Perspectives

Stronger: OCC's heightened expectations

Enhancing risk management and driving growth

The latest guidance issued by the Office of the Comptroller of the Currency (OCC) continues the trend of greater regulatory involvement. The OCC has proposed minimum standards for the design and implementation of a Risk Governance Framework and the role of the board of directors in administering its oversight. These proposed standards apply to large national banks and are consistent with the principles embedded in the Federal Reserve's expectations for large bank holding companies.

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Six key takeaways

Within this paper, six possible takeaways are identified for boards of directors and executives responsible for leading their institutions' governance- and risk-related initiatives. The six areas deserving special focus are:

  • Risk and strategy alignment
  • Board responsibilities
  • Three lines of defense
  • Internal audit
  • Risk data and infrastructure
  • Talent and culture

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Our thoughts

In this report, you will find our thoughts on the implications of new guidelines on each of these area —as well as actions your institution can begin taking in order to not only comply with them, but to use them as a springboard to growth.

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Strong risk management

Fundamental components of strong risk management:

  1. Governance: Board of directors and senior management set the right “tone at the top".
  2. Policies and procedures: Should address the complexity of an institution’s business and risk appetite.
  3. Internal controls: Effective internal controls should prevent and detect inappropriate/unapproved risk taking.
  4. Measure, monitor, and report Institutions: Should have the ability to identify, measure, monitor, and report all risks, including concentrations and risk appetite breaches.

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Enhanced prudential standards

The final rule