Overview

• The OCC said evidence of politicized or unlawful debanking will factor into reviews of branch, merger and leadership applications as well as Community Reinvestment Act evaluations.
• Comptroller Jonathan Gould requested information from the nine largest OCC‑regulated banks about any debanking activity and updated the agency’s customer complaint portal.
• The OCC issued a separate bulletin reminding banks to safeguard customer financial records and warned against using voluntary Suspicious Activity Reports to evade the Right to Financial Privacy Act.
• The SBA directed more than 5,000 lenders to identify, reinstate and notify affected clients by December 5, 2025, and to file compliance reports by January 5, 2026, with potential punitive measures for failures.
• Regulators have begun removing references to reputational risk from supervisory materials, and confirmed findings of debanking could lead to CRA downgrades, consent orders or referrals to the Attorney General under the executive order.