OCC to focus on Debanking in CRA Reviews

Following President Trump’s Executive Order last month, Executive Order 14331 (the “EO”), on September 8, 2025, the Office of the Comptroller of the Currency (“OCC”) released a bulletin on politicized or unlawful debanking (the “Bulletin”).

The Bulletin – from newly Senate confirmed comptroller Jonathan Gould – clarifies how the OCC will consider politicized or unlawful debanking in licensing files and bank records under the Community Reinvestment Act (“CRA”) consistent with the EO.

Specifically, the Bulletin notes that the OCC will:

• As part of its review of licensing filings, consider a bank’s record of, and policies and procedures designed to avoid, engaging in politicized or unlawful debanking.
• Examine whether a bank has engaged in politicized or unlawful debanking in determining, on a case-by-case basis, a bank’s CRA rating.

For its part, the EO cited a number of examples of the type of “debanking” activity the OCC may be looking for as part of the Bulletin, including reports of institutions flagging transactions at companies like Cabela’s and Bass Pro Shop or flagging peer-to-peer transfers referencing Preside Trump or “MAGA.”

Banks should be aware that potential debanking activity will be a focus of the OCC in CRA reviews going forward.

The OCC Bulletin can be found here.

A copy of President Trump’s Executive Order on “debanking” is available here.