Summary of: Prohibition on the Use of Reputation Risk by Regulators
Updated 10/27/2026
On April 10, 2026, the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) published a final rule codifying the elimination of reputation risk from their supervisory programs, with an effective date of June 9, 2026. While the rule change occurred earlier this year, affected banks continue to consider how the change may affect upcoming exams. The final rule prohibits the agencies from criticizing, formally or informally, or taking adverse supervisory action against an institution based solely on reputation risk. It also prohibits the agencies from requiring, instructing, or encouraging an institution to enter into, modify, or terminate a customer or third-party relationship, account, product, or service based on reputation risk, including where the concern relates to political, social, cultural, or religious views or beliefs, constitutionally protected speech or otherwise lawful but politically disfavored business activities.
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