The Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation jointly issued a final rule codifying the elimination of reputation risk from their supervisory programs. The rule defines “reputation risk” and prohibits the agencies from criticizing or taking adverse action against an institution on the basis of reputation risk. The final rule also prohibits the agencies from requiring, instructing, or encouraging an institution to close customer accounts or take other actions based on a person or entity’s political, social, cultural, or religious views or beliefs, constitutionally protected speech, or solely on the basis of politically disfavored but lawful business activities perceived to present reputation risk. It responds to concerns raised in Executive Order 14331, Guaranteeing Fair Banking for All Americans, that reputation risk could be used as a pretext to restrict law-abiding individuals’ and businesses’ access to financial services based on political or religious beliefs or lawful business activities.
Office of the Comptroller of the Currency 2026-04-07
US Office of the Comptroller of the Currency and Federal Deposit Insurance Corporation finalize rule barring supervisory actions based on reputation risk
The Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation issued a final rule eliminating “reputation risk” from their supervisory programs, defining the term and barring adverse action against institutions on that basis. The rule also prohibits the agencies from pressuring institutions to close accounts or act based on customers’ political, social, cultural, or religious views, constitutionally protected speech, or lawful but politically disfavored activities, addressing concerns in Executive Order 14331 on fair access to banking services.