Document Type
Article
Comments
This comment letter predates the author's affiliation with Cornell Law School.
Abstract
The Federal Financial Institutions Examination Council (FFIEC) issued a notice and request for comment regarding the Uniform Interagency Consumer Compliance Rating System (CC Rating System). The FFIEC is seeking to revise the CC Rating System “to reflect the regulatory, examination (supervisory), technological, and market changes that have occurred in the years since the current rating system was established.” 81 F.R. 26553. It is a positive development that the federal government is seeking to implement a consistent approach to consumer protection across a broad swath of the financial services industry. Nonetheless, the proposed CC Ratings System can be refined to further improve consumer protection in the financial services industry.
Date of Authorship for this Version
7-5-2016
Keywords
Federal Financial Institutions Examination Council, Uniform Interagency Consumer Compliance Rating System, Mortgages
Recommended Citation
Reiss, David J., "FFIEC Consumer Compliance Comment Letter" (2016). Cornell Law Faculty Working Papers. 150.
https://scholarship.law.cornell.edu/clsops_papers/150