The Office of the Comptroller of the Currency (OCC), the Federal Reserve Board (Board), and the Federal Deposit Insurance Corporation (FDIC) (collectively, the Agencies) have jointly announced a proposed rulemaking that would extend the existing transitional periods for certain regulatory capital deductions and risk weights (Proposed Rule). The proposed extension would apply to banking organizations that are not subject to the advanced approaches capital rules, which generally means those banking organizations with less than $250 billion in total consolidated assets and less than $10 billion in total foreign exposure. Significantly, the Agencies state that the Proposed Rule is being issued in preparation for a forthcoming proposal that would “simplify the regulatory capital treatment of these items.”
The federal bank and credit union regulatory agencies (including the Consumer Financial Protection Bureau (CFPB)), acting through the Federal Financial Institutions Examination Council (FFIEC), have substantially revised the Uniform Interagency Consumer Compliance Rating System (Rating System). The new Rating System substantially reconfigures the legacy ratings system for consumer compliance, which is a standardized system used by federal and state bank supervisors to assess and rate the level and quality of a regulated financial institution’s compliance with consumer laws and regulations (not including the Community Reinvestment Act, which is separately reviewed and evaluated).
The new Ratings System, which was previously proposed for comment in May 2016, takes effect on March 31, 2017. It will apply to all banks and credit unions that are federally regulated as well as all firms that are subject to CFPB regulation and supervision. The Rating System also will be used by state bank regulatory agencies, consistent with individual states’ examination and supervision policies and practices.
The Federal Financial Institutions Examination Council (FFIEC), an interagency body tasked with prescribing principles and standards for the examination of federally regulated banking and other financial institutions, recently released proposed rules to update the Uniform Interagency Consumer Compliance Rating System (CC Rating System). The CC Rating System is used by FFIEC member agencies and their examiners to evaluate the consumer financial services compliance programs at the financial institutions that those agencies supervise. FFIEC consists of the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, the Office of the Comptroller of the Currency, the State Liaison Committee, and the Consumer Financial Protection Bureau.