Letter supports balancing the Management component, ensuring technology-neutral examinations, and prioritizing material prudential risk to promote consistent and transparent supervisory outcomes

Washington, D.C. (August 17, 2026) – The American Fintech Council (AFC), the largest industry association representing both responsible fintech companies and innovative banks, submitted a comment letter to the Federal Financial Institutions Examination Council (FFIEC) in response to its request for comment regarding proposed revisions to the Uniform Financial Institutions Rating System (UFIRS), commonly known as CAMELS. AFC commends the FFIEC for undertaking the first comprehensive modernization of the CAMELS framework in nearly three decades and emphasizes its support of a materiality based approach which distinguishes material financial risk from technical supervisory findings.

“A modernized CAMELS rating system is essential to accurately assessing the health of today’s innovative banking system,” said Phil Goldfeder, CEO of the American Fintech Council. “By shifting examination focus to material prudential risks rather than isolated technical shortcomings, regulators can ensure that supervisory outcomes remain tied to an institution’s actual financial condition, helping to promote a more transparent and proportionate examination process.”

AFC emphasizes the recent evolution of the banking industry and how institutions are increasingly relying on technology-enabled products and bank-fintech partnerships to expand access to financial services. To accommodate new and future innovation, AFC encourages the FFIEC to implement a technology-neutral framework which evaluates supervised institutions based on the effectiveness of their governance and risk management, rather than the specific technological models they employ.

“Supervisory ratings carry significant regulatory consequences that extend well beyond the examination process itself, influencing everything from expansion opportunities to merger activity,” said Ian P. Moloney, Chief Policy Officer of the American Fintech Council. “Eliminating the disproportionate weight historically placed on the Management component and ensuring that all six CAMELS components are properly structured will ensure composite ratings represent a more accurate, balanced reflection of an institution’s overall risk profile. In turn, these changes will allow examiners the ability to focus specifically on identifying any material financial risks within the examination process.”

AFC also highlights the need for consistency, predictability, and regulatory certainty in the examination process, advocating for supplemental implementation guidance, robust examiner training across agencies, clear communication regarding rating determinations, and a refined supervisory appeals process to ensure that the modernized framework is applied uniformly and objectively across all similarly situated institutions.

A standards-based organization, the American Fintech Council (AFC) is the largest and most diverse trade association representing financial technology (fintech) companies and innovative banks. On behalf of over 150 member companies and partners, AFC promotes a transparent, inclusive, and customer-centric financial system by supporting responsible innovation in financial services and encouraging sound public policy. AFC members foster competition in consumer finance and pioneer products to better serve underserved consumer segments and geographies.

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