Washington, D.C. – The Federal Reserve’s proposed 2026 stress test scenarios reflect a welcome effort to enhance transparency and public accountability, the Bank Policy Institute, American Bankers Association, Financial Services Forum, Securities Industry and Financial Markets Association, International Swaps and Derivatives Association and Institute of International Bankers said in a comment letter submitted today.
The associations commend the Fed for, for the first time, publishing its proposed 2026 stress test scenarios for public comment and for articulating a more detailed scenario design policy, including guides and a macro model that describe how key variables are calibrated. These actions respond constructively to longstanding calls for the Fed to bring its stress testing models and scenarios into the Administrative Procedure Act’s notice-and-comment framework and reflect a serious effort to increase public insight into the process. Still, the scenarios, which in many cases replicate scenarios from past stress tests and were established before the new Fed guidelines, would benefit from some revisions. For example, the scenarios and associated models that the Federal Reserve uses to design the scenarios often compress the timelines of observed stress periods to achieve peak-level stress calibrations over a shorter number of quarters than is reflected in historical precedents.
Open questions remain on how the Fed will exercise its discretion on scenario design in practice. Greater clarity and firmer guardrails on how that discretion is applied year to year would further bolster the framework’s credibility and ensure that bank capital requirements are based on a coherent and plausible foundation.
“The Enhanced Transparency NPR and the publication of the Proposed 2026 Scenarios for public comment represent an improvement in the overall transparency and accountability of the Federal Reserve’s stress testing processes. However, the proposed framework would grant inordinate discretion to the Federal Reserve, without requiring sufficient explanation for its design choices year-to-year,” the associations stated in the letter.
Background. The Fed on Oct. 24, 2025, issued proposals to increase transparency and accountability in the stress testing process, in line with BPI and co-plaintiffs’ 2024 legal challenge, which called for the Fed to subject its stress testing scenarios and models to public comment under the Administrative Procedure Act.[1]
Why It Matters. The proposed framework will drive how the central bank establishes binding capital requirements that determine the cost of credit in the economy. The design choices underpinning models and scenarios ultimately drive the cost of loans and financing. With insufficient explanation of design choices, the stress tests could continue to produce volatile results year-to-year, distorting the cost of financial intermediation.
Specific Concerns. The associations highlight several instances where more explanation would be beneficial in the proposed scenarios. For example:
[1] This legal challenge was filed in December 2024 by the Bank Policy Institute, the American Bankers Association, the U.S. Chamber of Commerce, the Ohio Bankers League and the Ohio Chamber of Commerce.
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The Bank Policy Institute is a nonpartisan public policy, research and advocacy group that represents universal banks, regional banks and the major foreign banks doing business in the United States. The Institute produces academic research and analysis on regulatory and monetary policy topics, analyzes and comments on proposed regulations, and represents the financial services industry with respect to cybersecurity, fraud and other information security issues.
The American Bankers Association is the voice of the nation’s $25.1 trillion banking industry, which is composed of small, regional and large banks that together employ more than 2 million people, safeguard $19.7 trillion in deposits and extend $13.2 trillion in loans.
The Financial Services Forum is an economic policy and advocacy organization whose members are the eight largest and most diversified financial institutions headquartered in the United States. Forum member institutions are a leading source of lending and investment in the United States and serve millions of consumers, businesses, investors, and communities throughout the country. The Forum promotes policies that support savings and investment, financial inclusion, deep and liquid capital markets, a competitive global marketplace, and a sound financial system.
SIFMA is the leading trade association for broker-dealers, investment banks and asset managers operating in the U.S. and global capital markets. On behalf of our industry’s nearly 1 million employees, we advocate for legislation, regulation and business policy, affecting retail and institutional investors, equity and fixed income markets and related products and services. We serve as an industry coordinating body to promote fair and orderly markets, informed regulatory compliance, and efficient market operations and resiliency. We also provide a forum for industry policy and professional development. SIFMA, with offices in New York and Washington, D.C., is the U.S. regional member of the Global Financial Markets Association (GFMA). For more information, visit http://www.sifma.org.
Since 1985, ISDA has worked to make the global derivatives markets safer and more efficient. Today, ISDA has over 1,000 member institutions from 78 countries. These members comprise a broad range of derivatives market participants, including corporations, investment managers, government and supranational entities, insurance companies, energy and commodities firms, and international and regional banks. In addition to market participants, members also include key components of the derivatives market infrastructure, such as exchanges, intermediaries, clearing houses and repositories, as well as law firms, accounting firms and other service providers. Information about ISDA and its activities is available on the Association’s website: www.isda.org. Follow us on LinkedIn and YouTube.
The Institute of International Bankers (IIB) represents the U.S. operations of internationally headquartered financial institutions from more than 35 countries around the world. The membership consists of international banks that operate branches, agencies, bank subsidiaries, and broker-dealer subsidiaries in the United States. The IIB works to ensure a level playing field for these institutions, which supported $5.4 trillion in foreign direct investment by underwriting more than 70% of debt issuance in the United States by internationally headquartered companies over the last four years. These institutions also underwrote more than 40% of U.S. financing raised since 2020 and comprise the majority of U.S. primary dealers.
Tara Payne
Bank Policy Institute
media@bpi.com
Josh Britton
American Bankers Association
jbritton@aba.com
Laura Peavey
Financial Services Forum
lpeavey@fsforum.com
Lindsay Gilbride
Securities Industry and Financial Markets Association
lgilbride@sifma.org
Christopher Faimali
International Swaps and Derivatives Association
cfaimali@isda.org
Jana Conner
Institute of International Bankers
jconner@iib.org
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Crystal Lake, Illinois, December 1, 2025 – AptarGroup, Inc. (NYSE: ATR), a global leader in drug and consumer product dosing, dispensing and protection technologies, today announced that it has acquired Sommaplast, a specialized provider of oral dosing pharma packaging solutions, such as closures, droppers, dispensers and dosing cups, based in Brazil.
“Aptar has manufactured in Brazil for 25 years and this acquisition is expected to further reinforce our footprint in the region. It also helps position us to capitalize on Brazil’s fast-growing oral dosing, over-the-counter and nutraceutical markets. This growth is driven by an expanding population, rising middle class and aging demographic,” explained Gael Touya, President, Aptar Pharma.
Sommaplast was founded over 20 years ago and operates from a facility in Sao Paulo, Brazil with a team of over 400 employees. Today, Sommaplast is recognized for its strong team, deep customer relationships and high level of dosing know-how. With this acquisition, Aptar is building on its over 80-year history innovation and excellence. Aptar currently has manufacturing facilities in Cajamar, Jundiaí, Maringá and Camaçari, Brazil and this transaction expands the company’s presence in Latin America and brings together shared manufacturing strengths.
Further building on the acquisition rationale, Touya said, “We plan to further extend Sommaplast’s offerings in the oral dosing pharma markets through its strong commercial capabilities and expanded product offering. Together, our operational synergies and precision injection molding expertise will greatly benefit customers. We intend to maintain the DNA of Sommaplast’s family-owned company, while leveraging our global network of solutions, services and product experts.”
Read the full press release here.
About Aptar
Aptar is a global leader in drug and consumer product dosing, dispensing and protection technologies. Aptar serves a number of attractive end markets including pharmaceutical, beauty, food, beverage, personal care and home care. Using market expertise, proprietary design, engineering and science to create innovative solutions for many of the world’s leading brands, Aptar in turn makes a meaningful difference in the lives, looks, health and homes of millions of patients and consumers around the world. Aptar is headquartered in Crystal Lake, Illinois and has over 13,000 dedicated employees in 20 countries. For more information, visit www.aptar.com.
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