The Federal Reserve has directed its supervisors to eliminate reputational risk as a standalone factor in bank examination programmes, shifting scrutiny instead to concrete financial metrics.
The Fed’s decision, announced on 23 June 2025, reforms supervisory frameworks by removing all references to reputational risk from examination manuals and related materials. This places greater emphasis on tangible financial exposures—credit, liquidity, market, operational and legal risks—mirroring the stance already adopted by the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation.
In its official statement, the Fed clarified that examiners will undergo training to uniformly implement this adjustment across banks under its oversight and to ensure alignment with other federal regulators. While reputational considerations will no longer guide supervisory assessments, banks are still expected to maintain strong internal risk-management mechanisms and may incorporate reputational factors in their own decision-making processes.
Market analysts say the move addresses long-standing industry concerns. Bankers had argued that the concept of reputational risk was too subjective—allowing for arbitrary judgements over lawful, financially sound activities—potentially chilling innovation or prompting unwarranted corrective actions. The Fed’s pivot to more specific financial criteria is seen as a bid to enhance transparency and reduce regulatory ambiguity.
Nevertheless, the Fed insists that the policy adjustment does not weaken its commitment to safety and soundness. It affirmed that the shift is procedural—about refining supervisory focus—not a relaxation of oversight standards. The Board emphasised that its expectations for robust risk governance remain unchanged.
In parallel, this recalibration may affect emerging sectors like cryptocurrency. Observers suggest the de-emphasis on reputational risk could lower compliance barriers for banks seeking to engage in digital asset services. However, the Fed has made no direct reference to crypto in its announcement. It remains unclear whether other regulators, such as the Securities and Exchange Commission, will follow suit in adopting similar adjustments.
Critics caution that removing reputational risk from the supervisory toolkit may overlook the broader implications of public trust. While financial measures remain central, reputational damage—stemming from scandals, data breaches or environmental and social controversies—can lead to litigation, customer attrition and systemic instability, even if immediate financial indicators appear stable. Some analysts argue a comprehensive risk approach should balance quantifiable metrics with qualitative reputational insights.
The Fed’s timeline for implementation spans several months. Examiners must be retrained and supervisory documents updated across all Reserve Banks. Coordination with fellow regulators remains key to maintaining consistent supervisory practices nationwide.
As the Fed charts its new supervisory trajectory, attention now turns to how institutions recalibrate. Will banks reduce spend on communications and brand monitoring? Or will they independently sustain reputational frameworks to safeguard stakeholder confidence? The answer may shape the future of reputational governance in the financial sector.