On September 2, the OCC published its final guidelines to purportedly strengthen the governance and risk management practices of large financial institutions. The guidelines provide that covered institutions should establish and adhere to a written risk governance framework to manage and control risk-taking activities. The guidelines also provide minimum standards for the institutions’ boards of directors to oversee the risk governance framework. The covered institutions include insured national banks, insured federal savings associations, and insured federal branches of foreign banks with $50 billion or more in average total consolidated assets. The guidelines also apply to OCC-regulated institutions with less than $50 billion in average total consolidated assets if the institution’s parent company controls at least one other covered institution. The size of the covered institution’s average total consolidated assets determines when that institution is expected to begin complying with the new guidelines following publication in the Federal Register, with the largest institutions (and their qualifying subsidiaries) being expected to comply sooner (or even immediately) than smaller ones.