ARTICLE
16 November 2016

FFIEC Revises Consumer Compliance Rating System

CW
Cadwalader, Wickersham & Taft LLP

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The Federal Financial Institutions Examinations Council ("FFIEC") revised the Uniform Interagency Consumer Compliance Rating System ("CC Rating System").
United States Finance and Banking

The Federal Financial Institutions Examinations Council ("FFIEC") revised the Uniform Interagency Consumer Compliance Rating System ("CC Rating System"). The CC Rating System is a supervisory policy for evaluating procedures employed by financial institutions to meet consumer compliance requirements. The FFIEC's changes to the CC Rating System reflect the "regulatory, examination (supervisory), technological, and market changes that have occurred in the years since the original rating system was established in 1980."

Revisions are designed "to more fully align the CC Rating System with the Agencies' current risk-based, tailored examination processes." The FFIEC emphasized that the "revisions to the CC Rating System were not developed to set new or higher supervisory expectations for financial institutions and their adoption will represent no additional regulatory burden."

Based on responses to a June 9, 2016 request for comments, the FFIEC updated language in the CC Rating System's Guidance by adding references to the self-identification of consumer compliance issues to the description of the "Corrective Action and Self-Identification" assessment factor.

The revised CC Rating System will become effective on March 31, 2017.

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