OCC's final 'heightened expectations': an overview focusing on how the OCC responded to industry comments

On Sep 2, 2014, the Office of the Comptroller of the Currency (OCC) issued final guidelines establishing heightened risk governance standards for OCC-regulated large financial institutions and their OCC-regulated affiliates (Guidelines). This update provides a broad overview of the scope, implementation timing, structure, and requirements of the Guidelines, and it highlights in chart form the way in which the OCC revised the proposed form of the Guidelines in response to industry concerns that were raised during the comment process. The core element of the Guidelines is the requirement for a formal, written risk governance framework approved by the board of directors or the risk committee of the board of directors. The Guidelines are the third significant risk management-focused rulemaking to be finalized this year, in addition to the Volcker Rule and the Federal Reserve's enhanced prudential standards (Regulation YY).