Compliance Rating System Updates

The Regulatory Agencies have announced an update to their compliance rating system. It is to be used beginning on or after March 31, 2017.

The 1-5 system considers factors in three main categories: Board and Management Oversight; Compliance Program; and Violations of Law and Consumer Harm. The relevance of each factor will vary based on the size, complexity and overall risk profile of the institution. The lower the rating, the lower the degree of supervisory concern. In other words, the lower, the better:

1 = Strong
2 = Satisfactory
3 = Deficient
4 = Seriously deficient
5 = Critically deficient

These changes are partly due to the Agencies’ transition from a transaction testing focus to a risk-based focus of your overall Compliance Management System (CMS).

Diane Dean

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