On October 21, 2025, the NCUA issued a a notice of proposed rulemaking to codify the elimination of reputation risk from its supervisory program. The FDIC and the OCC previously issued a joint proposal to formalize the elimination of reputation risk from their supervisory programs.
Among other things, the NCUA’s proposed rule would prohibit the agency from criticizing or taking adverse action against an institution, defined as an entity for which the NCUA makes or will make supervisory determinations or other decisions, either solely or jointly on the basis of reputation risk. The proposed rule would also prohibit the agency from asking or encouraging an institution to close an account, refuse to provide an account, product, or service, or change or end any product or service based on a person or entity's political, social, cultural, or religious views or beliefs. It also covers constitutionally protected speech and politically unpopular but lawful business activities that may seem risky to their reputation.
The proposed rule can be found here.