U.S. banking agencies remove reputation risk references from interagency guidance

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Dan Blystone

02.06.2026

U.S. banking agencies remove reputation risk references from interagency guidance — Regulators revise risk guidance

U.S. bank regulators are continuing a broader overhaul of supervisory standards by deleting references to reputation risk from a series of shared policy documents. The move follows an April 10, 2026 final rule by the FDIC and OCC and is aimed at keeping supervisory decisions focused on material financial risks.

Highlights

On April 10, 2026, the FDIC and OCC published a final rule codifying the removal of reputation risk from supervisory programs.
U.S. banking agencies jointly revised interagency guidance to eliminate reputation risk references, aiming to focus supervisory decisions on material financial risks.
The updates affect documents regarding asset securitization, subprime lending, life insurance risk management, cyber risk, and other key compliance areas.

Supervisory guidance updated across agencies

As reported by the Federal Deposit Insurance Corporation, the FDIC, the Office of the Comptroller of the Currency and the Board of Governors of the Federal Reserve System have jointly revised several interagency documents to remove references to reputation risk.

The agencies say references to reputation in supervisory materials could be misused to limit individuals' and lawful businesses' access to financial services because of constitutionally protected political or religious beliefs, speech, conduct, or other lawful business activities. They say the changes are intended to improve clarity and support more precise supervisory decision-making based on material financial risks.

The revisions are limited to removing references to reputation risk. Some of the updated documents are being issued alongside other members of the Federal Financial Institutions Examination Council or other entities, including the Financial Crimes Enforcement Network.

Broader compliance and industry implications

On April 10, 2026, the FDIC and OCC published a final rule in the Federal Register codifying the elimination of reputation risk from their supervisory programs. The latest updates extend that effort across interagency guidance used in areas such as asset securitization, subprime lending, life insurance risk management, customer identification, home equity lending, remote deposit capture, counterparty credit risk, operational resilience and cyber risk.

The agencies also updated statements covering elder financial exploitation, loan participations and cyber attacks involving extortion. They say they continue to review supervisory materials and may revise additional documents as appropriate.

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