Comptroller Gould Statement on Final Rule Eliminating Reputation Risk from OCC Bank Supervision

Summary

Comptroller of the Currency Jonathan Gould on April 7, 2026, issued a statement at the FDIC board meeting on a final rule codifying the elimination of reputation risk from OCC supervisory programs, calling reputation risk a pretext regulators and banks have used for decisions unrelated to safety and soundness that denied lawful businesses access to banking services. The rule implements the President's fair banking Executive Order, and Gould said the OCC continues reviewing alleged debanking by the largest national banks.

Market Impact

Codifying the removal of reputation risk in regulation, rather than leaving it as supervisory guidance, makes the change durable across administrations and removes a supervisory basis that had been cited in bank decisions to exit crypto, firearms, payday lending, and other politically sensitive client categories. The ongoing OCC review of alleged debanking by the largest national banks creates continuing examination exposure for those institutions' account termination policies and customer onboarding standards.

Why It Matters

Reputation risk elimination changes the supervisory calculus for banks serving controversial-but-lawful industries: institutions can no longer point to examiner reputation risk expectations when restricting such customers, and under the fair banking Executive Order they now face scrutiny in the opposite direction -- for restricting access based on political or religious beliefs or lawful business activity.

Key Points

• The final rule codifies the elimination of reputation risk from OCC supervisory programs, announced at an FDIC board meeting on April 7, 2026.
• Gould said reputation risk has too often been used as a pretext for decisions with no connection to safety and soundness, financial risk, or BSA/AML compliance, resulting in lawful businesses denied banking services.
• The rulemaking implements the President's fair banking Executive Order, with Gould noting work under the EO is not done.
• The OCC has made significant progress reviewing alleged debanking actions of the largest national banks and continues investigating specific complaints and policy choices.
• Gould said agencies and banks should not restrict access to financial services on the basis of political or religious beliefs or lawful business activities.

Key Entities

Evidence

a final rule that codifies the elimination of reputation risk from Office of the Comptroller of the Currency supervisory programs.

Supports: The core action: reputation risk elimination codified in a final rule

Regulators and banks have too often used it as a pretext for decisions that have nothing to do with safety and soundness, financial risk, or even BSA/AML compliance. The result, in too many cases, has been lawful busi...

Supports: Gould's rationale: reputation risk functioned as a pretext that produced debanking of lawful businesses

Although we have made significant progress in our review of the alleged debanking actions of the largest national banks, we continue to delve into the details of specific complaints and policy choices.

Supports: The ongoing enforcement dimension: continuing OCC review of largest banks' alleged debanking