What happened
The Office of the Comptroller of the Currency published a 47-page follow-up report on Wednesday to the preliminary debanking findings it issued last December. The regulator said it reviewed nearly 100,000 complaints made to institutions it supervises and combed roughly 420,000 pages of documents covering bank policies, procedures, practices and individual customer decisions at nine banks: JPMorgan Chase, Bank of America, Citi, Wells Fargo, U.S. Bank, PNC, Capital One, TD and BMO.
Comptroller of the Currency Jonathan Gould said the report "provides irrefutable evidence that the nation's largest banks have denied, debanked and discriminated against customers and lawful businesses," adding that fair access to financial services "is not a mantra, it is a mandate." The OCC's core finding is procedural: broad policies on reputational risk "lacked clear standards and objective, risk-based criteria," which the agency says disadvantaged certain Americans.
The report cites specific decisions. JPMorgan allegedly denied services to a conservative-leaning retailer between 2021 and 2023, with internal documents quoted as saying that as more far-right competitor companies take the retailer's extreme clients, "it may become more mainstream and more appropriate for JPM to bank." TD is said to have denied a COVID-era emergency loan to a nonprofit with an anti-immigration stance, with the report pointing to the group's designation as a hate organisation by the Southern Poverty Law Center as an influence. Not every example ran one way: the OCC alleges Capital One rejected an organisation supporting reproductive rights, citing a risk employee's note that the group's political contributions were "about 95% Democrat."
The banks dispute the characterisation. JPMorgan said its policies prohibit discrimination based on political or religious views, described the cited interactions as limited and historical, and told Bloomberg that years of operating under a regulatory environment that often second-guessed decisions contributed to a culture of caution. Gould said he is not confident the banks' efforts will be enough and that the OCC will assess further changes to the regulatory and supervisory framework. The Consumer Financial Protection Bureau said on the same day that it will investigate whether the institutions complied with federal consumer financial laws, with Acting Director Mark Paoletta issuing a statement. President Trump has separately sued JPMorgan and Capital One over debanking.
Why this is a GRC story
Reputational risk without written criteria is the finding. Where "reputational risk" is not defined with objective standards, individual judgement decides who gets an account. Examiners now expect documented criteria, consistent application and evidence.
Challenge and monitoring failed quietly. Decisions that quote a customer's political leanings as a factor are a symptom of criteria drift that quality assurance and second line review should catch long before a regulator does.
De-risking is a governance decision, not a branch one. Fair access expectations require escalation paths, written rationale for exits and periodic review of the policy itself, not just the files.
What to watch
Watch what the OCC changes in examination expectations, whether the CFPB opens enforcement, and how banks rewrite reputational risk language and account closure documentation. The review method, complaints combined with policy documents and decision files, is portable and other regulators may copy it.
Attribution: Analysis based on Banking Dive and related public reporting. This article is original commentary, not a repost of the source material.