ICBA urges OCC to adjust threshold for heightened standards proposal
March 03, 2026 / By ICBA
ICBA said that while it supports efforts to improve clarity and reduce unnecessary burden, the OCC’s proposal to increase the asset threshold for heightened governance standards goes beyond what is appropriate given recent supervisory experience.
Details: In a letter to the OCC, ICBA said the OCC’s proposed $700 billion threshold goes far beyond what is appropriate or safe and urged the agency to establish the threshold at $100 billion.
Background: The OCC in December proposed increasing the asset threshold at which guidelines regarding heightened risk governance framework standards apply to national banks. The proposed rule would raise the average total consolidated assets threshold for applying the guidelines from $50 billion to $700 billion, remove certain institutions from longstanding governance and risk-management standards, and make related technical changes.
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