OCC says all nine largest US banks used policies that restricted access to banking from 2020 to September 2025

The Office of the Comptroller of the Currency (OCC) has concluded that each of the nine largest lenders under its supervision operated policies that limited access to financial services on political, religious, or sector-specific grounds. For high-risk operators, the useful part is not the rhetoric; it is that the regulator has now put reputation-risk-driven debanking squarely on the supervisory agenda.

1. 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 OCC carried out the work under President’s Executive Order, “Guaranteeing Fair Access to Banking for All Americans,” and said it was checking whether internal rules or practices led staff to refuse or curtail services because of customers’ beliefs or legally permitted commercial activities.
2. According to the OCC, broad reputation risk frameworks without defined standards or objective, risk-based tests put some Americans at a disadvantage because of their political, religious or social views, or because of the lawful businesses they ran. The regulator also identified published and internal policies that limited banking access for whole industries.
3. Those industries included oil and gas exploration, coal mining and coal-fired power generation, firearms and ammunition production or distribution, the building or running of detention facilities, tobacco and e-cigarette manufacturing, distribution or online sales, and digital asset activities. In practice, that is the sort of policy language that matters to PSPs, acquirers, and banks deciding whether a merchant category gets a yes, a no, or a slow walk to nowhere.
4. To build its case, the OCC reviewed close to 100,000 complaints submitted to the institutions it oversees and obtained roughly 50,000 documents from the nine banks, totaling around 420,000 pages. Those records covered policies, procedures, practices, and decisions on individual customers.
5. The OCC launched the review in September 2025 and published its initial conclusions in December 2025. It has already removed reputation risk from bank examinations, clarified how improper debanking factors into licensing reviews and some examinations, and upgraded how it receives and assesses complaints. Further work is under way, including possible measures to stop banks from discriminating against existing or prospective customers over political or religious beliefs and to address the role reputation risk plays in lending and account decisions.

Jonathan V. Gould, OCC comptroller of the currency, said the report provides “irrefutable evidence” that the nation’s largest banks have denied, debanked, and discriminated against customers and lawful businesses. For high-risk firms, the operative point is simple: the OCC has moved fair-access issues from the complaint box into the exam framework, and that changes the way bank onboarding, renewals, and account reviews can be handled.