The Office of the Comptroller of the Currency (OCC) announced a set of actions intended to eliminate politicized or unlawful debanking in the federal banking system, aligned with the President’s Executive Order 14331. The package includes two bulletins that clarify how the OCC will treat debanking-related practices in licensing reviews and Community Reinvestment Act (CRA) performance assessments, and that restate expectations for protecting customer financial records and the use of suspicious activity reports. In Bulletin 2025-22, the OCC said it will consider a bank’s past record and current policies and procedures aimed at avoiding politicized or unlawful debanking when evaluating applicable statutory and regulatory factors for licensing activities, and that debanking considerations will also be assessed when determining CRA ratings. As part of its review, the OCC has requested information from its nine largest regulated institutions on debanking activities, updated its customer complaint website to support reporting and identification of unlawful debanking, and is using complaint data and other government and third-party sources to refine examination efforts. Bulletin 2025-23 highlights the limited circumstances under which customer financial records may be released and addresses proper use of suspicious activity reports, while encouraging institutions to align relevant policies and procedures with Executive Order 14331. The OCC is also reviewing its Bank Secrecy Act/anti-money laundering supervision approach to ensure it is not contributing to unlawful debanking and indicated it will make changes if needed, including working with other federal agencies on broader BSA/AML framework shortcomings. It also stated that after removing references to reputation risk from handbooks and guidance earlier in 2025, it will soon propose a rule to remove those references from its regulations.
Office of the Comptroller of the Currency 2025-09-08
Office of the Comptroller of the Currency links unlawful debanking to licensing and CRA assessments and issues guidance on customer financial records
The Office of the Comptroller of the Currency (OCC) announced measures to eliminate politicized or unlawful debanking, in line with Executive Order 14331. The OCC issued bulletins clarifying debanking practices in licensing reviews and Community Reinvestment Act assessments, and restating expectations for customer financial record protection and suspicious activity report usage. Additionally, the OCC is reviewing its Bank Secrecy Act/anti-money laundering supervision to prevent unlawful debanking and plans to propose a rule removing reputation risk references from regulations.