The Office of the Comptroller of the Currency (OCC) released findings from a yearlong review of nine of the largest national banks it supervises by asset size, covering the period from 2020 through September 2025.
The review followed the Trump administration’s August 2025 Executive Order 14331, “Guaranteeing Fair Banking for All Americans,” which directed federal banking regulators to examine whether banks had engaged in unlawful debanking practices. The OCC evaluated nearly 100,000 complaints, hundreds of individual bank decisions and about 420,000 pages of bank documents. The OCC previously shared initial findings from its review in December 2025.
The report concluded that reputation-risk and industry-specific policies at the nine banks created an elevated risk of denying or limiting access to financial services based on customers’ political or religious beliefs, affiliations or lawful business activities. The same day the OCC released its report, the Consumer Financial Protection Bureau (CFPB) announced it will examine whether the nine banks reviewed by the OCC, and others, complied with federal consumer financial laws. Together, the two announcements point to continued regulatory scrutiny of debanking practices.
The OCC report
The OCC organized its findings around two categories of bank policies it identified as creating an elevated risk of improperly limiting access to financial services: reputation-risk policies and industry-specific restrictions.
Reputation-risk policies and industry-specific restrictions
According to the OCC, the banks reviewed maintained policies addressing the concern that certain customers or business activities could negatively affect the bank’s reputation or public image.
The OCC found that banks generally assessed this risk by considering the views of a range of internal and external stakeholders, but did not have clear, objective or quantifiable standards for making that assessment. The report noted that, without such standards, reviews of similarly situated customers produced materially different outcomes, with results often turning on a customer’s public visibility, whether the customer’s viewpoint was seen as outside the political or social “mainstream,” or revenue attributed to the customer.
The OCC also described “industry-specific restriction policies and practices” as those barring entire sectors from accessing financial services based on reputational concerns tied to the bank’s association with a particular industry. The report identified six categories subject to such restrictions:
- Oil and gas exploration, development or production in the Arctic
- Coal mining or coal-powered plants
- Firearms, firearms accessories, or ammunition manufacturing or distribution
- Construction or operation of detention facilities
- Digital asset activities
- Tobacco or e-cigarette manufacturing, distribution or online retail
The OCC found that, in several instances, large and well-established companies in a restricted sector obtained exceptions or continued financing, while smaller competitors seeking new relationships were declined based on sector status alone. The report stated that this dynamic risked entrenching incumbents and discouraging competition and innovation in otherwise lawful industries.
Other OCC findings
The OCC scrutinized communications between the banks and affected customers regarding account closures or refusals. Per the OCC, account closure letters were often vague with “little to no” explanation and cited only the bank’s contractual right to close an account for any reason. The report also noted that customer service representatives generally could not provide more insight for affected customers, as the representatives followed scripted language. The OCC highlighted that, in several cases, better communication before closure likely would have allowed the relationship to continue. The OCC acknowledged that confidentiality obligations tied to suspicious activity reporting legitimately limit what a bank can disclose in some cases, but asserted that concern for those obligations does not explain the broader pattern of poor communication.
The OCC report also noted that several states – including Florida, Tennessee and Idaho – enacted “fair access” laws during the review period that prohibit certain financial institutions from denying or canceling services based on factors such as a customer’s political or religious views or affiliations, or any factor that is not a “quantitative, impartial, and risk-based standard.” The report stated that passage of these laws likely prompted many banks to revise or clarify their industry-specific policies in 2023 and 2024, though the OCC noted it did not assess the extent of banks’ actual compliance with these state laws.
The CFPB report
The same day the OCC released its report, the CFPB announced an initiative in response to the OCC’s findings. The CFPB stated that it will address consumer harm identified in the OCC’s report at the nine banks and will investigate whether those institutions – and others – complied with federal consumer financial laws, taking “appropriate action” where warranted. The CFPB also said it has already been reviewing consumer complaint data and supervisory information in response to Executive Order 14331. The announcement signals that the OCC’s findings may lead to parallel consumer-protection scrutiny, with multiple regulators now positioned to pursue follow-on investigations.
What’s next
In connection with the report’s release, the OCC outlined plans to improve its complaint-intake process and coordinate with other federal and state regulators on debanking issues going forward. On money laundering and terrorist financing compliance, the OCC said it is considering additional guidance or rule changes aimed at preventing banks from relying on Bank Secrecy Act compliance as a basis for account terminations that are actually rooted in reputational concerns rather than legitimate money-laundering or terrorist-financing risk, building on a pending interagency proposal addressing the risk-based nature of those requirements.
The OCC report follows a number of prior actions by the OCC and other federal agencies to combat debanking. For example, the OCC finalized a rule with the Federal Deposit Insurance Corporation (FDIC) eliminating reputation risk from its supervisory programs and prohibiting regulators from penalizing institutions based on reputation risk, or from encouraging account closures based on a customer’s political, social, cultural or religious views. In June, the OCC, FDIC and Federal Reserve jointly updated 15 interagency documents to remove references to reputation risk.
Together, the OCC report and the CFPB’s parallel announcement indicate that debanking practices will remain an area of active regulatory attention, and that banks’ reputation-risk and industry-restriction policies, as well as their customer communications, are likely to draw continued examiner and public scrutiny.