The proposed revision to the bank ratings framework is consistent with the approach that regulators have taken to supervision recently, including the Fed’s recently revised Statement of Supervisory Operating Principles. 

Key features of the proposal are that the CAMELS components are retained, but there would be an emphasis on the consideration of material financial risks over concerns related to policies, procedures, and documentation. In addition, the framework would no…

The OCC’s proposed rulemaking appears to be intended to address potential court challenges to the OCC’s authority to charter limited-purpose trust banks based on the activities in which such banks engage (or do not engage). The applications that OCC has acted on have drawn comments, basically saying that the OCC does not have authority to approve the applications. (See .)

The provision at issue in the proposed rule and the changes made are both a matter of a very few words. However,…

The OCC noted that it expects that smaller banks not subject to heightened standards will maintain robust risk governance frameworks, risk management systems, and processes that are tailored to their individual size, complexity, and risk profile. In addition, the OCC asks for comment on a number of matters, including whether any parts of the heightened standards (such as those relating to strategic plans, risk appetite statements, talent management processes, compensation and performance…

The Comptroller’s brief notes that the Comptroller sits on the board of the Federal Deposit Insurance Corporation, in which capacity the Comptroller has an interest in preserving the competitive equality between national and state-chartered banks.