Bank Supervision: Removing References to Reputation Risk

Today the Office of the Comptroller of the Currency (OCC), along with the Federal Deposit Insurance Corporation (FDIC) and the Board of Governors of the Federal Reserve System (collectively, the agencies), reissued 15 interagency guidance documents in which references to reputation risk have been removed. The agencies are issuing some of these documents along with the other members of the Federal Financial Institutions Examination Council (FFIEC) or other entities, such as the National Credit Union Administration and the Financial Crimes Enforcement Network (FinCEN). The agencies continue to review interagency documents and expect to expeditiously remove any further references to reputation risk.

Highlights

The OCC reissued the following documents with references to reputation risk removed:

• “Interagency Statement on Sales of 100% Loan Participations,” which was transmitted by OCC Bulletin 1997-21
• “Interagency Guidance on Asset Securitization Activities,” which was transmitted by OCC Bulletin 1999-46
• “Subprime Lending: Expanded Guidance for Subprime Lending Programs,” which was transmitted by OCC Bulletin 2001-6
• “Interagency Policy on Banks/Thrifts Providing Financial Support to Funds Advised by the Banking Organization or its Affiliates,” which was transmitted by OCC Bulletin 2004-2
• “Interagency Statement on the Purchase and Risk Management of Life Insurance,” which was transmitted by OCC Bulletin 2004-56
• “Interagency Guidance on Customer Identification Programs: Frequency Asked Questions,” which was transmitted by OCC Bulletin 2005-16
• “Interagency Credit Risk Management Guidance for Home Equity Lending,” which was transmitted by OCC Bulletin 2005-22
• “Interagency Guidance on Risk Management of Remote Deposit Capture,” which was transmitted by OCC Bulletin 2009-4 (Rescinded) and reflected in the Comptroller’s Handbook following OCC Bulletin 2021-49, “Payment Systems: Revised Comptroller’s Handbook Booklet and Rescissions”
• “Interagency Supervisory Guidance on Counterparty Credit Risk Management,” which was transmitted by OCC Bulletin 2011-30
• “Cyber Attacks on Financial Institutions’ Automated Teller Machine and Card Authorization Systems,” which was transmitted by OCC Bulletin 2014-13
• “Distributed Denial-of-Service (DDoS) Cyber-Attacks, Risk Mitigation, and Additional Resources,” which was transmitted by OCC Bulletin 2014-14
• “Joint Statement on Cyber Attacks Involving Extortion,” which was transmitted by OCC Bulletin 2015-40
• “Joint Statement on Cyber Insurance and Its Potential Role in Risk Management Programs,” which was transmitted by OCC Bulletin 2018-8
• “Sound Practices to Strengthen Operational Resilience,” which was transmitted by OCC Bulletin 2020-94
• “Interagency Statement on Elder Financial Exploitation,” which was transmitted by OCC Bulletin 2024-34

Background

On March 20, 2025, the OCC announced that it would no longer examine its banks for reputation risk and would commence removing references to reputation risk from its policy issuances. On April 10, 2026, the OCC and Federal Deposit Insurance Corporation published a final rule in the Federal Register that codified the elimination of reputation risk from their supervisory programs.

Further Information

Please contact the Office of the Chief National Bank Examiner at 202-649-5420.

James M. Gallagher
Senior Deputy Comptroller and Chief National Bank Examiner