Are You Ready for the New Consumer Compliance Rating System?
In November 2016, the Federal Financial Institutions Examination Council (FFIEC) updated the Uniform Interagency Consumer Compliance Rating System, commonly known as the CC Rating System, to reflect changes in regulations, supervisory frameworks, technological advancements, and market conditions.
The FFIEC stipulated that the revised rating system was an attempt to institute risk-based expectations commensurate with the size, complexity, and risk profile of institutions while incenting them to prevent, self-identify, and address compliance issues.
In issuing final guidance on the CC Rating System, the FFIEC made it clear that the revisions were not intended to set new or higher supervisory expectations and that their adoption does not represent additional regulatory burden. The revisions were designed to “better reflect current consumer compliance supervisory approaches and to more fully align the rating system with the agencies’ current risk-based, tailored examination processes."1
The FFIEC recommended that the agencies—the Federal Reserve, the Consumer Financial Protection Bureau, the Federal Deposit Insurance Corporation, the National Credit Union Administration, the Office of the Comptroller of the Currency, and the State Liaison Committee—implement the updated rating system for compliance examinations beginning on or after March 31, 2017.
Senior Managing Director, Co-Leader of Financial Services