--- title: "When Banks Say No for Nonfinancial Reasons: Inside the OCC’s Debanking Report" description: An OCC review found that subjective factors sometimes influenced banking access, raising questions about fair treatment and risk controls. image: https://americanimpact.org/hubfs/image%20(1)-Oct-20-2026-08-56-39-3078-AM.jpg --- [![American Impact - Trimmed Logo one PNG](https://americanimpact.org/hs-fs/hubfs/American%20Impact%20-%20Trimmed%20Logo%20one%20PNG.png?width=1249&height=574&name=American%20Impact%20-%20Trimmed%20Logo%20one%20PNG.png "American Impact - Trimmed Logo one PNG")](https://americanimpact.org/) - [Home](https://americanimpact.org) - [About](https://americanimpact.org/about-american-impact) - [About the Foundation](https://americanimpact.org/about-the-american-impact-0) - [FAQs](https://americanimpact.org/frequently-asked-questions) - Issues - [Legislation](https://americanimpact.org/legislation) - [Monetary Policy](https://americanimpact.org/monetary-policy) - [Investing](https://americanimpact.org/investing) - [Entitlement Programs](https://americanimpact.org/entitlement-programs) - [Government Taxation, Spending, and Debt](https://americanimpact.org/government-taxation-spending-and-debt) - [Financial Literacy in the United States](https://americanimpact.org/financial-literacy) - [Articles](https://americanimpact.org/blog) - [Donate](https://americanimpact.org/donate) - [Charitable Solicitation Registration Statement](https://americanimpact.org/charitable-solicitation-registration-statement) [Contact Us](https://americanimpact.org/contact) # When Banks Say No for Nonfinancial Reasons: Inside the OCC’s Debanking Report [American Impact](https://americanimpact.org/blog/author/american-impact) Oct 31, 2026, 8:00:00 AM ###### [Financial Literacy](https://americanimpact.org/blog/tag/financial-literacy) *An OCC review found that subjective factors sometimes influenced banking access, raising questions about fair treatment and risk controls.* ## **What to Know** - OCC reviewed the **nine largest national banks** under its supervision. - Investigators examined nearly **100,000 complaints** and approximately **420,000 pages** of bank documents. - All nine banks maintained policies or practices that could influence access based on political, religious, social, or lawful-business considerations. - OCC imposed **no fines or sanctions** through the report. - Customers of national banks and federal savings associations may submit debanking complaints through HelpWithMyBank.gov. Banking access can determine whether a household pays its bills or whether a small business can accept payments, cover payroll, and obtain credit. An unexpected denial or account closure can therefore cause immediate disruption, even when the customer has not been accused of illegal activity. President Donald Trump’s Executive Order **14331**, “Guaranteeing Fair Banking for All Americans,” directed federal banking regulators to investigate whether financial institutions had restricted services because of customers’ political or religious beliefs or lawful business activities. OCC conducted its review of the largest national banks in response to that order.   ![](https://americanimpact.org/hs-fs/hubfs/undefined-Oct-29-2026-11-00-22-2243-AM.png?width=580&height=326&name=undefined-Oct-29-2026-11-00-22-2243-AM.png) Via [news.bitcoin](https://news.bitcoin.com/regulation-and-legal/occ-blows-lid-off-debanking-practices-americas-9-bank-giants/) OCC’s October 2026 report raises a difficult question: when does legitimate risk management become subjective exclusion? Banks must prevent fraud, comply with sanctions, monitor suspicious transactions, and protect their financial stability. Decisions become harder to defend when they rest on anticipated criticism, political controversy, or dissatisfaction with an otherwise lawful industry. ## **What the OCC Review Found** OCC examined JPMorgan Chase, Bank of America, Citibank, Wells Fargo, U.S. Bank, Capital One, PNC Bank, TD Bank, and BMO Bank. Together, these institutions held a majority of the commercial-bank assets supervised by the agency when the review began. Investigators reviewed decisions and policies covering **2020 through September 2025**, along with nearly **100,000 complaints**, hundreds of individual customer decisions, and roughly **50,000 documents** totaling about **420,000 pages**. OCC concluded that all nine banks had policies or practices that could require, encourage, or influence restrictions based on political or religious beliefs or lawful business activities. **![](https://americanimpact.org/hs-fs/hubfs/undefined-Oct-29-2026-11-00-21-9040-AM.png?width=654&height=296&name=undefined-Oct-29-2026-11-00-21-9040-AM.png)** *Asset distribution among the nine reviewed banks and other OCC-regulated institutions, via*[*Office of the Comptroller of the Currency*](https://www.occ.gov/news-issuances/news-releases/2026/nr-occ-2026-90a.pdf)*.* Specific cases showed how those policies could affect individual customers. According to the OCC report, JPMorgan-owned payment processor WePay closed a merchant account selling pro-Trump merchandise in February **2021** after employees reviewed its political content. WePay later closed another account selling conservative and Republican merchandise, including Trump-related items. Examples extended across the political spectrum. Capital One reportedly declined a public-education organization in **2023** partly because its political arm endorsed Democratic candidates, illustrating why OCC questioned decisions based on partisan identity rather than measurable financial risk. Findings did not establish that every denied account was improper. OCC acknowledged that available records did not allow it to measure the complete scale or customer cost of debanking. Banks told Reuters that they make account decisions because of legal, financial, and compliance risks rather than political or religious views. No penalties accompanied the report. Those limitations make the document a supervisory finding, not a court judgment resolving every disputed closure. ## **Financial Risk Is Not the Same as Reputational Risk** Legitimate compliance decisions begin with identifiable risks. Banks must know their customers, follow economic sanctions, investigate fraud indicators, and maintain programs against money laundering and terrorist financing. A customer’s transaction pattern, inability to verify ownership, exposure to sanctioned parties, or evidence of illegal conduct can justify additional review or termination. **![](https://americanimpact.org/hs-fs/hubfs/undefined-Oct-29-2026-11-00-23-2506-AM.png?width=578&height=699&name=undefined-Oct-29-2026-11-00-23-2506-AM.png)** *Three examples identified during the supervisory review, via*[*Office of the Comptroller of the Currency*](https://www.occ.gov/news-issuances/news-releases/2026/nr-occ-2026-90a.pdf)*.* Broad reputational-risk policies operate differently. OCC found that some banks considered negative news, advocacy-group opinions, anticipated social-media reaction, political controversy, or possible criticism from stakeholders. Such factors often lacked measurable thresholds and sometimes produced inconsistent results for similar customers. | **Decision basis** | **Appropriate risk question** | **Central concern** | | --- | --- | --- | | Fraud or financial crime | Does documented activity indicate fraud, money laundering, or sanctions exposure? | Banks must comply with law and protect the financial system. | | Credit or operational risk | Can the customer repay, and can the bank safely provide the service? | Measurable financial and operational exposure may justify restrictions. | | Industry classification | Does this specific customer present an identifiable risk? | Treating an entire lawful industry as uniformly risky can deny individualized review. | | Political or religious affiliation | Does the affiliation create a documented legal or financial risk? | Beliefs alone should not determine access to ordinary banking services. | | Public controversy | Can the bank connect anticipated criticism to a measurable financial consequence? | Vague concern about headlines can become a substitute for objective analysis. | Federal guidance supports a customer-specific approach. Financial regulators have advised banks to manage risks within individual relationships instead of refusing entire categories of customers. That principle does not require a bank to ignore suspicious activity. It requires the institution to connect an adverse decision to evidence rather than social disfavor. ## **What Customers and Small Businesses Can Do** Banks may legally close accounts under some circumstances, including suspected fraud, inactivity, or terms contained in a deposit agreement. Prior notice is not always required. A closure therefore does not, by itself, prove discrimination or regulatory misconduct. Customers should first request an explanation in writing and review the bank’s notice and account agreement. Records such as emails, letters, statements, application materials, and dates of conversations can help establish what happened. Small businesses should also document interrupted payments, frozen funds, rejected transactions, or lost access to merchant-processing services. **![](https://americanimpact.org/hs-fs/hubfs/undefined-Oct-29-2026-11-00-24-1256-AM.png?width=651&height=634&name=undefined-Oct-29-2026-11-00-24-1256-AM.png)** *Instructions for resolving a dispute and submitting documentation to the proper regulator, via*[*HelpWithMyBank.gov*](https://www.helpwithmybank.gov/file-a-complaint/index-file-a-complaint.html)*.* Complaints should go to the institution’s correct regulator. OCC’s Customer Assistance Group handles complaints involving national banks and federal savings associations. Its process asks customers to contact the bank first, confirm OCC jurisdiction, gather supporting information, submit a complaint, and track or appeal the response. Other institutions may fall under the Federal Reserve, Federal Deposit Insurance Corporation, Consumer Financial Protection Bureau, National Credit Union Administration, or a state regulator. OCC cannot act as a customer’s attorney, decide a private lawsuit, or award compensation through its complaint process. Filing can nevertheless place the dispute before the regulator and help agencies identify patterns across multiple customers. ## **What Has Changed and What Could Change Next** Several regulatory changes have already occurred. OCC eliminated reputation-risk considerations from its bank examinations, revised parts of its licensing and examination process to account for improper debanking, and expanded complaint intake. A final interagency rule has also removed reputation risk from OCC and FDIC supervisory programs. Parallel federal scrutiny began on October **14, 2026**, when the Consumer Financial Protection Bureau announced an investigation into whether banks identified by OCC, along with other financial institutions under CFPB jurisdiction, violated federal consumer-financial laws. CFPB said its review could examine adverse-action requirements and potential unfair, deceptive, or abusive practices. An investigation does not establish that a bank violated the law or guarantee prosecution. Further action remains unsettled. OCC is considering additional regulatory and supervisory changes, clearer treatment of political and religious discrimination, and reforms aimed at preventing banks from using anti-money-laundering requirements as a pretext for unrelated account terminations. CFPB’s investigation could produce separate enforcement action if investigators establish violations within the agency’s authority.   **![](https://americanimpact.org/hs-fs/hubfs/undefined-Oct-29-2026-11-00-22-6228-AM.png?width=635&height=423&name=undefined-Oct-29-2026-11-00-22-6228-AM.png)** *Financial institutions face pressure to balance fair access with legal and safety obligations, via*[*Reuters*](https://www.reuters.com/legal/transactional/us-bank-regulator-faults-several-large-lenders-over-debanking-practices-2026-10-14/)*.* Policymakers must preserve room for genuine risk decisions. Requiring a detailed public explanation for every closure could reveal confidential fraud controls or information associated with suspicious-activity reporting. Providing no meaningful explanation, however, can prevent legitimate customers from correcting errors or challenging inconsistent decisions. A workable framework would require documented, individualized reasons; senior review for sensitive closures; consistent treatment of comparable customers; and a complaint channel that protects confidential compliance information. Such safeguards could improve accountability without forcing banks to maintain relationships involving illegal activity or demonstrable financial risk. ## **Wrap Up** OCC’s report provides evidence that subjective reputation concerns sometimes influenced access to banking services at the country’s largest national banks. It does not show that every closure was politically motivated, impose penalties, or eliminate banks’ responsibility to control fraud and financial crime. Fair-access policy should distinguish lawful compliance from decisions based mainly on controversy, beliefs, or industry identity. Consumers and small businesses also need understandable notices and a practical route for challenging mistakes. Stronger documentation, individualized analysis, and regulatory review can protect fair access without weakening the safeguards required for a stable banking system. 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