OCC Proposes Uniform Interagency Consumer Compliance Rating System

On Thursday June 9, 2016, the Office of the Comptroller of the Currency (“OCC”) issued OCC Bulletin 2016-19 – Notice and Request for Comment on Proposed Uniform Interagency Consumer Compliance Rating System. This bulletin highlights proposed changes to the existing Uniform Interagency Consumer Compliance Rating System (CC Rating System). The current CC Rating System was originally adopted in 1980, and is a supervisory policy used to evaluate and assign a rating for consumer compliance requirements. The proposed update reflects various changes in the environment since the original CC Rating System was implemented, and many of these proposed changes are already being used in examinations.

The following highlights were taken directly from the OCC Bulletin:

  • The revisions are designed to more fully align the CC Rating System with the FFIEC agencies’ current risk-based, tailored examination approaches.
  • The proposed CC Rating System reflects risk-based expectations commensurate with the size, complexity, and risk profile of institutions and incentivizes institutions to prevent, self-identify, and address compliance issues.
  • The proposed revisions were not developed with the intention of setting new or higher supervisory expectations for financial institutions, and their adoption will represent no additional regulatory burden.
  • The FFIEC invites public comments on any aspect of the proposal. Comments must be received within 60 days from publication in the Federal Register. All comments received, including any personal information provided, will be posted, generally without change, to www.regulations.gov.

You can read more about the proposal and submit formal comments at the Federal Register. The comment period for this proposal ends on July 5, 2016.