ICBA sent a letter to the Federal Reserve in response to its request for comment on proposals to enhance the transparency and public accountability of its annual stress test for large banks. ICBA said the Fed should not make changes that would transform stress testing into a mere compliance exercise that can be manipulated, which would have significant negative implications for the safety and soundness of the banking system. ICBA also said that while it appreciates the Fed’s work to reconsider regulatory and supervisory burden, these efforts should be directed towards the undue burdens imposed on smaller institutions that pose little risk to the banking system.