Statement by Chairman Travis Hill on the Proposal to Revise the CAMELS Rating System

Shifting CAMELS from process assessment to financial condition is sound policy, but the proposal is silent on the recordkeeping infrastructure that makes ratings defensible. When a bank fails shortly after a satisfactory composite, the post-mortem hinges on whether examiners documented which risks they judged immaterial, who approved the weighting, and what evidence supported the override of adverse specialty findings. Without decision records tying component scores to named officials and written rationales, the new framework risks the same outcome divergence that plagued SVB and Signature. Decisions deserve engineering rigor — especially the ones that determine regulatory consequences.