Pierre Rochard, CEO of The Bitcoin Bond Company, has formally requested that the Federal Reserve include Bitcoin as an explicit, standalone variable in its 2026 supervisory stress tests for banks. The request, submitted on January 20, argues that Bitcoin's extreme volatility and growing institutional footprint necessitate separate treatment from other cryptocurrencies in banking risk assessments.
Rochard's detailed letter challenges the Fed's current practice of grouping Bitcoin with a broad crypto category, stating it masks the asset's unique and non-linear risk profile. His quantitative analysis, covering data from 2015 through early 2026, shows Bitcoin with an annualized realized volatility of 73.3%, compared to 18.1% for the S&P 500. The analysis also documents a maximum peak-to-trough drawdown of 83.8% and daily return extremes ranging from -10.0% at the 1st percentile to 10.7% at the 99th percentile.
"Bitcoin’s risk profile is unusually idiosyncratic and materially non-linear: it has experienced repeated, deep peak-to-trough drawdowns and sustained periods of very high realized volatility," Rochard wrote. He warned that using a fixed 'beta' mapping from equities to Bitcoin would lead to inconsistent risk assessments across different market regimes.
To ensure consistent modeling, Rochard recommends the Fed provide quarterly Bitcoin price paths for baseline, adverse, and severely adverse scenarios, with optional daily paths for global-market-shock exercises. He proposed three calibration methods: historical feature matching, regime-switching time-series models, and jump-diffusion frameworks with stochastic volatility.
The request coincides with recent market stress, where Bitcoin plunged to $88,000 amid over $1 billion in liquidations, while gold surged past $4,800 per ounce. This divergence has renewed debate over Bitcoin's role as a strategic reserve asset. Galaxy CEO Mike Novogratz commented on the situation, noting gold's price signal about dollar dominance while expressing disappointment that Bitcoin was still facing selling pressure.
The submission also follows recent regulatory confusion over the U.S. government's handling of seized Bitcoin. After blockchain analysts flagged a transfer of 57.5 BTC from the Samourai Wallet case to a Coinbase Prime address, the Department of Justice, via White House crypto advisor Patrick Witt, confirmed the assets had not been liquidated and would be handled in compliance with Executive Order 14233, which directs confiscated Bitcoin to a Strategic Bitcoin Reserve.
The Federal Reserve's comment period for the 2026 stress test scenarios closes on February 21. The push for inclusion aligns with broader political advocacy, such as Senator Cynthia Lummis's proposed legislation to acquire up to 1 million Bitcoin for the U.S. government over five years through budget-neutral methods.
