FDIC and OCC Issue Final Rule Eliminating Reputation Risk in Supervision

On April 7, 2026 the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency jointly issued a final rule that removes “reputation risk” from their supervisory programs. The rule defines reputation risk and prohibits the agencies from criticizing or taking adverse action against a financial institution on that basis. It also bars regulators from requiring, instructing or encouraging an institution to close customer accounts or take other actions based on a person’s or entity’s political, social, cultural, or religious views, constitutionally protected speech, or lawful business activities that might be perceived to carry reputation risk. The rule responds to concerns raised in Executive Order 14331, which warned that reputation risk could be used to limit lawful access to banking services.

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