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FFIEC Proposed Revisions to the CAMELS Rating System Member Survey

Purpose. The FFIEC has proposed the first major revision to the CAMELS examination rating system in 30 years. Your input will directly shape a potential NYCUA comment letter. The survey takes about 8–10 minutes.
Confidentiality. Responses are used in aggregate. NYCUA will not attribute any individual credit union’s answers in its comment letter without express permission, and any examples cited will be de-identified.
Please respond by July 29, 2026.
Section A: About Your Credit Union
1.Charter Type:(Required.)
2.Asset Size:(Required.)
3.Your Role:(Required.)
Section B: Your Recent Examination Experience
4.In your most recent examinations, how much did the Management component or process/documentation findings affect your composite or component ratings, relative to your actual financial condition?(Required.)
5.In the last three exam cycles, have specialty-review findings (BSA/AML, consumer compliance, or IT) contributed to a Management or composite rating outcome you viewed as disproportionate to your actual financial risk?(Required.)
6.Has a management depth or succession concern ever factored into a Management rating or supervisory comment for your credit union?(Required.)
Section C: Reaction to the Core Proposed Changes
7.Please indicate your level of support for each proposed change:(Required.)
Strongly Support
Support
Neutral
Slightly Negative
Clearly Negative
Unsure
Removing the “special consideration” given to Management in the composite rating
Requiring a finding of material financial risk before a Management rating of 3 or worse
Limiting specialty-review findings to those reflecting material financial risk or significant noncompliance
Requiring less-than-satisfactory financial performance (not process alone) for a composite of 3 or worse
Setting an expectation that no single component should drive the composite rating
Setting an expectation that Management is rarely rated less than satisfactory when all other components are satisfactory
8.Overall, the proposal’s net effect on your credit union’s examination outcomes would be:(Required.)
Section D: Key Open Questions from the FFIEC
9.The proposal never defines “material financial risk,” the term the whole framework turns on. NCUA should:(Required.)
10.The proposal never defines “material financial risk,” the term the whole framework turns on. NCUA should:(Required.)
11.How should specialty-review findings influence ratings?(Required.)
Section E: Credit-Union-Specific Concerns
12.Which of the added Sensitivity to Market Risk factors are relevant to your balance sheet? (Select all that apply)(Required.)
13.The Capital Adequacy factors still reference shareholders, holding companies, and capital-markets access, sources unavailable to member-owned cooperatives that build capital through retained earnings. How much of a concern is this bank-centric language for your credit union?(Required.)
14.(FISCUs only) How concerned are you that a revised federal CAMELS framework could diverge from your NYS DFS examination standards, leaving you subject to two different rating approaches?
15.Which refinements should NYCUA prioritize in its comment letter?(Required.)
Section F: Overall Position and Input
16.What specific examination experience or example would best illustrate the impact of the current versus the proposed framework?
17.Any other issues, concerns, or points you would like NYCUA to raise in the comment letter?
18.May NYCUA follow up with you, or quote a de-identified example from your response?(Required.)
19.If you answered, "Yes, NYCUA may contact me" in question 17, please provide your contact information (Name, Email, Phone):
If you have any further questions, comments, or concerns, please contact Association Vice President of Legislative and Regulatory Affairs Jeremy Newman at jeremy.newman@nycua.org.