The Independent Community Bankers of America (“ICBA”) appreciates the opportunity to provide comments on the Federal Financial Institutions Examination Council’s (“FFIEC”) notice and request for comment related to proposed revisions to the Uniform Financial Institutions Rating System (“UFIRS”), more commonly referred to as the CAMELS rating system.

ICBA supports the FFIEC’s efforts to improve the effectiveness of the CAMELS rating system as a supervisory tool and to increase public confidence in supervisors’ assessment of the banking system. ICBA particularly supports placing appropriate guardrails to reduce excessive subjectivity.