Comptroller of the Currency Tom Curry told bankers gathered at ABA’s Risk Management Forum in Orlando last week that the OCC’s proposed “heightened expectations” guidelines will not apply to small banks.
Curry said the guidelines, which set minimum standards for a bank’s risk governance framework and for oversight of that framework by the board of directors, do not apply to banks under $50 billion. The only exception is if a bank’s operations are highly complex or present a heightened risk -- a threshold that Curry said would only be crossed in “extraordinary circumstances.”
“Some community bankers may be reading that language as a loophole that we will use to impose onerous new requirements on community banks,” Curry said. “I want to assure you that this is not the case and not our intent.”
Curry also clarified that enforcing the guidelines means that if a bank fails to meet the guidelines, it will be required to develop and implement a plan to achieve compliance. “A formal enforcement action is only necessary in the event that a bank fails to submit or comply with an acceptable plan,” he said.
Read Curry’s speech.