Placed on Senate Legislative Calendar under General Orders. Calendar No. 32.
The FIRM Act bars Federal banking agencies from considering “reputational risk” when supervising, examining, or taking enforcement actions against depository institutions, and requires agencies to remove the term from guidance and rules.
It also mandates tailored regulation based on institution risk profiles, a 7-year look-back and revision of recent regulations, short-form call reports for banks eligible for the Community Bank Leverage Ratio, and reports to Congress on implementation and modernization of supervision.
Narrow administrative focus improves prospects, but high ideological salience and opposition from regulatory/consumer groups make enactment uncertain absent broad bipartisan support.
How solid the drafting looks.
Left stresses AML, consumer protection and systemic-risk concerns
Left stresses AML, consumer protection and systemic-risk concerns
Likely skeptical of the bill overall.
While it contains targeted regulatory relief for community banks and calls for modernization, removing reputational risk from supervisory consideration could weaken agencies' ability to address illicit-finance and consumer harms tied to business relationships.
Mixed but cautiously receptive.
The bill's emphasis on tailoring rules and reducing unnecessary reporting aligns with efficiency goals, but outright banning consideration of reputational risk may unduly constrain supervisors' discretion to address complex, non-balance-sheet risks.
Favorable overall.
The bill addresses concerns about agency politicization—citing Operation Choke Point—by prohibiting subjective reputational-risk supervision and reducing burdens on community banks, aligning with deregulatory and free-market priorities.
Reached or meaningfully advanced
Reached or meaningfully advanced
Still ahead
Still ahead
Still ahead
Narrow administrative focus improves prospects, but high ideological salience and opposition from regulatory/consumer groups make enactment uncertain absent broad bipartisan support.
The bill has not accumulated any surfaced votes yet.
Left stresses AML, consumer protection and systemic-risk concerns
Narrow administrative focus improves prospects, but high ideological salience and opposition from regulatory/consumer groups make enactment…
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