The American Bankers Association (ABA) appreciates the opportunity to respond to the FFIEC's notice and request for comment (Notice or Proposal) regarding revisions to the Uniform Financial Institution Rating System (UFIRS or CAMELS Rating System). ABA supports the Proposal as an important step towards refocusing the CAMELS Rating System on material financial risks and safety-and-soundness rather than process, documentation, or qualitative supervisory judgments. We support the proposed revisions to the CAMELS Rating System that prioritize safety and soundness; however, because CAMELS ratings carry significant consequences, the final framework should be objective, predictable, and demonstrably tied to the institution's financial condition and risk profile. Accordingly, we urge the FFIEC to adopt the recommendations in the attached letter for the final Notice to ensure that CAMELS ratings are objective, predictable, and tied to material financial risk.
OCCNonrulemakingOCC-2026-0562
Uniform Financial Institutions Rating System
RIN
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Last modified
Jun 24, 2026
Comment window
closed 33d ago
American Bankers Association filings
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American Bankers Association filed 1 comment on this docket between Aug 17, 2026 and Aug 17, 2026. 24 other organizations filed here. The comment window closed 33d ago.
What American Bankers Association filed (1)
Aug 17, 2026· The American Bankers Association· OCC-2026-0562-0051
Abstract
The Federal Financial Institutions Examination Council (FFIEC) is requesting comment onproposed revisions to the Uniform Financial Institutions Rating System (UFIRS), commonly referred to as the CAMELS rating system. The proposal would strengthen the link betweenCAMELS ratings and a financial institution’s safety and soundness by focusing component and composite ratings on factors that materially affect an institution’s financial condition and risk profile, and by improving the transparency of CAMELS ratings.
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