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The Office of the Comptroller of the Currency recently issued final guidelines establishing risk management standards for large national banks, insured federal savings associations, and insured federal branches of foreign banks. The guidelines formalize and make enforceable five “heightened expectations” that the OCC developed and began communicating to large banks informally following the financial crisis. Among other things, the guidelines will require banks to adopt a written risk governance framework to manage their risks in compliance with various substantive, procedural, and organizational structure requirements, and also impose certain standards on their boards, including a requirement that two directors be independent of both the bank and its holding company. The guidelines are part of a larger trend by U.S. federal banking regulators to scrutinize the risk management practices and procedures of large banking organizations.