Earlier this month, the FDIC and the OCC issued a final rule prohibiting the use of “reputation risk” as a standalone basis for bank supervision and enforcement, effective June 9, 2026. Regulators may no longer cite reputation risk alone to support supervisory criticism, enforcement actions, or exam findings.

The agencies found that reputation risk was subjective and inconsistently applied. Under the rule, examiners may not pressure banks to deny or limit services based on a customer’s political, social, cultural, or religious views, constitutionally protected speech, or lawful business activities. Supervisory focus must remain on objective, measurable risks tied to safety and soundness.

You can access the final rule here.

CCI suggests sharing this update with your compliance and risk team. Please reach out to us via inquiries@completecompli.com if you have any questions.

Sarah Smith, CRCM, CAFP