Recently, the Federal Deposit Insurance Corporation (FDIC), Office of the Comptroller of the Currency (OCC) and Federal Reserve Board (Federal Reserve) jointly updated 15 supervisory interagency guidance documents by removing references to “reputation risk.” The updated guidance follows other agency actions to remove “reputation risk” from supervisory guidance and examinations and is part of a broader federal effort to eliminate so-called politicized or unlawful debanking.
Background
In August 2025, President Donald Trump signed an executive order, “Guaranteeing Fair Banking Access for All Americans,” which directed federal banking regulators, including the FDIC, OCC and Federal Reserve to take certain actions to combat debanking. These actions included:
- Removing all considerations of “reputation risk” (and similar concepts) from guidance materials used to regulate or examine supervised financial institutions.
- Issuing new, formal guidance to their examiners including these changes.
In response, in April 2026, the OCC and FDIC jointly published a final rule codifying the elimination of “reputation risk” from their supervisory activities. The Federal Reserve is expected to finalize a similar rule proposed in February 2026.
Revisions to the guidance documents
In announcing the revised guidance, the agencies stated that references to “reputation” could be “misused as a basis to restrict individuals’ and legal businesses’ access to financial services due to their constitutionally protected political or religious beliefs, speech, or conduct or lawful business activities.” Removing “reputation risk” from the documents is intended to refocus supervision on “material financial risks.”
The reissued documents cover a range of topics, including asset securitization, subprime lending programs, financial support to affiliated funds, bank-owned life insurance, customer identification program FAQs, home equity lending risk management, remote deposit capture, counterparty credit risk, ATM and card authorization, cyber threats, distributed denial-of-service attacks, cyber extortion, cyber insurance, operational resilience, elder financial exploitation and loan participation sales.
What’s next
The agencies have indicated they will continue to review their supervisory materials and may update additional documents as appropriate. Banks and other regulated institutions should review their examination preparation materials and internal risk frameworks to determine whether any remaining references to “reputation risk” require updating to reflect the agencies’ current posture – while keeping in mind that all safety-and-soundness expectations grounded in tangible financial risks remain fully intact.