The Federal Reserve, the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation on Tuesday jointly reissued 15 interagency supervisory documents with every reference to "reputation risk" stripped out — the latest piece of a methodical Trump-era dismantling of the supervisory rubric that crypto firms and fintechs have for three years called the operating mechanism of "Operation Choke Point 2.0."
The reissued documents, listed in OCC Bulletin 2026-23, span 27 years of guidance — from a 1997 statement on loan participations and 2001 subprime-lending guidance through the 2024 statement on elder financial exploitation.
The action complements the OCC and FDIC's April final rule codifying the elimination of reputation risk, published in the Federal Register on April 10 and effective Friday, and the Federal Reserve's separate February 23 proposal to codify the same removal in its own supervisory program. The OCC stopped examining banks for reputation risk on March 20, 2025; the Fed followed on June 23, 2025.
For US-listed firms whose business sits closest to the banking perimeter, the stakes are concrete. Public companies now hold $85.5 billion in bitcoin across 175 reporting entities, led by Strategy's $56.7 billion position, CoinGecko's public-treasury tracker shows. USDT and USDC together account for roughly 11% of the $2.41 trillion crypto market cap, per CoinGecko global data — a wedge of the industry whose business model depends entirely on commercial-bank settlement rails.
