OCC Releases Findings on Large Banks' Debanking Activities

On December 10, 2025, the OCC released preliminary findings from its supervisory review of debanking activities at the nine largest national banks it supervises: JPMorgan Chase Bank, Bank of America, Citibank, Wells Fargo Bank, U.S. Bank, Capital One, PNC Bank, TD Bank, and BMO Bank. The supervisory review was carried out by the OCC in accordance with the President’s Executive Order Guaranteeing Fair Banking for All Americans to assess if any institutions debanked or discriminated against customers based on their political or religious beliefs or lawful business activities.

The OCC found that between 2020 and 2023, the banks maintained public and nonpublic policies restricting certain industry sectors’ access to banking services, including by requiring escalated reviews and approvals before providing access to financial services. Restrictions on banks often stemmed more from reputational concerns about engaging with certain industries than from actual financial risks or compliance with applicable laws. Industry sectors subjected to restricted access by the nation’s largest banks include oil and gas exploration, coal mining, firearms, private prisons, tobacco and e-cigarette manufacturers, adult entertainment, and digital assets.

The OCC said that it is continuing to examine the effects of certain actions on affected industries and the American economy, with a focus on how policies were implemented over the past five years. They are also reviewing complaints to identify instances of political and religious debanking and plan to hold banks accountable for any unlawful activities, including referrals to the Attorney General as necessary.

Read the OCC’s news release here.

The full Preliminary Findings document can be found here.

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