OCCGeneralApril 10, 2026

OCC & FDIC Ban 'Reputation Risk' as a Basis for Supervisory or Account Actions

The OCC and FDIC have finalized a rule prohibiting themselves from using 'reputation risk' as a grounds for supervisory criticism or adverse action, and from pressuring banks to close or deny accounts based on a customer's lawful business activities, political views, or constitutionally protected speech. This is directly relevant to crypto and fintech firms that have experienced debanking or account closures, as it limits regulators' ability to push banks away from serving these industries on reputational grounds alone. Banks serving crypto clients should document this rule as support for maintaining those relationships.

What to do

Share this final rule with your legal and compliance teams, and use it to inform internal policy discussions about onboarding or retaining crypto and fintech customers that may have previously been declined on reputation risk grounds.

Who this affects

Bank / Credit UnionCrypto ExchangeCrypto CustodianMoney Services BusinessPayments CompanyFintech / Neobank

Does this affect your program?

Pick your institution type for an instant read on whether you're in scope — then see exactly which sections of your own policies this changes.

Source

Read the official publication

This radar entry is educational and does not constitute legal advice. Summaries are AI-assisted and grounded in the linked official source; always verify against the primary source and consult qualified legal counsel for jurisdiction-specific guidance.

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