In 2025, debanking initiatives continued to intensify, with new guidance, legislation, and other actions at both the federal and state levels aimed at so-called “discriminatory debanking.” Those actions included:
- Federal and state policymakers advancing “fair access” initiatives aimed at preventing financial institutions from denying or restricting services based on certain factors, including political opinions, religious beliefs, and environmental, social, and governance standards.
- The Guaranteeing Fair Banking for All Americans Executive Order (the Executive Order) providing that federal banking regulators must eliminate “reputational risk” as a supervisory factor and requires such regulators to identify and remediate any “politicized or unlawful debanking” practices.
- Federal agencies, including the Office of the Comptroller of the Currency (OCC) and Small Business Administration (SBA), issued parallel guidance and enforcement directives, while Congress has advanced legislation aimed at creating a uniform national standard.
- States, such as Florida, Tennessee, and Idaho enacted their own “fair access” laws prohibiting discriminatory debanking, with similar legislation pending in several other states.