Consumer Compliance Rating System Program - 2017 Update


Recently, the FFIEC finalized the issuance of its updated Interagency Consumer Compliance Rating System (CCRS). A close reading of the 31-page document provides a helpful glimpse into future regulatory expectations regarding a bank's Compliance Management System (CMS) and what is meant by a Culture of Compliance.

While the updated CCRS "was not developed with the intention of new or higher supervisory expectations for banks" it did, however, provide pearls of wisdom and afford banks with an opportunity to review their present CMS to stay abreast of regulatory expectations and lower the risk of an adverse compliance rating.

This two-hour program will address all three main categories - "Board and Management Oversight", "Compliance Program" and "Violations of Law and Consumer Harm" - along with each of those categories 19 subcomponents.


This was the first material update to the agencies rating methodology since 1980 and is intended to guide examiners in their future compliance examinations. We will cover the seemingly contradictory regulatory guidance on the level of transaction testing and address the degree of proactivity expected of a bank in self-identifying and reporting violations.

Participants receive a detailed manual that serves as a valuable resource long after the conclusion of the program which will serve as a vital resource in enhancing your bank’s Compliance Management Program. These materials are intended to place your compliance program in alignment with regulatory expectations.

Covered Topics:

  • Detailed explanation of all assessment factors that drive exam ratings
  • Expectations regarding risk assessments
  • Accountability of compliance staff for consumer affairs laws and regulations - perhaps in job descriptions or within written policies and procedures
  • Guidance regarding initial and ongoing oversight of third parties that perform functions for the bank
  • Consumer complaint response expectations
  • Promptness and comprehensiveness in responding to identified compliance deficiencies
  • Tailored, periodic, comprehensive compliance training for all bank personnel

Who Should Attend?

The program is designed for second and third line of defense personnel in banks which will include: Compliance Officers, Branch Administration, Deposit Operations, Senior Management, Auditors, and those responsible for the auditing or monitoring functions of a bank’s deposit compliance program.