BANKING ACCESS & CREDIT POLICY · OCTOBER 16, 2026

OCC Review Finds Fair-Access Problems at Nine Large Banks

The OCC said its review found that nine large national banks had policies between 2020 and September 2025 that could deny or limit services based on political or religious beliefs or lawful business activities.

Business owner and banking professionals reviewing account access, objective risk criteria, compliance, and financing options
PFCS INSIGHTSOCC Review Finds Fair-Access Problems at Nine Large Banks

What the OCC released

Source publication date: October 14, 2026. The Office of the Comptroller of the Currency published findings from its supervisory review of debanking activity at the nine largest national banks it supervises. The review examined whether policies or practices may have denied or limited access to financial services based on political or religious beliefs or lawful business activities. The OCC said all nine banks had such policies between 2020 and September 2025.

PFCS VISUAL BRIEFLarge-bank fair-access review
9 banksinstitutions in the OCC supervisory review
  1. 01Nearly 100,000 complaints reviewed
  2. 02Sector restrictions were identified
  3. 03Prepare objective risk evidence
Educational visual · Transaction terms and lender requirements vary.

The review focused on reputation policies and sector limits

The OCC reported that broad reputation-risk policies without clear standards and objective, risk-based criteria disadvantaged certain customers. It also found public and nonpublic restrictions affecting sectors including oil and gas, coal, firearms, detention facilities, tobacco or e-cigarettes, and digital assets. The agency reviewed nearly 100,000 complaints and received about 50,000 documents totaling roughly 420,000 pages. The findings concern supervisory policy and do not require a bank to approve any particular account or loan.

Further supervisory changes may follow

The OCC said it has removed reputation-risk considerations from bank examinations, clarified how improper debanking can affect certain licensing and examination matters, and improved complaint intake and review. It is considering additional regulatory and supervisory changes for the largest banks. Institutions can still make lawful, objective decisions based on credit, fraud, anti-money-laundering, sanctions, compliance, operational, and other risks. Actual product availability and underwriting remain bank- and transaction-specific.

Practical borrower takeaway

Businesses in sectors that draw heightened review should maintain clear ownership and beneficial-owner records, licenses, policies, financial statements, tax filings, source-of-funds support, customer and vendor diligence, compliance evidence, and a concise explanation of lawful operations. Ask a bank which objective issues drive any restriction and use appropriate complaint or review channels when warranted. Preserve backup operating accounts and multiple financing relationships where practical, but never use account fragmentation or another tactic to evade lawful controls.

PFCS borrower takeaway

Borrowers in scrutinized industries should document lawful operations, objective risk controls, ownership, cash flow, and compliance while preserving more than one suitable banking and financing relationship.

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This independent summary is based on the cited source and is provided for general educational purposes only. Terms and program requirements may change.