S 875
· 119th Congress
· Finance and Financial Sector
FIRM Act
Sponsor
Latest action
Placed on Senate Legislative Calendar under General Orders. Calendar No. 32.
Action timeline
Every recorded action on this bill, newest first. Stage badges color-code the legislative path.
Mar 18, 2025
committee
Committee on Banking, Housing, and Urban Affairs. Reported by Senator Scott SC, under authority of the order of the Senate of 03/14/2025 with an amendment in the nature of a substitute. Without written report.
Banking, Housing, and Urban Affairs Committee
Mar 18, 2025
other
Placed on Senate Legislative Calendar under General Orders. Calendar No. 32.
Mar 13, 2025
committee
Committee on Banking, Housing, and Urban Affairs. Ordered to be reported with an amendment in the nature of a substitute favorably.
Banking, Housing, and Urban Affairs Committee
Mar 06, 2025
introduced
Introduced in Senate
Mar 06, 2025
introduced
Read twice and referred to the Committee on Banking, Housing, and Urban Affairs.
Banking, Housing, and Urban Affairs Committee
Text versions
Each stage of the bill — official text published by GPO. Click any format to read on congress.gov / govinfo.
CRS summaries
Plain-English summaries written by the Congressional Research Service — neutral, nonpartisan staff who summarize bills as they advance through stages. The authoritative description of what each version of the bill does.
00
Introduced in Senate
Mar 06, 2025
Financial Integrity and Regulation Management Act or the FIRM Act
This bill prohibits the consideration of reputational risk by federal banking agencies when regulating, examining, or supervising a depository institution or credit union. The bill defines reputational risk as the potential for negative publicity or public attention to decrease confidence in the institution, lead to litigation, reduce revenues, or result in other adverse impacts to the institution.
Agencies must report on the implementation of this bill.
via Congressional Research Service · published through congress.gov
Changelog
ⓘ
How a bill moves through Congress. Each stage produces a new official text. The diff between them shows what changed at that step.
ih / is — Introduced in House / Senate. First filed version.rfh / rfs — Referred to a committee for review.rh / rs — Reported back by the committee to the floor (often with amendments — this is where most language changes happen).pcs / pch — Placed on Calendar for floor consideration.eh / es — Engrossed. Passed by the originating chamber. Text is now what was actually voted on.rdh / rds — Received by the other chamber.eah / eas — Engrossed Amendment. The other chamber passed an amended version.ath / ats — Agreed to. Both chambers settled on the same text.enr — Enrolled. Final reconciled text, sent to the President.pl — Public Law. Signed by the President. It's now law.pp — Public Print. Official printing post-enactment.
Most bills die before eh/es. Going from pcs → enr is the full path through both chambers.
ⓘ
How a bill moves through Congress. Each stage produces a new official text. The diff between them shows what changed at that step.
ih/is— Introduced in House / Senate. First filed version.rfh/rfs— Referred to a committee for review.rh/rs— Reported back by the committee to the floor (often with amendments — this is where most language changes happen).pcs/pch— Placed on Calendar for floor consideration.eh/es— Engrossed. Passed by the originating chamber. Text is now what was actually voted on.rdh/rds— Received by the other chamber.eah/eas— Engrossed Amendment. The other chamber passed an amended version.ath/ats— Agreed to. Both chambers settled on the same text.enr— Enrolled. Final reconciled text, sent to the President.pl— Public Law. Signed by the President. It's now law.pp— Public Print. Official printing post-enactment.
Most bills die before eh/es. Going from pcs → enr is the full path through both chambers.
Line-level diff between text versions of this bill — what actually changed at each legislative stage.
+267
−8
40 unchanged
--- Introduced (Senate)
+++ Reported (Senate)
@@ -1,8 +1,9 @@
[From the U.S. Government Publishing Office]
-[S. 875 Introduced in Senate (IS)]
+[S. 875 Reported in Senate (RS)]
<DOC>
+Calendar No. 32
119th CONGRESS
1st Session
S. 875
@@ -23,6 +24,13 @@
following bill; which was read twice and referred to the Committee on
Banking, Housing, and Urban Affairs
+March 18, 2025
+
+Reported under authority of the order of the Senate of March 14, 2025,
+by Mr. Scott of South Carolina, with an amendment
+[Strike out all after the enacting clause and insert the part printed
+in italic]
+
_______________________________________________________________________
A BILL
@@ -34,16 +42,142 @@
Be it enacted by the Senate and House of Representatives of the
United States of America in Congress assembled,
+<DELETED>SECTION 1. SHORT TITLE.</DELETED>
+
+<DELETED> This Act may be cited as the ``Financial Integrity and
+Regulation Management Act'' or the ``FIRM Act''.</DELETED>
+
+<DELETED>SEC. 2. FINDINGS; PURPOSES.</DELETED>
+
+<DELETED> (a) Findings.--Congress finds that--</DELETED>
+<DELETED> (1) the primary objective of financial regulation
+and supervision by the Federal banking agencies is to promote
+safety and soundness of depository institutions;</DELETED>
+<DELETED> (2) all federally legal businesses and law-abiding
+citizens regardless of political ideology should have equal
+opportunity to obtain financial services and should not face
+unlawful discrimination in obtaining such services;</DELETED>
+<DELETED> (3) financial service providers are private
+entities entitled to provide services to whichever customers
+they so choose, provided that those decisions do not violate
+the law;</DELETED>
+<DELETED> (4) financial service providers should strive to
+ensure that all business decisions are based on factors free
+from unlawful prejudice or political influence;</DELETED>
+<DELETED> (5) the use of reputational risk in supervisory
+frameworks encourages Federal banking agencies to regulate
+depository institutions based on the subjective view of
+negative publicity and provides cover for the agencies to
+implement their own political agenda unrelated to the safety
+and soundness of a depository institution;</DELETED>
+<DELETED> (6) Federal banking agencies have in fact used
+reputational risk to limit access of federally legal businesses
+and law-abiding citizens to financial services 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'';</DELETED>
+<DELETED> (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.</DELETED>
+
+<DELETED>SEC. 3. DEFINITIONS.</DELETED>
+
+<DELETED> In this Act:</DELETED>
+<DELETED> (1) Depository institution.--The term ``depository
+institution''--</DELETED>
+<DELETED> (A) has the meaning given the term in
+section 3 of the Federal Deposit Insurance Act (12
+U.S.C. 1813); and</DELETED>
+<DELETED> (B) includes an insured credit
+union.</DELETED>
+<DELETED> (2) Federal banking agency.--The term ``Federal
+banking agency''--</DELETED>
+<DELETED> (A) has the meaning given the term in
+section 3 of the Federal Deposit Insurance Act (12
+U.S.C. 1813); and</DELETED>
+<DELETED> (B) includes--</DELETED>
+<DELETED> (i) the National Credit Union
+Administration; and</DELETED>
+<DELETED> (ii) the Bureau of Consumer
+Financial Protection.</DELETED>
+<DELETED> (3) Insured credit union.--The term ``insured
+credit union'' has the meaning given the term in section 101 of
+the Federal Credit Union Act (12 U.S.C. 1752).</DELETED>
+<DELETED> (4) Reputational risk.--The term ``reputational
+risk'' means the potential that negative 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.</DELETED>
+
+<DELETED>SEC. 4. REMOVAL OF REPUTATIONAL RISK AS A CONSIDERATION IN THE
+SUPERVISION OF DEPOSITORY INSTITUTIONS.</DELETED>
+
+<DELETED> 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 supervision of depository
+institutions such that reputational risk, or any term substantially
+similar, is no longer taken into consideration by the Federal banking
+agency when examining and supervising a depository
+institution.</DELETED>
+
+<DELETED>SEC. 5. PROHIBITION.</DELETED>
+
+<DELETED> No Federal banking agency may engage in any activity
+concerning or related to the regulation, supervision, or examination,
+of the reputational risk, or any term substantially similar, or the
+management thereof, of a depository institution, including--</DELETED>
+<DELETED> (1) establishing any rule, regulation,
+requirement, standard, or supervisory expectation concerning or
+related to the reputational risk, or any term substantially
+similar, or the management thereof, of a depository institution
+whether binding or not;</DELETED>
+<DELETED> (2) conducting any examination, assessment, data
+collection, or other supervisory exercise concerning or related
+to reputational risk, or any term substantially similar, or the
+management thereof, of a depository institution;</DELETED>
+<DELETED> (3) issuing any examination finding, supervisory
+criticism, or other supervisory or examination communication
+concerning or related to reputational risk, or any term
+substantially similar, or the management thereof, of a
+depository institution;</DELETED>
+<DELETED> (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 management thereof, of a
+depository institution; and</DELETED>
+<DELETED> (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.</DELETED>
+
+<DELETED>SEC. 6. REPORTS.</DELETED>
+
+<DELETED> 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--
+</DELETED>
+<DELETED> (1) confirms implementation of this Act;
+and</DELETED>
+<DELETED> (2) describes any changes made to internal
+policies as a result of this Act.</DELETED>
+
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--
+SEC. 2. FINDINGS.
+
+Congress finds that--
(1) the primary objective of financial regulation and
-supervision by the Federal banking agencies is to promote
+supervision by the Federal banking agencies is to promote the
safety and soundness of depository institutions;
(2) all federally legal businesses and law-abiding citizens
regardless of political ideology should have equal opportunity
@@ -117,7 +251,7 @@
No Federal banking agency may engage in any activity concerning or
related to the regulation, supervision, or examination, of the
reputational risk, or any term substantially similar, or the management
-thereof, of a depository institution, including--
+thereof, of a depository institution, including by--
(1) establishing any rule, regulation, requirement,
standard, or supervisory expectation concerning or related to
the reputational risk, or any term substantially similar, or
@@ -143,7 +277,112 @@
similar, or the management thereof, of a depository
institution.
-SEC. 6. REPORTS.
+SEC. 6. TAKING ACCOUNT OF INSTITUTIONS WITH LOW OPERATIONAL RISK.
+
+(a) Tailoring Regulation to Business Model and Risk.--
+(1) Definitions.--In this subsection--
+(A) the term ``Federal financial institutions
+regulatory agency'' means the Office of the Comptroller
+of the Currency, the Board of Governors of the Federal
+Reserve System, the Federal Deposit Insurance
+Corporation, the National Credit Union Administration,
+and the Bureau of Consumer Financial Protection; and
+(B) the term ``regulatory action''--
+(i) means any proposed, interim, or final
+rule or regulation; and
+(ii) does not include any action taken by a
+Federal financial institutions regulatory
+agency that is solely applicable to an
+individual institution, including an
+enforcement action or order.
+(2) Consideration and tailoring.--For any regulatory action
+occurring after the date of enactment of this Act, each Federal
+financial institutions regulatory agency shall--
+(A) take into consideration the risk profile and
+business models of each type of institution or class of
+institutions subject to the regulatory action; and
+(B) tailor the regulatory action applicable to an
+institution, or type of institution, in a manner that
+limits the regulatory impact, including cost, human
+resource allocation, and other burdens, on the
+institution or type of institution as is appropriate
+for the risk profile and business model involved.
+(3) Factors to consider.--In carrying out the requirements
+of paragraph (2), each Federal financial institutions
+regulatory agency shall consider--
+(A) the aggregate impact of all applicable
+regulatory actions on the ability of institutions to
+flexibly serve their customers and local markets after
+the date of enactment of this Act;
+(B) the potential impact that efforts to implement
+the applicable regulatory action and third-party
+service provider actions may work to undercut efforts
+to tailor the regulatory action described in paragraph
+(2)(B); and
+(C) the statutory provision authorizing the
+applicable regulatory action, the congressional intent
+with respect to the statutory provision, and the
+underlying policy objectives of the regulatory action.
+(4) Notice of proposed and final rulemaking.--Each Federal
+financial institutions regulatory agency shall disclose and
+document in every notice of proposed rulemaking and in every
+final rulemaking for a regulatory action how the agency has
+applied paragraphs (2) and (3).
+(5) Limited look-back application.--
+(A) In general.--Each Federal financial
+institutions regulatory agency shall--
+(i) conduct a review of all regulations
+issued in final form pursuant to statutes
+enacted during the period beginning on the date
+that is 7 years before the date on which this
+Act is introduced in the Senate and ending on
+the date of enactment of this Act; and
+(ii) apply the requirements of this
+subsection to the regulations described in
+clause (i).
+(B) Revision.--Any regulation revised under
+subparagraph (A) shall be revised not later than 3
+years after the date of enactment of this Act.
+(6) Reports to congress.--Not later than 1 year after the
+date of enactment of this Act, and annually thereafter, each
+Federal financial institutions regulatory 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 on the specific actions taken to
+tailor the regulatory actions of the Federal financial
+institutions regulatory agency pursuant to the requirements of
+this subsection.
+(b) Short-form Call Reports for All Banks Eligible for the
+Community Bank Leverage Ratio.--The appropriate Federal banking
+agencies, as defined in section 3 of the Federal Deposit Insurance Act
+(12 U.S.C. 1813), shall promulgate regulations establishing a reduced
+reporting requirement for all banks eligible for the Community Bank
+Leverage Ratio, as defined in section 201(a) of the Economic Growth,
+Regulatory Relief, and Consumer Protection Act (12 U.S.C. 5371 note),
+when making the first and third report of condition of a year, as
+required by section 7(a) of the Federal Deposit Insurance Act (12
+U.S.C. 1817(a)).
+(c) Report to Congress on Modernization of Supervision.--Not later
+than 18 months after the date of enactment of this Act, the appropriate
+Federal banking agencies, as defined in section 3 of the Federal
+Deposit Insurance Act (12 U.S.C. 1813), in consultation with State bank
+supervisors, 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 on the modernization of bank
+supervision, including the following factors:
+(1) Changing bank business models.
+(2) Examiner workforce and training.
+(3) The structure of supervisory activities within banking
+agencies.
+(4) Improving bank-supervisor communication and
+collaboration.
+(5) The use of supervisory technology.
+(6) Supervisory factors uniquely applicable to community
+banks.
+(7) Changes in statutes necessary to achieve more effective
+supervision.
+
+SEC. 7. 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,
@@ -152,4 +391,24 @@
(1) confirms implementation of this Act; and
(2) describes any changes made to internal policies as a
result of this Act.
-<all>
+Calendar No. 32
+
+119th CONGRESS
+
+1st Session
+
+S. 875
+
+_______________________________________________________________________
+
+A BILL
+
+To curtail the political weaponization of Federal banking agencies by
+eliminating reputational risk as a component of the supervision of
+depository institutions.
+
+_______________________________________________________________________
+
+March 18, 2025
+
+Reported with an amendment
Lobbying activity
Organizations whose LDA filings reference this bill, ranked by filing count. Position not disclosed — LDA does not require lobbyists to report support / oppose / monitor. Bill-number references can be stale (lobbyists sometimes copy text year-over-year), so verify against the filing description.
BLOCKCHAIN ASSOCIATION
BANFIN
6
filings · 2025 Q3
5
filings · 2026 Q3
5
filings · 2026 Q3
5
filings · 2026 Q3
5
filings · 2026 Q3
5
filings · 2026 Q3
5
filings · 2026 Q3
4
filings · 2026 Q3
4
filings · 2025 Q3
SOLANA POLICY INSTITUTE
BANFIN
3
filings · 2025 Q3
via Senate LDA · self-reported quarterly. Filing count = filings mentioning this bill (no position required), not money spent on it. Click a client to see all bills they've filed on.
Cosponsors (12)
Members who signed on to support this bill.