The Office of the Comptroller of the Currency (OCC) concluded that all nine major U.S. national banks maintained policies capable of restricting customer access to financial services based on political beliefs, religious affiliations, or lawful commercial activities. The investigation examined JPMorgan Chase, Bank of America, Citibank, Wells Fargo, U.S. Bank, Capital One, PNC, TD Bank, and BMO Bank.
The OCC reviewed nearly 100,000 complaints and approximately 420,000 pages of internal documents covering the period from 2020 through September 2025. The findings identified instances where banks applied subjective judgments rather than measurable financial criteria when assessing reputation risks.
Specific Cases Identified
JPMorgan's payment subsidiary Wepay terminated an account selling Trump merchandise and Make America Great Again merchandise in February 2021. An internal employee explanation stated the account was closed for violating the company's terms of service regarding MAGA and Trump-related items.
PNC declined to extend credit to a conservative media company, with an internal email questioning whether the bank should associate with the firm given the owners' public political and religious positions.
The investigation also identified restrictions affecting a politically active organization supporting Democratic candidates, indicating that politically motivated restrictions were not limited to one political party.
Industry-Specific Restrictions
Regulators found that six major industries experienced debanking practices, including digital assets, firearms, coal, oil and gas, tobacco, and detention facilities. Banks imposed internal social standards on lawful firearms businesses, including restrictions on magazine capacity and sales to customers under 21.
The report stated: Policies adopting industry-specific restrictions had real-world consequences. Smaller businesses sometimes faced financing obstacles while established companies in the same industries received exceptions.
Inconsistent Application
The OCC uncovered inconsistencies in how banks applied reputation risk assessments. Some customers lost access to services over unfavorable publicity or unverified allegations, while certain wealthy clients retained banking relationships despite attracting more serious negative attention. The regulator acknowledged inability to establish the total number of affected customers or calculate complete financial damage.
Regulatory Response
Comptroller Jonathan V. Gould stated: Today's report provides irrefutable evidence that the nation's largest banks have denied, debanked and discriminated against customers and lawful businesses.
Although banks have revised certain policies, regulators found that reputation risk considerations sometimes persisted under alternative labels including brand risk and franchise risk. Gould cautioned that voluntary changes might prove insufficient and stated: I am not confident that they will be enough.
The OCC has eliminated reputation risk considerations from bank examinations and is weighing additional supervisory changes. Gould concluded: Fair access to financial services is not a mantra—it is a mandate.
