On October 14 the OCC released the results of its review of debanking at the nine largest national banks it supervises. They are JPMorgan Chase, Bank of America, Citibank, Wells Fargo, U.S. Bank, Capital One, PNC, TD and BMO. The OCC found that between 2020 and September 2025, all nine had policies that could deny or limit access to financial services because of customers’ political or religious beliefs or lawful business activities.
The report puts much of the blame on reputation risk. The OCC found that “broad reputation risk policies—which lacked clear standards and objective, risk-based criteria—disadvantaged certain Americans based on their political, religious, or social views or based on their lawful business activities.” The restricted sectors it names include oil and gas, coal, firearms and ammunition, detention facilities, tobacco and e-cigarettes, and digital assets. The OCC reviewed nearly 100,000 complaints and about 420,000 pages of bank documents.
Comptroller Gould framed it in one line. “Fair access to financial services is not a mantra—it is a mandate.”
The CFPB picks up the thread
The same day the CFPB announced its own initiative. “The CFPB will fully investigate whether the institutions featured in OCC’s report and others have complied with federal consumer financial laws and take appropriate action,” it said. The bureau named the Equal Credit Opportunity Act, with a focus on adverse action notices, the Fair Credit Reporting Act and its UDAAP authority. It has also updated its complaint portal to invite debanking complaints.
- Sep 2025OCC opens its review of the nine largest banksIt followed the fair-access executive order.
- Dec 2025Preliminary findings issued
- Oct 14Final report releasedAll nine banks had restrictive policies.
- Oct 14CFPB announces a follow-on initiativeIt covers ECOA, FCRA and UDAAP.
The report names nine banks. The complaint portal is open to customers of every bank.
- Review every account-closure and decline policy for criteria based on reputation or industry category. Replace them with documented, risk-based reasons.
- Confirm that adverse action notices on credit declines and line reductions state the specific reasons. The CFPB named ECOA notices as a focus.
- Expect debanking complaints through the CFPB portal, and route them to compliance for a documented response.
Zovos keeps the risk-based rationale for every account exit and decline with the decision itself. A fair-access complaint then has its answer on file before it arrives.
This is for information only and is not legal advice. Confirm your fair-access obligations with counsel before acting.