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OCC People:  Five Minutes with Amy Friend


Amy Friend is Senior Deputy Comptroller and Chief Counsel.

Tell us about the Chief Counsel’s Office

The Chief Counsel’s Office (CCO) manages a Law Department of seven legal practice areas and the Licensing and Community Affairs divisions. We have approximately 320 team members in total.

Amy Friend

Senior Deputy Comptroller and Chief Counsel Amy Friend

OCC attorneys in the Law Department in Headquarters and the districts develop interpretive opinions of the banking laws; enforce compliance with those laws, including through administrative actions; ensure protection and fair treatment of bank and savings association customers through application of consumer laws and regulations; develop banking regulations and legislation; advise on international banking issues, including by participating in international working groups; represent the Comptroller in litigation; and provide legal advice relating to the OCC’s operation as a federal agency.

Five minutes with...

Licensing administers the OCC’s policies and procedures relative to the formation of a new bank, entry into the federal banking system, and the implementation of structural changes and corporate expansion. Licensing works closely with OCC supervisory offices and the other units in CCO to render decisions that are supported by a sound record of facts and financial, supervisory and legal analyses. Licensing has offices in Washington, D.C., and each district. In Washington, there are three functional areas: Licensing Activities, Large Bank Licensing, and Thrift Licensing.

Community Affairs is composed of Community Affairs Policy and Community Development, and is represented in the districts by District Community Development Officers and staff.  Community Affairs engages in outreach and develops publications to help banks provide financial services to underserved markets. Community Affairs also administers the national bank public welfare investment authority and comparable authority for federal savings associations. It also assists with Community Reinvestment Act exams. 

Before becoming Chief Counsel at the OCC, you were Chief Counsel for the Senate Banking Committee and played a prominent role in drafting the Dodd–Frank Wall Street Reform and Consumer Protection Act. Do you have any observations on the legislation or its implementation now that you have been at the OCC for nine months or so?

It’s very interesting to have worked on the legislation in Congress and now to have an opportunity to shape the way in which the legislation is being implemented. Clearly,  Dodd – Frank  was a landmark piece of legislation. Each title was a major undertaking, and in aggregate, it addresses almost every aspect of financial regulation. In many areas, Congress required a collaborative rulemaking process to implement the law, and we are engaged in that process now with our interagency colleagues. Many of the issues are highly technical and complex and have taken time to work through. However, we are making significant progress on a number of fronts, and I think the Congressional objectives behind the legislation are coming to fruition in its implementation.

Tell us about the important projects you are currently involved with.

Too many to mention! But let me talk about a project that I think is very important to the agency. Following the financial crisis, the OCC set higher supervisory expectations for our larger banks through our “heightened expectations” program. The program, which has been refined over the last few years, focuses on risk management, internal controls and audit, and corporate governance. Expectations include ensuring that boards of directors are sufficiently engaged to be able to provide a credible challenge to bank management, having processes in place to ensure that the banks are attracting and retaining talented officers needed to manage their business in a safe and sound manner, and defining and communicating acceptable risk tolerance. Currently, Large Bank Supervision, Midsize and Community Bank Supervision, and the Law Department are collaborating on a project to formalize the heightened expectations program by issuing for notice and comment standards that would be enforceable. 

You are the Executive Sponsor for the Comptroller’s “Engaging” initiative.  What do you think of engagement within the OCC?  In your opinion, how can the OCC improve engagement?

I think there is room for further enhancements. We are taking steps to improve the ability for OCC employees to interact with the Comptroller and the rest of the Executive Committee and have tried to foster and encourage communication across business units in Washington and the district offices. One of the cornerstones of engagement is effective communication. Whether it is between management and staff, department to department, or office-to-office, enhancing communication is a fundamental aspect of improving engagement. We are looking to improve our communication throughout the agency, and we are doing so through individually focused activities like communication skills training and through broader initiatives that encourage collaboration among business units. Although there may be benefits to a business unit having a narrow, defined focus, such a focus should not lead to separation from other parts of the agency.  We are trying to break down “silos” and encourage multidisciplinary coordination.

Changing gears, can you tell us a little more about yourself?  What do you like to do outside of work?

Work-life balance can sometimes be difficult to achieve in this job, but I think I’m improving in that regard. On the weekends, I cherish the time I can take for myself outside of work, and I value my time with my family and friends. I have a son and a daughter. Neither of them is living at home–my daughter is a senior in college, and my son recently graduated from college but he lives nearby. I am an empty nester–but happy in my home with my husband and my dog, who is my running partner. I try to exercise on a daily basis. It just makes me feel better about everything, especially when I am in the office.  I also enjoy travelling and am currently planning a trip to Africa next summer.

Last Updated: 01/27/2015