Impacted Domains: Reputation, Financial
Impacted Industries: All Industries
Date: October 15, 2025

The OCC and FDIC have proposed eliminating reputation risk as a factor in supervisory actions — narrowing evaluations to financial and legal performance only (JD Supra, Oct 7, 2025).

So What:
Removing reputation considerations from regulatory oversight may cause supervisors to overlook early indicators of governance failures, cultural issues, or unethical practices. This shift places greater responsibility on organizations to self-monitor trust, culture, and public-perception risks — areas that can rapidly impact financial and operational performance if ignored.

Risk Value:
$5M–$80M for mid-size and large organizations, depending on governance maturity and stakeholder exposure.

Mitigation Cost:
$50K–$300K for small/midsize firms for MRA updates, documentation, and targeted training.

What to Do:

• Automate continuous compliance monitoring to align with evolving supervisory standards and expectations.

• Use data-driven analytics to prioritize material financial and legal risks while maintaining transparency across unregulated but high-impact domains.

• Implement dynamic training on updated MRA frameworks, oversight protocols, and internal governance duties.

• Equip leadership with real-time dashboards tracking regulatory shifts and organization-wide risk exposure.

Risk AIQ Score: 8

🔗 JD Supra — OCC and FDIC Propose Standardizing Supervisory Practices