The 2017 Comprehensive Capital Analysis and Review may contain a few surprises — to the upside.

Recent regulatory changes to the review, also called CCAR, mean that a swath of banks could push capital returns to levels unseen since the process began. This year could mark a significant evolution in the regulatory review process, where internal planning is less of an issue for some banks alongside a general belief that the nation's largest banks are finally safe and capitalized enough to begin making significant returns.

Over the years, the process and planning issues that made up the qualitative portion of the test have ebbed in importance as banks brought their capital planning procedures up to speed. For analysts who cover the largest banks, the biggest question has shifted from which bank might receive a surprise objection to how aggressive will they be in their capital returns. The results of the exercise will be released June 28 after markets close.

"We sense a heightened interest in this year's CCAR, which we attribute to easing rules around 'qualitative' failure potential (nearly two-thirds of participating companies will not need to worry about this wildcard) and hopes that 'asks' could become even more aggressive than has been the case in past cycles," wrote Sandler O'Neill analyst Jeffery Harte, the lead analyst in a June 1 report previewing the test.

He wrote that Sandler has "very few" concerns about banks passing and has a median earnings payout of 88.0% for its covered companies, its highest estimate since it began previewing expectations. Keefe Bruyette & Woods analysts modeled a slightly lower payout ratio of 85%, compared to 72% last year, according to a May 18 report. The payout ratio refers to both dividend and share repurchases.

The economic scenarios in this year's review are slightly more severe than last year, which could be a good omen for institutions that fared well in last year's test. The review should demonstrate that the nation's largest banks have "further capacity to meaningfully increase" their capital deployments, wrote Vining Sparks analyst Marty Mosby in a May 23 note. He wrote that these institutions should be able to "generate double-digit dividend growth for the 5th consecutive year, increase share repurchase authorization by about 50%, and move the median total payout ratio up to approximately 100% for the first time since the financial crisis."

This year also marks the first time that participating banks with assets of less than $250 billion and nonbank assets of less than $75 billion will be exempted from the qualitative portion and subject only to what the Fed is calling the "horizontal capital review." Twenty-one of the 34 banks meet this standard.

Raymond James analyst David Long wrote in a June 2 report that CCAR "winners" could be Bank of America Corp., Northern Trust Corp. and Regions Financial Corp. He has modeled a larger-than-consensus dividend increase at Bank of America and a larger-than-consensus increase in share repurchase authorization at Northern Trust, with Regions having the highest expected total payout ratio of banks in Raymond James' coverage universe.

Sandler analysts believed Bank of New York Mellon Corp., Discover Financial Services, Fifth Third Bancorp, M&T Bank Corp. and Regions could all reach the 100% total payout ratio, qualifying that Fifth Third's announcement tends to have a lower headline number with the potential for additional repurchases. KBW analysts said they believe CIT Group Inc., M&T, Regions, Citizens Financial Group Inc. and Goldman Sachs Group Inc. could reach or breach 100%.

Sandler also expected better performance in this year's exercise from Huntington Bancshares Inc. and KeyCorp. Both of the superregionals had announced deals that had significant ramifications to their 2016 performance, and their asks this year could trend toward the lower end of the group as they rebuild capital.

One bank that many analysts expect to struggle with the exercise, or perhaps receive an objection, is Wells Fargo & Co. Both Long and Harte wrote that the bank is at higher risk of failing the qualitative portion because of oversight issues associated with its fake-account scandal in 2016.

"This opinion has nothing to do with Wells Fargo's quantitative ability to support higher capital return. Rather, we have simply witnessed enough instances of high-profile intra-cycle 'incidents' that have negative ramifications come the next CCAR," Harte wrote.

But Sandler cautioned that expectations from bank observers may be more aggressive than the banks themselves, who may be wary of a mulligan or a conditional nonobjection. While banks may have the capacity to ask for a greater capital return and regulators may be more flexible, Harte wrote that institutions may "test the waters for a year or so before committing to significantly more aggressive asks that go well beyond 100% payouts."

Click here to view an article on the capital plans announced by CCAR participants in mid-2016. Public companies report information on dividends paid in their cash flow statement. The cash flow section can be found in the 'As-Reported' segment under the financials tab on the companies briefing book page on the SNL website.