Another criticism of the process is that the information provided in the living wills will be dated by the time the regulators release their assessments. The feedback provided by the Fed and the FDIC was from reports submitted in 2015, meaning that both the structures of the banks and market conditions may have changed.
“What are we supposed to do with this information? It’s already old,” said Mayra Rodriguez Valladares, the managing principal of financial consulting firm MRV Associates.