Fed, OCC and FDIC Strip 'Reputation Risk' From 15 Interagency Guidance Documents

The Federal Reserve, the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation on Tuesday jointly reissued 15 interagency supervisory documents with every reference to "reputation risk" stripped out — the latest piece of a methodical Trump-era dismantling of the supervisory rubric that crypto firms and fintechs have for three years called the operating mechanism of "Operation Choke Point 2.0."

The reissued documents, listed in OCC Bulletin 2026-23, span 27 years of guidance — from a 1997 statement on loan participations and 2001 subprime-lending guidance through the 2024 statement on elder financial exploitation.

The action complements the OCC and FDIC's April final rule codifying the elimination of reputation risk, published in the Federal Register on April 10 and effective Friday, and the Federal Reserve's separate February 23 proposal to codify the same removal in its own supervisory program. The OCC stopped examining banks for reputation risk on March 20, 2025; the Fed followed on June 23, 2025.

For US-listed firms whose business sits closest to the banking perimeter, the stakes are concrete. Public companies now hold $85.5 billion in bitcoin across 175 reporting entities, led by Strategy's $56.7 billion position, CoinGecko's public-treasury tracker shows. USDT and USDC together account for roughly 11% of the $2.41 trillion crypto market cap, per CoinGecko global data — a wedge of the industry whose business model depends entirely on commercial-bank settlement rails.

"We have heard of troubling cases of debanking — where supervisors use concerns about reputation risk to pressure financial institutions to debank customers because of their political views, religious beliefs, or involvement in disfavored but lawful businesses," Federal Reserve Vice Chair for Supervision Michelle W. Bowman said in her February statement on the Fed proposal, language the agencies echoed in Tuesday's joint release.

Tied to the Executive Order — and to the Choke Point 2.0 Allegations

The codification arc traces directly to Executive Order 14331, "Guaranteeing Fair Banking for All Americans," signed in August 2025, which the OCC explicitly cited as the impetus for the April final rule. The order recited concerns that reputation risk had been used as a pretext to restrict law-abiding businesses' access to financial services.

Crypto firms have argued the same for years. The Blockchain Association, in a report compiling 30-plus debanking incidents submitted to the House Financial Services Committee in November 2025, framed Choke Point 2.0 as a Biden-era coordination among supervisors to deter lender relationships with digital-asset firms; the House Oversight Committee under Chairman James Comer opened a parallel probe.

Senator Elizabeth Warren — long viewed by the crypto industry as the architect of the prior posture — publicly acknowledged in early 2025 that debanking was a real problem, though her May 2026 letter challenging nine OCC trust-bank charters granted to Ripple, Circle, Paxos, BitGo, Coinbase and Fidelity Digital Assets drew immediate "Choke Point 3.0" pushback.

The Custodia Asterisk

The supervisory-text rewrite does not, on its own, hand every crypto institution a banking relationship it has been denied. Wyoming-chartered Custodia Bank, led by Caitlin Long, has litigated against the Federal Reserve since 2022 over the denial of a master account it first applied for in October 2020.

For bank compliance teams currently declining or limiting crypto-firm relationships, the practical change is the disappearance of an interagency text hook.

Decisions to terminate or withhold accounts now must rest on identified credit, market, liquidity, BSA/AML, operational or consumer-compliance risk rather than on a residual category that, in Bowman's words, lacked clarity and a clear remediation path.