Simpson Thacher discusses OCC Guidelines for Bank Risk Governance

On September 2, 2014, the Office of the Comptroller of the Currency (the “OCC”) issued final guidelines (the “Guidelines”) establishing risk management standards for large national banks, insured federal savings associations, and insured federal branches of foreign banks (each, a “bank”).[1] The Guidelines formalize and make enforceable five “heightened expectations” that the OCC developed and began communicating to large banks informally following the financial crisis, and which were eventually proposed as enforceable guidelines in January 2014. The five heightened expectations are:

  • for the board of directors of a bank to preserve the “sanctity of the charter” by ensuring that the

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