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Press Release: Agencies Remove Additional References to Reputation Risk

AI Analysis

On 2026-06-02, the FDIC, OCC, and Federal Reserve jointly updated certain interagency supervisory documents to remove references to reputation risk. The agencies said the edits are meant to align with their earlier actions ending the use of reputation risk in supervision and to keep supervisory judgments focused on material financial risks.

Key dates

2026-06-02
FDIC, OCC, and Federal Reserve jointly announced updates to certain interagency documents removing references to reputation risk

Suggested considerations

  • Compliance teams may wish to inventory supervisory manuals, internal policies, and model examination references that still mention reputation risk and assess whether any language should be updated for consistency with the agencies’ approach.
  • Firms should consider whether account-closure, onboarding, or risk-acceptance frameworks rely on reputation-risk concepts that may now be less aligned with supervisory expectations.
  • Banks may wish to review escalation criteria and decision records to ensure they are grounded in material financial, operational, or legal risk factors rather than vague reputational concerns.
  • Supervisory response teams may wish to brief relevant business lines on the agencies’ stated focus on financial risk and the agencies’ concern that reputation risk can be used to pressure restrictions on lawful customer activity.
  • Compliance functions may wish to monitor whether additional interagency documents are revised in subsequent FDIC, OCC, or Federal Reserve publications.

What changed

The publication says the agencies updated certain interagency documents and removed references to reputation risk. The stated scope of the change is narrow: the agencies said the updates are limited to removing references to reputation risk, not to imposing new obligations on banks. The agencies also reiterated that reputation risk can be misused to pressure banks to restrict access to financial services based on constitutionally protected political or religious beliefs, speech, conduct, or lawful business activities. The release says the agencies will continue reviewing supervisory materials and may update additional documents later.

Compliance impact

The impact is moderate but notable because the agencies are signaling that supervisory decisions should be anchored in material financial risks rather than reputation risk concepts. The release does not create a new compliance obligation, but it does indicate a supervisory posture that may reduce tolerance for policies or practices justified primarily by reputational concerns.

Who is affected

  • FDIC-supervised financial institutions
  • OCC-supervised banks
  • Federal Reserve-supervised banks
  • Compliance teams responsible for supervisory, account review, and customer access policies
  • 12 CFR Part 302
  • 12 CFR Part 2
  • Interagency supervisory materials on examination and risk management

AI-generated analysis. May contain errors or omissions — verify with the original FDIC source before acting. Full disclaimer.

What the FDIC said

PRESS RELEASE | JUNE 2, 2026 Agencies Remove Additional References to Reputation Risk WASHINGTON—The federal bank regulatory agencies today jointly updated certain interagency documents to remove references to reputation risk. The agencies are taking this action to complement their earlier actions that ended the use…

Extract from FDIC . Read the full notice at the source for the authoritative text.

Relevant Firm Types

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