Public Comment | American Trade

Request for Public Comments Regarding Prohibition on Use of Reputation Risk by Regulators

Jeff Schlagenhauf December 29, 2025

America First Policy Institute (AFPI) is pleased to submit its comments on the Federal Deposit Insurance Corporation’s (FDIC) and Office of Comptroller of the Currency (OCC), collectively referred to here as “the agencies,” proposed rule that would prohibit the use of reputation risk from their supervisory programs. AFPI supports the agencies proposed rule as it will ensure that regulators are prohibited from pressuring financial institutions to deny or terminate banking privileges for political, religious, or other non-pecuniary reasons. Accordingly, removing reputation risk will strengthen the safety and soundness of the financial system by protecting financial institutions and their customers from regulatory overreach.

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