CUNA supports revisions by the Federal Financial Institutions Examination Council (FFIEC) to the Uniform Consumer Compliance Rating System (CC Rating System).

In a letter sent Tuesday, CUNA said it appreciated that the FFIEC’s revisions reflect the regulatory, examination, technological, and market changes that have occurred since the initial establishment of the current rating system.

CUNA supports the shift to a risk-based, tailored-examination focus as opposed to the current focus on transaction testing. The CC Rating System, which has been in place since 1980, is a supervisory policy for evaluating financial institutions’ adherence to consumer compliance requirements.

“We greatly appreciate the rulemaking’s premise that ‘the CC Rating System [was] not developed to set new or higher supervisory expectations for financial institutions and their adoption will represent no additional regulatory burden,’” the letter reads. “We lament that any change in a standard must certainly create some sort of regulatory burden therefore, and thus, we urge the agencies (for credit unions, the CFPB and NCUA), to follow this statement with fervor.

“If indeed these changes properly implement a risk-based tailored-examination focus, they should ideally result in a lessened regulatory burden on credit unions.”

CUNA’s letter also noted support of NCUA’s representation in the proposal that the principles and standards of the CC Rating System will be integrated into the existing CAMEL rating structure, in place of a separate rating.

“CUNA believes the integration into the Management component is an appropriate place to assess an institution’s compliance risk, as opposed to having a stand-alone rating,” the letter concluded.