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International banks press Fed to reform ROCA and CUSO ratings that affect 'well‑managed' status

Federal Reserve Board of Governors · April 8, 2026
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Summary

Representatives of internationally headquartered banks told a Federal Reserve outreach panel that ROCA and CUSO ratings overemphasize policy and governance and can mechanically downgrade foreign bank operations, and they urged the Fed to articulate well‑managed standards and increase transparency.

Stephanie Webster, general counsel of the Institute of International Bankers, told the panel that ROCA and CUSO rating systems applied to foreign banking organizations can have severe consequences when those ratings emphasize nonfinancial issues and lack transparent weighting.

"ROCA and CUSO ratings do not appropriately balance risk management issues against financial condition and those material…

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