On September 2, 2014, the OCC published final guidelines to strengthen certain governance and risk management practices of 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 final guidelines also apply to an OCC-regulated institution with less than $50 billion in average total consolidated assets if that institution’s parent company controls at least one other covered institution. Pursuant to the guidelines, these large financial institutions should establish and comply with a written risk governance framework to manage its risk-taking activities. The guidelines set forth minimum standards for the institutions’ boards of directors to oversee the risk governance framework.
Institutions with $750 billion or more in average total consolidated assets should comply with the guidelines immediately upon the effective date as published in the Federal Register. Institutions with between $100 billion and $750 billion in average total consolidated assets have until six months of the effective date to comply. For institutions with average total consolidated assets ranging from $50 billion to $100 billion, compliance is expected within 18 months of the effective date and for those with less than $50 billion in average total consolidated assets that are covered because their parent company controls at least one other covered bank, compliance should be by the same date that the other covered bank is expected to comply. Institutions that reach the $50 billion threshold following publication of the guidelines should comply within 18 months from the date of the call report determining that it exceeded the threshold.
The final guidelines are available at: