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Tuesday, October 27

OCC’s Debanking Report: What Large Banks Did (and Didn’t) Document

Small business owner holding a folder outside a bank door

On October 14, the Office of the Comptroller of the Currency (OCC) released a 47-page report on “debanking” 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 headline finding is that between 2020 and September 2025, all nine had policies that may have required, encouraged or influenced decisions to deny or limit services because of customers’ political or religious beliefs or lawful business activities.

Comptroller Jonathan V. Gould didn’t soften it. “Today’s report provides irrefutable evidence that the nation’s largest banks have denied, debanked and discriminated against customers and lawful businesses,” he said in the OCC’s announcement.

The political fight over debanking is loud. The part that matters most for customers is quieter: what banks wrote down, what they didn’t, and what they told the people they turned away.

How the review worked

The OCC says it ran the review under Executive Order 14331, “Guaranteeing Fair Access to Banking for All Americans.” It reviewed nearly 100,000 complaints and roughly 50,000 bank documents, about 420,000 pages, covering policies, procedures, and individual customer decisions. Preliminary findings came out in December 2025.

Speaking in Lexington, Kentucky, with Rep. Andy Barr, Gould focused on coal and firearms. Banks restricting coal financing cited “negative headlines, public protests, and the perceived reputational consequences of supporting the industry” rather than financial risk, he said. He described one bank turning down a loan of less than $50,000 to a small firearms-related business while approving a multimillion-dollar letter of credit for a larger industry player.

Other restricted sectors included oil and gas exploration, detention facilities, tobacco and e-cigarettes, and digital assets. The screens didn’t only cut one way, either. Capital One’s “partisan activity” policy, the OCC wrote, appears to have been applied consistently to organizations on both sides of the political spectrum, and the report cites the bank passing on an organization that supported reproductive rights after a risk employee noted its political contributions were “about 95% Democrat.”

The documentation findings

Standards that weren’t really standards. The OCC says the banks “largely lacked clear and measurable standards and objective, risk-based criteria” for judging reputation risk. Even after recent reforms, few could say, when pressed, what measurable yardstick employees would use.

Records too thin for a full count. The OCC says its conclusions were limited by the banks’ responses, their internal tracking, and “the availability of detailed documentation reflecting the contemporaneous reasons for bank decisions.” As a result, it could not quantify how much debanking happened or what it cost customers.

Records that got edited. In one example, a bank’s payments subsidiary closed a nonprofit’s account after employees described it in charged political and religious terms. A reputation risk employee later removed the references to the group being “right wing” and “religious” from the bank’s internal tracking system.

Closure letters that explained nothing. After reviewing hundreds of account closure letters, the OCC found customers “frequently received vague account closure letters, often without forewarning,” that simply cited the bank’s contractual right to close an account at any time. In several cases, the OCC concluded, the account “could likely have remained open” if the bank had been more transparent before closing it.

No accounting for the past. According to the report, no bank has fully and publicly acknowledged its past debanking decisions or set up a comprehensive program to make affected customers whole.

What the banks and other agencies say

JPMorgan said its policies prohibit discrimination based on political or religious views, that the report cites “a limited number of historical interactions,” and that it has “improved the way we do business,” according to Banking Dive. It added that years of regulatory second-guessing “contributed to a culture of caution across the banking industry.”

The OCC acknowledges banks began changing course around 2023, as states passed fair-access laws. Several now require senior review before a reputation-based denial, which banks describe as producing more “documented decisions.” Gould still isn’t convinced. “I am not confident that they will be enough,” he said. The Consumer Financial Protection Bureau said it will investigate whether the banks complied with federal consumer financial laws.

What customers should know

  • Ask for the reason in writing. The report notes banks aren’t required to explain an account termination and often don’t. Asking still creates a record. A September 2, 2026 joint statement from the OCC, Federal Reserve, FDIC, FinCEN, and NCUA clarified that suspicious activity report confidentiality rules don’t stop a bank from discussing the underlying facts and transactions with a customer.
  • Keep your own file. Save closure letters, emails, and call notes. Businesses in scrutinized industries should keep licenses and compliance records handy.
  • Keep a backup account. A second account at another insured institution means a sudden closure doesn’t strand your paycheck.
  • Use the regulator’s complaint channel. The OCC points national bank customers to HelpWithMyBank.gov, which now includes instructions for reporting debanking concerns.

Where this goes next

The report is part of a broader administration policy push, and JPMorgan, for one, disputes parts of its framing. The documentation findings hold up on their own. A bank that can’t explain why it closed an account, even to its regulator, has a process problem no matter who’s in office. For customers, the defense is an old habit: get it in writing and keep a copy.

Sources and Further Reading

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