The Institute of International Bankers submitted a comment letter supporting the Federal Financial Institutions Examination Council’s proposed CAMELS reforms and calling for comparable changes to the ROCA rating system for U.S. branches and agencies of international banks. It argued that ROCA, which focuses largely on nonfinancial risks and controls and can affect an international bank’s well managed status, should become more transparent, predictable and closely aligned with assessments of financial condition, safety and soundness, and material financial risks. The group recommended that no single Risk Management, Operational Controls or Compliance component should, by itself, result in an unsatisfactory composite ROCA rating. It also called for the Risk Management component to focus primarily on the branch’s management of material financial risks and brand resilience, and for regulators to reassess the international bank supervisory ratings model to improve consistency across rating systems and support national treatment.
2026-08-17Institute of International Bankers
Institute of International Bankers calls for ROCA rating reforms alongside CAMELS changes
The Institute of International Bankers called for reforms to the ROCA rating system for U.S. branches and agencies of international banks alongside proposed CAMELS changes. It recommended that no single ROCA component should independently produce an unsatisfactory composite rating and sought greater transparency, predictability and consistency across supervisory rating systems.