On October 14, 2026, the OCC released a report of its findings from its supervisory review of debanking activities at the nine largest national banks it supervises, including JPMorgan Chase Bank, Bank of America, Citibank, Wells Fargo Bank, U.S. Bank, Capital One, PNC Bank, TD Bank, and BMO Bank. The review examined whether these banks’ policies or practices influenced them to deny or limit financial services to Americans based on their political or religious beliefs or lawful business activities.
The OCC reviewed nearly 100,000 complaints to OCC-regulated institutions received between 2020 and September 2025. The OCC identified the following key observations:
The banks largely lacked clear and measurable standards and objective, risk-based criteria for assessing the reputation risks of customer relationships;
The banks’ implementation of ambiguous reputation risk policies disadvantaged Americans holding certain political, religious, and social views;
Fear of being on the wrong side of public opinion led at least one bank to distance itself from certain customer affiliations that could possibly be viewed as “partisan”;
Mere allegations, negative press, or negative reviews contributed to some banks declining to serve average Americans, even in the absence of any validation of the underlying facts or concerns; yet some banks were able to find ways to get comfortable with the reputation risks posed by high-net-worth clients;
Policies adopting restrictions on industries were not merely “talking points” to satisfy “stakeholders.” They had real-world consequences, especially for small to midsized companies;
Attempts by the banks to respond to political and social sentiment have whipsawed many industries;
Industry-based restrictions risked hindering competition and innovation in lawful industries, such as firearms, often harming smaller businesses in particular;
Passage of state fair access laws likely acted as a catalyst for changes in many banks’ policies;
Poor communication impaired the ability of customers and prospective customers to understand the reason for a bank’s inquiries or decisions, or to correct misunderstandings; and
Despite taking some steps to address fair access concerns, opportunities for future debanking remain due, in part, to inexact reputational risk policies and processes.
Comptroller Gould said that despite efforts by the largest banks to address these practices, further action may be needed. The OCC will assess additional changes to its regulatory and supervisory framework for the largest banks to help prevent these practices from recurring.
In a separate news release, the CFPB announced a new initiative to address the OCC’s findings. In a statement, CFPB’s Acting Director Mark Paoletta said that the CFPB will fully investigate whether the institutions featured in OCC’s report and others have complied with federal consumer financial laws and take appropriate action.
Read the OCC’s press release here.
The full report can be found here.
The CFPB’s press release can be found here.