The Office of the Comptroller of the Currency published findings from its supervisory review of the nine largest national banks it supervises, concluding that all nine maintained policies between 2020 and September 2025 that may have required, encouraged or influenced restrictions on financial services because of customers’ political or religious beliefs or lawful business activities. The report follows preliminary findings issued in December 2025 and provides detailed support for the agency’s ongoing work on alleged debanking. Broad reputation risk policies lacked clear standards and objective, risk based criteria, disadvantaging some customers based on their political, religious or social views or lawful activities. The banks also maintained public and nonpublic restrictions affecting sectors including fossil fuels, firearms, detention facilities, tobacco and e-cigarettes, and digital assets. The review covered nearly 100,000 complaints and about 50,000 documents totaling approximately 420,000 pages. The OCC is assessing further changes to the regulatory and supervisory framework for the largest banks because it considers banks’ efforts to curb these practices potentially insufficient. This builds on its removal of reputation risk considerations from bank examinations, clarification of how improper debanking may affect licensing and certain examinations, and changes to its complaint processes.
United States Office of the Comptroller of the Currency finds policies linked to debanking at all nine largest supervised national banks
The Office of the Comptroller of the Currency found that all nine largest national banks it supervises maintained policies between 2020 and September 2025 that may have encouraged or influenced service restrictions based on beliefs or lawful business activities. It cited vague reputation risk standards and restrictions affecting sectors including fossil fuels, firearms and digital assets. The agency is assessing further regulatory and supervisory changes for the largest banks.