Statement on Final Rule Removing Reputational Risk from Supervisory Program
Summary
FDIC Chairman Travis Hill issued a statement announcing a final rule that eliminates "reputational risk" from the FDIC's bank supervisory program. The rule codifies the removal of supervisory focus on reputation risk as a standalone risk category, effective April 7, 2026. The change addresses concerns that unfocused attention to reputation risk could lead to pressure on banks to debank law-abiding customers.
What changed
The final rule removes "reputational risk" as a standalone supervisory focus from the FDIC's bank examination program. The FDIC acknowledges that while bank reputation and public confidence are critically important, an explicit or implicit supervisory focus on reputation risk untethered from traditional risk channels (credit risk, market risk) adds little value to safety and soundness supervision and may improperly pressure banks into debanking law-abiding customers.
Banks and their compliance teams should note that future FDIC examinations will no longer include standalone reputational risk evaluations. Institutions should review their internal risk management frameworks to ensure reputational considerations are addressed within existing risk categories (credit, market, operational) rather than as a separate supervisory concern. This change aligns FDIC examination practices with traditional safety and soundness standards and may reduce regulatory pressure related to customer debanking decisions.
What to do next
- Review internal supervisory examination procedures to align with the elimination of standalone reputational risk assessment
- Update compliance policies to reflect that reputational risk will no longer be evaluated independently of traditional risk channels
- Monitor for related OCC guidance, as the OCC also participated in this rulemaking
Archived snapshot
Apr 8, 2026GovPing 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.
Statement by Chairman Travis Hill on the Final Rule to Remove Reputational Risk from the FDIC’s Supervisory Program
Chairman Travis Hill Statement, Board Meeting April 7, 2026 Today’s final rule would codify the elimination of “reputation risk” from the FDIC’s supervisory program. While a bank’s reputation is critically important, and many financial institutions over the years have failed due to a loss of confidence, 1 supervisory focus on “reputation risk” outside of traditional risk channels (such as credit risk or market risk) adds little value to promoting safety and soundness. On the other hand, an explicit or implicit focus on “reputation risk” untethered from other risk channels can pressure banks into debanking law-abiding customers who are viewed unfavorably by supervisors. Today’s final rule is one step in ensuring we remain focused on our key responsibilities, color within the lines, and “keep the main thing the main thing.” 2
I thank the FDIC and OCC staff for their work on the final rule and throughout the rulemaking process.
| 1 | See, e.g., ** John Maxfield, “ The 12 Reasons Banks Fail - Pt. 2,” Maxfield on Banks (Feb. 8, 2025) (“Confidence is king in banking. Lose that, you lose your bank.”). |
| 2 | Dave McMenamin, “ NBA Finals: Inside the relationships and history that bind the Lakers and Heat,” ESPN (Oct. 20, 2020) (“There’s almost no phrase you’ll hear [LeBron] James say more often than keep the main thing the main thing.’ It’s a Pat Riley staple, a saying the Heat president uses to underscore the discipline he believes an individual must have to reach the pinnacle of the sport.”). |
Last Updated: April 7, 2026
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