OCC and FDIC bar reputation-risk supervision
Bank examiners must stop using reputation risk as a supervisory basis
Change
The OCC and FDIC issued a final rule eliminating reputation risk from their supervisory programs and barring supervisory criticism, adverse action, or account-closure pressure on that basis.
Why it matters
The rule removes reputation risk as a permissible supervisory ground for OCC and FDIC action. It also blocks the agencies from directing or encouraging banks to close accounts or take other action because of protected speech, political or religious views, or lawful business activities treated as politically disfavored.
Implications
- — OCC and FDIC examination teams must remove reputation-risk reasoning from supervisory criticism, adverse-action support, and account-closure pressure — continued reliance on reputation risk would breach the final rule.
- — Banks supervised by the OCC or FDIC must separate lawful customer-risk decisions from examiner reputation-risk pressure — account closures tied only to protected views, speech, or lawful politically disfavored activity now fall outside the agencies' supervisory authority.
Who is affected
- — OCC and FDIC supervisory and examination teams
- — Banks supervised by the OCC or FDIC
- — Bank compliance and legal teams handling examiner findings or account-closure decisions
What to watch
- — Final rule issued: 2026-04-07 — OCC and FDIC reputation-risk supervision prohibition codified.