The Office of the Comptroller of the Currency on Oct. 14 released a review that concludes the nine largest national banks used policies and practices that may have denied or limited services to customers because of their political or religious beliefs or lawful business activity. The Consumer Financial Protection Bureau said on the same day it will investigate whether those institutions complied with federal consumer‑finance laws.
What the OCC reviewed and found
The OCC conducted its review under Executive Order 14331, “Guaranteeing Fair Access to Banking for All Americans,” examining bank policies and practices through Sept. 2025. The agency said it examined nearly 100,000 complaints and reviewed about 420,000 pages of documents provided by the banks.
| Findings | Character |
|---|---|
| Reputation‑risk policies | Broad rules that “lacked clear standards and objective, risk‑based criteria” and disadvantaged certain customers |
| Sector restrictions | Policies restricting services for customers in specific industries, such as oil and gas, coal, firearms, detention facilities, tobacco and digital assets |
Regulators move from policy to possible enforcement
The OCC said its assessment followed preliminary findings issued in December 2025 and acknowledged that banks had made some efforts to change practices. Comptroller Jonathan V. Gould was quoted about remaining doubts:
“not confident that they will be enough”
The Comptroller’s comment, as reported by the OCC materials, indicates the regulator sees deficiencies that may require further action.
Separately, the CFPB said it will investigate whether the nine banks, “and others,” complied with federal consumer financial laws. The bureau’s statement signals the federal consumer‑protection regulator may pursue supervisory reviews or enforcement if it finds legal violations.
Why this matters to consumers
- Bank policies about reputation risk and sector restrictions can affect whether individuals or small businesses keep accounts, access payments, obtain loans or receive other basic financial services.
- The agencies’ reviews could lead to guidance, supervisory action or enforcement that changes how large banks screen customers and manage risk, with nationwide effects on access to banking.
- Consumers who have been denied services for lawful activity or industry reasons may see new routes for review or remediation if regulators find legal violations.
The OCC review and the CFPB inquiry represent a coordinated federal effort to test whether bank risk‑management frameworks have cut off or narrowed account access for people and businesses for reasons unrelated to illicit conduct. The OCC report and the CFPB announcement together move the debate from policy statements to institution‑level findings and potential enforcement steps.
The OCC’s report and the CFPB’s statement are public actions by two federal regulators; neither the review nor the CFPB notice is a judicial finding. The agencies’ next steps could include supervisory directives, formal enforcement actions or regulatory guidance, depending on what each agency uncovers in follow‑up work.
