September 2025

REGULATORY DEVELOPMENTS

Executive Order Directing Banking Regulators to Remove Use of Reputational Risk from Examining Process

On August 7 President Trump issued an executive order (“Guaranteeing Fair Banking for All Americans”). Among other points, the order makes the claim that banking regulators have at times used influence over regulated banks to direct and/or encourage “politized or unlawful debanking activities” by directing banks to minimize involvement with certain organizations and individuals “based on factors other than individualized, objective, risk-based standards.”

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