Gibson Dunn discusses OCC Proposed Guidelines for Heightened Governance Standards for Large US Banks and Their Boards

The Office of the Comptroller of the Currency (OCC) has issued for public comment proposed guidelines (Guidelines) to establish minimum standards for risk management governance at large insured national banks, insured federal savings associations, and insured branches of non-U.S. banks (Banks).[1] The proposed Guidelines would generally apply to any such institution that has average total consolidated assets of $50 billion or more, measured over the four most recent consecutive quarters.

The Guidelines are yet another step in what is becoming a codified corporate governance framework for banking organizations that are deemed systemically significant, like the enhanced prudential standards proposed by

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