"The Treasury Department" by Robert Lyle Bolton is licensed under CC BY 2.0
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On December 10th, 2025, the Office of the Comptroller of the Currency released its preliminary findings on its review of debanking activities.
The findings reiterate that debanking targeted certain industries on the basis of reputational risk. The OCC listed sectors that were mainly affected, including, but not limited to: fossil fuel companies, firearms manufacturers and retailers, tobacco and e-cigarette manufacturers and distributors, digital asset issuers, and political entities.
The OCC stated that it is “continuing its work to better understand the full extent and effects of these actions, and their impact on affected industries and the American economy”.
In October, the OCC announced that the agency would undertake measures to eliminate politicized and unlawful debanking. Among these measures, the OCC and FDIC issued a notice of proposed rulemaking to codify the elimination of reputational risk from bank supervision activities. The proposed rule would prohibit the OCC and FDIC from meddling in bank-customer relationships by requiring or encouraging banks to close accounts or refrain from providing services on the basis of social, cultural, political, or religious views.
The OCC stated that it is committed to aligning future policies and practices with President Trump’s executive order to end debanking. President Trump’s order directed federal agencies to rescind all rules that could result in politically motivated debanking and remove the reputational risk category for supervision assessments.
Debanking began under the Obama administration. A House Oversight Committee report in 2014 documented numerous instances of FDIC regulators harassing and encouraging banks to debank customers operating in industries that were politically disfavored by the Obama administration. On December 1st, 2025, the House Financial Services Committee released its finalized report on Operation Choke Point 2.0, detailing how Biden-era regulators acted to stifle digital asset firms.
The report noted that:
“The FDIC sent ‘pause’ letters to financial institutions effectively encouraging them to stop efforts to engage in digital asset-related activities. This delay tactic—and the FDIC’s voluminous document requests—made it impracticable for financial institutions to pursue digital asset-related activities.”
The report also found that the OCC “layered on additional red tape for digital asset-related activities, for example by requiring each supervised institution to receive a non-objection letter before engaging in digital asset activities.”
Regulators have no business in assessing banks on reputational risk matters. Banks are already invested in safeguarding their reputation in order to deliver shareholder value and protect clients against any material harm that reputational damage may incur. The notion that regulators can be more aligned with a bank’s reputational concerns than the bank itself should be dismissed.
Regulators have long weaponized reputational risk matters to compel banks in debanking customers. The Trump administration’s executive order, along with the commitments made by the FDIC and OCC to abandon reputational risk considerations, is a step in the right direction.
Banks do not arbitrarily debank customers based on their beliefs and political viewpoints. This phenomenon is not a manifestation of free market forces, but the effect of heavy-handed government interference. Regulators have demonstrated they are willing to abuse their power to advance political agendas.
The OCC should continue to undo the damage done by the previous administration and implement the agenda outlined in President Trump’s executive order. By limiting the power of administrative agencies to influence access to financial services, the administration will be able to put an end to debanking.
