OCC Finds Nine Largest US Banks Denied Services on Reputation Risk

The Office of the Comptroller of the Currency (OCC) said on October 14 that all nine of the largest national banks it supervises had policies from 2020 through September 2025 that could deny or limit services over political or religious views or lawful business activities, in an OCC debanking reputation risk report.

The OCC named JPMorgan Chase Bank, Bank of America, Citibank, Wells Fargo Bank, U.S. Bank, Capital One, PNC Bank, TD Bank and BMO Bank. It announced no enforcement actions or penalties, but said it is considering further changes to how it supervises the largest banks.

For compliance and risk teams, the report puts customer-acceptance and account-closure decisions under direct supervisory scrutiny. It targets the use of reputation risk as a reason to decline or exit a client, a practice that sits alongside AML, sanctions and credit criteria in many onboarding policies.

What the OCC debanking reputation risk report found

The report, titled “Guaranteeing Fair Banking for All Americans,” follows Executive Order 14331, signed in August 2025. The order directed federal regulators to address debanking, which means a bank closing or refusing accounts or services for reasons other than individualized, risk-based analysis.

The OCC focused on two kinds of policy. The first was broad reputation risk policies that lacked clear standards and objective, risk-based criteria. The OCC said these disadvantaged people based on political, religious or social views, or on lawful business activities.

The second was industry-specific policies, some public and some not. The OCC found restrictions on oil and gas exploration, coal mining and coal-powered plants, firearms and ammunition, detention facilities, tobacco and e-cigarettes, and digital asset activities.

The report gives examples. A bank-owned payment processor closed a merchant account selling pro-Trump merchandise in 2021. One bank treated “partisan activity” as presumptively high reputation risk, a policy the OCC noted appeared to affect organizations across the political spectrum.

The review also covered account closure practices, the content and timing of closure notices, and how banks handled complaints.

Data and method behind the debanking findings

The OCC reviewed nearly 100,000 complaints made to OCC-regulated institutions. It also received about 50,000 documents from the nine banks, totaling roughly 420,000 pages. These covered policies, procedures, practices and individual customer decisions.

The agency announced the review in September 2025 and issued preliminary findings in December 2025. Its September 2025 announcement also said it would weigh debanking in licensing decisions and Community Reinvestment Act evaluations.

The OCC said its review of complaints about political and religious debanking is continuing, and that it will report on them later.

Pending OCC actions on debanking and reputation risk

Comptroller of the Currency Jonathan V. Gould said the banks’ own efforts to change course may fall short.

“Notwithstanding certain efforts by the largest banks to rein in these practices, I am not confident that they will be enough.” Jonathan V. Gould, Comptroller of the Currency, OCC

The OCC said it is considering actions to stop banks discriminating against customers or prospective customers because of political or religious beliefs. It is also considering actions on the role of reputation risk in bank decision-making. It said it “will be assessing further changes to the regulatory and supervisory framework applicable to the largest banks.”

The release does not name specific rules or changes to the Comptroller’s Handbook. No proposal or timetable has been published.

The OCC says it has already removed reputation risk from its examinations and clarified how it treats improper debanking in licensing applications and certain examinations. It has also improved how it takes in and reviews complaints.

The rule already barring reputation risk in exams

The report builds on a rule. The OCC and the Federal Deposit Insurance Corporation adopted a joint final rule on April 7, 2026, published in the Federal Register on April 10 (91 FR 18279). It took effect June 9, 2026.

The rule bars the agencies from criticizing institutions, formally or informally, or taking adverse action against them on the basis of reputation risk. It is codified at 12 CFR 4.91 for the OCC and 12 CFR 302.100 for the FDIC. It also removes references to reputation risk from other agency regulations and manuals.

That rule restricts what examiners may do. The October report goes to what banks do. Examiners can no longer cite reputation risk in an exam, but the OCC is now questioning whether the largest banks should apply it in customer decisions at all.

The CFPB announced on the same day that it would examine whether the nine banks and others complied with federal consumer financial law. It named three areas: the Equal Credit Opportunity Act, the adverse action notice requirements of the Fair Credit Reporting Act, and the prohibition on unfair, deceptive or abusive acts or practices. The CFPB has supervisory and enforcement authority over banks with more than $10 billion in assets.

Reaction to the OCC debanking reputation risk findings

The Bank Policy Institute, a trade group for large banks, said the industry supports fair access to banking. It said it backs recent regulatory efforts and clear and consistent standards. Several banks, including BMO, pointed reporters to that statement. Wells Fargo declined to comment.

JPMorgan Chase said its policies prohibit discrimination against customers based on political or religious views. A JPMorgan spokesperson said the payment unit involved in the 2021 closure no longer operates.

Critics of the report see a political purpose. Adam Levitin, professor of law and finance at Georgetown University, called the findings a “nothing burger” and said the banks’ actions were legal. He argued the OCC found no denial of services, only heightened review of lines of business that carry reputational risk.

That argument goes to a live question for risk functions. Reputation risk is a recognized category in enterprise risk frameworks, and banks have long used it to decide which clients to take on. The OCC’s position is that, without objective criteria, the label becomes a proxy for views the bank dislikes.

Supervision is already contested ground. Senator Elizabeth Warren has urged the Fed, OCC and FDIC to restore bank examiner powers that she says recent changes curtailed.

What debanking scrutiny means for bank controls

The report’s findings point to documentation. The OCC examined written policies, nonpublic sector restrictions, closure notices and complaint files. Banks that exit customers will need records showing the risk-based reason for each decision, a point that overlaps with the audit trails described in data-driven audit programs.

Sector policies are the clearest exposure. Restrictions on firearms, fossil fuels or digital assets that were adopted as reputation risk appetite statements are the type the OCC listed. Banks that keep them will have to show a credit, legal, AML or sanctions basis.

The OCC has not said what supervisory step comes next or when. The agency said its review of political and religious debanking complaints continues, and further findings are due after that work ends.