The Office of the Comptroller of the Currency is reportedly preparing findings from a review to oversee whether major US lenders have improperly closed or restricted customer accounts for political, religious or industry-related reasons.
The review put JPMorgan, Bank of America, Citigroup, Wells Fargo, Capital One, US Bank, PNC, TD Bank and BMO Bank under renewed scrutiny for so-called foreclosures, a term used to describe situations in which banks cut off or limit access to financial services. The OCC is expected to publish its findings in the coming weeks and may name specific banks, with potential consequences ranging from private regulatory notices to civil enforcement actions and penalties.
The issue has become a hot topic under President Donald Trump, who has accused the banks of discriminating against conservatives and brought legal claims against JPMorgan and Capital One over account closures. Banks have denied political bias and said account decisions are driven by risk management, irregular activity, paperwork concerns, proper customer care and other compliance factors. The first work of the OCC previously marked that nine major banks have policies between 2020 and 2023 that limit services to certain industries or groups, and the agency is reviewing 100,000 related complaints.
For CFOs and financial directors, the case directly cuts the tension between ethical risk, reputational risk and legitimate customer access. Financial institutions have spent years strengthening anti-money laundering controls, sanctions screening, know-your-customer procedures and risk sector policies. The current review examines whether those controls can be applied without creating the impression that customers are not engaging in political views, religious beliefs or legitimate marketing activity.
The US Attorney’s Office in Washington is also investigating whether the banks may have violated the Financial Institutions Reform, Recovery and Enforcement Act of 1989. That expands the issue beyond surveillance to the risk of legal exposure, although the enforcement theory remains unclear. Activist Jonathan Gould told lawmakers this month that the OCC is investigating the bank’s bankruptcy and is looking at where the debt could come from under existing law.
The wider financial sector will be watching closely because any public findings could reshape the way banks write account closures, sector exclusions and risk appetite decisions. JPMorgan has already lifted restrictions on certain gun-related businesses, while Citi has lifted a policy that restricted services for gun dealers.
Financial professionals at regulated institutions should expect increased scrutiny of client exit decisions, board-level policy approvals and a paper trail behind the high-risk banking sector. If the OCC moves from review to enforcement, bailouts may become a permanent compliance issue for banks weighing legal access, political pressure and financial crime control.
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