What the OCC’s Debanking Report Shows—and Leaves Unanswered

Nicholas Anthony

Are banks systematically discriminating against conservatives and Christians? That’s what the Office of the Comptroller of the Currency’s (OCC’s) new report on debanking has led many people to believe. OCC head Jonathan V. Gould said, “Today’s report provides irrefutable evidence that the nation’s largest banks have denied, debanked and discriminated against customers and lawful businesses.” 

Yet, a careful read of the report shows something else. The OCC simultaneously overstated and understated the problem. 

Evidence Without Scale

In preparation for this report, the OCC reviewed nearly 100,000 complaints—an impressive feat. Yet, the OCC failed to establish just how widespread discrimination might be. The report identifies only about 13 cases of suspected religious or political debanking. Making matters worse, these cases were only provided with minimal information, and it does not appear that the banks were given the chance to provide context for each decision (or at least, no context was published). That’s a problem considering one famous case of alleged religious debanking also involved the ministry running a debt-collection agency in Uganda. 

To be fair, the OCC disclosed that the list provided is not comprehensive, but it’s hard to land on the “irrefutable” conclusion that systemic discrimination against conservatives and Christians is taking place in banking when that’s the only evidence being offered. 

The Missing Link

Perhaps the most unfortunate aspect of this report is the absence of any serious consideration of the government as a driver of debanking. The report repeatedly identifies decisions made around reputational concerns as a driving factor in debanking. The basic idea is that banks don’t want to be associated with someone who is controversial because it might drive away customers on the other side of the issue. And it does appear that banks have been extremely risk-averse in some cases.

What the report largely leaves unexplored, however, is the government’s role in requiring banks to manage reputational risk. The report acknowledges this regulatory framework, primarily when discussing its (limited) repeal in 2026, but does not establish how regulatory requirements and supervisory pressure shaped the decisions it criticizes. The repeal was welcome, but those requirements were in place during the review period, and a full accounting of debanking should examine their consequences.

Conclusion

Debanking is a complicated issue, and sweeping claims will not fix the issue. It’s unfortunate that the OCC left so much off the table, but Congress has a duty to get the full picture before it responds with legislation. 

The OCC did not respond to multiple requests for comment in time for this piece.