On June 2, 2026, the FDIC, Federal Reserve Board, and OCC jointly updated several interagency documents to remove references to reputation risk. This complements earlier actions that ended the use of reputation risk in the agencies’ supervision.

According to the agencies, reputation risk can be misused by supervisors as a basis to encourage or pressure a bank 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. The updates are intended to ensure that supervisory decisions are grounded in material financial risks while improving clarity and promoting more precise decision-making.The updates to the interagency documents are limited to removing references to reputation risk.

Read the agencies’ joining press release here.

Adam Witmer

Adam Witmer is a speaker, author, and founder of the Compliance Cohort. Adam has taught hundreds of seminars and training sessions to thousands of bankers throughout the United States and teaches on all areas of regulatory compliance. Adam has written five e-books that he never published, hit a grizzly bear while driving in a National Park, and is an award winning photographer and musician (though he no longer takes photos nor plays any instruments). In his spare time, Adam can be found kayaking on the lake, doing taekwondo with his kids, working on his (project) house, or spending time with his family.

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