The Office of the Comptroller of the Currency (OCC) found that all nine of the largest national banks it supervises had policies between 2020 and September 2025 that could deny or limit financial services based on political or religious beliefs or lawful business activities. The banks reviewed were JPMorgan Chase Bank, Bank of America, Citibank, Wells Fargo Bank, U.S. Bank, Capital One, PNC Bank, TD Bank and BMO Bank.
The OCC said broad reputation risk policies, which lacked clear standards and objective, risk-based criteria, disadvantaged some Americans because of their political, religious or social views or their lawful business activities. Comptroller Jonathan V. Gould said the report provides "irrefutable evidence" that the largest banks denied, debanked and discriminated against customers and lawful businesses.
TWO CATEGORIES OF RISKY POLICY
The OCC identified two primary categories of policies that presented an elevated risk of encouraging or otherwise influencing institutions to deny access to financial services based on political or religious beliefs or affiliations or lawful business activities. Reputation risk is not defined in the executive order behind the review, but it generally means potential economic or brand harm from negative public perception of a customer relationship.
Banks had public and nonpublic policies restricting sectors including oil and gas exploration, coal mining and coal-powered plants, firearms and ammunition, detention facilities, tobacco and e-cigarettes, and digital assets. The restrictions ranged from categorical prohibitions to escalated reviews and approvals before service was provided.
EXAMPLES FROM THE BANKS' DECISIONS
Most banks restricted financing of oil and gas exploration, development or production in the Arctic. Most also restricted financing for new or expanded coal mining or plant operations. Gould said the coal decisions were not based on financial risk, as banks cited concerns about negative headlines, public protests and the perceived reputational consequences of supporting the industry.
Many institutions restricted banking of digital asset issuers, exchanges or administrators, often citing financial crime concerns. One bank denied a firearms business help with an initial public offering because its lawful sales policies did not match the bank's own standards.
In February 2021, a payment processor owned by one bank closed the account of a merchant selling Trump/MAGA merchandise. In February 2023, one bank declined services to a public education organisation because its political arm endorsed only Democratic candidates.
SCOPE AND TIMELINE OF THE REVIEW
The OCC conducted the review under Executive Order 14331, covering the nine largest banks by asset size under its supervision. It examined nearly 100,000 complaints and about 50,000 bank documents totalling about 420,000 pages.
The OCC announced the review in September 2025 and issued preliminary findings in December 2025, covering 2020–2023 conduct. The order directed federal banking regulators to remove reputation risk from guidance and exam materials within 180 days. At the preliminary stage, the OCC said it was still reviewing thousands of complaints on political and religious debanking and would report on them in due course.
OCC WEIGHS FURTHER CHANGES
The OCC will assess further changes to the regulatory and supervisory framework for the largest banks to reduce the chance of these practices recurring. It is also considering actions to stop banks discriminating on political or religious beliefs and to address reputation risk in decision-making. Gould acknowledged "certain efforts by the largest banks to rein in these practices" but said he is not confident they will be enough.
Gould said: "We are not forcing these banks to serve every customer." The OCC has removed reputation risk from its own supervisory framework, clarified how improper debanking is weighed in licensing and certain examinations, and improved complaint intake and review. The report is the latest in a series of OCC actions on debanking and fair access.
Gould discussed the findings at a press conference in Lexington, Kentucky, with Rep. Andy Barr. He credited the President and Treasury Secretary Bessent for the push to ensure fair access to financial services.