I 
119TH CONGRESS 
1ST SESSION H. R. 2702 
To curtail the political weaponization of Federal banking agencies by elimi-
nating reputational risk as a component of the supervision of depository 
institutions. 
IN THE HOUSE OF REPRESENTATIVES 
APRIL 8, 2025 
Mr. BARR (for himself, Mr. TORRES of New York, Mrs. MCCLAIN, Mr. LUCAS, 
Mr. LOUDERMILK, Mr. ROSE, Mrs. WAGNER, Mr. STUTZMAN, Mr. 
TIMMONS, Mr. FITZGERALD, Mr. MOORE
of North Carolina, Mr. 
MESSMER, Mr. OGLES, Mr. DOWNING, Mr. SESSIONS, Mr. LAMALFA, 
and Mr. GROTHMAN) introduced the following bill; which was referred to 
the Committee on Financial Services 
A BILL 
To curtail the political weaponization of Federal banking 
agencies by eliminating reputational risk as a component 
of the supervision of depository institutions. 
Be it enacted by the Senate and House of Representa-
tives of the United States of America in Congress assembled, 
SECTION 1. SHORT TITLE. 
This Act may be cited as the ‘‘Financial Integrity and 
Regulation Management Act’’ or the ‘‘FIRM Act’’. 
SEC. 2. FINDINGS; PURPOSES. 
(a) FINDINGS.—Congress finds that— 
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(1) the primary objective of financial regulation 
and supervision by the Federal banking agencies is 
to promote safety and soundness of depository insti-
tutions; 
(2) all federally legal businesses and law-abid-
ing citizens regardless of political ideology should 
have equal opportunity to obtain financial services 
and should not face unlawful discrimination in ob-
taining such services; 
(3) financial service providers are private enti-
ties entitled to provide services to whichever cus-
tomers they so choose, provided that those decisions 
do not violate the law; 
(4) financial service providers should strive to 
ensure that all business decisions are based on fac-
tors free from unlawful prejudice or political influ-
ence; 
(5) the use of reputational risk in supervisory 
frameworks encourages Federal banking agencies to 
regulate depository institutions based on the subjec-
tive view of negative publicity and provides cover for 
the agencies to implement their own political agenda 
unrelated to the safety and soundness of a deposi-
tory institution; 
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(6) Federal banking agencies have in fact used 
reputational risk to limit access of federally legal 
businesses and law-abiding citizens to financial serv-
ices in 2018 when the Federal Deposit Insurance 
Corporation acknowledged that the agency used 
reputational risk reviews to limit access to financial 
services by certain industries, commonly known as 
‘‘Operation Choke Point’’; and 
(7) reputational risk does not appear in any 
statute and is an unnecessary and improper use of 
supervisory authority that does not contribute to the 
safety and soundness of the financial system. 
SEC. 3. DEFINITIONS. 
In this Act: 
(1) DEPOSITORY INSTITUTION.—The term ‘‘de-
pository institution’’— 
(A) has the meaning given the term in sec-
tion 3 of the Federal Deposit Insurance Act (12 
U.S.C. 1813); and 
(B) includes an insured credit union. 
(2) FEDERAL
BANKING
AGENCY.—The term 
‘‘Federal banking agency’’— 
(A) has the meaning given the term in sec-
tion 3 of the Federal Deposit Insurance Act (12 
U.S.C. 1813); and 
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(B) includes— 
(i) the National Credit Union Admin-
istration; and 
(ii) the Bureau of Consumer Financial 
Protection. 
(3) INSURED CREDIT UNION.—The term ‘‘in-
sured credit union’’ has the meaning given the term 
in section 101 of the Federal Credit Union Act (12 
U.S.C. 1752). 
(4) 
REPUTATIONAL
RISK.—The 
term 
‘‘reputational risk’’ means the potential that nega-
tive publicity or negative public opinion regarding an 
institution’s business practices, whether true or not, 
will cause a decline in confidence in the institution 
or a decline in the customer base, costly litigation, 
or revenue reductions or otherwise adversely impact 
the depository institution. 
SEC. 4. REMOVAL OF REPUTATIONAL RISK AS A CONSIDER-
ATION IN THE SUPERVISION OF DEPOSITORY 
INSTITUTIONS. 
Each Federal banking agency shall remove from any 
guidance, rule, examination manual, or similar document 
established by the agency any reference to reputational 
risk, or any term substantially similar, regarding the su-
pervision of depository institutions such that reputational 
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risk, or any term substantially similar, is no longer taken 
into consideration by the Federal banking agency when 
examining and supervising a depository institution. 
SEC. 5. PROHIBITION. 
No Federal banking agency may engage in any activ-
ity concerning or related to the regulation, supervision, or 
examination, of the reputational risk, or any term sub-
stantially similar, or the management thereof, of a deposi-
tory institution, including— 
(1) establishing any rule, regulation, require-
ment, standard, or supervisory expectation con-
cerning or related to the reputational risk, or any 
term substantially similar, or the management there-
of, of a depository institution whether binding or 
not; 
(2) conducting any examination, assessment, 
data collection, or other supervisory exercise con-
cerning or related to reputational risk, or any term 
substantially similar, or the management thereof, of 
a depository institution; 
(3) issuing any examination finding, supervisory 
criticism, or other supervisory or examination com-
munication concerning or related to reputational 
risk, or any term substantially similar, or the man-
agement thereof, of a depository institution; 
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(4) making any supervisory ratings decision or 
determination that is based, in whole or in part, on 
any matter concerning or related to reputational 
risk, or any term substantially similar, or the man-
agement thereof, of a depository institution; and 
(5) taking any formal or informal enforcement 
action that is based, in whole or in part, on any 
matter concerning or related to reputational risk, or 
any term substantially similar, or the management 
thereof, of a depository institution. 
SEC. 6. REPORTS. 
Not later than 180 days after the date of enactment 
of this Act, each Federal banking agency shall submit to 
the Committee on Banking, Housing, and Urban Affairs 
of the Senate and the Committee on Financial Services 
of the House of Representatives a report that— 
(1) confirms implementation of this Act; and 
(2) describes any changes made to internal poli-
cies as a result of this Act. 
Æ 
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