The Davis Polk Capital and Prudential Standards Blog is under redesign. We plan to relaunch in early 2017.
The OCC has issued final risk governance guidelines that formalize its heightened expectations for large national banks and federal savings associations. The risk governance guidelines set new, and much higher, minimum standards for the design and implementation of a bank’s own risk governance framework and the oversight of such framework by the bank’s board of directors. The guidelines are enforceable under the OCC’s statutory authority to prescribe operational and managerial standards for national banks and federal savings associations.
State banks that are not subject to the OCC’s risk governance guidelines should still pay attention because the same or similar principles will likely be applied by the Federal Reserve and the FDIC to large state member and non-member banks.… Read More
The U.S. banking agencies have finalized revisions to the denominator of the supplementary leverage ratio (SLR), which include a number of key changes and clarifications to their April 2014 proposal. The SLR represents the U.S. implementation of the Basel III leverage ratio. Under the U.S. banking agencies’ SLR framework, advanced approaches firms must maintain a minimum SLR of 3%, while the 8 U.S. bank holding companies that have been identified as global systemically important banks (U.S. G-SIBs) and their U.S. insured depository institution subsidiaries are subject to enhanced SLR standards.… Read More
The U.S. banking agencies have issued a final rule to implement the Basel III liquidity coverage ratio (LCR) in the United States. The LCR requires large banking organizations to maintain a minimum amount of liquid assets to withstand a 30-day standardized stress scenario. The U.S. LCR final rule is more stringent than the Basel Committee’s LCR framework in several significant respects. In addition, the final rule makes a number of key changes to the proposed rule.
Davis Polk’s visual memorandum uses diagrams, flowcharts, timelines, examples and comparison tables to illustrate key aspects of the U.S.… Read More