OCC finds all nine of its largest national banks had debanking policies

The Office of the Comptroller of the Currency (OCC) released a report on 14 October 2026 on its supervisory review of 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 review was carried out under the President's executive order "Guaranteeing Fair Access to Banking for All Americans". It tested whether the banks' policies or practices "may have required, encouraged, or otherwise influenced" them to deny or limit services because of customers' political or religious beliefs or lawful business activities. The OCC says that between 2020 and September 2025, all nine banks had such policies.

They still bear on how large banks write and apply customer acceptance and exit policies. The OCC's central criticism is of "broad reputation risk policies" that "lacked clear standards and objective, risk-based criteria". The OCC has already removed reputation risk from its examinations. It has also said it will consider improper debanking when it assesses licensing applications and during certain examinations. Comptroller Jonathan V. Gould said the report provides "irrefutable evidence that the nation's largest banks have denied, debanked and discriminated against customers and lawful businesses".

What the OCC found

According to the OCC, the reputation risk policies disadvantaged certain Americans "based on their political, religious, or social views or based on their lawful business activities". The banks also maintained both public and nonpublic policies that restricted whole industry sectors' access to financial services. The sectors named are:

- oil and gas exploration;
- coal mining or coal-powered plants;
- firearms or ammunition manufacturing or distribution;
- construction or operation of detention facilities;
- the manufacturing, distribution or online retail of tobacco or e-cigarettes;
- digital asset activities.

The OCC reviewed nearly 100,000 complaints made to OCC-regulated institutions. It also received about 50,000 documents, roughly 420,000 pages, from the banks on their policies, procedures, practices and individual customer decisions. PYMNTS reported that the report, titled "Guaranteeing Fair Banking for All Americans", runs to 45 pages.

The OCC announced the review in September 2025 and issued preliminary findings in December 2025.

Further changes for the largest banks

Gould signalled that the report is not the end of the matter. "Notwithstanding certain efforts by the largest banks to rein in these practices, I am not confident that they will be enough," he said. He added that the OCC "will be assessing further changes to the regulatory and supervisory framework applicable to the largest banks". The OCC says it is considering actions to stop banks discriminating against customers or prospective customers on the basis of political or religious beliefs, and to address "the problematic role of reputation risk in bank decision-making".

The report came six days after the OCC assessed a $350m civil money penalty against American Express National Bank over Bank Secrecy Act and anti-money laundering failures. In Atlas's view, the two actions together mean the OCC expects exits and refusals to rest on documented, customer-specific risk. A sector exclusion or a reputational judgement will not suffice, while AML obligations remain fully in force.