Banking and Finance Law Daily Wrap Up, BANKING OPERATIONS—OCC’s Gould signals further action on reputation-risk debanking, (Oct 15, 2026)

By George M. Gullo, J.D.

Gould said the OCC may pursue additional regulatory changes after finding that large banks used reputation-risk policies to influence access to financial services.

Comptroller of the Currency Jonathan V. Gould, in remarks on the debanking of coal, firearms, and other industries, said an Office of the Comptroller of the Currency (OCC) review found that all nine large national banks examined had reputation-risk policies that allowed political considerations, public opinion, and social pressures to influence access to financial services. In his prepared remarks delivered October 14, 2026, in Lexington, Kentucky, Gould argued that banks should evaluate customers using objective, risk-based criteria, although the OCC is not forcing them to serve every customer. He said the agency had eliminated reputation risk from its supervisory framework and would assess further regulatory and supervisory changes applicable to the largest banks to reduce the likelihood that such practices recur.

Debanking report. According to Gould, the OCC released its Debanking Report in response to President Trump’s executive order, Guaranteeing Fair Banking for All Americans, which directed federal banking regulators to examine whether institutions denied access because of political or religious beliefs or lawful business activities. Banking and Finance Law Daily previously reported that the review found the nine largest supervised banks engaged in debanking from 2020 to 2025 by denying or limiting services because of applicants’ political or religious views (see Banking and Finance Law Daily, Oct. 14, 2026). The review examined nearly 100,000 complaints and approximately 420,000 pages of documents, Gould said.

Gould stated that lawful industries faced heightened scrutiny because some banks or employees considered their activities controversial. He characterized the practices as having evolved from executive decisions into institutionalized, opaque bureaucracies that enabled employees to cut off people and industries from financial services or create procedural barriers with the same practical effect. “Banks should make decisions based on financial risk, not the political or social preferences of their employees or executives,” Gould said.

Industry examples. Coal and firearms were two industries particularly affected, according to Gould. Many banks maintained policies restricting financing for new or expanded coal-mining operations and coal-fired power plants, while some restricted services based on how much revenue a company derived from coal-related activities. Gould said banks cited negative headlines, public protests, and perceived reputational consequences, rather than financial risk, when making those decisions.

Several banks also restricted financing for firearms manufacturers and retailers, Gould said. In one example, a bank declined a loan of less than $50,000 to a small firearms-related business while approving a multimillion-dollar letter of credit for a larger industry participant. In another, a bank denied a firearms business assistance with an initial public offering because the company’s policies governing lawful firearms sales did not align with the bank’s standards.

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