Regulatory Alerts2025-10-07 | FIL-46-2025Agencies Issue Proposal to Prohibit Use of Reputation Risk by Regulators; FDIC Removes References from Examination and Other Materials
The Office of the Comptroller of the Currency and Federal Deposit Insurance Corporation issued a joint proposed rule codifying the removal of reputation risk from their supervisory programs. The rule prohibits both agencies from issuing formal or informal supervisory criticisms, taking adverse actions, or requiring account closures based on reputation risk, political views, or constitutionally protected speech. Concurrently, the FDIC eliminated reputation risk references from its core examination manuals and policy documents to formally instruct examiners against using it as a basis for supervisory criticism.
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