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The FDIC and OCC final rule implements President Donald Trump's "Guaranteeing Fair Banking For All Americans" "By focusing on reputation risk, supervisors attempt to understand and anticipate public opinion and then to attempt to directly connect this public opinion regarding issues and events to an institution's condition in ways that have proven nearly impossible to assess or quantify with accuracy," the Caroline Swett, a partner at Debevoise and Plimpton, says the final rule acknowledges that public perception has a role to play in bank examination a fact best illustrated by bank runs, where customers all attempt to withdraw their deposits at the same time out of fear that the institution is insolvent, a notoriously self-fulfilling prophecy

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