On February 28, BPI submitted a supplemental comment letter to the Fed and FDIC in response to the agencies’ request for information on their use of the Uniform Financial Institution Rating System (UFIRS), also known as the CAMELS rating system. The recommendations included in the letter were based on a survey of BPI members to ascertain their views regarding the federal banking agencies’ application of the UFIRS. The survey responses show that there is a significant need to improve the consistency, transparency, and fairness of the way the agencies apply the UFIRS, including, in particular, the Management rating. The letter proposes several process improvements to assigning CAMELS ratings to address those deficiencies. The letter is intended to be read in conjunction with BPI’s January 10, 2020 letter explaining the need for a substantive review and revision of the UFIRs framework to take into account both of its current, changed role in banking regulation and substantial changes in other regulations that it has failed to incorporate over the years.
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