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‘Heightened Standards’ for Large Banks: OCC Proposed Guidelines

On January 16, 2014, the Office of the Comptroller of the Currency (OCC) released a proposal seeking comment on guidelines that would establish minimum standards of governance, risk management and board independence for certain large national banks, Federal savings associations, and Federal branches (collectively, “banks”). The guidelines are intended to become an integral part of the OCC’s safety and soundness regulations (12 CFR Part 30).

The OCC would apply these guidelines to insured national banks, insured Federal savings associations, and insured Federal branches of foreign banks (but not uninsured trust banks or uninsured Federal branches and agencies) with average total consolidated assets equal to or greater than $50 billion. However, the OCC would reserve authority for applying the guidelines to smaller banks if it determines that the operations of a bank are highly complex or otherwise present heightened risk, based on analysis of the bank’s complexity of products and services, risk profile, and scope of operations.

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If you have any questions, please contact the authors above or Walter B. Donaldson, II CFE, Managing Director, Freeh Group International Solutions, LLC at