C. Michelle Chen, H. Rodgin Cohen and Charles C. Gray

Sullivan & Cromwell Discusses Proposed FDIC and OCC Rules to Prohibit Regulators’ Use of Reputation Risk

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On October 7, 2025, the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency (the “agencies”) jointly issued a notice of proposed rulemaking (“NPR”)[1] that would codify the removal of reputation risk from the agencies’ …