FDIC, Fed and OCC Drop Reputation Risk References from Guidance

The Federal Deposit Insurance Corporation (FDIC), the Federal Reserve and the Office of the Comptroller of the Currency (OCC) said on 2 Jun that they had updated multiple guidance documents, examination procedures and supervisory manuals to remove references to reputation risk, arguing that the concept could be misused to restrict access to banking services for lawful businesses or individuals based on political or religious beliefs. 

The move follows a final rule adopted by the FDIC and OCC in April that formally prohibited regulators from criticizing banks or taking supervisory actions based on reputation risk.  That rule, in turn, stemmed from an executive order by President Donald Trump in August 2025 that directed federal agencies to eliminate the concept from their supervisory frameworks. 

The latest changes affect more than a dozen interagency documents covering areas including asset securitization, subprime lending, cyber risk, customer identification programmes and operational resilience. 

"References to 'reputation' in these interagency documents could be misused as a basis to restrict individuals' and legal businesses' access to financial services due to their constitutionally protected political or religious beliefs, speech, or conduct or lawful business activities," the agencies said in a joint statement. 

Debanking concerns 

The revisions represent the next phase of a regulatory overhaul that began shortly after President Trump returned to office and intensified scrutiny of so-called "debanking" claims from crypto firms, firearms manufacturers, religious organizations and politically conservative groups. 

The issue has become a priority for the administration. Speaking at the Bitcoin 2026 conference in Las Vegas, Eric Trump linked his family's embrace of digital assets to what he described as years of politically motivated debanking. 

"We became the most cancelled people probably in the history of the world," Eric Trump said, claiming major banks had closed hundreds of accounts tied to the Trump Organization and affiliated properties. 

According to Trump, the accounts were targeted "simply because they didn't like the fact that there's a person in my family" involved in politics. Trump argued the experience demonstrated how financial institutions could be used to exert political pressure, adding that if banks could take such action against a large business family, "what can they do to the everyday person?" 

Crypto implications 

The changes are likely to be welcomed by digital-asset companies, which have long argued that federal regulators used reputation risk concerns to pressure banks away from serving crypto-related businesses. 

The issue gained prominence following allegations of "Operation Choke Point 2.0", a term used by crypto industry participants to describe what they viewed as coordinated efforts by regulators to limit banking access for digital-asset firms. 

While the updated guidance does not require banks to provide services to any particular customer or industry, it further limits regulators' ability to cite reputational concerns when supervising financial institutions.