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Unpublished Paper
FFIEC Consumer Compliance Comment Letter
Brooklyn Law School Faculty Scholarship (2016)
  • David J Reiss
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.
  • FFIEC,
  • mortgage,
  • consumer protection,
  • banking
Publication Date
July 5, 2016
Citation Information
David J Reiss. "FFIEC Consumer Compliance Comment Letter" Brooklyn Law School Faculty Scholarship (2016)
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