On September 8, 2025, the Office of the Comptroller of the Currency (OCC) released Bulletin 2025-22, announcing that the OCC will assess an entity’s debanking practices when considering licensing filings and applications and during Community Reinvestment Act (CRA) assessments. National banks and federal savings associations are now on notice that prior allegations of politicized or unlawful debanking levied by consumers, as well as any current efforts undertaken to prevent debanking from occurring, may have an impact on future operations.

Specifically, when reviewing license filings and applications, the OCC will consider a bank’s history of engaging in politicized or unlawful debanking, as well as the policies and procedures maintained by the entity in order to ensure that it does not engage in debanking. This type of review may occur, for instance, when a national bank seeks to acquire or relocate a branch or seeks to convert to a federal savings association.

Similarly, in connection with CRA assessments when the OCC is examining a “bank’s record of meeting the credit needs of its entire community,” the OCC may consider “whether [the] bank has engaged in politicized or unlawful debanking.”

Therefore, if a bank has prior instances where one or more customers — regardless of whether they be prospective, current or former customers — alleged that they were subjected to debanking, that may become relevant in connection with a CRA assessment and could impact the consideration of any future applications related to business changes. That said, especially in connection with OCC filings and future applications, an entity may be able to combat prior debanking allegations by implementing robust policies and procedures to eliminate and prevent any future instances of debanking from occurring.

The OCC’s Bulletin 2025-22 represents the agency’s effort to implement Executive Order 14331, which targeted politicized or unlawful debanking and is titled “Guaranteeing Fair Banking For All Americans.” As we previously wrote, the August 7^th executive order directed the federal banking regulators, including the OCC, to identify financial entities that may have engaged in politicized or unlawful debanking and to identify entities that “have had any past or current, formal or informal, policies or practices that require, encourage, or otherwise influence such financial institution to engage in politicized or unlawful debanking.” The regulators are also instructed to take appropriate action with respect to any debanking instances that they identify.

We also previously predicted that President Trump’s debanking executive order signaled that horizontal reviews related to debanking practices would likely happen soon. In connection with the release of Bulletin 2025-22, the OCC also published News Release 2025-84, which confirmed that the agency has already gone through that process and requested information from the nine largest banks that it regulates.

In light of Executive Order 14331 and the federal banking regulators’ ongoing efforts to implement President Trump’s directive, banks and federal savings associations of all sizes should conduct a comprehensive review of prior debanking-related complaints or allegations and ensure that it maintains appropriate policies and procedures that will ensure it does not engage in future debanking. These actions may help mitigate potential scrutiny from regulators and eliminate hurdles (or outright barriers) that could impact future applications related to business activities that require regulator approval