OCC Says Reputation Risk No Biggie for Banks, But Trust Still Underpins B2B

All the digital innovation in the world doesn’t change the fact that trust, transparency and perceived risk ultimately form the backbone of B2B payments.

Still, in a move that could recalibrate how banks assess risk, the Office of the Comptroller of the Currency (OCC) announced Thursday (March 20) that it will no longer examine financial institutions for reputation risk. The OCC, which regulates and supervises national banks and federal savings associations, is stripping references to “reputation risk” from its Comptroller’s Handbook and associated guidance materials.

The decision, it says, is intended to clarify its regulatory focus on quantifiable risk categories. But in the high-stakes, interdependent world of B2B payments, reputation is far from irrelevant. In fact, given today’s uncertain operating environment, it’s arguably more critical than ever.

While regulators may no longer scrutinize a bank’s reputation per se, the real world of B2B commerce doesn’t have that luxury. Vendor selection, partnership decisions and even cross-border settlement strategies are still deeply influenced by how counterparties perceive one another.

After all, reputational risk hasn’t disappeared. It has just migrated from the regulator’s playbook to the front lines of business operations.

See also: What Treasurers Can Learn From How Central Banks Approach Risk

Trust Is the Currency in B2B Payments

The modern B2B payments ecosystem spanning application programming interfaces (APIs), embedded finance, real-time settlement and even stablecoin rails depends on trust as much as it does on technology. That trust is constructed not only through regulatory compliance but also through transparency, performance and consistent delivery.

Payment structures, ultimately, are only as strong as the perceived trust between participants.

“The digital front doors of most businesses are not very secure,” Prove Identity CEO Rodger Desai told PYMNTS last spring. The solution is that “these things have to be signed — because by signing it, you can authenticate the vendor or counterparty and make sure it’s someone you trust.”

Digital B2B payment innovation and trust can go both ways. PYMNTS Intelligence from the “B2B and Digital Payments Tracker® Series” found in February that in the most recent full year, 86% of general contractors reported receiving payments more promptly when developers employed digital payment methods. This shift not only improved cash flow but also fostered stronger relationships between developers and contractors.

Procurement teams can regularly factor in vendor history, client testimonials, executive behavior and media coverage, all of which are non-regulatory variables, when choosing partners.

For many corporates, especially in industries like healthcare and energy, a tarnished payments partner can trigger more than inconvenience; it can invite scrutiny from customers, investors and even the U.S. Congress.

Reputation takes on an added layer of complexity in cross-border payments, where regulatory regimes, political climates and enforcement standards vary widely. When dealing with international partners, businesses can often rely on brand reputation and third-party assurances as proxies for due diligence.

Read more: Bad B2B Payments Are a Sales Problem With an Obvious Fix

Technology Amplifies, Not Replaces, Reputation

In an ironic twist in the evolution of payments, as systems become more frictionless, businesses are applying more — not less — human judgment in evaluating partners.

Businesses want to know: Are they committed to ethical AI use? Are they investing in fraud prevention? What happens when there’s a data breach?

“The payments modernization winners will be the ones that can rapidly adjust and evolve to meet the needs of their customers,” Boost Payment Solutions Chief Operating Officer Illya Shell told PYMNTS.  “The inflexibility of traditional systems and platforms have prevented lots of companies from moving forward and keeping up with the changing dynamics of the large B2B buyer-supplier relationships.”

At the same time, the March edition of The 2025 Certainty Project found that mid-market firms are responding to uncertainty by negotiating with their suppliers, an option named by 65% of CFOs, and one where trust plays a crucial role.

The OCC’s move may relieve banks of some regulatory overhead, but it doesn’t erase the reputational calculus embedded in B2B transactions. In fact, by removing reputational oversight, the OCC may be increasing the pressure on businesses to do that work themselves.

This decentralization of reputational risk management places more responsibility — and more liability — on treasurers, CFOs and procurement officers. They are now the reputational stewards, even if regulators are stepping aside. That’s because, in B2B payments, reputation isn’t a footnote. It’s a foundation. And whether or not the OCC tracks it, the market certainly does.

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