- Potential benefitIncreases consistency and predictability of supervisory ratings across similar financial institutions.
- Potential benefitPromotes greater transparency by requiring a clearly documented, objective rating methodology.
- Potential benefitMay reduce perceived examiner subjectivity and provide clearer benchmarks for institutions.
HUMPS Act of 2025
Placed on the Union Calendar, Calendar No. 136.
The HUMPS Act of 2025 directs the Federal Financial Institutions Examination Council (FFIEC) to recommend and the federal banking agencies to adopt objective, transparent revisions to the CAMELS (Capital, Asset quality, Management, Earnings, Liquidity, Sensitivity) rating system. It requires clear criteria, revised factor weightings, either elimination or narrowing of the Management component to objective governance measures, explicit consideration of anti-money-laundering compliance in composite ratings, a joint rulemaking within 12 months, and a minimum 90-day public comment period.
Left fears weakened supervision and lost qualitative oversight
Relative to its intended legislative type, this bill provides a clear policy objective and a limited statutory framework to drive administrative change in supervisory ratings, but it leaves significant substantive detail and several implementation responsibilities to the Council and agencies without attaching deadlines, resource direction, or measurement requirements.
The HUMPS Act of 2025 directs the Federal Financial Institutions Examination Council (FFIEC) to recommend and the federal banking agencies to adopt objective, transparent revisions to the CAMELS (Capital, Asset quality, Management, Earnings, Liquidity, Sensitivity) rating system.
It requires clear criteria, revised factor weightings, either elimination or narrowing of the Management component to objective governance measures, explicit consideration of anti-money-laundering compliance in composite ratings, a joint rulemaking within 12 months, and a minimum 90-day public comment period.
The bill also amends a Bank Holding Company Act definition related to "well managed," removing certain clauses tied to CAMEL assessments.
Technocratic, non‑spending reform increases chances, but regulator resistance, stakeholder disagreement, and Senate procedure reduce probability.
Relative to its intended legislative type, this bill provides a clear policy objective and a limited statutory framework to drive administrative change in supervisory ratings, but it leaves significant substantive detail and several implementation responsibilities to the Council and agencies without attaching deadlines, resource direction, or measurement requirements.
Left fears weakened supervision and lost qualitative oversight
Who stands to gain, and who may push back.
These are examples from the analysis, not a ranked list of the most-affected groups.
- Potential burdenMay limit regulators' discretionary ability to address qualitative risks like management judgment or culture.
- Potential burdenEliminating or narrowing the management component could overlook leadership failures and governance weaknesses.
- Potential burdenTransitioning to new objective metrics could impose compliance and administrative costs on banks and agencies.
Why the argument around this bill splits.
Left fears weakened supervision and lost qualitative oversight
Skeptical.
Supports transparency but worries that rigid, objective criteria and removing subjective judgment could weaken supervision, hide misconduct, and undermine consumer protections.
Concerned about narrowing qualitative assessment of management and nonfinancial risks.
Cautiously positive.
Values predictability and clarity, and likes the public-rulemaking process.
Wants safeguards so fixed rules do not blind supervisors to emerging or qualitative risks.
Supportive.
Favors reducing subjective examiner discretion, increasing objective standards, and improving regulatory predictability for banks.
Views transparency and objective CAMELS criteria as reducing arbitrary enforcement and regulatory uncertainty.
The path through Congress.
Reached or meaningfully advanced
Reached or meaningfully advanced
Still ahead
Still ahead
Still ahead
Technocratic, non‑spending reform increases chances, but regulator resistance, stakeholder disagreement, and Senate procedure reduce probability.
- Positions of banking regulators (acceptance or opposition)
- Industry (large vs community banks) support or resistance
Recent votes on the bill.
No vote history yet
The bill has not accumulated any surfaced votes yet.
Go deeper than the headline read.
Left fears weakened supervision and lost qualitative oversight
Technocratic, non‑spending reform increases chances, but regulator resistance, stakeholder disagreement, and Senate procedure reduce probab…
Relative to its intended legislative type, this bill provides a clear policy objective and a limited statutory framework to drive administrative change in supervisory ratings, but it leaves significant substantive detai…
Go beyond the headline summary with full stakeholder mapping, legislative design analysis, passage barriers, and lens-by-lens tradeoff breakdowns.