OCC Report Lists Digital Asset Businesses Among Sectors Facing Limits

The Office of the Comptroller of the Currency’s report, Guaranteeing Fair Banking for All Americans, found that policies at nine large banks could shape customer access to financial services, including for digital asset businesses.

The review covered policies and practices from 2020 through September 2025. Across the nine institutions, some policies could affect whether customers received or kept services when political or religious beliefs, or lawful business activities, entered the decision.

The institutions were JPMorgan Chase Bank, Bank of America, Citibank, Wells Fargo Bank, U.S. Bank, Capital One, PNC Bank, TD Bank and BMO Bank. As of Sept. 30, 2025, they held $12.7 trillion, or 76%, of the $16.7 trillion in assets at OCC-regulated institutions.

The examination included nearly 100,000 complaints and about 50,000 documents totaling approximately 420,000 pages. The documents covered bank policies, procedures, practices and individual customer decisions. Broad reputation-risk policies lacked clear standards and objective, risk-based criteria. Such policies disadvantaged some Americans because of their political, religious or social views or lawful business activities.

Digital asset issuers, exchanges and administrators were among the businesses subject to restrictions. Limits on digital asset activities were often attributed to financial-crime considerations. Other sectors included oil and gas exploration, coal mining and coal-fired power, firearms and ammunition, detention facilities, tobacco and e-cigarettes.

Examples included a bank-owned payment processor closing an account in February 2021 for a merchant selling Trump and MAGA-branded merchandise, and a February 2023 denial involving a public education organization whose political arm endorsed only Democratic candidates. Neither example identified a digital asset business.

The review could not comprehensively quantify the full extent of debanking or alleged debanking. President Donald Trump signed Executive Order 14331 on Aug. 7, 2025, directing federal banking regulators to review institutions’ practices and remove reputation-risk concepts from certain guidance and examination materials.

The Consumer Financial Protection Bureau (CFPB) will investigate whether banks featured in the report and others complied with federal consumer financial laws. The OCC is considering additional supervisory and regulatory changes.

Comptroller of the Currency Jonathan V. Gould said, “We are not forcing these banks to serve every customer.”