FDIC and OCC Issue Final Rule Prohibiting Use of Reputation Risk by Regulators

On April 7, 2026, the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC) jointly issued a final rule (Final Rule) codifying the elimination of reputation risk from their supervisory programs – a shift in the agencies’ supervisory philosophy that places limits on how examiners may evaluate regulated institutions.... By: Goodwin