OCC Finds Policies at Nine Biggest Banks Could Lead to Debanking, Proposes Supervisory Changes

The Office of the Comptroller of the Currency said Thursday that all nine of the largest national banks it supervises had policies in place from 2020 through Sept. 30, 2025, that could influence the denial or restriction of banking services based on customers’ political or religious beliefs or their lawful business activities.

In a final report titled “Guaranteeing Fair Banking for All Americans,” the OCC said the review covered JPMorgan Chase Bank, Bank of America, Citibank, Wells Fargo Bank, U.S. Bank, Capital One, PNC Bank, TD Bank and BMO Bank. The agency said it reviewed nearly 100,000 complaints and obtained about 50,000 documents totaling roughly 420,000 pages.

The OCC’s central finding was not that every disputed account closure was unlawful, but that each of the nine banks maintained policies that could require, encourage or otherwise influence such decisions. The regulator said two types of policies created elevated debanking risk: broad “reputation risk” standards without clear, objective limits, and industry-specific restrictions on serving certain legal businesses.

According to the report, the sectors most commonly affected included Arctic oil and gas exploration, coal mining and coal-fired power plants, firearms and ammunition manufacturing and distribution, construction or operation of detention facilities, tobacco and e-cigarette manufacturing, distribution and online retail, and digital asset activities.

The OCC said banks in some cases pointed to financial-crime or operational concerns, especially around digital asset activities. But the agency said the way some policies were written or applied could steer decisions about whether to deny or limit services for reasons tied to viewpoint, religion or lawful lines of business.

The report included examples meant to illustrate how those policies could play out. In February 2021, the OCC said, a payment processor owned by one bank closed a merchant account that sold pro-Trump and MAGA merchandise. In February 2023, the agency said, one bank declined to provide services to a public-education organization because its political arm endorsed only Democratic candidates.

Comptroller Jonathan V. Gould said in the agency’s release that “Today’s report provides irrefutable evidence that the nation’s largest banks have denied, debanked and discriminated against customers and lawful businesses.”

At the same time, the OCC said it could not comprehensively quantify the full extent of debanking across the nine banks. The report did not announce fines or enforcement actions, and it is a supervisory finding by the regulator rather than a court determination.

Instead, the agency said the report carries immediate supervisory consequences. The OCC said it is taking or considering several changes, including removing references to “reputation risk” from its supervisory framework, considering debanking issues in bank licensing reviews and Community Reinvestment Act exams, improving how it takes in complaints, and exploring further rulemaking.

The Consumer Financial Protection Bureau, a separate federal agency that enforces consumer financial laws, announced its own initiative Thursday. The CFPB said it will investigate whether the banks named in the OCC report, as well as others, complied with federal consumer financial laws.

“The CFPB will fully investigate whether the institutions featured in OCC’s report and others have complied with federal consumer financial laws and take appropriate action,” Acting Director Mark Paoletta said.

The review stems from Executive Order 14331, signed Aug. 7, 2025, which directed federal banking regulators to examine politicized or unlawful debanking. The OCC announced the review in September 2025 and issued preliminary findings in December 2025 before releasing the final version Thursday.

The report also fits into a broader regulatory shift already underway this year. Earlier in 2026, federal banking agencies had moved to remove “reputation risk” from supervisory materials. With Thursday’s report, the OCC tied that shift to a detailed review of the largest national banks and signaled that access-to-banking issues will now play a larger role in supervision, examinations and possible future rulemaking.