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Guaranteeing Fair Banking for All Americans

Executive Summary

Under President Donald J. Trump's leadership, the U.S. government is committed to restoring fair access to financial services, which is a fundamental principle of the U.S. banking system.

Debanking Report Background

In accordance with Executive Order 14331, Guaranteeing Fair Access to Banking for All Americans, the OCC conducted a supervisory review of debanking activities at the nine largest banks by asset size under its supervision to determine whether these banks’ policies or practices may have required, encouraged, or otherwise influenced banks to deny or limit access to financial services to Americans because of their political or religious beliefs or lawful business activities.

The OCC's findings show that, between 2020 and September 2025, all nine banks had such policies.

“Total assets of OCC-regulated institutions: $16.7 trillion.” The subheading reads “The nine largest institutions hold $12.7 trillion, or 76 percent of the total. The pie chart shows JPMorgan Chase has $3.8 trillion in assets; Bank of America holds $2.7 trillion in assets; Citibank holds $1.8 trillion in assets; Wells Fargo holds $1.8 trillion in assets; U.S. Bank holds $683 billion in assets; Capital One holds $652 billion in assets; PNC holds $564 billion in assets; TD Bank holds $476 billion in assets; BMO Bank holds $249 billion in assets; and all other OCC regulated institutions hold $4 trillion in assets. This data is current as of September 30, 2025.

Primary Categories Identified

The OCC identified two primary categories of policies that presented an elevated risk of “encouraging” or “otherwise influencing” institutions to deny access to financial services to categories of customers or prospective customers based on their political or religious beliefs or affiliations or lawful business activities.

Reputation Risk Practices

Reputation Risk Practices

Bank policies, procedures, and practices that restricted entering or maintaining customer relationships to manage "reputation risk." Although not defined under the Executive Order, reputation risk generally refers to the potential for adverse economic or brand impact to an institution resulting from negative public perception associated with a particular customer relationship.
industry-Specific Practices

Industry-Specific Practices

Bank policies, procedures, and practices that restricted certain industry sectors' access to financial services for reasons unrelated to financial or operational concerns. These restrictions varied from categorical prohibitions to escalated reviews and approvals before providing access to financial services.

Highlighted Examples

Debanking Partisan Groups
In February 2023, one bank declined to provide financial services to a public education organization due to its partisan leanings-namely, the organization's political arm's endorsement of solely Democratic candidates.
Reputation Risk Impacts Debanking Partisan Groups
Firearms, Ammo & Accessories
Several banks restricted financing to firearms manufacturers or retailers, including those offering assault- or military-style weapons for civilian use. Others included certain firearms accessories.
Industry-Specific Impacts Firearms, Ammo & Accessories
Merchant Selling MAGA Gear
In February 2021, a payment processor owned by one bank closed the account of a merchant that sold merchandise promoting President Trump and the Make America Great Again (MAGA) brand.
Reputation Risk Impacts Merchant Selling MAGA Gear
Oil and Gas Exploration
Most banks restricted access to financing oil and gas exploration, development or production in the Arctic. These restrictions in general were part of larger "ambitious" climate campaigns intended to advance the banks' "environmental commitments."
Industry-Specific Impacts Oil & Gas Exploration
Digital Asset Activities
Many institutions also placed restrictions on banking digital asset activities, including on issuers, exchanges, or administrators, often attributed to financial crime considerations.
Industry-Specific Impacts Digital Asset Activities
Coal Mining or Plants
Most banks restricted access to financing for new, or expansions of existing, coal mining or plant operations. Some banks went as far as to state that they would not provide financial services to companies deriving a percentage of their revenue from coal extraction, mining, or coal products.
Industry-Specific Impacts Coal Mining or Plants

"It is the policy of the United States that no American should be denied access to financial services because of their constitutionally or statutorily protected beliefs, affiliations, or political views, and to ensure that politicized or unlawful debanking is not used as a tool to inhibit such beliefs, affiliations, or political views."

PRESIDENT TRUMP'S EXECUTIVE ORDER 14331 "Guaranteeing Fair Banking for All Americans"
Detention Facilities
Most institutions restricted access to certain financial products or services for detention facilities, with some banks or lines of business in banks listing "immigrant detention centers" in this category.
Industry-Specific Impacts Detention Facilities
Tobacco & E-Cigarette Manufacturing
Many banks restricted access to one or more of these providers with respect to certain financial products or services. Some banks extended these restrictions to certain related products, including filters, packaging, pipes, and "other smokers' supplies."
Industry-Specific Impacts Tobacco & E-Cigarette Manufacturing

OCC Efforts to Address Debanking and Promote Fair Access

Americans who are denied financial services or whose accounts are suddenly closed experience real world financial consequences. The OCC has taken or is considering taking the following actions to promote fair access to financial services in the federal banking system:

Guaranteeing Fair Banking for All Americans is and will remain a priority of the OCC.