Fed may be forced to model Bitcoin in bank stress tests
Pierre Rochard’s call for the Federal Reserve to incorporate Bitcoin into its bank stress tests comes at a notable moment, as the Fed is simultaneously seeking public feedback on its 2026 scenarios and proposing greater transparency in how those models are built and updated. The issue is not whether the Fed would “endorse” Bitcoin, but whether it can realistically treat Bitcoin as a risk variable without turning it into policy.
The analysis suggests the question is fundamentally technical rather than ideological. The Fed is unlikely to mainstream Bitcoin simply because of external pressure. However, if banks’ exposures to Bitcoin—through custody, derivatives, ETF intermediation, or prime-brokerage-style services—grow large enough to materially affect capital or liquidity metrics, the Fed may have little choice but to model Bitcoin price shocks in the same way it models equity drawdowns or credit spread widening.
Such a move would not signal approval of Bitcoin. Instead, it would acknowledge that Bitcoin has become sufficiently embedded in regulated bank balance sheets that ignoring it would undermine the credibility of stress testing. In practice, Bitcoin could first enter the framework as part of the global market shock applied to banks with significant trading or custody operations, rather than as a core macroeconomic variable.
If Bitcoin were included, stress tests would standardize how banks assess crypto-related risks, replacing today’s patchwork of proxies. Banks would likely face tighter controls, stronger governance, more rigorous model validation, and more detailed data requirements for crypto-facing businesses. Ultimately, Bitcoin would appear in stress tests not as a policy statement, but because its footprint in the regulated financial system had grown too large for the Fed to overlook.
