The Office of the Comptroller of the Currency (OCC), alongside the Federal Deposit Insurance Corporation (FDIC) and the Board of Governors of the Federal Reserve System, has reissued 15 interagency guidance documents, removing all references to "reputation risk." This collaborative effort aims to streamline supervisory programs across national banks, federal savings associations, and federal branches and agencies.
This action follows the OCC's March 20, 2025, announcement that it would cease examining banks for reputation risk. Subsequently, on April 10, 2026, the OCC and FDIC published a final rule in the Federal Register, codifying the elimination of reputation risk from their supervisory frameworks.
The reissued documents, which include guidance on asset securitization, subprime lending, and cyber attacks, apply to community banks to the same extent as their original issuances. The agencies, sometimes in conjunction with the Federal Financial Institutions Examination Council (FFIEC) and other entities, continue to review interagency documents and anticipate expeditiously removing any remaining references to reputation risk.