TCH Letter to OCC on Proposed Heightened Standards Offers Support, Suggests Clarification of Certain Aspects of Proposed Guidelines
The Clearing House Association (TCH) submitted a comment letter to the Office of the Comptroller of the Currency (OCC) today in response to the agency’s January 2014 proposed guidelines that would establish minimum standards for risk governance and bank boards of directors for banks with $50 billion or more in total consolidated assets. In its letter, TCH reiterates its strong support for the primary objective of the guidelines – a strong and effective risk management framework for banks – but recommends clarification of certain key aspects of the proposed guidelines in order to ensure that they achieve their stated purpose.