NAFCU statement on joint Interagency Proposal on consumer compliance rating

WASHINGTON, DC (April 29, 2016) — National Association of Federal Credit Unions (NAFCU) Senior Regulatory Affairs Counsel Michael Emancipator issued the following statement in response to the Interagency Proposal to update the Uniform Interagency Consumer Compliance Rating System announced today. Federal Financial Institutions Examination Council (FFIEC), along with other regulators, including the National Credit Union Administration (NCUA), issued today’s proposal.

“NAFCU is evaluating the proposal to determine its full impact on credit unions,” said Emancipator. “Credit unions already are struggling with an overload of regulations and we oppose any additional requirements that will exacerbate the compliance burden on credit unions.”

Under this system, institutions are assigned confidential “consumer compliance” ratings based on an evaluation (during the examination process) of its compliance with consumer financial laws and the adequacy of its systems designed to ensure compliance on a continuing basis. The rating is on a scale of 1-5 in order of increasing supervisory concern, i.e., 1 is the lowest level of concern and 5 is the highest level of consumer.

The rating system announced today is voluntary. NCUA does not currently release an institution’s “compliance rating” publicly. This number is incorporated into various aspects of a credit union’s CAMEL rating. There are no plans to change this process.


The National Association of Federally-Insured Credit Unions is the only national trade association focusing exclusively on federal issues affecting the nation’s federally-insured credit unions. NAFCU membership is direct and provides credit unions with the best in federal advocacy, education and compliance assistance. For more information on NAFCU, go to or @NAFCU on Twitter.


Molly Safreed, (NAFCU)

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