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Comptroller Statement on Final Rule Eliminating Reputation Risk from Bank Supervision

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Summary

The OCC and FDIC jointly issued a final rule removing reputation risk as a basis for bank supervisory action. The rule, presented by Comptroller Jonathan V. Gould, prohibits regulators from using subjective reputation-based grounds to deny banking services to lawful businesses and individuals. The rule implements the President's fair banking Executive Order and requires ongoing review of alleged debanking actions at the largest national banks.

What changed

The OCC and FDIC jointly issued a final rule formally eliminating reputation risk from the bank supervisory framework. The rule removes a subjective measure that regulators and banks have used as pretext for denying banking services to lawful businesses and individuals. The Comptroller's statement explicitly acknowledged that reputation risk has too often served as a basis for decisions unrelated to safety and soundness, financial risk, or BSA/AML compliance.

Banks previously subject to supervisory scrutiny on reputation grounds should review their compliance posture under the new objective standards. The rule requires the OCC to continue investigating alleged debanking by large national banks and ensure neither regulators nor banks restrict financial services access based on political, religious, or lawful business activity grounds. Compliance teams should monitor for implementation guidance.

What to do next

  1. Update bank supervision and examination frameworks to remove reputation risk considerations
  2. Review pending supervisory actions for compliance with new objective standards
  3. Monitor for OCC implementation guidance on fair banking Executive Order

Archived snapshot

Apr 8, 2026

GovPing captured this document from the original source. If the source has since changed or been removed, this is the text as it existed at that time.

News Release 2026-27 | April 7, 2026

Comptroller Statement on Final Rule Eliminating Reputation Risk from Bank Supervision

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WASHINGTON—Comptroller of the Currency Jonathan V. Gould issued the following statement today at the Federal Deposit Insurance Corporation’s board meeting about a final rule that codifies the elimination of reputation risk from Office of the Comptroller of the Currency supervisory programs.

Today’s final rule is another step toward reducing the opportunities for regulatory abuse by removing reputation risk as a basis for government action.

Reputation risk is not a sound basis for supervision. Regulators and banks have too often used it as a pretext for decisions that have nothing to do with safety and soundness, financial risk, or even BSA/AML compliance. The result, in too many cases, has been lawful businesses and individuals denied access to banking services. Supervisory action should be grounded in less subjective measures. This rule, together with other actions we are taking, helps move us in that direction.

Our rulemaking also implements the President’s fair banking Executive Order. But our work is not done under that EO. Although we have made significant progress in our review of the alleged debanking actions of the largest national banks, we continue to delve into the details of specific complaints and policy choices. Our collective efforts under the EO should shine a spotlight on the actions of agencies and certain banks, bringing accountability and ensuring that neither we nor banks restrict access to financial services on the basis of political or religious beliefs or lawful business activities.

I want to thank the teams at the FDIC and the OCC for their efforts in finalizing this rule, and I look forward to its implementation.

Related Link


Media Contact

Stephanie Collins
(202) 649-6870


Topic(s):

Named provisions

Reputation Risk Elimination Fair Banking Executive Order Implementation

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Last updated

Classification

Agency
OCC
Published
April 7th, 2026
Instrument
Rule
Legal weight
Binding
Stage
Final
Change scope
Substantive
Document ID
NR-OCC-2026-27

Who this affects

Applies to
Banks Government agencies
Industry sector
5221 Commercial Banking
Activity scope
Bank supervision Risk-based examination Regulatory compliance
Geographic scope
United States US

Taxonomy

Primary area
Banking
Operational domain
Compliance
Compliance frameworks
Basel III Dodd-Frank
Topics
Consumer Finance Consumer Protection

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