• Heightened Risk Governance Standards for Banks and Bank Boards of Directors: Proposed OCC “Guidelines” Would Establish Heightened Standards for Large National Banks’ Risk Governance Frameworks and Boards of Directors, and Accelerate Trends of Regulatory Involvement and Reliance on Enforcement
  • January 24, 2014
  • Law Firm: Sullivan Cromwell LLP - New York Office
  • On January 16, 2014, the Office of the Comptroller of the Currency (the “OCC”) solicited public comment, through a Notice of Proposed Rulemaking (the “NPR”), on proposed “guidelines” to establish minimum standards for the design and implementation of risk governance frameworks by certain large banks and minimum standards for the boards of directors of those banks in overseeing the frameworks’ design and implementation (the “Guidelines”). The NPR describes the Guidelines as building upon and formalizing informal “heightened expectations” for risk governance developed by the OCC in 2010 and as intended to improve examiners’ ability to assess compliance with the OCC’s expectations.