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Article July 17, 2025

Stress Testing Isn't Just a Fed Requirement - It's a Survival Strategy

Stress Testing Isn't Just a Fed Requirement - It's a Survival Strategy

Sergey Yeremenko, Internal Audit Director - ALM, Model and Market Risk, PNC BankLinkedIn profile for Sergey Yeremenko

A banking executive explores how stress testing reveals vulnerabilities in capital and operations, highlighting its value as both a regulatory tool and a strategic compass in an unpredictable economic environment.

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When I considered buying a small hotel in Ocean City, New Jersey, I wasn’t just thinking about the charm of owning a seaside business. I was calculating how my finances would hold up if bookings dried up for a season or two.

That same logic applies to how financial institutions should be thinking about capital stress testing – less as a regulatory checkbox and more as a hard look at what could go wrong, and how deeply.

This perspective shaped my recent remarks at Risk Americas, where we dug into the evolving role of stress testing in capital and balance sheet management.

For banks with assets over $100 billion, the Federal Reserve’s stress capital buffer framework remains a central influence. It’s a powerful tool in shaping minimum capital requirements, particularly for CET1 ratios, by subjecting banks to a range of hypothetical but severely adverse conditions.

But the real value of stress testing is revealed when institutions go beyond the Fed’s templates and start interrogating their own vulnerabilities.

At its best, internal stress testing is an exercise in scenario craftsmanship. Banks build their own adverse narratives, rooted in their specific exposures, geographies, business models, and balance sheet characteristics.

It’s an iterative process that demands input from across the enterprise – from risk teams to business lines to treasury – and rewards those who can turn raw risk inventory into coherent, plausible futures.

Interest rate volatility remains top of mind. At the session, we explored the sharp unrealized losses that can hit banks when bond portfolios mark to market in a rising-rate environment.

Importantly, these losses have occurred without any underlying credit deterioration. They’ve simply been a function of market moves and accounting. That disconnect has real consequences – impacting reported capital, influencing strategic decisions, and drawing regulatory attention.

Some banks have proactively restructured their securities holdings to reduce rate sensitivity. Others have waited, and the difference in outcomes is now visible.

This is where internal stress testing adds value: it reveals which choices today could become liabilities tomorrow, especially when regulatory scenarios assume rate cuts that may never come.

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