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OCC Proposes Guidelines Establishing Heightened Standards for Large Institutions

by Erich M. Hellmold
Kilpatrick Townsend & Stockton LLP - Washington Office

Michael A. Mancusi
Kilpatrick Townsend & Stockton LLP - Washington Office

Kevin M. Toomey
Kilpatrick Townsend & Stockton LLP - Washington Office

January 31, 2014

Previously published on January 24, 2014

On January 16, 2014, the Office of the Comptroller of the Currency (“OCC”) released a proposal establishing minimum standards for the design and implementation of a risk governance framework for large insured national institutions, insured federal savings associations, and insured federal branches of foreign institutions with average total consolidated assets of $50 billion or more (the “Proposed Framework”), and minimum standards for the board of directors’ oversight of the framework’s design and implementation (the “Proposed Board Requirements”) (collectively, the “Proposed Heightened Standards”). The Proposed Heightened Standards would reserve the OCC’s authority to apply the guidelines to an institution with less than $50 billion in assets if the OCC determines that it is highly complex or otherwise presents a heightened risk. In making such determination, the OCC will consider the institution’s risk profile, scope of operations, and the complexity of products and services offered by the institution.


The views expressed in this document are solely the views of the author and not Martindale-Hubbell. This document is intended for informational purposes only and is not legal advice or a substitute for consultation with a licensed legal professional in a particular case or circumstance.

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