Placed on the Union Calendar, Calendar No. 131.
The FIRM Act prohibits Federal banking agencies from using "reputational risk" (or similar terms) when supervising, examining, or taking enforcement actions against depository institutions. Agencies must remove references to reputational risk from guidance, rules, and manuals, and are banned from conducting related examinations, findings, ratings, or enforcement actions.
Progressives emphasize consumer protection and anti-discrimination risks.
Relative to its intended legislative type, this bill is a clear administrative directive that prohibits Federal banking agencies from considering or supervising 'reputational risk' with a defined exception and requires agencies to report on implementation within 180 days.
The FIRM Act prohibits Federal banking agencies from using "reputational risk" (or similar terms) when supervising, examining, or taking enforcement actions against depository institutions.
Agencies must remove references to reputational risk from guidance, rules, and manuals, and are banned from conducting related examinations, findings, ratings, or enforcement actions.
The bill excludes reputational concerns tied to unlawful transactions involving state sponsors of terrorism or designated foreign terrorist organizations, and requires agencies to report implementation actions to Congressional committees within 180 days.
Targeted deregulatory statute with partisan framing and limited compromise features faces significant Senate and executive hurdles.
Relative to its intended legislative type, this bill is a clear administrative directive that prohibits Federal banking agencies from considering or supervising 'reputational risk' with a defined exception and requires agencies to report on implementation within 180 days. It specifies mechanisms and actors, but leaves some operational and fiscal details unspecified.
Progressives emphasize consumer protection and anti-discrimination risks.
These are examples from the analysis, not a ranked list of the most-affected groups.
Progressives emphasize consumer protection and anti-discrimination risks.
Likely skeptical or opposed.
While the bill aims to limit political misuse of supervision, it also removes a subjective supervisory tool that Democrats and progressives often view as necessary to protect consumers, marginalized groups, and deter harmful industry practices.
Mixed.
Sees merit in reducing subjective or politicized supervisory practices, but worries a wholesale ban removes useful supervisory flexibility tied to safety and soundness.
Supportive.
Views the bill as a necessary check on regulatory activism and a way to prevent agencies from pressuring banks over political or cultural issues.
Reached or meaningfully advanced
Reached or meaningfully advanced
Still ahead
Still ahead
Still ahead
Targeted deregulatory statute with partisan framing and limited compromise features faces significant Senate and executive hurdles.
The bill has not accumulated any surfaced votes yet.
Progressives emphasize consumer protection and anti-discrimination risks.
Targeted deregulatory statute with partisan framing and limited compromise features faces significant Senate and executive hurdles.
Relative to its intended legislative type, this bill is a clear administrative directive that prohibits Federal banking agencies from considering or supervising 'reputational risk' with a defined exception and requires…
Go beyond the headline summary with full stakeholder mapping, legislative design analysis, passage barriers, and lens-by-lens tradeoff breakdowns.