OCC Implements New Guidance to Deter Politicized Debanking, Citing Direct Consequences

Washington D.C. – The Office of the Comptroller of the Currency (OCC) on September 8, 2025, rolled out new guidance aimed at curbing "politicized or unlawful debanking" within the federal banking system. This move clarifies the agency's stance on banks denying services based on political or religious beliefs, or lawful business activities, and introduces tangible repercussions for non-compliance. The guidance follows a recent Executive Order from President Donald Trump, which directed federal agencies to investigate discriminatory banking practices.

Comptroller of the Currency Jonathan Gould emphasized the agency's commitment to addressing these issues. "We are working to root out bank activities that unlawfully debank or discriminate against customers on the basis of political or religious beliefs, or lawful business activities," Gould stated. The new directives underscore a shift towards ensuring fair access to financial services for all Americans.

The updated guidance specifies that the OCC will now factor a bank's engagement in "politicized or unlawful debanking" into its assessment of licensing applications and Community Reinvestment Act (CRA) reviews. This means that allegations or evidence of such practices could significantly impact a bank's ability to secure new branches, pursue mergers, or undergo leadership changes, potentially derailing routine business with the OCC.

Industry observers, including Alexander Grieve, highlighted the significance of the OCC's new approach. Grieve noted on social media, > "The single most important line in the @USOCC's debanking guidance yesterday -- actual consequences for banks who participate in debanking. Hats off to @USComptroller Jonathan Gould." This sentiment reflects the perceived strength of the new measures.

Beyond impacting licensing and CRA evaluations, banks found in violation could face more direct disciplinary actions. The Executive Order and subsequent OCC guidance suggest potential remedies including fines, consent decrees, and other disciplinary measures. Furthermore, the OCC has updated its online customer complaint website, allowing consumers to report instances of "unlawful debanking," thereby providing a direct channel for oversight and enforcement.