Comptroller Statement on Proposed Revisions to the Uniform Financial Institutions Ratings System

WASHINGTON-Comptroller of the Currency Jonathan V. Gould issued the following statement today about the Federal Financial Institutions Examination Council's (FFIEC) proposed revisions to the Uniform Financial Institutions Rating System, commonly known as the CAMELS rating system.

I appreciate the collaborative efforts of the FFIEC and its member agencies in developing the proposed revisions to the CAMELS ratings system. The revisions shift supervision away from process-heavy oversight toward a stronger focus on material financial risk. Modernizing CAMELS to more explicitly reflect material financial risks is a critical step to ensure our supervisory tools remain robust and responsive to the evolving banking landscape.

While I support the direction of this proposal, I remain concerned that the revisions do not sufficiently address "double counting" within the Management, or M, component. For the CAMELS framework to function effectively, each component must provide distinct, incremental value. Historically, the Management rating has reflected deficiencies already captured in other components. To maintain the integrity and transparency of the CAMELS system, it is vital that the Management rating serve as a standalone assessment rather than a secondary reflection of other components.

Furthermore, it is imperative that the financial institution regulators maintain a balanced and transparent supervisory perspective. Absent extenuating circumstances, no single component rating should disproportionately drive the composite rating. A bank's overall health is the sum of its parts, and the composite rating should be a transparent evaluation of all the factors rather than being driven by a single component.

I encourage commenters to pay close attention to these nuances during the comment period. We welcome feedback on how the framework can better distinguish between components to prevent overlapping assessments and ensure that the composite rating reflects a fair representation of a bank's risk profile.

Comments from the public are due 90 days from the date of publication of the proposed revisions in the Federal Register.

Related Link

• FFIEC News Release: Agencies Request Comment on Financial Institutions Rating System