|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.