Question: Read the OCC Guidelines Establishing Heightened Standards , and in particular read carefully the general comments (pp. 54518-54539) received by the OCC during the comment

  • Read theOCC Guidelines Establishing Heightened Standards, and in particular read carefully the general comments (pp. 54518-54539) received by the OCC during the comment period prior to the guidance being finalized.
    • What surprised you in terms of industry push-back on some of the requirements?
  • Read theFederal Reserve's Cease and Desist Order against Wells Fargo
    • Highlight key areas of failure on the part of Wells Fargo and their Board that were clear requirements in the OCC's Heightened Standards.

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