In a June 30, 2016 comment letter to the Federal Financial Institutions Examination Council (Agencies) CBAI urged the Agencies to make certain changes to its revision of the Uniform Interagency Consumer Compliance Rating System (CC Rating System) prior to final implementation.
CBAI took exception to the Agencies' claim that the system imposes no higher supervisory expectations or additional regulatory burden. To suggest that a comprehensive revision of the CC Rating System and examination process will not set new or higher supervisory expectations or will not create an additional regulatory burden has not been proven in the first instance and is completely untrue in the second.
While CBAI appreciates the Agencies' effort to modernize the CC Rating System, we believe the Agencies are discounting the resources community banks devote to assessing the impact of regulations and meeting supervisory expectations. CBAI recommended that the Agencies undertake a new and thorough analysis of the burden that this proposal will impose.
In addition, CBAI recommended that a higher legal standard of accountability be set for the Agencies and their examiner in the scoping and conducting of risk-based compliance examinations. We also recommended that it be made clear in the guidance that consumer harm can only be caused by a violation of the law to avoid a misinterpretation or misapplication of the guidance. Read CBAI Comment Letter.
June 30, 2016