OCC Proposes Heightened Supervisory Standards for Large Insured National Banks, Insured Federal Savings Associations and Insured Federal Branches

On January 27, 2014 the Office of the Comptroller of the Currency (the "OCC") published proposed guidelines in the Federal Register ("Proposed Guidelines") that would formalize heightened supervisory expectations for large national banks, federal savings associations and federal branches of foreign banks. The OCC already has been examining some large institutions under these heightened standards since 2012 and meeting with management of these institutions quarterly for progress updates. Through the Proposed Guidelines, the OCC seeks to make these heightened expectations formal, enforceable and potentially applicable to a greater number of institutions.