Overview

• The OCC has already removed “reputational risk” references from its handbooks, and the FDIC plans rulemaking to prohibit examiners from using such criteria after the Federal Reserve dropped it in June.
• The executive order mandates regulators to identify institutions that engaged in politicized debanking and take remedial actions within 120 days, and to strip reputational-risk language from rules and guidance within 180 days.
• The SBA is tasked with notifying lenders to identify and offer reinstatement to customers denied services due to political or religious beliefs by December 5, 2025.
• Banks and legal advisers warn the order’s broad language creates legal uncertainty and could trigger extensive historical account reviews and compliance burdens.
• Tennessee’s new anti-debanking law covering banking and insurance underscores growing state-federal overlaps and strengthens calls for Congress to reform AML and BSA frameworks.