Overview

• The Federal Reserve, OCC and FDIC have moved to strip references to reputational risk from supervisory materials and signaled additional rule updates in line with the executive order.
• The order sets deadlines that include SBA notices by Oct. 6, 2025, lender identification and reinstatement of affected customers by Dec. 5, 2025, and broader regulator reviews by Feb. 3, 2026.
• Banks including JPMorgan Chase and Bank of America state they do not close accounts for political or religious reasons and say they welcome clearer rules.
• A Reuters analysis of CFPB data shows 35 of 8,361 detailed account‑closure complaints since 2012 mention politics or religion, even as the White House and advocates allege broader problems.
• Anonymous bank executives allege earlier regulatory pressure tied to Operation Choke Point, and legal advisers expect heightened UDAP/UDAAP and ECOA scrutiny alongside new advocacy campaigns in the U.S. and Europe.