On Wednesday the Office of the Comptroller of the Currency, the federal regulator of national banks, published the final report of its review of debanking at the nine largest banks it supervises: JPMorgan Chase, Bank of America, Citibank, Wells Fargo, U.S. Bank, Capital One, PNC, TD and BMO (OCC news release).
The report is called Guaranteeing Fair Banking for All Americans. Its central finding is that between 2020 and September 2025, all nine banks had policies that could have required, encouraged or otherwise influenced them to deny services because of customers’ political or religious beliefs or lawful business.
Most of the coverage today is about whose accounts were closed. We think the more important finding is how, because the mechanism the report documents is one this coalition has spent a year describing.
A label from outside the bank went into the file. The account came out. The customer was rarely told why.
Story at a glance
- The OCC reviewed nearly 100,000 complaints and about 50,000 bank documents running to some 420,000 pages (OCC).
- To judge “reputation risk,” banks relied on what the report calls non-traditional sources, including “the opinions of advocacy organizations, like the Southern Poverty Law Center, third-party environmental and social governance reports, and complaint data” (report, p. 17 of the PDF).
- In four of the report’s examples, a Southern Poverty Law Center “hate group” label appears in the bank’s reasoning. In one, a bank employee later edited the internal record to remove the words “right wing” and “religious.”
- Capital One turned away a reproductive-rights group, a public-education group whose political arm endorsed Democrats, and a gun-rights group, all under one “partisan activity” policy.
- Closure letters routinely gave no real reason. In several cases, the OCC found the account “could likely have remained open” if the bank had explained itself.
- The OCC announced no fines or penalties (Reuters).
What the regulator looked at
The review was ordered under Executive Order 14331, signed August 7, 2025, which directs bank regulators to ensure decisions are made “on the basis of individualized, objective, and risk-based analyses” (White House). The OCC announced the review in September 2025 and published preliminary findings that December, which focused on restricted industries such as oil and gas, coal, firearms and private prisons.
The final report goes further. It examines individual decisions about individual customers, quoting the banks’ own internal notes. Names are redacted; the examples are, in the OCC’s words, “non-exhaustive.” We haven’t seen the underlying files, and we quote only what the OCC published.
The label did the work
The report’s description of how banks assessed reputation risk is the passage we would put in front of every member of Congress. Banks, it says, consulted negative-news screenings and also relied on advocacy groups’ opinions and ESG reports. “Reliance on these sources added another layer of potential subjectiveness and bias to an already speculative determination” (report, p. 17).
The examples show what that looked like:
- JPMorgan’s payments subsidiary, WePay, closed the account of a conservative legal advocacy organization in December 2020 “due to the merchant being associated with a known hate group.” The notes flagged the Southern Poverty Law Center’s identification of the group (p. 20).
- In June 2021, WePay closed the account of a religious nonprofit it had served since 2019 after an escalation that cited the SPLC’s “extremist hate group” label. The OCC found “no evidence to suggest the merchant’s views changed during that time.” In 2023, a bank reputation-risk employee removed references in the internal tracking system to the nonprofit being “right wing” and “religious” (p. 21).
- Wells Fargo sent a payment processor third-party material on a religious nonprofit’s views on same-sex marriage and asked whether it “change[d] their stance.” The processor cut the nonprofit off with immediate effect. When it asked how to identify problem clients, Wells Fargo pointed to three resources: the SPLC, the Anti-Defamation League and BloodMoney.org. The nonprofit “received no advanced warning” (p. 22).
- TD gave a nonprofit a “High” reputation-risk rating in 2021 partly because of SPLC “hate group” allegations, and prepared talking points saying it would not process a second Paycheck Protection Program loan (p. 23).
- PNC declined a line of credit to a growing media company after its ESG group noted that one owner’s foundation had funded groups “identified as hate groups by the Southern Poverty Law Center” (p. 18).
We take no position here on the SPLC’s right to publish its opinions; that is protected speech. The problem the report identifies is what happened next: a private group’s label was treated as a finding of risk by an institution that never asked the customer for their side.
It cut both ways
This is the part of the report most of today’s headlines skip, and it’s the reason the findings should matter to everyone.
Until 2025, one Capital One business line treated any entity engaged in “partisan activity” as presumptively high reputation risk, regardless of party. The OCC says the policy “appears to have been applied consistently to organizations on both sides of the political spectrum” and that the bank “declined to provide financial services to organizations merely for the constitutionally protected views the organizations espoused” (p. 24).
Under it, Capital One passed on an organization supporting reproductive rights (“Contributions to politicians are about 95% Democrat”), a second reproductive-rights group (“it’s become so synonymous with abortion and the Dems”), a public-education organization whose political arm endorsed only Democrats, and a gun-rights organization “due to optics that we endorsed its position on gun rights” (p. 24; see also Axios and The Wall Street Journal).
A right that only protects one side isn’t a right. The report’s evidence supports a viewpoint-neutral rule, and that is the only kind worth asking Congress for.
Nobody was told why
The OCC reviewed hundreds of closure letters across the nine banks. Customers “frequently received vague account closure letters, often without forewarning, that provided little to no reason” (p. 37). The report quotes some of the language they got:
“your risk profile no longer aligns with the bank’s risk tolerance”
“continuing a relationship is not in the best interest of either party”
“a business decision” or “a risk-based decision”
Customers who called for more were “often read scripts that provided no meaningful explanation.” And in several cases, the OCC found that “if a bank had been more transparent with the customer regarding the reason for its decision prior to closure, the account could likely have remained open” (p. 38).
That last sentence is the whole case for notice. A person who isn’t told the reason can’t correct it.
What the report does not say
- It doesn’t find that the previous administration ordered these closures. Some headlines say the groups were “disfavored by Biden admin.” The report’s findings are about the banks’ own policies. It lists “the views of government entities (including the banks’ own regulators)” among many stakeholder opinions banks weighed, and says the guesswork occurred “whether instigated by regulators or the banks themselves” (p. 8). That is a finding of influence among many factors, not of direction.
- It imposes no penalties. Comptroller Jonathan Gould said the OCC will assess further changes to the rules for the largest banks, and acknowledged “certain efforts by the largest banks to rein in these practices” (OCC). The Consumer Financial Protection Bureau says it will investigate the named banks (Bloomberg, via TechFlow), and the U.S. Attorney for the District of Columbia has subpoenaed several of them (Ground News, summarizing the WSJ).
- The banks haven’t answered yet. Representatives for the banks did not immediately respond to requests for comment (Axios). We will add their responses when they do.
Why we’re following it
Our debanking case study follows one man, the German organizer Michael Ballweg, through the same pattern: a screening-database entry, accounts closed one after another, and no bank willing to say why. The OCC report doesn’t mention him, and the U.S. account he lost in 2026 wasn’t at one of these nine banks. What the report confirms is that the mechanism isn’t foreign and it isn’t rare. It ran inside the largest American banks for five years.
Americans already have a legal right to see and dispute what a credit report says about them. Nothing comparable exists for a reputation-risk file or a screening label. The OCC has now documented, in the banks’ own words, what that gap costs.
If you believe you were debanked for your views or lawful business, the OCC asks you to file a complaint at HelpWithMyBank.gov (report, p. 9).
Restore the First founder Sayer Ji walked through the report’s findings in a thread on X: