On 2 June 2026, the OCC, FDIC, and Federal Reserve Board jointly reissued 15 interagency guidance documents with all references to reputation risk removed.
The agencies determined that reputation risk language could be misused to restrict individuals and legal businesses from accessing financial services based on protected political or religious beliefs.
Supervisory decisions will now be required to rest on material financial risks, with the agencies citing a need for greater clarity and precision in their oversight activities.
The reissued documents cover a broad span of regulatory history, ranging from a 1997 statement on loan participations to a 2024 statement on elder financial exploitation.
The action builds on a final rule jointly issued by the OCC and FDIC, published in the Federal Register on 10 April 2026 and effective that same week, which formally codified the elimination of reputation risk.
The Federal Reserve had separately issued its own proposal on 23 February 2026 to codify the same removal within its supervisory programme.
Across the updated documents, references to both “reputation risk” and, in some cases, simply “reputation” have been stripped out, reinforcing the agencies’ earlier supervisory policy shift.
The agencies had previously moved to stop using reputation risk as the basis for examination findings or for pressuring financial institutions to exit or avoid certain banking relationships.
For bank compliance teams that have been limiting relationships with crypto firms, the practical effect is the removal of an interagency text hook that previously gave examiners broad discretionary leverage.
Decisions to terminate or withhold accounts must now be grounded in identified credit, market, liquidity, BSA/AML, operational, or consumer-compliance risk rather than an ambiguous category without a clear remediation path.
The three agencies stated they continue to review their supervisory materials and may update additional documents as appropriate in the coming months.