On June 2, the OCC, the FDIC, and the Fed announced that they have jointly reissued 15 interagency guidance documents to remove references to reputation risk. The documents cover topics including asset securitization, subprime lending, customer identification, home equity lending, cybersecurity, operational resilience, and elder financial exploitation. The agencies noted that reputation risk can be misused to pressure banks into restricting access to financial services based on customers’ constitutionally protected political or religious beliefs, speech, or lawful business activities.

According to the regulators, the updates are intended to ensure that supervisory decisions focus on material financial risks and to promote greater clarity and precision in the examination process. The agencies noted that the updates complement earlier steps to eliminate reputation risk from the agencies’ supervisory programs. As previously covered by InfoBytes, in April, the OCC and the FDIC published a final rule in the Federal Register codifying the elimination of reputation risk from their supervisory programs. In February, the Fed separately proposed a rule to codify its own removal of reputation risk (covered by InfoBytes here), but that rule has not yet been finalized. The agencies indicated that their review of supervisory materials is ongoing and that further updates may follow.