FFIEC Finalizes Consumer Compliance System

11/16/16

The Federal Financial Institutions Examination Council last week announced the final version of its uniform interagency consumer compliance rating system, more commonly known as the “CC Rating System.” In its guidance the agency explained that the new rating system was re-designed “to better reflect current consumer compliance supervisory approaches and to more fully align the CC Rating System with the agencies’ current risk-based, tailored examination processes.”

It said the revisions “were not developed to set new or higher supervisory expectations for financial institutions and their adoption will represent no additional regulatory burden.” The new system will begin to be used by FFIEC member agencies for examinations beginning on or after March 31, 2017. 

The new model retains the 1-to-5 rating scale, which would be “based primarily on the adequacy of its CMS,” the agency said. Institutions would be assessed on board and management oversight, compliance program and violations of law and consumer harm.