Compliance Resource training manuals are designed to be used when conducting in-house training, whether initial training upon implementation of the new requirement, periodic training for new team members or remedial training for longer-term team members.
On November 7, 2016 FFIEC announced the issuance of an updated Uniform Interagency Consumer Compliance Rating System (CCRS) – the first update to the CCRS since 1980, shortly after FFIEC was formed. The CCRS is key to banks as it’s the supervisory policy for evaluating banks adherence to consumer compliance requirements and assigning a numerical rating. The new CCRS is designed to more fully align the rating system with the FFIEC agencies’ current risk-based, tailored examination approaches and the regulatory guidance stresses that the updated document was not developed with the intention of setting new or higher supervisory expectations for banks.
The purpose of the revisions to the CCRS is to:
• Provid a general framework for evaluating compliance assessment factors in order to assign a consumer compliance rating to each federally regulated bank;
• Ensure that regulated banks are evaluated in a comprehensive and consistent manner and that supervisory resources are appropriately focused on areas exhibiting risk of consumer harm and on banks that warrant elevated supervisory attention; and
• Better reflect current consumer compliance supervisory approaches and to more fully align the rating system with the Agencies’ current risk-based, tailored examination processes.
The revisions to the CC Rating System were not developed to set new or higher supervisory expectations for banks and their adoption will represent no additional regulatory burden. However, understanding the components of the CCRS is an important element in attaining the rating desired by your financial institution.