Agencies Remove References to Reputation Risk in Interagency Documents

Examination Procedures and Manual Updates

Laws and Regulations

Supervisory Guidance

June 2, 2026

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Summary:
The Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC) and the Board of Governors of the Federal Reserve System (the agencies), have jointly updated several interagency documents to remove references to reputation risk, complementing earlier actions that ended the use of reputation risk in supervision. References to “reputation” in these interagency documents 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. These updates help ensure supervisory decisions are based on material financial risks, as well as increase clarity and facilitate greater precision in supervisory decision making. These updates are limited to removing references to reputation risk. The agencies are issuing some of these documents along with the other members of the Federal Financial Institutions Examination Council or other entities, such as the Financial Crimes Enforcement Network. The agencies continue to review their supervisory materials and may update additional documents as appropriate. Statement of Applicability:
The contents of, and material referenced in, this FIL apply to all FDIC-supervised financial institutions. Highlights:
On April 10, 2026, the FDIC and OCC published a final rule in the Federal Register that codified the elimination of reputation risk from their supervisory programs. In furtherance of the objective to remove reputation risk from the supervisory framework, the agencies updated the following documents:
“Interagency Guidance on Asset Securitization Activities,” which was transmitted by FIL-109-99 “Subprime Lending: Expanded Guidance for Subprime Lending Programs,” which was transmitted by FIL-09-2001 “Interagency Policy on Banks/Thrifts Providing Financial Support to Funds Advised by the Banking Organization or its Affiliates,” which was transmitted by FIL-1-2004 “Interagency Statement on the Purchase and Risk Management of Life Insurance,” which was transmitted by FIL-127-2004 “Interagency Guidance on Customer Identification Programs: Frequency Asked Questions,” which was transmitted by FIL-34-2005 “Interagency Credit Risk Management Guidance for Home Equity Lending,” which was transmitted by FIL-45-2005 “Interagency Guidance on Risk Management of Remote Deposit Capture,” which was transmitted by FIL-4-2009

“Interagency Supervisory Guidance on Counterparty Credit Risk Management,” which was transmitted by FIL-53-2011 “Cyber Attacks on Financial Institutions’ Automated Teller Machine and Card Authorization Systems,” which was transmitted by FIL-10-2014 “Distributed Denial-of-Service (DDoS) Cyber-Attacks, Risk Mitigation, and Additional Resources,” which was transmitted by FIL-11-2014 “Joint Statement on Cyber Insurance and Its Potential Role in Risk Management Programs,” which was transmitted by FIL-16-2018 “Sound Practices to Strengthen Operational Resilience,” which was transmitted by FIL-103-2020 “Interagency Statement on Elder Financial Exploitation,” which was transmitted by FIL-83-2024 “ Interagency Statement on Sales of 100% Loan Participations ” “ Joint Statement on Cyber Attacks Involving Extortion ”

FIL-27-2026

Attachment(s)

News Release, “Agencies Issue Final Rule to Prohibit Use of Reputation Risk by Regulators,” April 7, 2026

Federal Register Notice

News Release, “Agencies Issue Proposal to Prohibit Use of Reputation Risk by Regulators,” October 7, 2025

Related Topics

Examination Processes and Procedures

Contact(s)

Division of Depositor and Consumer Protection

Division of Risk Management Supervision

Legal Division