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CCAR Data Aggregation


With the passing of the Dodd-Frank Wall Street Reform and Consumer Protection Act in 2010 came the CCAR stress tests for all banks with greater than $50 billion in US assets — approximately thirty institutions. These stress tests comprised hundreds of loan specific and economic data points, making them some of the most comprehensive ever developed. However, it was the responsibility of each bank to build proprietary models to complete these stress tests with requisite detail.

Few institutions considered the immense amount of previously uncollected loan-level data that these models would consume. Our client required a portfolio wide data aggregation effort that would need to be completed in less than six months.


The BRS team of 120 credit-trained individuals with experience in CRE, C&I and Residential Mortgage underwriting took the lead on manually aggregating data for the entire portfolio. Both physical and electronic files were allocated across three asset specific teams, in three different bank locations. The teams completed two levels of quality control reviews on the entire portfolio to ensure the highest level of accuracy in our data collection efforts.


At the completion of the assignment, our client had a Matters Requiring Immediate Attention (MRIA) exception lifted and it was noted across the industry that the bank had now set the gold standard for data integrity. Our team reviewed 250,000 unique loan files and collected over 4.5 million data elements in less than six months, all while maintaining an accuracy rate of 99.8% across every asset class.

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