View or download a PDF of the letter here.
Banking regulators have long considered the reputational risks posed by a depository institution’s activities like: abuses of their own customers in violation to consumer protection laws, persistent failures to protect consumers from predatory practices, failure to maintain adequate enforcement of anti-money laundering and sanctions laws, and dangerous entanglements with risky business partners. AFREF opposes the proposed rule which would prohibit examiners from considering reputation risk, as the proposal 1) fails to justify any of its assertions that supervision of reputation risk is ineffective or abusive, 2) contains confusing definitions and requirements that would be impossible to enforce, and 3) fails to consider any costs associated with the proposal.