The Comprehensive Capital Analysis and Review (“CCAR”) involved the Federal Reserve  Board’s (“Board”) forward looking evaluation of the internal capital planning processes of large, complex bank holding companies and their proposals to undertake capital actions in 2011, such as increasing dividend payments or repurchasing or redeeming stock. On 17 November 2010, the Board issued guidelines to provide a common, conservative approach to ensure that these bank holding companies hold adequate capital to maintain ready access to funding, continue operations and meet their obligations to creditors and counterparties, and continue to serve as credit intermediaries, even under adverse conditions. Nineteen large bank holding companies submitted comprehensive capital plans and additional supervisory information to the Federal Reserve in early January. The Federal Reserve evaluated these plans across five areas of supervisory consideration. These are the bank holding company’s: (i) capital assessment and planning processes; (ii) capital distribution policy; (iii) plans to repay any government investment; (iv) ability to absorb losses under several scenarios; and (v) plans for addressing the expected impact of Basel III and the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010.