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FIL-56-96 Attachment

[Federal Register: July 18, 1996 (Volume 61, Number 139)]

[Notices]

[Page 37472-37478]

From the Federal Register Online via GPO Access [wais.access.gpo.gov]


 

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FEDERAL FINANCIAL INSTITUTIONS EXAMINATION COUNCIL


 

 

Uniform Financial Institutions Rating System


 

AGENCY: Federal Financial Institutions Examination Council.


 

ACTION: Notice and request for comment.


 

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SUMMARY: The Federal Financial Institutions Examination Council (FFIEC)

is requesting comment on proposed changes to the Uniform Financial

institutions Rating System (UFIRS), commonly referred to as the CAMEL

rating system. The term ``financial institutions'' refers to those

insured depository institutions whose primary Federal supervisory

agency is represented on the FFIEC. The agencies comprising the FFIEC

are the Board of Governors of the Federal Reserve System (Board), the

Federal Deposit Insurance Corporation (FDIC), the National Credit Union

Association (NCUA), the Office of the Comptroller of the Currency

(OCC), and the Office of Thrift Supervision (OTS).

The proposed revisions update the rating system to reflect changes

that have occurred in the financial services


 

[[Page 37473]]


 

industry and in supervisory policies and procedures since the rating

system was first adopted in 1979. The proposed changes include: The

reformatting and clarification of the existing component rating

descriptions; the addition of a sixth rating component addressing

sensitivity to market risks; an increase in emphasis on the quality of

risk management processes in each of the rating components,

particularly in the management component; the addition of language in

composite rating definitions to parallel the proposed changes in

component rating descriptions; and, the explicit identification of the

risk types that are to be considered in assigning component ratings.

After reviewing public comments, the FFIEC intends to make appropriate

additional changes to the revised UFIRS and adopt a final rating

system.

The FFIEC notes that some agency regulations currently use an

institution's UFIRS or CAMEL rating in determining an institution's

status under those regulations. The agencies may consider amending

those regulations to incorporate any changes made to the UFIRS system.


 

DATES: Comments must be received by September 16, 1996.


 

ADDRESSES: Comments should be sent to Joe M. Cleaver, Executive

Secretary, Federal Financial Institutions Examination Council, 2100

Pennsylvania Avenue NW., Suite 200, Washington, DC 20037, or by

facsimile transmission to (202) 634-6556.


 

FOR FURTHER INFORMATION CONTACT:

OCC: Lawrence W. (Bill) Morris, National Bank Examiner, Office of Chief

National Bank Examiner, (202) 874-5350, Office of the Comptroller of

the Currency, 250 E Street SW., Washington, DC 20219.

FRB: Kevin Bertsch, Supervisory Financial Analyst, (202) 452-5265, or

Constance Powell, Supervisory Financial Analyst, (202) 452-3506,

Division of Banking Supervision and Regulation, Board of Governors of

the Federal Reserve System. For the hearing impaired only,

Telecommunication Device for the Deaf (TDD), Dorothea Thompson, (202)

452-3544, Board of Governors of the Federal Reserve System, 20th and C

Streets NW., Washington, DC 20551.

FDIC: Daniel M. Gautsch, Examination Specialist, (202) 898-6912, Office

of Policy, Division of Supervision. For legal issues, Linda L. Stamp,

Counsel, (202) 898-7310, Supervision and Legislation Branch, Federal

Deposit Insurance Corporation, 550 17th Street NW., Washington, DC

20429.

OTS: William J. Magrini, Senior Project Manager, (202) 906-5744,

Supervision Policy, Office of Thrift Supervision, 1700 G Street NW.,

Washington, DC 20552.


 

SUPPLEMENTARY INFORMATION:


 

Background Information


 

The UFIRS is an internal supervisory rating system used by the

Federal supervisory agencies for evaluating the soundness of financial

institutions on a uniform basis and for identifying those institutions

requiring special supervisory attention or concern. The UFIRS was

adopted in 1979 and is commonly referred to as the CAMEL rating system.

Under the UFIRS, each financial institution is assigned a composite

rating based on an evaluation and rating of five essential components

of an institution's financial condition and operations. These component

factors address the adequacy of capital, the quality of assets, the

capability of management, the quality and level of earnings, and the

adequacy of liquidity. Both the composite and the component ratings are

assigned on a 1 to 5 numerical scale. A 1 indicates the strongest

performance and management practices, and the least degree of

supervisory concern, while a 5 indicates the weakest performance and

management practices and, therefore, the highest degree of supervisory

concern.

The composite rating reflects an institution's overall financial

condition, compliance with laws and regulations, and management

capability. The composite ratings are used by the Federal supervisory

agencies to monitor aggregate trends in the overall soundness of

financial institutions.

The rating system also provides a means for the Federal supervisory

agencies to monitor, for various statistical and supervisory purposes,

the types and severity of problems that institutions may be

experiencing. This monitoring is possible since the composite rating

assigned under UFIRS is based on the ratings of several essential

aspects of a financial institution's condition and operations. For

example, liquidity is one of the aspects of an institution's operations

that is assigned a component rating. Thus, UFIRS allows the Federal

supervisory agencies to readily identify all institutions that are

experiencing a liquidity problem, to gauge the severity of the problem,

and to determine the level of supervisory concern that may be

warranted.

UFIRS has proven to be an effective means for the Federal

supervisory agencies to determine the safety and soundness of financial

institutions. A number of changes, however, have occurred in the

financial services industry and in supervisory policies and procedures

since the rating system was first adopted. The FFIEC's Task Force on

Supervision has reviewed the existing rating system in light of these

industry trends. The Task Force has concluded that the current UFIRS

framework continues to provide an effective vehicle for summarizing

conclusions about the soundness of financial institutions. As a result,

the FFIEC proposes to retain the basic rating framework, and the

revised rating system will continue to assign a composite rating based

on an evaluation and rating of essential components of an institution's

financial condition and operations. However, the FFIEC proposes certain

enhancements to the rating system.


 

Discussion of Proposed Changes to the Rating System


 

1. Structure and Format


 

The FFIEC proposes to enhance and clarify the component rating

descriptions by reformatting each component into three distinct

sections. These sections are: (a) An introductory paragraph discussing

in general terms the areas to be considered when rating each component;

(b) a bullet-style listing of the specific evaluation factors to be

considered when assigning the component rating; and, (c) a brief

qualitative description of the five rating grades that can be assigned

to a particular component.


 

2. Component for Sensitivity to Market Risks


 

The FFIEC proposes to adopt a sixth rating component addressing

sensitivity to market risks. This component would include interest rate

risk, to which every institution is subject, price risk, and foreign

exchange risk.

In recent years, financial institutions have increased their

holdings of complicated on- and off-balance sheet instruments, such as

structured notes and collateralized mortgaged obligations (CMOs), that

are sensitive to changes in interest rates. In addition, the increase

in competitive pressures has constrained, in some cases, institutions'

abilities to advantageously price loans and deposits. Thus, there is a

growing need for financial institutions to monitor and manage their

interest rate risk, as well as for the Federal supervisory agencies to

monitor the degree of this risk. In addition, for those institutions

that have substantial trading


 

[[Page 37474]]


 

operations or large foreign positions, there is an increased

susceptibility to price and foreign exchange risks that also must be

closely monitored by the Federal supervisory agencies.

Under the current UFIRS, these market risks are considered within a

number of components. For example, interest rate risk is considered

when evaluating the earnings component since this risk can have a

direct effect on future earnings. Interest rate risk is also considered

when evaluating the liquidity component since interest rate risk is a

factor of an institution's overall asset/liability management

practices. Under the revised rating system, certain aspects of an

institution's sensitivity to market risks would continue to be

considered when evaluating these other components. However, the

conclusions on an institution's sensitivity to interest rate, price,

and foreign exchange risks would be summarized under the new component

in recognition of the impact these risks can have on an institution's

overall risk profile.


 

3. Risk Management


 

The FFIEC is proposing that the revised rating system reflect an

increase in emphasis on risk management processes. The Federal

supervisory agencies currently consider the quality of risk management

processes in applying the UFIRS, particularly in the management

component. Changes in the financial services industry, however, have

broadened the range of financial products offered by institutions and

accelerated the pace of transactions. These trends reinforce the

importance of institutions having sound risk management processes.

Accordingly, the revised rating system would contain language in each

of the components emphasizing the consideration of processes of

identify, measure, monitor, and control risks.


 

4. Composite Rating Definitions


 

The FFIEC is proposing changes in the composite rating definitions

to parallel the changes in the component rating descriptions. Under the

FFIEC's proposal, the revised composite rating definitions would

contain an explicit reference to the quality of overall risk management

practices. The basic context of the existing composite rating

definitions is being retained. The composite rating would continue to

be based on a careful evaluation of an institution's managerial,

operational, financial, and compliance performance.


 

5. Identification of Risk Types


 

The FFIEC is proposing that the types of risks associated with each

of the component ratings be explicitly identified. For example, the

proposed rating description for asset quality notes that a primary

consideration in assigning the component rating is an assessment of

credit risk associated with loans, investments, other real estate

owned, and certain off-balance sheet transactions. However, all other

risks affecting the quality of assets, including, but not limited to,

operational, market, reputation, strategic, and compliance risks, also

would be considered.


 

Request for Comments


 

The FFIEC requests comment on the proposed changes to the rating

system. In addition, the FFIEC invites comments on the following

questions:

1. Does the proposed, revised rating system capture the essential

aspects of a financial institution's condition, compliance with laws

and regulations, and overall operating soundness? If not, what

additional or different components should be considered?

2. Does the proposed management component rating adequately

represent an assessment of the quality of the board of directors' and

management's oversight regarding an institution's operating

performance, risk management practices, and internal controls? If not,

what other factors should be considered when rating management?


 

Proposed Text of the Uniform Financial Institutions Rating System


 

Uniform Financial Institutions \1\ Rating System


 

Introduction

The Uniform Financial Institutions Rating System (UFIRS) was

adopted by the Federal Financial Institutions Examination Council

(FFIEC) on November 13, 1979. Over the years, the UFIRS has proven to

be an effective internal supervisory tool for evaluating the soundness

of financial institutions on a uniform basis and for identifying those

institutions requiring special attention or concern. A number of

changes, however, have occurred in the banking industry and in the

Federal supervisory agencies' policies and procedures which have

prompted a review and revision of the 1979 rating system. The revisions

to UFIRS include the addition of a sixth component addressing

sensitivity to market risks; the explicit reference to the quality of

risk management processes in the management component; and the

identification of risk elements within the composite and component

rating descriptions.

---------------------------------------------------------------------------


 

\1\ For purposes of this rating system, the term financial

institution refers to those insured depository institutions whose

primary Federal supervisory agency is represented on the Federal

Financial Institutions Examination Council (FFIEC). The agencies

comprising the FFIEC are the Board of Governors of the Federal

Reserve System, the Federal Deposit Insurance Corporation, the

National Credit Union Administration, the Office of the Comptroller

of the Currency, and the Office of Thrift Supervision. The term

financial institution includes Federally supervised commercial

banks, savings and loan associations, mutual savings banks and

credit unions.

---------------------------------------------------------------------------


 

The UFIRS takes into consideration certain financial, managerial,

and compliance factors that are common to all institutions. Under this

system, the supervisory agencies endeavor to ensure that all financial

institutions are evaluated in a comprehensive and uniform manner, and

that supervisory attention is appropriately focused on the financial

institutions exhibiting financial and operational weaknesses or adverse

trends.

The UFIRS also serves as a useful vehicle for identifying problem

or deteriorating financial institutions, as well as for categorizing

institutions with deficiencies in particular component areas. Further,

the rating system assists Congress in following safety and soundness

trends and in assessing the aggregate strength and soundness of the

financial industry. As such, the UFIRS assists the agencies in

fulfilling their collective mission of maintaining stability and public

confidence in the nation's financial system.

Overview

Under the UFIRS, each financial institution is assigned a composite

rating based on an evaluation and rating of six essential components of

an institution's financial condition and operations. These component

factors address the adequacy of capital, the quality of assets, the

capability of management, the quality and level of earnings, the

adequacy of liquidity, and the sensitivity to market risks.

Composite and component ratings are assigned based on a 1 to 5

numerical scale. A 1 indicates the highest rating, strongest

performance and risk management practices, and least degree of

supervisory concern, while a 5 indicates the lowest rating, weakest

performance and risk management practices and, therefore, the highest

degree of supervisory concern.

The composite rating generally bears a close relationship to the

component ratings assigned. Each component rating is based on a

qualitative analysis of the factors comprising that component and its

interrelationship with the other components. When assigning a composite

rating, some components may be given more weight than others


 

[[Page 37475]]


 

depending on the situation at the institution. In general, assignment

of a composite rating may incorporate any factor that bears

significantly on the overall condition and soundness of the financial

institution. Therefore, the composite rating is not derived by

computing an arithmetic average of the component ratings.

The ability of management to respond to changing circumstances and

to address the risks that may arise from changing business conditions,

or the initiation of new activities or products, is an important factor

in evaluating a financial institution's overall risk profile and the

level of supervisory attention warranted. For this reason, the

management component is given special consideration when assigning a

composite rating.

The following two sections contain the composite rating

definitions, and the descriptions and definitions for the six component

ratings.


 

Composite Ratings


 

Composite ratings are based on a careful evaluation of an

institution's managerial, operational, financial, and compliance

performance. The six key components used to assess an institution's

financial condition and operations are: capital adequacy, asset

quality, management capability, earnings quantity and quality, the

adequacy of liquidity, and sensitivity to market risks. The rating

scale ranges from 1 to 5, with a rating of 1 indicating the strongest

performance and risk management practices, and the level of least

supervisory concern. A 5 rating indicates the most critically deficient

level of performance, the weakest risk management practices, and the

greatest supervisory concern. The composite ratings are defined as

follows:


 

Composite 1


 

Financial institutions in this group are sound in every respect; as

such, all components are rated 1 or 2. Any weakness is minor and can be

handled in a routine manner by management. Substantial compliance with

laws and regulations is noted. These financial institutions are more

capable of withstanding the vagaries of business conditions and are

resistant to outside influences such as economic instability in their

trade area. As a result, these financial institutions exhibit the

strongest performance and risk management practices and give no cause

for supervisory concern.


 

Composite 2


 

Financial institutions in this group are fundamentally sound. For a

financial institution to receive this rating, normally no component

rating should be more severe than 3. Only modest weaknesses are present

and are well within management's capabilities and willingness to

correct. These financial institutions are stable and are capable of

withstanding business fluctuations. These financial institutions are in

substantial compliance with laws and regulations and there are no

material supervisory concerns. Overall risk management practices are

satisfactory. As a result, the supervisory response is informal and

limited.


 

Composite 3


 

Financial institutions in this group exhibit some degree of

supervisory concern in one or more of the component areas. These

financial institutions exhibit a combination of weaknesses that may

range from moderate to severe. Risk management practices may be less

than satisfactory. The concerns, however, are not of the magnitude to

cause a component to be rated more severely than 4.

Financial institutions in this group generally are less capable of

withstanding business fluctuations; are more vulnerable to outside

influences than those institutions rated a composite 1 or 2; and,

management may lack the ability or willingness to effectively address

weaknesses within appropriate time frames. Additionally, these

financial institutions may be in significant noncompliance with laws

and regulations. These financial institutions are a supervisory concern

and require more than normal supervision, which may include formal or

informal enforcement actions. Failure appears unlikely, however, given

the overall strength and financial capacity of these institutions.


 

Composite 4


 

Financial institutions in this group are in an unsafe and unsound

condition. These are serious financial or managerial deficiencies that

result in unsatisfactory performance. The problems range from severe to

critically deficient. Risk management practices are generally

unacceptable. The weaknesses and problems are not being satisfactorily

addressed or resolved by management. There may be significant

noncompliance with laws and regulations. Financial institutions in this

group generally are not capable of withstanding business fluctuations.

Close supervisory attention is required, which means, in most cases,

formal enforcement action is necessary to address the problems.

Institutions in this group pose a risk to the deposit insurance fund.

Failure is a distinct possibility if the problems and weaknesses are

not satisfactorily addressed and resolved.


 

Composite 5


 

Financial institutions in this group are in an extremely unsafe and

unsound condition, exhibit a critically deficient performance, often

contain the weakest risk management practices, and are of the greatest

supervisory concern. The volume and severity of problems is beyond

management's ability or willingness to control or correct. Immediate

outside financial or other assistance is needed in order for the

financial institution to be viable. Continuous close supervisory

attention is warranted. Institutions in this group pose a significant

risk to the deposit insurance fund. Failure is highly probable and the

least-cost resolution alternatives are being considered by the

appropriate agencies.


 

Component Ratings


 

Each of the component rating descriptions is divided into three

sections: an introductory paragraph; a list of the principal evaluation

factors that relate to that component; and, a brief description of each

numerical rating for that component. Some of the evaluation factors are

reiterated under one or more of the other components to reinforce the

interrelationship between components.


 

Capital Adequacy


 

A financial institution is expected to maintain capital

commensurate with its existing and potential risk exposures and the

ability of management to identify, measure, monitor, and control these

exposures. The effect of credit, market and other risks on the

financial condition of an institution should be considered when

evaluating the adequacy of capital. The types and quantity of risk

inherent in an institution's activities will determine the extent of

which it may be necessary to maintain capital at levels above required

regulatory minimums to properly reflect the potentially adverse

consequences that these risks may have on the institution's capital.

The capital adequacy of an institution is rated based on an

assessment of:

The level and quality of capital and the overall financial

condition of the institution.

The nature and extent of risks to the organization.

The ability of management to identify, measure, monitor,

and control risk and address emerging needs for additional capital.


 

[[Page 37476]]


 

The nature, trend, and volume of problem assets, and the

adequacy of allowances for loan and lease losses and other valuation

reserves.

Balance sheet composition, including the nature and amount

of intangible assets, market risk, concentration risk, and risks

associated with nontraditional activities.

Risk exposure represented by off-balance sheet activities.

The quality and strength of earnings, and the

reasonableness of dividends.

Prospects and plans for growth, as well as past experience

in managing growth.

Access to capital markets and other sources of capital.

Compliance with applicable laws, regulations, and

supervisory guidelines, including plans for maintaining adequate

capital or correcting other deficiencies.


 

Ratings


 

1. A rating of 1 indicates a strong capital level that is more than

adequate to support an institution's risk profile.

2. A rating of 2 indicates a satisfactory capital level given the

financial institution's risk exposure and the quality of its risk

management practices.

3. A rating of 3 indicates a less than satisfactory level of

capital that does not fully support the institution's risk profile. The

rating indicates a need for improvement, even if the institution's

capital level exceeds minimum regulatory and statutory requirements.

4. A rating of 4 indicates a deficient level of capital. In light

of the level of risk exposure, viability of the institution may be

threatened. Assistance from shareholders or other external sources of

financial support is required.

5. A rating of 5 indicates a critically deficient level of capital

such that the institution's viability is threatened. Immediate

assistance from shareholders or other external sources of financial

support is required.


 

Asset Quality


 

The asset quality rating reflects the quantity of existing and

potential credit risk associated with the loan and investment

portfolios, other real estate owned, and off-balance sheet

transactions. The ability of management to identify, measure, monitor,

and control credit risk is also reflected here. The evaluation of asset

quality should consider the adequacy of the allowance for loan and

lease losses and weigh the exposure to counterparty, issuer, or

borrower default under actual or implied contractual agreements. All

other risks that may affect the value or salability of an institution's

assets, including, but not limited to, operating, market, reputation,

strategic, or compliance risks should also be considered.

The asset quality of a financial institution is rated based on an

assessment of:

The adequacy of underwriting standards and appropriateness

of risk identification practices.

The level, distribution, severity, and trend of classified

assets, nonaccrual and restructured loans, delinquent loans, and

nonperforming assets.

The adequacy of the allowance for loan and lease losses

and other asset valuation reserves.

The exposure to off-balance sheet transactions, such as

unfunded commitments, commercial and standby letters of credit, and

lines of credit.

The volume, diversification, and quality of the loan and

investment portfolios.

The extent of securities underwriting activities and

exposure to counterparties in trading activities.

The existence of asset concentrations.

The adequacy of loan and investment policies, procedures,

and practices.

The ability of management to properly administer its

assets, including the timely identification and collection of problem

assets.

The adequacy of internal controls and management

information systems.

Compliance with applicable laws and regulations.


 

Ratings


 

1. A rating of 1 indicates strong asset quality and credit

administration practices without either significant weaknesses or risk

exposure. Asset quality in such institutions is of minimal supervisory

concern.

2. A rating of 2 indicates satisfactory asset quality and credit

administration practices. The level and severity of classifications,

other weaknesses, and risks warrant a limited level of supervisory

attention.

3. A rating of 3 is assigned when asset quality or credit

administration practices are less than satisfactory. Trends may be

stable or indicate deterioration in asset quality or an increase in

risk exposure. The level and severity of classified assets, other

weaknesses, and risks require an elevated level of supervisory concern.

There is generally a need to improve credit administration and risk

management practices.

4. A rating of 4 is assigned to financial institutions with

deficient asset quality or credit administration practices. The levels

of risk and problem assets are significant, inadequately controlled,

and subject the financial institution to potential losses in excess of

a reasonable limit that, if left unchecked, may threaten its viability.

5. A rating of 5 represents critically deficient asset quality or

credit administration practices that present an imminent threat to the

institution's viability.


 

Management


 

The capability of the board of directors and management to

identify, measure, monitor, and control the risks of an institution's

activities and to ensure a financial institution's safe, sound, and

efficient operation in compliance with applicable laws and regulations

is reflected in this rating. Depending on the nature and scope of an

institution's activities, management practices may need to address some

or all of the following risks: credit, market, operating or

transaction, reputation, strategic, compliance, legal, liquidity, and

other risks. Sound management practices are demonstrated by: active

oversight by the board of directors and management; competent

personnel; adequate policies, processes and controls addressing areas

of an institution's operations; and effective risk monitoring and

management information systems. This rating should reflect the board's

and management's ability as it applies to all aspects of banking

operations as well as other financial service activities in which the

institution may be involved.

The performance of management and the board of directors and the

quality of risk management is rated based upon an assessment of:

The level and quality of oversight and support of

institution activities by the board of directors and management.

The ability of the board of directors and management to

plan for, and respond to, changing circumstances, and address risks

that may arise from changing business conditions or the initiation of

new activities or products.

The adequacy of, and conformance with, internal policies

and controls addressing the operations and risks of significant

activities.

The accuracy, timeliness, and effectiveness of management

information and risk monitoring systems.

The adequacy of audits and internal controls to: promote

effective operations and reliable financial and regulatory reporting;

safeguard assets; and ensure compliance with laws, regulations, and

internal policies.


 

[[Page 37477]]


 

Compliance with laws and regulations.

Responsiveness to recommendations from auditors and

supervisory authorities.

Management depth and succession.

The extent that the board of directors and management is

affected by, or susceptible to, dominant influence or concentration of

authority.

Reasonableness of compensation policies and avoidance of

self-dealing.

Demonstrated willingness to serve the legitimate banking

needs of the community.

The overall performance of the institution and the level

of risk to which it is exposed.


 

Ratings


 

1. A rating of 1 indicates strong performance by management and the

board of directors and strong risk management practices. All

significant risks are consistently and effectively identified,

measured, monitored, and controlled. Management and the board have

demonstrated the ability to promptly and successfully address existing

and potential problems and risks.

2. A rating of 2 indicates satisfactory management and board

performance and risk management practices. Minor weakness may exist,

but are not material to the safety and soundness of the institution and

are being addressed. In general, significant risks and problems are

effectively identified, measured, monitored, and controlled.

3. A rating of 3 indicates management and board performance or risk

management practices that need improvement. Performance or risk

management practices are less than satisfactory given the nature of an

institution's activities. The capabilities of management and the board

of directors may be insufficient for the type, size, or condition of

the institution. Problems and significant risks may be inadequately

identified, measured, monitored, or controlled.

4. A rating of 4 indicates deficient management and board

performance or risk management practices. Risk management practices are

inadequate considering the institution's activities, or the level of

problems and risk exposure is excessive. Problems and significant risks

are inadequately identified, measured, monitored, or controlled and

require immediate action by the board and management to preserve the

soundness of the institution. Replacing or strengthening of management

or the board may be necessary.

5. A rating of 5 indicates critically deficient management and

board performance or risk management practices. Management and the

board of directors have not demonstrated the ability to correct

problems and implement appropriate risk management practices. Problems

and significant risks are inadequately identified, measured, monitored,

or controlled and now threaten the continued viability of the

institution. Replacing or strengthening of management or the board of

directors is necessary.


 

Earnings


 

This rating reflects not only the quantity of earnings, but also

factors that may affect the sustainability or quality of earnings. The

quantity as well as the quality of earnings can be affected by

excessive or inadequately managed credit risk, that may result in loan

losses and require additions to the allowance for loan and lease

losses, or high levels of market risk, that may unduly expose an

institution's earnings to volatility in interest rates. The quality of

earnings may also be diminished by undue reliance on extraordinary

gains, nonrecurring events, or favorable tax effects. Future earnings

may be adversely affected by: an inability to forecast or control

funding and operating expenses; improperly executed or ill-advised

business strategies; or poorly managed or uncontrolled exposure to

other risks.

The rating of an institution's earnings will be based on an

assessment of:

The level of earnings, including trends and stability.

The ability to provide for adequate capital through

retained earnings.

The quality and sources of earnings.

The level of expenses in relation to operations.

The adequacy of the budgeting systems, forecasting

processes, and management information systems in general.

The exposure to credit risk and the adequacy of the

allowance for loan and lease losses and other valuation allowance

accounts.

The exposure to market risks such as interest rate,

foreign exchange, and price risks.

The level of compliance with applicable laws and

regulations.


 

Ratings


 

1. A rating of 1 indicates earnings that are strong. Earnings are

sufficient to support operations and maintain an adequate level of

capital after consideration is given to risks and other factors

affecting the quality and quantity of earnings.

2. A rating of 2 indicates earnings that are satisfactory. However,

earnings that are relatively static, or even experiencing a slight

decline, may receive a 2 rating provided the institution's level of

earnings is adequate in view of the assessment factors listed above.

3. A rating of 3 should be accorded to earnings that need to be

improved in order to fully support operations and provide for the

accretion of capital in relation to the financial institution's

inherent risks.

4. A rating of 4 indicates earnings are deficient to support

operations and retain an appropriate capital level. Institutions so

rated may be characterized by erratic fluctuations in net income or net

interest margin, the development of a significant negative trend,

nominal earnings, unsustainable earnings, intermittent losses or a

substantive drop in earnings from the previous year.

5. A rating of 5 indicates earnings performance that is critically

deficient. A financial institution with earnings rated 5 is

experiencing losses that represent a distinct threat to its viability

through the erosion of capital.


 

Liquidity


 

In evaluating a financial institution's liquidity position and

risk, consideration should be given to current and prospective sources

of liquidity compared to funding needs, as well as to the adequacy of

funds management practices. In general, funds management practices

should ensure that an institution is able to maintain a level of

liquidity sufficient to meet its financial obligations in a timely

manner and to fulfill the legitimate credit needs of its community.

Practices should reflect the ability of the institution to manage

unplanned changes in funding sources, as well as react to changes in

market conditions that affect the ability to quickly liquidate assets

with minimal loss. In addition, funds management practices should

ensure that liquidity is not maintained at a high cost, or through

undue reliance on funding sources that may not be available in times of

financial stress or adverse changes in market conditions.

Liquidity is rated based on a review and assessment of:

The adequacy of liquidity sources compared to present and

future needs and the ability of the institution to meet liquidity needs

without adversely affecting operations or condition.

The availability of assets readily convertible to cash

without undue loss.


 

[[Page 37478]]


 

Access to money markets and other sources of funding.

The level of diversification of funding sources, both on-

and off-balance sheet.

The degree of reliance on short-term, volatile sources of

funds, including borrowings and brokered deposits.

The trend and stability of deposits.

The ability to securitize and sell certain pools of

assets.

The competence of management to properly identify,

measure, monitor and control the institution's liquidity position,

including the effectiveness of funds management strategies, liquidity

policies, management information systems, and contingency funding

plans.

Compliance with applicable laws and regulations.


 

Ratings


 

1. A rating of 1 indicates a strong liquidity position and well-

developed funds management practices after consideration of risk and

other factors. The institution has reliable access to a sufficient

volume of liquidity to meet present and anticipated liquidity needs.

Access to external sources of funds is on favorable terms.

2. A rating of 2 indicates satisfactory levels of liquidity and

risks, but modest weaknesses may be evident in quantitative measures of

liquidity or in funds management practices given risk exposures.

3. A rating of 3 denotes liquidity and risk levels or funds

management practices in need of improvement. Institutions rated 3 for

liquidity may lack ready access to funds on reasonable terms and may

evidence significant weaknesses in funds management practices given

risk exposures.

4. A rating of 4 represents a deficient liquidity and risk position

for current and anticipated needs and inadequate funds management

practices. Institutions so rated may not be able to obtain funds from

traditional funding sources to meet risk exposures.

5. A rating of 5 indicates a liquidity and risk position so

critically deficient that the continued viability of the institution is

threatened. Institutions rated 5 for liquidity require immediate

external financial assistance to meet maturing obligations and other

liquidity needs.


 

Sensitivity to Market Risks


 

The sensitivity to market risks component reflects the degree to

which changes in interest rates, foreign exchange rates, or commodity

or equity prices can affect a financial institution's assets, earnings,

liabilities and capital values. The capacity of management to identify,

measure, monitor and control market risk exposure is also a factor that

should be considered. Market risks encompass interest rate risk, price

risk, and foreign exchange risk. The primary element considered in

evaluating market risks is the sensitivity of assets, liabilities, off-

balance sheet commitments, and earnings to variability in interest

rates. This vulnerability is measured by potential changes in earnings

or economic value of capital under an appropriate range of economic

scenarios. When significant to an institution, consideration should

also be given to the price risk related to trading and investment

portfolios. If applicable, the foreign exchange risk to assets,

earnings, and capital should also be considered because of the periodic

revaluation of financial positions denominated in foreign currencies

into U.S. dollar equivalents.

Market risks are rated based on an assessment of the following, as

appropriate:

The sensitivity of the financial institutions's net

earnings or the economic value of its capital to changes in interest

rates under varying scenarios and stress environments.

The volume, composition, and volatility of any foreign

exchange or other trading positions taken by the financial

institutions.

The actual or potential volatility of earnings or capital

because of any change in market valuation of trading portfolios or

financial instruments.

The ability of management to identify, measure, monitor

and control exposure to interest rate risk, as well as price and

foreign exchange risk where applicable and material to an institution.


 

Ratings


 

1. A rating of 1 indicates minimal exposure to interest rate, price

or foreign exchange risk. Institutions rated 1 have limited exposure to

interest rate and other market risks and have strong management systems

in place to identify, measure, monitor and control these risks.

2. A rating of 2 is indicative of moderate and controlled exposure

to interest rate, price or foreign exchange risk. Management systems

are satisfactory, and ensure that market risks are maintained at an

acceptable level.

3. A rating of 3 indicates that one or more elements of this

component are in need of improvement. A 3 rating may reflect an

elevated level of interest rate sensitivity or exposure. It may also

indicate significant foreign exchange or repricing exposures which

subject earnings and capital to a moderate level of volatility.

Management systems for market risks may reflect weaknesses and need

improvement.

4. A rating of 4 reflects a financial institution that exhibits

exposures to market risks that may erode earnings and threaten

solvency. A 4 rating indicates an inordinate exposure to changes in

interest rates, or to foreign exchange revaluation or other repricing

effects. Management systems for market risks are deficient.

5. A rating of 5 reflects a financial institution with extreme

interest rate, foreign exchange, or price risk exposure constituting a

critical deficiency, and the continued viability of the institution is

threatened.


 

[End of proposed text of Uniform Financial Institution Rating System.]

Keith J. Todd,

Assistant Excecutive Secretary, Federal Financial Institutions

Examination Council.

[FR Doc. 96-18187 Filed 7-17-96; 8:45 am]

BILLING CODE OCC: 4810-33-M (25%); Board: 6210-01-M (25%); FDIC: 6714-

01-M (25%); OTS: 6720-01-M (25%)