shows minimum ratios incorporating any adjustments to capital distributions made by BHCs after reviewing the Federal Reserve's stress test projections and original planned capital distributions for those BHCs that did not make adjustments. The two minimum capital ratios presented below are for the period Q4 2012 to Q4 2014 and do not necessarily occur in the same quarter.

**The minimum ratios for BHCs are 4 percent for the tier 1 capital ratio, 8 percent for the total capital ratio, and 3 or 4 percent for the tier 1 leverage ratio (3 percent only for a BHC with a composite supervisory rating of "1" or that is subject to the Federal Reserve Board's market-risk rule [12 CFR part 225, appendix E]). Ally Financial Inc., American Express Company, and Capital One Financial Corporation are not subject to the market risk rule (12 CFR part 225, appendix E). All other BHCs that participated in CCAR 2013 are subject to the market risk rule, and accordingly, their minimum leverage ratio is 3 percent. The capital plan rule stipulates that a BHC must demonstrate the ability to maintain a tier 1 common ratio above 5 percent.**

### Projected capital ratios through Q4 2014 under the severely adverse scenario

Actual | Stressed ratios with original planned capital actions | Stressed ratios with adjusted planned capital actions | |
---|---|---|---|

Q3 2012 | Minimum | Minimum | |

Tier 1 common ratio (%) | 11.14 | 6.56 | 6.58 |

Tier 1 capital ratio (%) | 12.94 | 8.06 | 8.17 |

Total risk-based capital ratio (%) | 15.74 | 10.76 | 10.87 |

Tier 1 leverage ratio (%) | 7.96 | 5.23 | 5.30 |

### Table A.2. Comprehensive Capital Analysis and Review 2013

Projected minimum regulatory capital ratios and tier 1 common ratios,

Q4 2012 to Q4 2014

Federal Reserve estimates in the severely adverse scenario

**Ally Financial Inc.**

The capital ratios are calculated using original and adjusted planned capital actions from 2013 annual capital plans. These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital ratios. The center column shows the minimum ratio assuming the capital actions originally submitted by the BHC in its January 2013 annual capital plan. The right column shows minimum ratios incorporating any adjustments to capital distributions made by the BHC after reviewing the Federal Reserve's stress test projections. The two minimum capital ratios presented below are for the period Q4 2012 to Q4 2014 and do not necessarily occur in the same quarter.

**The minimum ratios for BHCs are 4 percent for the tier 1 capital ratio, 8 percent for the total capital ratio, and 3 or 4 percent for the tier 1 leverage ratio (3 percent only for a BHC with a composite supervisory rating of "1" or that is subject to the Federal Reserve Board's market-risk rule [12 CFR part 225, appendix E]). Ally Financial Inc., American Express Company, and Capital One Financial Corporation are not subject to the market risk rule (12 CFR part 225, appendix E). All other BHCs that participated in CCAR 2013 are subject to the market risk rule, and accordingly, their minimum leverage ratio is 3 percent. The capital plan rule stipulates that a BHC must demonstrate the ability to maintain a tier 1 common ratio above 5 percent.**

### Projected capital ratios through Q4 2014 under the severely adverse scenario

Actual | Stressed ratios with original planned capital actions | Stressed ratios with adjusted planned capital actions | |
---|---|---|---|

Q3 2012 | Minimum | Minimum | |

Tier 1 common ratio (%) | 7.33 | 1.78 | 1.52 |

Tier 1 capital ratio (%) | 13.64 | 4.07 | 11.02 |

Total risk-based capital ratio (%) | 14.63 | 5.96 | 12.59 |

Tier 1 leverage ratio (%) | 11.29 | 3.50 | 9.42 |

Note: The post-stress capital ratios presented in the table are based on an assumption that Ally remains subject to contingent liabilities associated with Residential Capital, LLC ("ResCap"). On May 14, 2012, ResCap and certain of its subsidiaries filed for relief under Chapter 11 of the Bankruptcy Code in the United States Bankruptcy Court for the Southern District of New York. As of March 6, 2013, the outcome of the ResCap bankruptcy remained pending.

### Table A.3. Comprehensive Capital Analysis and Review 2013

Projected minimum regulatory capital ratios and tier 1 common ratios,

Q4 2012 to Q4 2014

Federal Reserve estimates in the severely adverse scenario

**American Express Company**

The capital ratios are calculated using original and adjusted planned capital actions from 2013 annual capital plans. These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital ratios. The center column shows the minimum ratio assuming the capital actions originally submitted by the BHC in its January 2013 annual capital plan. The right column shows minimum ratios incorporating any adjustments to capital distributions made by the BHC after reviewing the Federal Reserve's stress test projections. The two minimum capital ratios presented below are for the period Q4 2012 to Q4 2014 and do not necessarily occur in the same quarter.

**The minimum ratios for BHCs are 4 percent for the tier 1 capital ratio, 8 percent for the total capital ratio, and 3 or 4 percent for the tier 1 leverage ratio (3 percent only for a BHC with a composite supervisory rating of "1" or that is subject to the Federal Reserve Board's market-risk rule [12 CFR part 225, appendix E]). Ally Financial Inc., American Express Company, and Capital One Financial Corporation are not subject to the market risk rule (12 CFR part 225, appendix E). All other BHCs that participated in CCAR 2013 are subject to the market risk rule, and accordingly, their minimum leverage ratio is 3 percent. The capital plan rule stipulates that a BHC must demonstrate the ability to maintain a tier 1 common ratio above 5 percent.**

### Projected capital ratios through Q4 2014 under the severely adverse scenario

Actual | Stressed ratios with original planned capital actions | Stressed ratios with adjusted planned capital actions | |
---|---|---|---|

Q3 2012 | Minimum | Minimum | |

Tier 1 common ratio (%) | 12.73 | 4.97 | 6.42 |

Tier 1 capital ratio (%) | 12.75 | 4.98 | 6.43 |

Total risk-based capital ratio (%) | 14.70 | 7.06 | 8.54 |

Tier 1 leverage ratio (%) | 10.71 | 3.99 | 5.15 |

### Table A.4. Comprehensive Capital Analysis and Review 2013

Projected minimum regulatory capital ratios and tier 1 common ratios,

Q4 2012 to Q4 2014

Federal Reserve estimates in the severely adverse scenario

**Bank of America Corporation**

The capital ratios are calculated using original and adjusted planned capital actions from 2013 annual capital plans. These projections represent hypothetical estimates that involve an economic outcome that is more adverse than expected. These estimates are not forecasts of capital ratios. The center column shows the minimum ratio assuming the capital actions originally submitted by the BHC in its January 2013 annual capital plan. The right column shows minimum ratios incorporating any adjustments to capital distributions made by the BHC after reviewing the Federal Reserve's stress test projections. The two minimum capital ratios presented below are for the period Q4 2012 to Q4 2014 and do not necessarily occur in the same quarter.

### Projected capital ratios through Q4 2014 under the severely adverse scenario

Actual | Stressed ratios with original planned capital actions | Stressed ratios with adjusted planned capital actions | |
---|---|---|---|

Q3 2012 | Minimum | Minimum | |

Tier 1 common ratio (%) | 11.41 | 6.04 | |

Tier 1 capital ratio (%) | 13.64 | 7.20 | |

Total risk-based capital ratio (%) | 17.16 | 10.24 | |

Tier 1 leverage ratio (%) | 7.84 | 4.62 |

### Table A.5. Comprehensive Capital Analysis and Review 2013

Projected minimum regulatory capital ratios and tier 1 common ratios,

Q4 2012 to Q4 2014

Federal Reserve estimates in the severely adverse scenario

**The Bank of New York Mellon Corporation**

### Projected capital ratios through Q4 2014 under the severely adverse scenario

Actual | Stressed ratios with original planned capital actions | Stressed ratios with adjusted planned capital actions | |
---|---|---|---|

Q3 2012 | Minimum | Minimum | |

Tier 1 common ratio (%) | 13.28 | 13.21 | |

Tier 1 capital ratio (%) | 15.29 | 14.66 | |

Total risk-based capital ratio (%) | 16.86 | 15.31 | |

Tier 1 leverage ratio (%) | 5.63 | 5.03 |

### Table A.6. Comprehensive Capital Analysis and Review 2013

Projected minimum regulatory capital ratios and tier 1 common ratios,

Q4 2012 to Q4 2014

Federal Reserve estimates in the severely adverse scenario

**BB&T Corporation**

### Projected capital ratios through Q4 2014 under the severely adverse scenario

Actual | Stressed ratios with original planned capital actions | Stressed ratios with adjusted planned capital actions | |
---|---|---|---|

Q3 2012 | Minimum | Minimum | |

Tier 1 common ratio (%) | 9.52 | 7.76 | |

Tier 1 capital ratio (%) | 10.86 | 9.52 | |

Total risk-based capital ratio (%) | 14.01 | 11.75 | |

Tier 1 leverage ratio (%) | 7.90 | 7.06 |

Note: The actual and post-stress capital ratios presented in the table are based on information that BB&T provided to the Federal Reserve in regulatory reports on or before February 6, 2013. The information that BB&T provided to the Federal Reserve includes information regarding BB&T's risk-weighted assets. On March 4, 2013, BB&T disclosed publicly that it had reevaluated its process related to calculating risk-weighted assets and determined that certain adjustments, primarily related to the presentation of certain unfunded lending commitments, were required in order to conform to regulatory guidance. These adjustments resulted in an increase to risk-weighted assets and a decrease in BB&T's risk-based capital ratios and are not reflected in this table.

### Table A.7. Comprehensive Capital Analysis and Review 2013

Projected minimum regulatory capital ratios and tier 1 common ratios,

Q4 2012 to Q4 2014

Federal Reserve estimates in the severely adverse scenario

**Capital One Financial Corporation**

### Projected capital ratios through Q4 2014 under the severely adverse scenario

Actual | Stressed ratios with original planned capital actions | Stressed ratios with adjusted planned capital actions | |
---|---|---|---|

Q3 2012 | Minimum | Minimum | |

Tier 1 common ratio (%) | 10.69 | 6.69 | |

Tier 1 capital ratio (%) | 12.74 | 7.18 | |

Total risk-based capital ratio (%) | 14.98 | 9.48 | |

Tier 1 leverage ratio (%) | 9.88 | 5.23 |

### Table A.8. Comprehensive Capital Analysis and Review 2013

Projected minimum regulatory capital ratios and tier 1 common ratios,

Q4 2012 to Q4 2014

Federal Reserve estimates in the severely adverse scenario

**Citigroup Inc.**

### Projected capital ratios through Q4 2014 under the severely adverse scenario

Actual | Stressed ratios with original planned capital actions | Stressed ratios with adjusted planned capital actions | |
---|---|---|---|

Q3 2012 | Minimum | Minimum | |

Tier 1 common ratio (%) | 12.73 | 8.22 | |

Tier 1 capital ratio (%) | 13.92 | 9.35 | |

Total risk-based capital ratio (%) | 17.12 | 12.35 | |

Tier 1 leverage ratio (%) | 7.39 | 5.38 |

### Table A.9. Comprehensive Capital Analysis and Review 2013

Projected minimum regulatory capital ratios and tier 1 common ratios,

Q4 2012 to Q4 2014

Federal Reserve estimates in the severely adverse scenario

**Fifth Third Bancorp**

### Projected capital ratios through Q4 2014 under the severely adverse scenario

Actual | Stressed ratios with original planned capital actions | Stressed ratios with adjusted planned capital actions | |
---|---|---|---|

Q3 2012 | Minimum | Minimum | |

Tier 1 common ratio (%) | 9.67 | 7.50 | |

Tier 1 capital ratio (%) | 10.85 | 8.55 | |

Total risk-based capital ratio (%) | 14.76 | 12.26 | |

Tier 1 leverage ratio (%) | 10.09 | 8.04 |

### Table A.10. Comprehensive Capital Analysis and Review 2013

Projected minimum regulatory capital ratios and tier 1 common ratios,

Q4 2012 to Q4 2014

Federal Reserve estimates in the severely adverse scenario

**The Goldman Sachs Group, Inc.**

### Projected capital ratios through Q4 2014 under the severely adverse scenario

Actual | Stressed ratios with original planned capital actions | Stressed ratios with adjusted planned capital actions | |
---|---|---|---|

Q3 2012 | Minimum | Minimum | |

Tier 1 common ratio (%) | 13.12 | 5.26 | |

Tier 1 capital ratio (%) | 14.98 | 7.20 | |

Total risk-based capital ratio (%) | 18.07 | 9.96 | |

Tier 1 leverage ratio (%) | 7.17 | 3.85 |

### Table A.11. Comprehensive Capital Analysis and Review 2013

Projected minimum regulatory capital ratios and tier 1 common ratios,

Q4 2012 to Q4 2014

Federal Reserve estimates in the severely adverse scenario

**JPMorgan Chase & Co.**

### Projected capital ratios through Q4 2014 under the severely adverse scenario

Actual | Stressed ratios with original planned capital actions | Stressed ratios with adjusted planned capital actions | |
---|---|---|---|

Q3 2012 | Minimum | Minimum | |

Tier 1 common ratio (%) | 10.42 | 5.56 | |

Tier 1 capital ratio (%) | 11.93 | 6.80 | |

Total risk-based capital ratio (%) | 14.69 | 9.49 | |

Tier 1 leverage ratio (%) | 7.08 | 4.10 |

### Table A.12. Comprehensive Capital Analysis and Review 2013

Projected minimum regulatory capital ratios and tier 1 common ratios,

Q4 2012 to Q4 2014

Federal Reserve estimates in the severely adverse scenario

**KeyCorp**

### Projected capital ratios through Q4 2014 under the severely adverse scenario

Actual | Stressed ratios with original planned capital actions | Stressed ratios with adjusted planned capital actions | |
---|---|---|---|

Q3 2012 | Minimum | Minimum | |

Tier 1 common ratio (%) | 11.30 | 6.75 | |

Tier 1 capital ratio (%) | 12.10 | 7.37 | |

Total risk-based capital ratio (%) | 15.17 | 9.98 | |

Tier 1 leverage ratio (%) | 11.37 | 6.94 |

### Table A.13. Comprehensive Capital Analysis and Review 2013

Projected minimum regulatory capital ratios and tier 1 common ratios,

Q4 2012 to Q4 2014

Federal Reserve estimates in the severely adverse scenario

**Morgan Stanley**

### Projected capital ratios through Q4 2014 under the severely adverse scenario

Actual | Stressed ratios with original planned capital actions | Stressed ratios with adjusted planned capital actions | |
---|---|---|---|

Q3 2012 | Minimum | Minimum | |

Tier 1 common ratio (%) | 13.89 | 5.62 | |

Tier 1 capital ratio (%) | 16.95 | 7.44 | |

Total risk-based capital ratio (%) | 16.98 | 8.59 | |

Tier 1 leverage ratio (%) | 7.18 | 4.53 |

### Table A.14. Comprehensive Capital Analysis and Review 2013

Projected minimum regulatory capital ratios and tier 1 common ratios,

Q4 2012 to Q4 2014

Federal Reserve estimates in the severely adverse scenario

**The PNC Financial Services Group, Inc.**

### Projected capital ratios through Q4 2014 under the severely adverse scenario

Actual | Stressed ratios with original planned capital actions | Stressed ratios with adjusted planned capital actions | |
---|---|---|---|

Q3 2012 | Minimum | Minimum | |

Tier 1 common ratio (%) | 9.48 | 8.55 | |

Tier 1 capital ratio (%) | 11.68 | 10.82 | |

Total risk-based capital ratio (%) | 14.49 | 14.18 | |

Tier 1 leverage ratio (%) | 10.38 | 8.63 |

### Table A.15. Comprehensive Capital Analysis and Review 2013

Projected minimum regulatory capital ratios and tier 1 common ratios,

Q4 2012 to Q4 2014

Federal Reserve estimates in the severely adverse scenario

**Regions Financial Corporation**

### Projected capital ratios through Q4 2014 under the severely adverse scenario

Actual | Stressed ratios with original planned capital actions | Stressed ratios with adjusted planned capital actions | |
---|---|---|---|

Q3 2012 | Minimum | Minimum | |

Tier 1 common ratio (%) | 10.46 | 7.00 | |

Tier 1 capital ratio (%) | 11.48 | 7.54 | |

Total risk-based capital ratio (%) | 14.95 | 10.52 | |

Tier 1 leverage ratio (%) | 9.10 | 6.00 |

### Table A.16. Comprehensive Capital Analysis and Review 2013

Projected minimum regulatory capital ratios and tier 1 common ratios,

Q4 2012 to Q4 2014

Federal Reserve estimates in the severely adverse scenario

**State Street Corporation**

### Projected capital ratios through Q4 2014 under the severely adverse scenario

Actual | Stressed ratios with original planned capital actions | Stressed ratios with adjusted planned capital actions | |
---|---|---|---|

Q3 2012 | Minimum | Minimum | |

Tier 1 common ratio (%) | 17.78 | 9.65 | |

Tier 1 capital ratio (%) | 19.78 | 11.22 | |

Total risk-based capital ratio (%) | 21.32 | 13.86 | |

Tier 1 leverage ratio (%) | 7.60 | 5.48 |

### Table A.17. Comprehensive Capital Analysis and Review 2013

Projected minimum regulatory capital ratios and tier 1 common ratios,

Q4 2012 to Q4 2014

Federal Reserve estimates in the severely adverse scenario

**SunTrust Banks, Inc.**

### Projected capital ratios through Q4 2014 under the severely adverse scenario

Actual | Stressed ratios with original planned capital actions | Stressed ratios with adjusted planned capital actions | |
---|---|---|---|

Q3 2012 | Minimum | Minimum | |

Tier 1 common ratio (%) | 9.82 | 6.91 | |

Tier 1 capital ratio (%) | 10.57 | 8.61 | |

Total risk-based capital ratio (%) | 12.95 | 10.75 | |

Tier 1 leverage ratio (%) | 8.49 | 6.86 |

### Table A.18. Comprehensive Capital Analysis and Review 2013

Projected minimum regulatory capital ratios and tier 1 common ratios,

Q4 2012 to Q4 2014

Federal Reserve estimates in the severely adverse scenario

**U.S. Bancorp**

### Projected capital ratios through Q4 2014 under the severely adverse scenario

Actual | Stressed ratios with original planned capital actions | Stressed ratios with adjusted planned capital actions | |
---|---|---|---|

Q3 2012 | Minimum | Minimum | |

Tier 1 common ratio (%) | 8.97 | 6.61 | |

Tier 1 capital ratio (%) | 10.91 | 8.54 | |

Total risk-based capital ratio (%) | 13.32 | 10.54 | |

Tier 1 leverage ratio (%) | 9.17 | 7.20 |

### Table A.19. Comprehensive Capital Analysis and Review 2013

Projected minimum regulatory capital ratios and tier 1 common ratios,

Q4 2012 to Q4 2014

Federal Reserve estimates in the severely adverse scenario

**Wells Fargo & Company**

### Projected capital ratios through Q4 2014 under the severely adverse scenario

Actual | Stressed ratios with original planned capital actions | Stressed ratios with adjusted planned capital actions | |
---|---|---|---|

Q3 2012 | Minimum | Minimum | |

Tier 1 common ratio (%) | 9.92 | 5.94 | |

Tier 1 capital ratio (%) | 11.50 | 7.73 | |

Total risk-based capital ratio (%) | 14.51 | 10.72 | |

Tier 1 leverage ratio (%) | 9.40 | 6.18 |