In our 2017 analysis of the FRB’s proposed standards for BHC boards governance (see Client Report CORPGOV23), we noted that the proposal holds directors to higher account despite criticism at the time that it relaxed them. As former Chair Yellen noted in her letter to Sen. Warren (D-MA) in concert with the FRB’s Friday action against Wells Fargo, the guidance plans tougher standards, but it is striking that the Board not only did not wait for finalization before deploying them, but also made a point of placing the blame very publicly on both past and current directors as well as the former CEO.
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