The Regulatory Pendulum Swings Back: Fed Proposals for Board Governance and a Supervisory Rating System for Large Institutions
View Client Update
- On August 3, 2017, the Federal Reserve Board (the “FRB”) issued two sets of proposals: (1) a package of governance expectations intended to back away from the granular requirements and expectations that the FRB had increasingly imposed on boards of directors; and (2) a new large financial institutions rating system. The proposals are subject to a 60-day comment period.
- Broadly speaking, these proposals indicate that the bank regulatory agencies are actively taking steps to re-calibrate the post-crisis framework to streamline and reduce unnecessary regulatory burdens, a welcome development for institutions large and small.
- As a practical matter, these proposals indicate that banking organization boards will be able to shift their time commitments away from the details of regulatory and compliance issues and towards strategic oversight.