Abstract: The use of annual stress tests to set minimum capital requirements for large banks was among the most important innovations in prudential regulation following the Global Financial Crisis of 2007-2009. Using stress tests for this purpose promised greater risk sensitivity at the individual firm level and a better assessment of the banking system as a whole than the pre-crisis methods of setting fixed minimum capital requirements or using banks' internal models. A dozen years later, however, the robust stress testing regime that motivated its use for setting capital requirements has been diluted and is now a more routinized, predictable process. As the current Federal Reserve stress tests proceed to conclusion in June, Harvard law professor Dan Tarullo, who oversaw supervision and regulation as a Federal Reserve governor from 2009 to 2017, seeks to prompt a debate on whether stress testing should remain the basis for large bank minimum capital requirements in the U.S.