The Office of the Comptroller of the Currency (OCC) recently shared initial findings from its ongoing review of potential debanking activities at the nine largest national banks it supervises. The review is part of the agency’s effort to implement mandates under Executive Order 14331, which directs “Federal banking regulators,” including the OCC, to remediate past instances, and prevent future acts of, politicized or unlawful debanking. The executive order specifically requires federal banking regulators to identify financial institutions that currently or previously have maintained policies or practices that “require, encourage or otherwise influence” debanking on the basis of political beliefs, religious beliefs or lawful business activities – and take appropriate remedial action.
As part of an ongoing review, the OCC is sifting through thousands of documents from 2020 to 2025, including nearly 100,000 consumer complaints from its internal complaint database and other sources, to identify potential instances of debanking. It is also looking to identify any evidence of bank coordination with federal law enforcement to surveil and reveal to law enforcement the private financial information of persons engaged in transactions “commonly associated with certain political views or affiliations.”
Preliminary findings
In its report, the OCC notes its observation that between 2020 and 2023, the financial institutions reviewed maintained public and nonpublic policies restricting access to banking services for certain sectors, such as by requiring heightened reviews and approvals before providing such access.
- Access restricted due to reputation and nonfinancial risks. According to the OCC, the financial institutions reviewed often cited “reputation risk” or environmental and social considerations, not just core financial risks, safety and soundness concerns, or legal compliance factors, in restricting access to banking services. The affected industries include payday and payroll lenders, consumer debt collectors and repossession agencies, auto title lenders, businesses offering high-cost consumer loans, digital asset companies, firearms manufacturers and coal mining companies, among others.
- Customer-level screening. The OCC reports that certain institutions adopted policies that may have resulted in a heightened review of customers or potential customers based on negative media coverage.
- Next steps. The OCC makes clear that its findings are preliminary and its review is ongoing. The OCC will continue to review complaints and work to assess how the financial institutions’ policies were applied in practice over the last five years. Where unlawful debanking is identified, the OCC intends to pursue accountability measures, including referrals to the attorney general as required by the executive order.
What this means
The OCC’s preliminary report is just the latest in the flurry of activity resulting from the debanking executive order.
In September 2025, the OCC issued guidance indicating that politicized or unlawful debanking may be considered in licensing decisions and Community Reinvestment Act performance evaluations. That guidance reminded institutions of limits on releasing customer financial records and proper use of suspicious activity reports. The OCC also announced a review of consumer complaint data and data from other government and third-party sources to refine its examination efforts; a review of its approaches to Bank Secrecy Act and anti-money laundering supervision; and updates to its online customer complaint website to facilitate reporting of unlawful debanking activities. In October, the OCC and the Federal Deposit Insurance Corporation issued a joint notice of proposed rulemaking to codify the elimination of reputation risk from their supervisory programs. The comment period closes December 29, 2025.
The US Small Business Administration has also taken action, sending letters to its network of more than 5,000 lenders requiring them to identify past or current practices that may provide for debanking and to make reasonable efforts to identify, reinstate and provide notice to any previous or potential clients denied services due to debanking.
We expect to see efforts to investigate debanking continue and to see legal or enforcement action against institutions determined to have engaged in debanking activity.