The Committee submitted a letter to the Federal Reserve (“Fed”) commending the Fed for seeking to clarify supervisory expectations for boards of directors, refocus expectations on boards’ core functions, and distinguish expectations for boards from those of management. The letter noted the Committee’s concern, however, that the Fed’s guidance could be construed as imposing rigid and prescriptive rules for how a board should fulfill its functions and encouraged the Fed to clarify that its guidance is not setting specific, binding requirements about how a board must act to effectively carry out core responsibilities.

The letter is available here.