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Final Rule Eliminates Reputation Risk from Bank Supervision Programs

The Office of the Comptroller of the Currency issued a final rule eliminating reputation risk as a basis for supervisory action. The rule, developed jointly with the FDIC, removes reputation risk from OCC supervisory programs and implements the President's fair banking Executive Order. National banks and federal thrifts are affected by this structural change to supervisory standards, which aims to prevent denial of banking services based on political, religious, or lawful business activity considerations.

Updated Model Risk Management Guidance for OCC-Supervised Institutions

The OCC, in coordination with the Federal Reserve Board and FDIC, issued updated model risk management guidance for OCC-supervised institutions, rescinding three prior OCC bulletins and the Model Risk Management booklet of the Comptroller's Handbook. The guidance is non-enforceable and establishes risk-based, tailored principles commensurate with an institution's size and complexity. It applies most directly to banking organizations with over $30 billion in total assets and explicitly excludes generative AI and agentic AI models from its scope.