The OCC conducted its supervisory review in accordance with the President’s Executive Order, “Guaranteeing Fair Access to Banking for All Americans.” Comptroller of the Currency Jonathan V. Gould said, “Americans should have access to financial services regardless of their beliefs, affiliations, or political views.”
The OCC found that broad reputation risk policies—which lacked clear standards and objective, risk-based criteria—disadvantaged certain Americans based on their political, religious, or social views or based on their lawful business activities.
The OCC first announced this review of its nine largest banks by asset size in September 2025 and issued preliminary findings in December 2025.
My guess is the next rule will turn that lack of confidence into a compliance requirement.
Comptroller Gould said, “Notwithstanding certain efforts by the largest banks to rein in these practices, I am not confident that they will be enough.”