On Oct. 14, 2026, the Office of the OCC issued a report titled “Guaranteeing Fair Banking for All Americans,” detailing the results of its supervisory review of potential debanking practices at the nine largest national banks it supervises. The report builds on the OCC’s December 2025 preliminary findings discussed in our January 2026 alert.

In the report, the OCC asserted that, between January 2020 and September 2025, broad reputation-risk policies that lacked clear standards and objective, risk-based criteria disadvantaged certain customers from having fair access to financial services based on their political, religious, or social views or based on their lawful business activities. Comptroller Jonathan V. Gould stated that banks are not required to serve every customer, but should evaluate customers using objective, risk-based criteria.1 The report notes that the banks have taken steps to address fair-access concerns.2 The report reflects a supervisory review, not an adjudication that particular conduct violated law.

Click here to read the full GT Alert.

1 See Jonathan V. Gould, Comptroller of the Currency, Remarks on the Debanking of Coal, Firearms, and Other Industries 2–3 (Oct. 14, 2026).

2 See Off. of the Comptroller of the Currency, News Release 2026-91, Comptroller Gould Discusses Findings of Debanking Report (Oct. 14, 2026); Off. of the Comptroller of the Currency, Guaranteeing Fair Banking for All Americans 6–8, 39–45 (Oct. 14, 2026).