Federal banking agencies are fundamentally recalibrating their supervisory approach. There is a concerted move away from process-oriented examinations and subjective factors (like reputation risk) toward a targeted focus on identifying and remediating material financial risks. This includes updated examination ratings that prevent non-financial weaknesses from disproportionately driving downgrades. For banks, this should translate to more efficient, risk-focused exams.
What you should do: Proactively review your risk management frameworks to ensure they clearly identify, measure, and control core financial risks. Document the objective, risk-based grounds for significant business decisions, especially those related to account openings or closures.
Source: Banking Regulation Themes To Anticipate In 2026 – Law360.pdf