Prohibition on the Use of Reputation Risk

Official abstract: On October 21, 2025, the Board issued its Notice of Proposed Rulemaking to codify the elimination of reputation risk from its supervisory framework. This change aligns with Executive Order 14331, "Guaranteeing Fair Banking for All Americans." Effective September 25, 2025, the NCUA ceased examining for reputation risk. This final rule affirms that the agency will not consider reputation risk--whether alone or in combination with other factors--in supervisory determinations or other decisions, nor will it take adverse actions on that basis.