On September 25, 2025, the NCUA announced that it had stopped the use of reputation risk and equivalent concepts in the examination and supervisory process. These updates come after White House Executive Order 14331, which requires federal banking regulators to stop using "reputational risk" or similar ideas that could lead to politically motivated or unlawful debanking.
In line with the changes, NCUA employees will no longer cite or discuss reputation risk during credit union exams or supervision. However, the agency will continue to include key review areas historically classified under reputation risk, like financial liability associated with active litigation and insider abuse, as part of an examination as necessary. Additionally, NCUA will no longer continue the practice of assigning ratings to the Risk Categories for the examination and supervision program.
Read the NCUA’s announcement here.