On May 2, the Federal Financial Institutions Examination Council (FFIEC) proposed revisions to the current Uniform Interagency Consumer Compliance Rating System (CC Rating System). The revisions are intended to reflect the regulatory, supervisory, technological and market changes that have occurred in the years since the CC Rating System was established. The purpose of the new CC Rating System is to ensure that all regulated financial institutions, as defined in 12 U.S.C. §3302(3), are evaluated in a comprehensive and consistent manner, and that regulators’ resources and attention are appropriately allocated to the institutions demonstrating the highest risk of consumer harm. One key change is that the new CC Rating System has shifted from assessing risk through transaction testing to a more comprehensive risk-based supervision that mainly focuses on the institution’s compliance management systems (CMS).
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