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TCH Highlights the Importance of Flexibility in Governance Structures and Practices in Comment Letter on BCBS Bank Governance Proposal

The Clearing House Association filed a comment letter with the Basel Committee on Banking Supervision in response to its Corporate Governance Principles for Banks consultative document. TCH’s letter recommends a number of changes designed to better: (i) delineate the board of directors’ responsibility for oversight of the business of a bank as distinct from management’s responsibility for the day-to-day operations, (ii) clarify the narrow nature of director fiduciary duties, and (iii) reinforce the importance of giving each banking organization sufficient flexibility to tailor its governance practices to its business and risk profile. TCH’s comment letter on the Basel consultative document forms an important part of TCH’s larger corporate governance advocacy agenda, and echoes many of the major themes articulated in TCH’s Guiding Principles for Enhancing Banking Organization Corporate Governance, the latest version of which was published for public comment in September 2014.