OCC Finds Debanking Practices at Nine Largest U.S. Banks

What Happened

The OCC reviewed JPMorgan Chase Bank, Bank of America, Citibank, Wells Fargo Bank, U.S. Bank, Capital One, PNC Bank, TD Bank, and BMO Bank. The review was conducted under President Donald Trump's Executive Order 14331, Guaranteeing Fair Banking for All Americans. The goal was to determine whether bank policies encouraged or otherwise influenced institutions to deny or limit access to financial services because of customers' political or religious beliefs or lawful business activities. The OCC found that broad reputation risk policies often lacked clear standards or objective, risk-based criteria. In some cases, decisions about which customers or industries to serve were influenced by considerations beyond traditional financial risk. The regulator also found that banks maintained public and nonpublic policies restricting certain industries. These included digital assets, oil and gas exploration, coal mining and coal-powered plants, firearms and ammunition manufacturing or distribution, detention facilities, and businesses involved in tobacco or e-cigarette products. The scope of the investigation was substantial. The OCC reviewed nearly 100,000 complaints and approximately 420,000 pages of bank documents. According to the agency, these policies disadvantaged certain customers and lawful businesses for reasons unrelated to objective financial risk.

Why This Is Trending Now

The October 14 report provides a closer look at how some of the nation's largest banks approached customers and industries considered controversial. Comptroller of the Currency Jonathan V. Gould addressed the findings directly, stating: "Americans should have access to financial services regardless of their beliefs, affiliations, or political views." His remarks reflect the OCC's position that banking decisions should be grounded in financial risk rather than political, religious, or social considerations. The agency has already taken steps in that direction. It removed reputation risk from bank examinations and clarified how improper debanking may affect licensing decisions and Community Reinvestment Act (CRA) performance evaluations. Although some large banks have made efforts to rein in these practices, Gould indicated that those changes may not be enough. The OCC is now evaluating whether additional adjustments to the regulatory and supervisory framework are needed to prevent similar practices from recurring. The report follows preliminary findings the OCC released in December 2025 and is part of a broader effort to examine fair access to financial services.

Why Businesses Should Pay Attention

For businesses, banking access underpins everyday operations, from managing payments and payroll to obtaining financing and maintaining customer relationships. That makes the OCC's findings particularly relevant to companies operating in industries that have historically faced banking restrictions. Digital-asset firms, energy companies, and other lawful businesses identified in the report have encountered policies that limited access to financial services without clearly defined, objective risk standards. Consider a company operating legally in an industry that a bank considers controversial. Even if the business meets ordinary financial requirements, a broad reputation risk policy could create additional obstacles to opening an account or securing financing. This is the central concern highlighted by the OCC's review. For businesses that have been debanked or experienced unexplained account restrictions, the report provides additional context for questioning how those decisions were made. It also reinforces the importance of understanding a bank's stated risk criteria and monitoring how federal oversight may change.

Practical Considerations

Businesses concerned about banking restrictions should start by keeping clear records. Document any account denial, restriction, or closure, including relevant dates, the bank's explanation, and any written policies referenced in the decision. If the reasoning is unclear, ask what objective, risk-based criteria were used. It's also worth reviewing existing banking relationships, particularly for companies operating in industries identified in the OCC report. Understanding a financial institution's policies before a problem arises may help businesses identify potential risks. Regulatory developments deserve attention as well. The OCC continues to evaluate potential supervisory and regulatory changes intended to prevent discriminatory debanking practices while promoting objective, risk-based banking decisions. For now, however, an important distinction remains: The report does not require a bank to open or restore an account simply because a business disputes a previous decision. Banks can still make legitimate, risk-based decisions about the customers they serve. The OCC's concern is whether those decisions rely on objective financial considerations rather than political or religious beliefs or lawful business activities.

Cogent Law Perspective

The OCC's report highlights a practical challenge for businesses: Banking relationships can be affected by policies that aren't always transparent to the customers subject to them. For companies in emerging or heavily regulated industries, understanding those policies is an important part of managing financial and operational risk. Cogent Law's banking, FinTech, and energy teams help clients evaluate bank-access issues, respond to denials or restrictions, and monitor OCC fair-access developments that may affect account strategy and compliance posture. As regulators continue examining debanking practices, businesses should pay attention not only to potential policy changes but also to how financial institutions apply those changes in practice. The distinction between legitimate financial risk and broader reputation concerns will likely remain central to that discussion.

Key Takeaways

• All nine banks were identified. The OCC found that the nine largest national banks it supervises had policies between 2020 and September 2025 that denied or limited financial services based on political or religious beliefs or lawful business activities.
• Several industries faced restrictions. These included digital assets, oil and gas, coal, firearms, detention facilities, and tobacco and e-cigarettes.
• Reputation risk policies lacked clear standards. The OCC found that broad policies sometimes relied on considerations unrelated to objective financial risk.
• Further regulatory changes may follow. The agency has removed reputation risk from examinations and is considering additional supervisory measures.
• Documentation matters. Businesses affected by debanking should maintain records of account restrictions, request clear explanations, and monitor future OCC guidance.

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