OCC finds fair-access concerns at nine national banks
The Office of the Comptroller of the Currency said nine of the largest national banks under its supervision maintained policies and practices that could have encouraged employees to deny or restrict financial services without clear, objective standards. The findings cover the period from January 2020 through September 2025.
The review focused on so-called debanking, a term used when a bank closes an account or declines to provide services. The OCC said broad reputation-risk policies and industry-specific procedures created an elevated risk that customers could lose access because of their political, religious or social views, or because of lawful business activities.
The agency released its final report, titled “Guaranteeing Fair Banking for All Americans,” on Oct. 14, 2026. Comptroller of the Currency Jonathan V. Gould said banks do not have to serve every potential customer, but their decisions should rely on objective, risk-based criteria rather than subjective judgments.
“was unable to quantify on a comprehensive basis the full extent of debanking or alleged debanking actions,” the OCC said.
The report does not identify a violation of law or announce an enforcement action. It also does not provide a comprehensive measure of how many customers may have been denied accounts or other banking services. Instead, the OCC described the findings as a supervisory warning about how banks design and apply their policies.
CFPB launches separate review
The Consumer Financial Protection Bureau has separately announced that it will investigate whether institutions named in the OCC report, and potentially other institutions, complied with federal consumer-finance laws. The CFPB’s review adds a consumer-protection inquiry to the OCC’s supervisory examination.
The agencies’ actions could affect how banks handle customer onboarding, account closures and complaints. The OCC said financial institutions should review those processes in light of fair-access requirements and regulatory expectations at both the federal and state levels. The report’s conclusions do not, by themselves, determine that any particular customer was unlawfully denied service.
| What the OCC reviewed | What the report says |
|---|---|
| Institutions | Nine of the largest national banks under OCC supervision |
| Review period | January 2020 to September 2025 |
| Primary concern | Reputation-risk and industry policies lacking clear, objective, risk-based standards |
| Enforcement announced | None in the report |
What banks are expected to examine
The OCC’s findings point banks toward several areas of internal review:
- Rules for accepting new customers and businesses.
- Standards used to terminate accounts or end banking relationships.
- Complaint systems and the way customer concerns are categorized.
- Whether fair-access expectations are reflected in federal and state compliance programs.
The report builds on preliminary findings the OCC issued in December 2025. The final report continues scrutiny of whether banks’ use of reputation-risk considerations can produce inconsistent treatment, while preserving the principle that banks may make risk-based decisions about whom they serve. The CFPB investigation could determine whether additional action is warranted under federal consumer-finance laws.