• 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.