The Federal Reserve announced on June 23, 2025, that it will no longer include “reputational risk” as a component of its bank supervisory examination programs. This decision aligns with similar moves by the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC), which had already removed reputational risk from their supervisory frameworks earlier in 2025. The Fed is revising its supervisory materials, including examination manuals, to eliminate references to reputational risk and, where appropriate, replace them with more specific discussions of financial risk.
Examiners will be trained to ensure consistent implementation across supervised banks, and the Fed will coordinate with other federal banking regulators to promote uniform practices. This change addresses industry concerns about the subjectivity of reputational risk, which was previously defined as the potential for negative publicity to harm a bank’s business or lead to costly litigation. Critics, particularly in the cryptocurrency sector, argued that reputational risk was used to justify “debanking,” where banks denied services to certain clients, such as crypto firms, due to perceived public perception issues.
The shift to focusing on measurable financial risks is seen as a move to enhance transparency and consistency in supervision, potentially easing banking access for crypto and other high-risk but compliant sectors. The Fed emphasized that this change does not lower expectations for banks to maintain robust risk management practices to ensure safety, soundness, and compliance with laws and regulations. Banks may still consider reputational risk in their internal risk management processes, but it will no longer be a formal supervisory metric.
By replacing reputational risk with measurable financial risks, banks gain clearer regulatory expectations. The subjective nature of reputational risk often led to inconsistent examiner judgments, creating compliance uncertainty. Banks can now focus on quantifiable metrics like credit, market, and operational risks. The Fed, alongside the OCC and FDIC, aims to standardize supervisory practices, reducing ambiguity. This shift may streamline examinations and reduce the risk of legal challenges from banks over vague supervisory criteria.
Cryptocurrency firms, cannabis businesses, and other industries often faced restricted banking access due to banks’ fears of reputational risk penalties, a practice critics called “debanking.” Removing this risk as a supervisory factor could encourage banks to serve these compliant but controversial sectors, fostering financial inclusion and innovation. Easier banking access for crypto firms may lower transaction costs and improve service availability for users of digital assets.
While reputational risk is no longer a supervisory requirement, banks may still address it internally to protect customer trust and market position. However, without regulatory pressure, some may deprioritize it, potentially increasing vulnerability to public relations issues that could indirectly affect financial stability. The emphasis on financial risks strengthens oversight of core banking safety and soundness but may limit regulators’ ability to address non-financial risks that could escalate, such as consumer backlash or litigation from high-profile controversies.
Reduced regulatory barriers could spur growth in fintech and crypto, aligning with pro-innovation sentiments from some policymakers and the incoming Trump administration’s crypto-friendly stance. Investors and customers may perceive banks serving high-risk industries as riskier, potentially affecting stock prices or deposit flows, though this depends on how banks communicate their risk management.
Banks and crypto advocates, including groups like the Blockchain Association, welcome the change, arguing that reputational risk was a pretext for overreach, stifling innovation. They see this as a victory for fairer regulation. Some regulators and consumer advocates worry that removing reputational risk weakens oversight of systemic risks tied to public perception, such as bank runs triggered by negative publicity (e.g., Silicon Valley Bank’s collapse in 2023). They argue it could embolden banks to take on riskier clients without adequate safeguards.
The decision aligns with Republican-led efforts to curb perceived regulatory hostility toward crypto, as seen in criticisms of the SEC and prior Fed policies under Democratic leadership. The Trump administration’s 2025 crypto agenda, including a national Bitcoin stockpile, amplifies this shift. Critics, including figures like Senator Elizabeth Warren, argue that loosening oversight risks financial instability and consumer harm, especially if banks engage with volatile sectors like crypto without robust checks. They view reputational risk as a tool to enforce ethical banking practices.
Despite the change, some banks may remain hesitant to serve crypto firms due to lingering compliance costs, AML/KYC requirements, and market volatility, creating friction with crypto firms seeking banking access. Crypto firms, backed by favorable regulatory shifts, are pressing for integration into traditional finance, but their rapid growth and regulatory gaps fuel skepticism among conservative bankers.
Younger, tech-savvy consumers and investors support easier banking for crypto, viewing it as progress toward financial modernization. Others, wary of crypto scams and volatility, fear that reduced oversight could expose the financial system to fraud or instability, eroding trust in banks. The removal of reputational risk from Federal Reserve exams clarifies and focuses regulatory oversight, potentially unlocking banking access for crypto and other high-risk sectors.
However, it risks overlooking non-financial factors that can destabilize banks and deepens divides between innovation advocates and risk-averse stakeholders. The long-term impact depends on how banks balance internal risk management with new opportunities and whether regulators can address emerging risks without reputational risk as a tool. The decision reflects a broader shift toward pro-crypto, deregulation-friendly policies in 2025, but tensions between innovation and stability persist.