Mike Murphy

Ladies and Gentlemen: I submit this comment as a former banking regulator who now applies the Uniform Financial Institutions Rating System (UFIRS) as Chief Risk Officer of The Bankers Bank, where my team uses CAMELS-based quantitative and qualitative tools to analyze and rate over 700 banks. I appreciate the opportunity to comment on the FFIEC's proposed revisions to UFIRS, published in the Federal Register on May 19, 2026. While I recognize the stated intent to strengthen the link between ratings and safety and soundness, I question whether revisions of this scope are necessary. UFIRS's core architecture has remained substantially unchanged since 1996 and has functioned through multiple credit cycles — including 2008 and the 2023 regional banking stress — without clear evidence that the framework itself produced unreliable ratings. As the first material revision to CAMELS in thirty years, this proposal should meet a high bar before reopening those fundamentals. In my experience, concerns that ratings are driven by process or documentation rather than material financial risk reflect supervisory execution, not defects in UFIRS itself — examiners already have latitude to weigh materiality when assigning ratings. Codifying new definitions and removing longstanding features, like Management's special consideration in the composite rating, risks years of interpretive uncertainty without a clear showing that guidance and training alone can't achieve the same result. For a detailed response to each of the eleven questions designed to frame the responses, please refer to the attached comment letter.