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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 formalized its "heightened expectations" for risk management and governance through its 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.

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

On the following pages, you will find our thoughts on the implications of new guidelines on each of these areas — 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.

As used in this document, "Deloitte" means Deloitte LLP and its subsidiaries. Please see for a detailed description of the legal structure of Deloitte LLP and its subsidiaries. Certain services may not be available to attest clients under the rules and regulations of public accounting.

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