LEGACY & INSIGHTS
The OCC Debanking Report Questions Reputation-Risk Decisions at Nine Major Banks
OCC debanking report findings ask when a bank’s reputation worry becomes a reason to turn away lawful customers, while the banks answer with policy and legal duties.

The OCC debanking report starts from a simple fact: when a bank closes an account, payroll, bill payments and donations can stop. On October 14, the Office of the Comptroller of the Currency released Guaranteeing Fair Banking for All Americans. In it, the agency says policies or practices at nine major banks from 2020 to 2025 may have required, encouraged or otherwise influenced cutting off customers over political or religious views or lawful business activity, Banking Dive reported. Those findings are the agency’s own, and no court has ruled on them. Still, the question is older than this report: when does a bank’s judgment about risk become a way of deciding who gets in?
The OCC Debanking Report Draws on Years of Complaints and Records
First, the agency named JPMorgan Chase, Bank of America, Citibank, Wells Fargo, U.S. Bank, Capital One, PNC Bank, TD Bank and BMO Bank. Also, it reviewed nearly 100,000 consumer complaints and about 420,000 pages of internal bank records, and the report is available as a PDF. Because not every finding necessarily applies to all nine banks, we tie each example to the bank named.
The OCC Debanking Report Meets a Longer History of Bank Bias
American banking has a documented record of shutting Black borrowers out. From 1934 until the 1960s, the Federal Housing Administration institutionalized redlining, according to the Federal Reserve. Congress responded with the Fair Housing Act of 1968, which banned discrimination in mortgage lending, including racially motivated redlining. The Equal Credit Opportunity Act followed in 1974, and the Community Reinvestment Act in 1977 affirmed banks’ duty to serve the communities where they operate.
That history is not over. In January 2024, the Justice Department announced a $1.9 million agreement with Patriot Bank to resolve allegations that, from 2015 through at least 2020, it avoided mortgage lending in majority-Black and Hispanic Memphis neighborhoods. Other banks drew nearly 3.5 times as many applications there, the department said. However, the bank denied the allegations.
None of this makes redlining the same as the closures in the OCC’s report. They involve different practices, evidence and legal questions, and the OCC frames its findings around political and religious beliefs and lawful business activity, not race.
Cases in the OCC Debanking Report Cross Ideological Lines
Banking Dive reported three examples from the OCC’s document. At JPMorgan, the OCC said the bank repeatedly denied services to a conservative-leaning retailer from 2021 to 2023. TD Bank, by contrast, denied a COVID-era emergency loan to a nonprofit with an anti-immigration stance, and the OCC said the group’s status as a “hate group” influenced the decision, a label Banking Dive tied to the Southern Poverty Law Center. Capital One, meanwhile, rejected a reproductive-rights organization, and a bank risk employee reportedly wrote that its political contributions “are about 95% Democrat.”
The TD example raises the hardest question: should a group labeled a “hate group” keep access to a bank? Banks are private companies, and federal law protects customers from discrimination based on race or religion but does not treat political viewpoint the same way. Still, banking is close to essential infrastructure, and the label comes from a third party whose designations critics call subjective. Many people therefore draw the line at conduct. A bank can refuse fraud, violence or sanctioned activity, but a belief alone should not decide.
Because the examples reach across viewpoints, the story is not about one side. Comptroller Jonathan Gould called the findings “irrefutable evidence” of debanking, Banking Dive reported. Banking Dive gave no examples for the other six banks, however, and the examples alone do not show how common such closures were.
Banks Cite Policy, and Three Questions Test the Claim
JPMorgan told Bloomberg that its policies prohibit discrimination based on political or religious views, Banking Dive reported. The bank said the OCC cited “a limited number of historical interactions” and that it has improved its practices. It added that regulatory second-guessing fostered caution: “That system needs fixing.”
Reputation risk is the chance that a customer relationship damages a bank’s public standing. Three questions separate risk management from exclusion. Did the bank cite a written, objective criterion? Did it apply that criterion the same way to every customer, whatever their politics, religion or race? Could it explain the decision to the customer? A yes to all three points toward risk management. A no to any of them invites a closer look.
Legal duties complicate the picture, because banks must follow anti-money-laundering, sanctions and fraud rules, and closing an account to meet them differs from closing one over reputation. Still, nothing in the reporting establishes an automatic right to an account regardless of legitimate risk.
CREATOR & INSTITUTIONAL INFRASTRUCTURE
What the OCC Debanking Report Means for Customers
An account closure has real costs. Households can lose direct deposit, small businesses can lose payroll and nonprofits can lose donation processing. If a bank closes an account, a customer can ask for the reason in writing and keep every notice. Complaints go to the OCC’s consumer help site for national banks, or to the CFPB complaint portal. Complaints are allegations, not findings, and one closure is not proof of bias.
What Comes Next After the OCC Debanking Report
Next, Gould said the OCC will assess further changes to its supervisory framework. Meanwhile, the CFPB said it will “fully investigate” whether the banks complied with federal consumer financial laws. Banking Dive reported no timeline for either. The Patriot Bank case shows what accountability can look like: application data, comparisons across neighborhoods and remedies that outlast the headlines. Whether the allegation involves race, politics or religion, the same demand applies. Banks should show their reasons, and regulators should show their work. Until both do, access to a bank account will keep depending on who is deciding.
Signal Breakdown
Confirmed / Documented
- Report. The OCC released Guaranteeing Fair Banking for All Americans on October 14 (OCC).
- Scope. The review covered nine named banks, while its period runs from 2020 through September 2025 (OCC).
- Evidence. It also drew on nearly 100,000 consumer complaints and about 420,000 pages of bank records (OCC).
- History. The Federal Reserve says the FHA institutionalized redlining from 1934 (Federal Reserve History).
- Enforcement. The Justice Department announced a $1.9 million Patriot Bank agreement in January 2024 to resolve redlining allegations (DOJ).
Reported / Attributed
- OCC view. The agency says policies or practices at nine banks may have influenced debanking over political or religious views or lawful business activity.
- Cases. Examples at JPMorgan, TD Bank and Capital One come from Banking Dive’s account, while JPMorgan says its policies prohibit such discrimination.
- CFPB. Banking Dive reports the agency will investigate compliance with federal consumer financial laws.
Not Established
Available evidence does not establish:
- a court ruling of wrongdoing
- that every closure was discriminatory
- a finding of racial discrimination in the OCC’s cited examples
- an automatic right to an account despite legitimate risk
- criminal misconduct or a final regulatory rule
RADAR / WHAT TO WATCH
KMOB1003 SELECTS
Music, style, tools, art and objects worth your attention.
















