Agencies Issue Proposal to Prohibit Use of Reputation Risk by Regulators — 2025-10-07

Washington, D.C.— The Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation (the agencies) today issued a joint notice of proposed rulemaking that would codify the elimination of reputation risk from their supervisory programs. The proposed rule would define “reputation risk” and prohibit the agencies from criticizing or taking adverse action against an institution on the basis of reputation risk. The proposed rule would also prohibit the agencies from requiring, instructing, or encouraging an institution to close customer accounts or take other actions on the basis of 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.