On October 14, 2026, the Office of the Comptroller of the Currency dropped a report that should be on every small business owner’s radar. After reviewing nearly 100,000 customer complaints and 420,000 pages of internal bank documents, the OCC found that all nine of the largest national banks it supervises had policies or practices that denied or restricted financial access to Americans based on their political or religious beliefs, or their otherwise lawful business activities.
The banks named in the report: JPMorgan Chase, Bank of America, Citibank, Wells Fargo, U.S. Bank, Capital One, PNC Bank, TD Bank, and BMO Bank. Together, they handle the lion’s share of small business checking accounts, credit lines, and merchant processing in this country.
What Changed
The OCC’s report is the final output of a supervisory review launched under President Trump’s Executive Order 14331, “Guaranteeing Fair Banking for All Americans.” The review covered bank behavior between 2020 and September 2025 — a five-year window during which the OCC found that these institutions maintained both public and nonpublic policies restricting access for entire industry sectors.
Those sectors included: oil and gas exploration, coal mining, firearms and ammunition manufacturing or distribution, construction or operation of detention facilities, tobacco and e-cigarette companies, and digital asset businesses.
“Today’s report provides irrefutable evidence that the nation’s largest banks have denied, debanked and discriminated against customers and lawful businesses,” said Comptroller of the Currency Jonathan V. Gould in the release. “Fair access to financial services is not a mantra — it is a mandate.”
In response, the Consumer Financial Protection Bureau (CFPB) also announced a separate initiative to investigate whether the named banks violated federal consumer financial laws, including the Equal Credit Opportunity Act and Unfair, Deceptive, or Abusive Acts or Practices standards. Translation: the federal scrutiny on these banks is not over.
The Numbers Behind It
The scope of this review is hard to overstate:
- 100,000 complaints reviewed from customers of OCC-regulated institutions
- 50,000 documents (approximately 420,000 pages) collected from the nine banks
- 9 of 9 banks reviewed had qualifying problematic policies or practices
- 5-year window covered: January 2020 through September 2025
The OCC identified a core problem: broad “reputation risk” policies that lacked clear, objective, risk-based criteria. These subjective standards gave banks cover to drop customers in industries that carried no actual financial risk — just regulatory or political baggage.
Per the OCC’s report, the agency has already taken steps including eliminating reputation risk from bank examinations, and the OCC and FDIC have finalized a rule barring examiners from pressuring banks to drop customers based on political or religious beliefs. The OCC said it is “considering further changes to the regulatory and supervisory framework” for the largest banks.
The Hustler’s Library Take
Here’s what most coverage of this story is missing: this isn’t just about guns and oil companies. The debanking problem has quietly affected a much wider range of entrepreneurs than anyone wants to admit.
Owners of cannabis-adjacent businesses, CBD retailers, adult content platforms, certain firearms retailers, vape shops, crypto traders, and even some politically vocal small business owners have faced sudden account closures with little to no explanation. The common thread wasn’t fraud or risk — it was that these businesses made banks nervous from a reputational standpoint.
The OCC’s new rule eliminating reputation risk from bank examinations is genuinely significant. But the bigger takeaway is this: the entire episode is a case study in why you should never put all your financial infrastructure in one place. If your operating account, merchant account, and business line of credit are all at the same big bank — and that bank decides your industry is inconvenient — you’re out of business before you even know what happened.
Fintech alternatives have matured enough that building a multi-rail financial setup is no longer complicated. And if you’re in a sector historically targeted by these policies, the OCC report is your signal to get your backup rails in place now, not after something goes wrong.
What You Should Do
1. Audit your banking dependencies right now. If your entire financial operation runs through one of the nine named banks, map out the exposure. That means your business checking, your merchant processing, your payroll provider, and your credit line. If more than two of those are at the same institution, diversify. The OCC’s own report makes clear that the risk of arbitrary access restrictions is real, documented, and ongoing despite recent reforms.
2. Build a backup merchant and banking rail. Platforms like Mercury, Relay, Bluevine, and others now offer FDIC-insured business banking with faster onboarding and fewer industry restrictions than legacy banks. If you’re in a sector that has historically drawn bank scrutiny (anything involving firearms, crypto, tobacco, adult content, or politically adjacent industries), open a secondary account at a fintech-native platform as insurance. Keeping 30 to 60 days of operating reserves there is cheap peace of mind. You can also explore our guide to decentralized finance alternatives for entrepreneurs to understand what’s possible outside the traditional banking system.
3. Document your banking relationships proactively. The OCC’s process relied heavily on complaints. If you’ve ever been debanked, had an account closed unexpectedly, or been denied credit without a clear explanation, file a complaint with the OCC (occ.gov) and the CFPB (consumerfinance.gov). The data being collected now is shaping future regulation. Your complaint becomes part of the official record — and this report proves that record gets read. You can also use this moment to strengthen the fundamentals: read up on how to build financial runway so a sudden banking disruption doesn’t become an existential crisis.
If you’ve had a positive SBA experience and your bank relationship is solid, good. But know that the OCC report found problems at every single one of the nine largest banks it reviewed. This is a systemic issue, not a one-off — and the smart play is to build resilience before you need it.
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