Senate Reputational Risk Elimination

Published on: Mar 11, 2025

On Mar. 6, Senate bill to curtail weaponization of banking agencies.

  • Senate introduced bill S 875, Financial integrity and regulation management (FIRM) Act, end ability for regulators to use reputational risk as component of supervision.
  • Published one-page fact sheet on legislation, reported on trade association support.
  • Bill Provisions
  • FIRM act defined reputational risk as potential that negative publicity or negative public opinion regarding depository institution business practices, whether true or not.
  • Also that will cause decline in confidence in institution/customer base, costly litigation, or revenue reductions or otherwise adversely impact the depository institution.
  • Act will eliminate all references to reputational risk as measure, consideration in supervision of regulated depository institutions to determine safety and soundness.
  • Will eliminate the federal banking agencies’ ability to promulgate new rules or guidance that use reputational risk to supervise or regulate depository institutions.
  • Require the federal banking agencies to report to Congress on their elimination of reputational risk as a component of the supervision of depository institutions.
  • Legislation is narrowly tailored so that removal of this subjective factor does not affect quantitative supervisory measures (e.g. concentration risk, liquidity risk, etc.).
  • Legislative History
  • On Mar. 6, 2025, bill introduced in Senate, referred to banking, housing, urban affairs.
Regulators
Senate
Entity Types
Bank; BHC; IHC
Reference
PR, Bill S.875, 3/6/2025
Functions
Compliance; Exams; Financial; Legal; Reporting; Risk; Treasury
Countries
United States of America
Category
Central Government
State
N/A
Products
Banking
Rule Type
Proposed
Regions
Am
Rule Date
Mar 6, 2025
Effective Date
Mar 6, 2025
Rule ID
246214
Linked to
N/A
Reg. Last Update
Mar 6, 2025
Report Section
US Banking