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OCC Bulletin 2025-4 | March 20, 2025
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Chief Executive Officers of All National Banks, Federal Savings Associations, and Federal Branches and Agencies; Department and Division Heads; All Examining Personnel; and Other Interested Parties
The Office of the Comptroller of the Currency (OCC) has commenced removing references to banks’1 reputation risk from its Comptroller’s Handbook booklets and guidance issuances. Concurrently, the OCC has instructed its examiners that they should no longer examine for reputation risk.
The OCC’s discontinuation of examining for reputation risk applies to community banks.
The OCC has never used reputation risk as a catch-all justification for supervisory action. 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. Nonetheless, the OCC believes removing references to reputation risk will improve transparency and confidence in the supervisory process. For handbooks and guidance issuances issued jointly with other regulators, the OCC will work with those regulators to expeditiously remove references to banks’ reputation risk.
The OCC expects banks to engage in sound risk management practices, operate in a safe and sound manner, and comply with applicable laws and regulations.
Please contact Bank Supervision Policy at (202) 649-6770.
Grovetta N. Gardineer Senior Deputy Comptroller for Bank Supervision Policy
1 “Banks” refers collectively to national banks, federal savings associations, covered savings associations, and federal branches and agencies of foreign banking organizations.
