The Office of the Comptroller of the Currency on Oct. 14 released the findings of its supervisory review of debanking at the nine largest national banks it supervises, and the verdict covers every one of them. According to OCC News Release 2026-90, JPMorgan Chase Bank, Bank of America, Citibank, Wells Fargo Bank, U.S. Bank, Capital One, PNC Bank, TD Bank and BMO Bank all had, between 2020 and September 2025, policies that could deny or limit access to financial services because of customers’ political or religious beliefs or lawful business activities.
The same day, the Consumer Financial Protection Bureau said it would use the report as the basis for its own investigations. That matters because the OCC report is a supervisory finding, not an enforcement action. The CFPB holds the consumer-law tools that could turn findings into liability. Neither agency attached a date to what comes next.
1. What the OCC found
The core finding concerns reputation risk. The OCC says broad reputation risk policies “lacked clear standards and objective, risk-based criteria” and disadvantaged Americans based on their views or lawful business activities. It also found public and nonpublic policies restricting entire sectors.
- Oil and gas exploration
- Coal mining or coal-powered plants
- Firearms or ammunition manufacturing or distribution
- Construction or operation of detention facilities
- Manufacturing, distribution or online retail of tobacco or e-cigarettes
- Digital asset activities
The evidence base is large. The OCC reviewed nearly 100,000 complaints to OCC-regulated institutions and received about 50,000 documents, roughly 420,000 pages, from the banks. The review was announced in September 2025, preliminary findings followed in December 2025, and the final report is titled “Guaranteeing Fair Banking for All Americans.”
A bank-by-bank scorecard is not what the public releases offer. They name all nine institutions and attribute the findings to the group, using quantifiers rather than names: “many of the banks” restricted financing for new coal mining and coal-fired plants, “some” screened companies by the share of revenue derived from coal, and “several” restricted financing for firearms makers and retailers. The CFPB says the report includes excerpts from bank documents, including emails.
2. The Kentucky case study
Comptroller Jonathan V. Gould presented the findings at a press conference in Lexington, Kentucky, with Rep. Andy Barr, alongside representatives of local coal and firearms businesses, according to News Release 2026-91. His most specific example: a bank that declined to help a firearms business with an initial public offering because the company’s policies on lawful firearms sales “did not align with the bank’s own standards.”
Gould argued the coal restrictions “were not based on financial risk,” saying banks cited “negative headlines, public protests, and the perceived reputational consequences.” He also described decisions by executives that became “institutionalized and opaque bureaucracies,” including “procedural frictions” that cut off customers in practice without a formal denial.
Notwithstanding certain efforts by the largest banks to rein in these practices, I am not confident that they will be enough. Accordingly, the OCC will be assessing further changes to the regulatory and supervisory framework applicable to the largest banks to reduce the likelihood of these harmful practices recurring in the future.
EXCERPT · Comptroller Jonathan V. Gould, OCC News Release 2026-90, Oct. 14, 2026
3. What the CFPB says it will do
The CFPB announcement frames the initiative as part of implementing Executive Order 14331. Acting Director Mark Paoletta said the bureau “will fully investigate whether the institutions featured in OCC’s report and others have complied with federal consumer financial laws and take appropriate action.” The words “and others” extend the scope beyond the nine.
| Agency | Stated next step | Legal hook | Timeline stated |
|---|---|---|---|
| OCC | Assess further changes to the framework for the largest banks; consider actions on political or religious discrimination and reputation risk | Supervisory and regulatory authority | None |
| CFPB | Investigate the nine banks and others; pursue its own investigations from complaint and supervisory data | ECOA, FCRA (adverse action notices), UDAAP | None |
| CFPB | Updated website and complaint portal; invites debanking complaints | Complaint intake | Already in place |
The emphasis on adverse action notices is telling. Those requirements turn on whether a customer was told why credit was refused, a procedural question that internal emails can answer. The more likely reading is that notice failures are the cleanest path to a case. Many of the OCC’s examples involve companies such as coal operators and firearms makers, and how much of that conduct maps onto consumer financial law is the open question. The bureau’s capacity is a separate one: its funding fight has now gone through three courts.
4. The banks’ case and the administration’s
The releases carry no response from any of the nine banks. The strongest version of the industry argument draws on the record itself. Banks are expected to manage risk and are punished when they do not; the OCC, FinCEN and OFAC just penalized Bank of America over a deficient anti-money-laundering program, a case gov.house covered Oct. 16. Reputation risk was also a supervisory concept, not a bank invention. The OCC lists “eliminating considerations of reputation risk in bank examinations” among its own recent actions, and the CFPB says it reviewed its Examination Manual to ensure it does not contain reputation risk concepts. For much of the 2020 to 2025 window, examiners were looking for exactly what the banks were managing.
For much of the review window, examiners were looking for exactly what the banks were managing.
The administration’s answer is that vague criteria are the problem. Gould said the OCC is “not forcing these banks to serve every customer,” only requiring “objective, risk-based criteria.” On that view, a sector exclusion triggered by headlines rather than credit analysis is not risk management at all. Paoletta’s statement goes further, calling the practices “thuggish tactics” aimed at supporters of President Trump.
5. What happens next
- OCC rulemaking or guidance: the agency says it is “considering actions” on discrimination and reputation risk. No proposal or date has been published.
- CFPB investigations: announced Oct. 14 with no timeline. Any public enforcement action would be the first concrete test of the ECOA, FCRA and UDAAP theories.
- The nine banks: Gould credited “certain efforts” to rein in the practices but called them possibly insufficient. Whether the banks publicly contest the findings is the next signal.
- Supervision: the OCC says it now weighs improper debanking in licensing applications and certain examinations, so the findings can surface in deal approvals before any rule is written.
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