Uniform Financial Institutions Rating System

Doug Wadsworth, representing the nonprofit advocacy organization Endangered Small Credit Union Defense (ESCUD), supports the proposed revisions to the CAMELS rating system. He argues that the changes will provide practical relief to small credit unions by focusing on material financial risks and reducing the burden of non-material documentation and subjective management evaluations.

Axos Bank supports the proposed revisions to the CAMELS rating system, arguing that the changes are a necessary correction to ensure ratings are based on material financial risk rather than subjective process observations. The bank recommends specific operational requirements, such as sequencing the Management rating last and requiring documentation to prevent double-counting of risks, to make the proposal's objectives enforceable.

Eugene H. Walpole, IV, President & CEO of Banks of South Carolina, supports the FFIEC's proposed revisions to the CAMELS rating system because they focus on measurable financial outcomes rather than procedural findings. He also suggests an additional reform for the public disclosure of a bank's composite CAMELS rating to increase transparency for stakeholders.

The commenter opposes the removal of factors related to management depth, succession, and responsiveness to regulatory recommendations from the rating system. They argue that these factors are essential for ensuring the safety and soundness of banks and that removing them would weaken the regulatory oversight process.

Prismm Inc., a company providing estate orchestration infrastructure, supports the proposed revisions to the Uniform Financial Institutions Rating System, particularly the inclusion of deposit stability as a Liquidity factor. They argue that the framework should also account for forward-looking, demographically driven deposit attrition caused by the death of account holders during intergenerational wealth transfers.

The commenter suggests that the supervisory framework should be refined to recognize and reward institutions with efficient internal credit delivery systems. They argue that while safety and soundness are paramount, operational efficiency in credit processing should be viewed as a positive indicator of risk management and a facilitator of healthy capital flow.

Michael S Dirk, a former financial institution examiner, supports the proposed changes to the Uniform Financial Institutions Rating System to sharpen the focus on risk measurements and financial condition. He argues for maintaining the "Special Consideration" for management ratings and suggests further refinements to ensure the framework balances financial condition with risk profile and management's causal influence.

Li Li, an independent researcher, supports the FFIEC's proposed revisions to the Uniform Financial Institutions Rating System (UFIRS) for shifting the focus toward factors that materially affect a bank's financial condition. The commenter recommends clarifying that "material financial risk" must be supported by a credible financial transmission mechanism and verifiable information rather than industry labels or process deficiencies alone.

Communication Federal Credit Union supports the proposed revisions to the Uniform Financial Institutions Rating System (UFIRS). They argue that the changes will improve consistency, transparency, and risk-focus by providing clearer thresholds for ratings and more specific evaluation criteria.

Mike Murphy, Chief Risk Officer of The Bankers Bank, opposes the proposed revisions to the Uniform Financial Institutions Rating System (UFIRS). He argues that the current framework has been durable for decades and that the agencies should achieve their goals through supervisory guidance and training rather than formal revisions that risk creating interpretive uncertainty.