H.R. 3379, HUMPS Act of 2025

Bill Summary

H.R. 3379 would require the Federal Financial Institutions Examination Council (FFIEC) to recommend changes to the Uniform Financial Institutions Rating System, commonly referred to as the CAMELS rating system. This system is used by the federal regulators to evaluate the soundness of financial institutions.

Among other requirements, the FFIEC would need to establish criteria for assessing each CAMELS component and ensure that ratings are determined based on a transparent methodology. The bill would direct the member agencies of the FFIEC—the Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve, National Credit Union Administration (NCUA), and Office of the Comptroller of the Currency (OCC)—to jointly issue rules to implement the changes.

Estimated Federal Cost

The estimated budgetary effect of H.R. 3379 is discussed below. The costs of the legislation fall within budget function 370 (commerce and housing credit).

Basis of Estimate

CBO expects that H.R. 3379 will be enacted by the end of 2025. The FFIEC is funded by its member agencies. Based on the cost of similar activities, CBO expects that each member agency would need one employee in 2026 and 2027 to implement the bill’s requirements.

CBO estimates that enacting H.R. 3379 would increase direct spending by $1 million, decrease revenues by $1 million, and decrease the federal deficit by $2 million over the 2026-2035 period. In addition, CBO estimates that implementing the bill would increase spending subject to appropriation by $1 million over the same period.

Direct Spending

The administrative costs of the FDIC, NCUA, and OCC are classified in the federal budget as direct spending. CBO estimates that enacting the legislation would increase gross direct spending by $2 million over the 2026-2035 period. However, the NCUA and OCC collect fees from financial institutions to offset their costs; those fees are treated as reductions in direct spending. After accounting for those fees, CBO estimates that enacting the legislation would increase net direct spending by $1 million over the same period.

Revenues

Costs incurred by the Federal Reserve reduce remittances to the Treasury, which are recorded in the budget as revenues. CBO estimates that enacting H.R. 3379 would decrease revenues by $1 million over the 2026-2035 period.

Spending Subject to Appropriation

Under current law, the CFPB is permanently authorized to spend amounts transferred from the combined earnings of the Federal Reserve in an amount necessary to carry out its responsibilities, subject to a statutory cap that was lowered by the 2025 reconciliation act. CBO expects that the CFPB will spend all the transferred funds up to its cap in each year over the 2026-2035 period. Thus, CBO treats any costs for the CFPB to implement H.R. 3379 as contingent on future appropriations; CBO estimates that implementing the bill would increase spending subject to appropriation by $1 million.

Uncertainty

The changes made to the CAMELS rating system under H.R. 3379 could affect fees collected by the FDIC. The FDIC charges a risk-based assessment fee that uses an institution’s CAMELS rating to determine the rate. CBO estimated only the additional administrative costs of enacting H.R. 3379 and did not estimate any other budgetary effects. CBO cannot predict the magnitude or direction of any budgetary effects because they depend on uncertain factors, including what types of changes are recommended and how many institutions would be affected by those changes.

Pay-As-You-Go Considerations

The Statutory Pay-As-You-Go Act of 2010 establishes budget-reporting and enforcement procedures for legislation affecting direct spending or revenues. CBO estimates that enacting H.R. 3379 would increase direct spending by $1 million and decrease revenues by $1 million over the 2026-2035 period.

Increase in Long-Term Net Direct Spending and Deficits

CBO estimates that enacting H.R. 3379 would not increase net direct spending or on-budget deficits in any of the four consecutive 10-year periods beginning in 2036.

Mandates

If federal financial regulators increase annual fees to offset the costs of implementing the bill, H.R. 3379 would increase the costs of an existing private-sector mandate on entities required to pay those fees. CBO estimates that the incremental cost of the mandate would be small and would fall well below the annual threshold established in the Unfunded Mandates Reform Act (UMRA) for private-sector mandates ($206 million in 2025, adjusted annually for inflation).

The bill contains no intergovernmental mandates as defined in UMRA.

Estimate Prepared By

Federal Costs:

David Hughes (for the Consumer Financial Protection Bureau and Federal Financial Institutions Examination Council)
Julia Aman (for the Federal Deposit Insurance Corporation, National Credit Union Administration, and Office of the Comptroller of the Currency)

Revenues: Nathaniel Frentz

Mandates: Rachel Austin

Estimate Reviewed By

Justin Humphrey
Chief, Finance, Housing, and Education Cost Estimates Unit

Joshua Shakin
Chief, Revenue Projections Unit

Kathleen FitzGerald
Chief, Public and Private Mandates Unit

H. Samuel Papenfuss 
Deputy Director of Budget Analysis

Estimate Approved By