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OCC’s nine-bank debanking review puts further large-bank rules under consideration

The OCC found broad reputation-risk controls and sector restrictions across the nine largest national banks it supervises. Its report connects those findings to changes in examinations, licensing and complaint handling, with further measures under consideration.

The OCC has put further large-bank regulatory and supervisory changes under consideration after finding that all nine of the largest national banks it supervises had policies that could restrict services because of political or religious views, affiliations or lawful business activities. The 14 October report covers policies in place between 2020 and September 2025.[1]

The institutions reviewed were JPMorgan Chase Bank, Bank of America, Citibank, Wells Fargo Bank, U.S. Bank, Capital One, PNC Bank, TD Bank and BMO Bank. The review followed an executive order on fair access and preliminary findings published in December 2025. Its conclusions concern the reviewed policies and practices; complaint counts describe the evidence examined, rather than substantiated findings in every individual case.[1][3]

Two policy categories drive the findings

Entities & regulation01

How the OCC classifies the problem

How the OCC classifies the problem
Policy typeWhat the OCC foundPractical distinction
Broad reputation-risk controlsPolicies without clear standards or objective risk criteria could influence entry into or continuation of customer relationships.The concern is subjective exclusion rather than a specific quantified credit, fraud, compliance or operational risk.Source 1Source 2
Industry-specific restrictionsSome banks prohibited or escalated approval for sectors including oil and gas, coal, firearms, detention facilities, tobacco, e-cigarettes and digital assets.A sector policy can restrict an otherwise lawful business before its individual financial and compliance risks are assessed.Source 1Source 2
Individual customer decisionsThe OCC highlights examples involving partisan organisations, political merchandise and specified business activities.A highlighted case illustrates the policy concern; it is not a universal finding about every customer in that category.Source 2
Key numbers02

Review scope

Review scope
MeasureValueContext
InstitutionsNine largest OCC-supervised national banksThe review is not a census of every US bank or credit union.Source 1
Policy period2020 to September 2025The final report extends beyond the 2020–2023 period described in the preliminary release.Source 1Source 3
Complaints reviewedNearly 100,000Complaints were one evidence stream alongside policies, procedures and customer-decision records.Source 1
Bank documentsAbout 50,000 documents / 420,000 pagesThe figures describe material received from the nine banks.Source 1

The OCC’s public examples show why “debanking” is not one mechanism. A categorical prohibition, an escalated approval requirement, a payment-processor closure and a lending restriction can all reduce access, but they affect different services and involve different risk decisions. The report’s policy thesis is that lawful activity should be assessed through objective financial, operational and legal criteria rather than an undefined reputational label.[2][1]

The supervisory framework is already changing

Event timeline03

OCC actions and open work

OCC actions and open work
ActionStatusConsequence
Remove reputation risk from supervisionFinal rule announced 7 April 2026OCC examinations should not use reputation risk as an independent supervisory basis.Source 4
Licensing and examination treatmentAlready identified as part of the fair-banking programmeImproper debanking can be considered in specified licensing and Community Reinvestment Act processes.Source 1Source 2
Complaint intake and reviewChanges underwayThe OCC says it is improving how complaints are received and assessed.Source 1
Further large-bank changesUnder considerationThe final report does not supply final rule text, scope or an implementation date.Source 1

Banks continue to assess applicants under anti-money-laundering, sanctions, consumer-protection, fraud, credit and safety-and-soundness requirements. The OCC’s stated policy direction calls for objective financial, operational and legal reasons for restrictions. Applying that approach requires a documented connection between the customer or service and the risk identified in the decision.[2][4]

The findings are supervisory conclusions, with no penalties announced in this release. Customer-level remedies depend on the account, product, contract and applicable law. Any further large-bank rulemaking will need to specify its scope, requirements and implementation date.[1][2]

Follow the evidence

Sources & further reading

  1. OCC releases report on large banks’ debanking activities Office of the Comptroller of the Currency · 14 Oct 2026 · Accessed 16 Oct 2026
  2. Guaranteeing Fair Banking for All Americans: findings and highlighted examples Office of the Comptroller of the Currency · Accessed 16 Oct 2026
  3. OCC releases preliminary findings from large-bank debanking review Office of the Comptroller of the Currency · 10 Dec 2025 · Accessed 16 Oct 2026
  4. Final rule eliminating reputation risk from OCC supervision Office of the Comptroller of the Currency · 7 Apr 2026 · Accessed 16 Oct 2026

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