“Reputation risk” will no longer be an element in examinations by the national bank regulator under a bulletin issued late Thursday by the agency, which also said it had instructed its examiners to stop assessing for the risk.
Under its Bulletin 2025-4, the Office of the Comptroller of the Currency (OCC) said it is removing references to banks’ reputation risk from its Comptroller’s Handbook booklets and guidance issuances. Examiners have also been told “they should no longer examine for reputation risk,” the agency said.
“The OCC has never used reputation risk as a catch-all justification for supervisory action,” the agency said. “Rather, the OCC has focused primarily on the risks to a bank’s current or projected financial condition and resilience arising from negative public opinion.”
The agency, it said, believes removing references to reputation risk will improve transparency and confidence in the supervisory process.
The OCC said that for handbooks and guidance issuances issued jointly with other regulators, it will work with those regulators to expeditiously remove references to banks’ reputation risk.
OCC Bulletin 2025-4: Bank Supervision: Removing References to Reputation Risk