ABA today expressed support for proposed revisions to the Federal Financial Institutions Examinations Council’s Consumer Compliance Rating System that reflect the significant regulatory, supervisory, technological and market changes that have occurred since the FFIEC adopted the existing consumer compliance evaluation process in 1980.
When the current rating system was adopted, examinations focused on transaction testing rather than on a risk-based evaluation of an institution’s compliance management system. ABA in a comment letter expressed support for the proposal’s risk-based and CMS-focused evaluation and recommended further improvements, including assigning responsibility for the CC Rating to the appropriate prudential regulator (rather than the Consumer Financial Protection Bureau) for banks with more than $10 billion in assets; using oversight to ensure that the proposed CC Rating System will not result in new or increased supervisory expectations; and clarifying the proposal’s discussion of “violations of law and consumer harm.”
