12/29/25
Letter in Support of Proposal to Prohibit the Use of Reputation Risk by the Agencies
ICBA sent a letter to the OCC and FDIC on the proposed rule to prohibit the use of reputation risk by the agencies. ICBA said it strongly supports this proposed rule and urged the agencies to finalize it promptly. ICBA noted that the elimination of reputation risk from supervisory frameworks will improve the objectivity, consistency, and predictability of bank supervision while reducing unnecessary compliance burdens on community banks.