ICBA sent a comment letter to the OCC regarding its proposed rulemaking to amend the OCC Guidelines Establishing Heightened Standards, which would raise the threshold for application of the guidelines from $50 billion in total consolidated assets to $700 billion, remove certain institutions from longstanding governance and risk-management standards, and make related technical changes. ICBA said that while it supports efforts to improve clarity and reduce unnecessary burden, the proposed increase to a $700 billion threshold goes far beyond what is appropriate or safe given recent supervisory experience. ICBA urged the OCC to adopt a calibrated modernization approach by establishing the Heightened Standards threshold at $100 billion.